Caixin Reveals the Meaning of Anonymous Behind RWA Policy: Differentiation of Regulations Between Hong Kong and Domestic Assets

As the No. 42 Document was issued by eight departments including the People’s Bank of China regarding virtual currency risk prevention, the industry is now gaining a clearer understanding of the hidden meaning behind the anonymity within the RWA (Real World Assets) regulatory framework. However, the true significance of this policy is much more nuanced than simply banning or restricting.

Understanding the Meaning of Anonymity in Document No. 42: Key Differences Between Domestic and Overseas

According to industry-insider regulation experts, the anonymity in No. 42 lies in the clear distinction between RWAs issued domestically versus those issued abroad. For domestically based assets, the policy is strict: a tight, no-exceptions ban. But for RWA issuance outside China, the situation is different—not an outright rejection, but a more rigorous and structured oversight mechanism. This is the true meaning of anonymity, often misunderstood by market participants.

This two-pronged approach reflects a smart regulatory effort: protecting the domestic financial ecosystem from uncontrolled risks while recognizing that blockchain innovation and asset tokenization cannot be completely halted.

Hong Kong RWA: Why It Is Not Under the Authority of Document No. 42

A key aspect of the policy’s anonymity is Hong Kong’s special status in the context of RWA issuance. According to sources familiar with the regulation, Hong Kong is designated as one of the offshore locations for RWA issuance that is not covered by the scope of No. 42. In other words, RWAs based on Hong Kong assets are not under the jurisdiction of China’s domestic regulatory departments.

This status is important because Hong Kong has its own well-established regulatory and supervisory framework. The Chinese government essentially delegates oversight responsibility to Hong Kong authorities, creating a clear separation of regulatory jurisdictions. To date, there have been no issuances of RWAs based on Chinese domestic securities or funds in Hong Kong or other foreign locations—at least not on a significant scale or publicly reported.

If There Are Domestic Asset RWAs Abroad: They Fall Under CSRC Authority

However, if there are initiatives to issue RWAs based on Chinese domestic securities or funds abroad, oversight responsibility falls to the CSRC (China Securities Regulatory Commission). Here, the stance is firm: “previously not permitted at all,” and in principle, that remains unchanged. There are no signs of a fundamental shift in this position.

Important Clarification: What No. 42 Document Does NOT Mean

Understanding the anonymity of No. 42 also involves clarifying what the policy does NOT intend. Strict supervision of domestic asset RWAs going abroad does not mean encouraging or facilitating their development. The framing of “not banning” should not be interpreted as “encouraging development.”

This subtle distinction often causes confusion in the market. Chinese regulation in this regard adopts a “neutral but cautious” approach—not fully closing the door to innovation, but also not providing explicit incentives or support. The hidden meaning of “not banning” is “we monitor and allow development within the applicable rules,” not “we welcome and promote.”

Therefore, industry players need to carefully understand the true meaning behind the nuances of No. 42—regulatory distinctions based on geography, underlying assets, and issuance location are key to operating within the appropriate policy framework.