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China's Web3 Policy Pivot: From Total Ban to Controlled RWA Pathway

· 11 min read
Dora Noda
Dora Noda
Software Engineer

On February 6, 2026, eight Chinese ministries jointly issued Document 42, fundamentally restructuring the country's approach to blockchain and digital assets. The document doesn't lift China's cryptocurrency ban — it refines it into something more strategic: prohibition for speculative crypto, controlled pathways for state-approved Real World Asset (RWA) tokenization.

This represents the most significant Chinese blockchain policy evolution since the 2021 total ban. Where previous regulations drew binary lines — crypto bad, blockchain good — Document 42 introduces nuance: compliant financial infrastructure for approved RWA projects, strict prohibition for everything else.

The policy shift isn't about embracing Web3. It's about controlling it. China recognizes blockchain's utility for financial infrastructure while maintaining absolute regulatory authority over what gets tokenized, who participates, and how value flows.

Document 42: The Eight-Ministry Framework​

Document 42, titled "Notice on Further Preventing and Dealing with Risks Related to Virtual Currencies," represents joint authority from China's financial regulatory apparatus:

  1. People's Bank of China (PBOC)
  2. National Development and Reform Commission
  3. Ministry of Industry and Information Technology
  4. Ministry of Public Security
  5. State Administration for Market Regulation
  6. State Financial Supervision Administration
  7. China Securities Regulatory Commission (CSRC)
  8. State Administration of Foreign Exchange

This coordination signals seriousness. When eight ministries align on blockchain policy, implementation becomes enforcement, not guidance.

The document officially repeals Announcement No. 924 (the 2021 total ban) and replaces it with categorized regulation: virtual currencies remain prohibited, RWA tokenization gains legal recognition through compliant infrastructure, stablecoins face strict controls based on asset backing.

Document 42 is the first Chinese ministerial regulation to explicitly define and regulate Real World Asset tokenization. This isn't accidental language — it's deliberate policy architecture creating legal frameworks for state-controlled digital asset infrastructure.

The "Risk Prevention + Channeled Guidance" Model​

China's new blockchain strategy operates on dual tracks:

Risk Prevention: Maintain strict prohibition on speculative cryptocurrency activity, foreign crypto exchanges serving mainland users, ICOs and token offerings, yuan-pegged stablecoins without government approval, and unauthorized cross-border crypto flows.

Channeled Guidance: Create compliant pathways for blockchain technology to serve state objectives through CSRC filing system for asset-backed security tokens, approved financial institutions participating in RWA tokenization, Blockchain-based Service Network (BSN) for standardized infrastructure, and e-CNY (digital yuan) replacing private stablecoin functionality.

The policy explicitly states "same business, same risk, same rules" — regardless of whether tokenization occurs in Hong Kong, Singapore, or offshore, Chinese underlying assets require mainland regulatory approval.

This dual-track approach enables blockchain experimentation within controlled parameters. RWA projects can proceed if they file with CSRC, use approved infrastructure, limit participation to qualified institutions, and maintain mainland regulatory compliance for Chinese-sourced assets.

The framework differs fundamentally from Western "regulate but don't prohibit" approaches. China doesn't aim for permissionless innovation — it designs permissioned infrastructure serving specific state goals.

What Document 42 Actually Permits​

The compliant RWA pathway involves specific requirements:

Asset Classes: Tokenization of financial assets (bonds, equity, fund shares), commodities with clear ownership rights, intellectual property with verified provenance, and real estate through approved channels. Speculative assets, cryptocurrency derivatives, and privacy-focused tokens remain banned.

Infrastructure Requirements: Use of BSN or other state-approved blockchain networks, integration with existing financial regulatory systems, KYC/AML compliance at institutional level, and transaction monitoring with government visibility.

Filing Process: CSRC registration for asset-backed security tokens, approval for tokenizing mainland Chinese assets overseas, annual reporting and compliance audits, and regulatory review of token economics and distribution.

Participant Restrictions: Limited to licensed financial institutions, qualified institutional investors only (no retail participation), and prohibition on foreign platforms serving mainland users without approval.

The framework creates legal certainty for approved projects while maintaining absolute state control. RWA is no longer operating in a regulatory gray zone — it's either compliant within narrow parameters or illegal.

Hong Kong's Strategic Position​

Hong Kong emerges as the controlled experimentation zone for China's blockchain ambitions.

The Securities and Futures Commission (SFC) treats tokenized securities like traditional securities, applying existing regulatory frameworks rather than creating separate crypto rules. This "same business, same risk, same rules" approach provides clarity for institutions navigating RWA tokenization.

Hong Kong's advantages for RWA development include established financial infrastructure and legal frameworks, international capital access while maintaining mainland connectivity, regulatory experience with digital assets (crypto ETFs, licensed exchanges), and proximity to mainland Chinese enterprises seeking compliant tokenization.

However, Document 42 extends mainland authority into Hong Kong operations. Chinese brokerages received guidance to halt certain RWA tokenization activities in Hong Kong. Overseas entities owned or controlled by Chinese firms cannot issue tokens to mainland users. Tokenization of mainland assets requires CSRC approval regardless of issuance location.

This creates complexity for Hong Kong-based projects. The SAR provides regulatory clarity and international access, but mainland oversight limits strategic autonomy. Hong Kong functions as a controlled bridge between Chinese capital and global blockchain infrastructure — useful for state-approved projects, restrictive for independent innovation.

The Stablecoin Prohibition​

Document 42 draws hard lines on stablecoins.

Yuan-pegged stablecoins are explicitly prohibited unless issued by government-approved entities. The logic: private stablecoins compete with e-CNY and enable capital flight circumventing forex controls.

Foreign stablecoins (USDT, USDC) remain illegal for mainland Chinese users. Offshore RWA services cannot offer stablecoin payments to mainland participants without approval. Platforms facilitating stablecoin transactions with mainland users face legal consequences.

The e-CNY represents China's stablecoin alternative. Converted from M0 to M1 status starting January 1, 2026, the digital yuan expands from consumer payments to institutional settlement. Shanghai's International e-CNY Operations Center builds cross-border payment infrastructure, digital asset platforms, and blockchain-based services — all with central bank visibility and control.

China's message: digital currency innovation must occur under state authority, not private crypto networks.

BSN: The State-Backed Infrastructure​

The Blockchain-based Service Network (BSN), launched in 2020, provides standardized, low-cost infrastructure for deploying blockchain applications globally.

BSN offers public and permissioned chain integration, international nodes while maintaining Chinese standards compliance, developer tools and standardized protocols, and cost structure significantly below commercial alternatives.

The network functions as China's blockchain infrastructure export. Countries adopting BSN gain affordable blockchain capabilities while integrating Chinese technical standards and governance models.

For domestic RWA projects, BSN provides the compliant infrastructure layer Document 42 requires. Projects building on BSN automatically align with state technical and regulatory requirements.

This approach mirrors China's broader technology strategy: provide superior infrastructure at competitive prices, embed standards and oversight mechanisms, and create dependency on state-controlled platforms.

International Implications​

Document 42's extraterritorial reach reshapes global RWA markets.

For International Platforms: Projects tokenizing Chinese assets require mainland approval regardless of platform location. Serving mainland Chinese users (even VPN circumvention) triggers regulatory violation. Partnerships with Chinese entities require compliance verification.

For Hong Kong RWA Projects: Must navigate both SFC requirements and mainland Document 42 compliance. Limited strategic autonomy for projects involving mainland capital or assets. Increased scrutiny on beneficial ownership and user geography.

For Global Tokenization Markets: China's "same business, same risk, same rules" principle extends regulatory reach globally. Fragmentation in tokenization standards (Western permissionless vs Chinese permissioned). Opportunities for compliant cross-border infrastructure serving approved use cases.

The framework creates a bifurcated RWA ecosystem: Western markets emphasizing permissionless innovation and retail access, Chinese-influenced markets prioritizing institutional participation and state oversight.

Projects attempting to bridge both worlds face complex compliance. Chinese capital can access global RWA markets through approved channels, but Chinese assets cannot be freely tokenized without state permission.

The Crypto Underground Persists​

Despite regulatory sophistication, crypto remains active in China through offshore exchanges and VPNs, over-the-counter (OTC) trading networks, peer-to-peer platforms, and privacy-focused cryptocurrencies.

The PBOC reiterated its restrictive stance on November 28, 2025, signaling continued enforcement. Financial crime prevention justifies these legal barriers. Enforcement focuses on visible platforms and large-scale operations rather than individual users.

The regulatory cat-and-mouse continues. Sophisticated users circumvent restrictions while accepting risks. The government tolerates small-scale activity while preventing systemic exposure.

Document 42 doesn't eliminate China's crypto underground — it clarifies legal boundaries and provides alternative pathways for legitimate blockchain business through compliant RWA infrastructure.

What This Means for Blockchain Development​

China's policy pivot creates strategic clarity:

For Institutional Finance: Clear pathway exists for approved RWA tokenization. Compliance costs are high but framework is explicit. State-backed infrastructure (BSN, e-CNY) provides operational foundation.

For Crypto Speculation: Prohibition remains absolute for speculative cryptocurrency trading, token offerings and ICOs, privacy coins and anonymous transactions, and retail crypto participation.

For Technology Development: Blockchain R&D continues with state support. BSN provides standardized infrastructure. Focus areas: supply chain verification, government services digitization, cross-border trade settlement (via e-CNY), intellectual property protection.

The strategy: extract blockchain's utility while eliminating financial speculation. Enable institutional efficiency gains while maintaining capital controls. Position China's digital infrastructure for global export while protecting domestic financial stability.

The Broader Strategic Context​

Document 42 fits within China's comprehensive financial technology strategy:

Digital Yuan Dominance: E-CNY expansion for domestic and cross-border payments, institutional settlement infrastructure replacing stablecoins, integration with Belt and Road Initiative trade flows.

Financial Infrastructure Control: BSN as blockchain infrastructure standard, state oversight of all significant digital asset activity, prevention of private crypto-denominated shadow economy.

Technology Standards Export: BSN international nodes spreading Chinese blockchain standards, countries adopting Chinese infrastructure gain efficiency but accept governance models, long-term positioning for digital infrastructure influence.

Capital Control Preservation: Crypto prohibition prevents forex control circumvention, compliant RWA pathways don't threaten capital account management, digital infrastructure enables enhanced monitoring.

The approach demonstrates sophisticated regulatory thinking: prohibition where necessary (speculative crypto), channeled guidance where useful (compliant RWA), infrastructure provision for strategic advantage (BSN, e-CNY).

What Comes Next​

Document 42 establishes frameworks, but implementation determines outcomes.

Key uncertainties include CSRC filing process efficiency and bottlenecks, international recognition of Chinese RWA tokenization standards, Hong Kong's ability to maintain distinct regulatory identity, and private sector innovation within narrow compliant pathways.

Early signals suggest pragmatic enforcement: approved projects proceed quickly, ambiguous cases face delays and scrutiny, and obvious violations trigger swift action.

The coming months will reveal whether China's "risk prevention + channeled guidance" model can capture blockchain's benefits without enabling the financial disintermediation crypto enthusiasts seek.

For global markets, China's approach represents the counter-model to Western permissionless innovation: centralized control, state-approved pathways, infrastructure dominance, and strategic technology deployment.

The bifurcation becomes permanent — not one blockchain future, but parallel systems serving different governance philosophies.

BlockEden.xyz provides enterprise-grade infrastructure for Web3 applications, offering reliable, high-performance RPC access across major blockchain ecosystems. Explore our services for compliant RWA and institutional blockchain infrastructure.

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