China's Blockchain Legal Framework 2025: What's Allowed, Banned, and the Gray Areas for Builders
China presents the world's most paradoxical blockchain landscape: a nation that has banned cryptocurrency while simultaneously investing $54.5 billion annually in blockchain infrastructure, processed $2.38 trillion in digital yuan transactions, and deployed over 2,000 enterprise blockchain applications. For builders trying to navigate this environment, the difference between success and legal jeopardy often comes down to understanding precisely where the lines are drawn.
As of 2025, China's regulatory framework has crystallized into a distinctive model—one that aggressively suppresses decentralized crypto while actively promoting state-controlled blockchain infrastructure. This guide breaks down exactly what's permitted, what's prohibited, and where the gray areas create both opportunity and risk for Web3 developers and enterprises.
The Hard Bans: What's Absolutely Prohibited
In 2025, China reaffirmed and strengthened its comprehensive ban on cryptocurrency. There's no ambiguity here—the prohibitions are explicit and enforced.
Cryptocurrency Trading and Ownership
All cryptocurrency transactions, exchanges, and ICOs are banned. Financial institutions are prohibited from offering any crypto-related services. The People's Bank of China (PBoC) has made clear that this includes newer instruments like algorithmic stablecoins.
The crypto ban decree became effective from June 1, 2025, introducing:
- Suspension of all crypto transactions
- Asset seizure measures for violators
- Enhanced enforcement mechanisms
- Significant financial penalties
Stablecoins Under the Ban
In November 2025, the PBoC explicitly clarified that stablecoins—once perceived as a potential gray area—are equally forbidden. This closed a loophole that some had hoped might allow compliant stablecoin operations within mainland China.
Mining Operations
Cryptocurrency mining remains completely prohibited. China's 2021 mining ban has been consistently enforced, with operations forced either underground or offshore.
Foreign Platform Access
Platforms like Binance, Coinbase, and other international exchanges are prohibited in mainland China. While some users attempt to access these via VPNs, doing so is illegal and can result in fines and further legal consequences.
Banking and Financial Services
New 2025 regulations require banks to actively monitor and report suspicious crypto transactions. When risky crypto activity is identified, banks must:
- Uncover the user's identity
- Assess past financial behaviors
- Implement financial restrictions on the account
What's Explicitly Permitted: Enterprise Blockchain and the Digital Yuan
China's approach isn't anti-blockchain—it's anti-decentralization. The government has made massive investments in controlled blockchain infrastructure.
Enterprise and Private Blockchain
Enterprise blockchain applications are explicitly permitted within the CAC (Cyberspace Administration of China) filing regime and cybersecurity laws. Private chains see more deployment than public chains in both public and private sectors because they allow centralized management of business operations and risk control.
Permitted use cases include:
- Supply chain management and provenance tracking
- Healthcare data management
- Identity verification systems
- Logistics and trade finance
- Judicial evidence storage and authentication
The Chinese government has invested heavily in private and consortium blockchain applications across the public sector. Judicial blockchain systems in Beijing, Hangzhou, Guangzhou, and other cities now support digital evidence storage, contract execution automation, and smart court management.
The Blockchain Service Network (BSN)
China's Blockchain Service Network represents the country's most ambitious blockchain initiative. Established in 2018 and launched in 2020 by the State Information Center under the National Development and Reform Commission, China Mobile, China UnionPay, and other partners, BSN has become one of the world's largest enterprise blockchain ecosystems.
Key BSN statistics:
- Over 2,000 blockchain applications deployed across enterprises and government organizations
- Nodes established in 20+ countries
- Resource costs reduced 20-33% compared to conventional blockchain cloud services
- Interoperability across different blockchain frameworks
In 2025, Chinese officials announced a roadmap for national blockchain infrastructure targeting approximately 400 billion yuan ($54.5 billion) in annual investments over the next five years. BSN sits at the center of this strategy, providing the backbone for smart cities, trade ecosystems, and digital identity systems.
The Digital Yuan (e-CNY)
China's central bank digital currency represents the permitted alternative to private cryptocurrency. The numbers are substantial:
2025 Statistics:
- $2.38 trillion in cumulative transaction value (16.7 trillion yuan)
- 3.48 billion transactions processed
- 225 million+ personal digital wallets
- Pilot program covering 17 provinces
The digital yuan's evolution continues. Starting January 1, 2026, commercial banks will begin paying interest on digital yuan holdings—marking a transition from "digital cash" to "digital deposit currency."
However, adoption challenges persist. The e-CNY faces stiff competition from entrenched mobile payment platforms like WeChat Pay and Alipay, which dominate China's cashless transaction landscape.
The Gray Areas: Where Opportunity Meets Risk
Between the clear prohibitions and explicit permissions lies significant gray territory—areas where regulations remain ambiguous or enforcement is inconsistent.
Digital Collectibles (NFTs with Chinese Characteristics)
NFTs exist in a regulatory gray area in China. They're not banned, but they can't be bought with crypto and can't be used as speculative investments. The solution has been "digital collectibles"—a uniquely Chinese NFT model.
Key differences from global NFTs:
- Labeled as "digital collectibles," never "tokens"
- Operated on private blockchains, not public chains
- No secondary trading or resale permitted
- Real-identity verification required
- Payment in yuan only, never cryptocurrency
Despite official restrictions, the digital collectibles market has exploded. By early July 2022, approximately 700 digital collectibles platforms operated in China—up from around 100 just five months earlier.
For brands and enterprises, the guardrails are:
- Use legally registered Chinese NFT platforms
- Describe items as "digital collectibles," never "tokens" or "currency"
- Never allow or encourage trading or speculation
- Never imply value appreciation
- Comply with real-identity verification requirements
The Ministry of Industry and Information Technology has indicated that digital collectibles represent a business model to be encouraged "in line with the country's conditions"—though comprehensive regulations haven't yet been released.
Underground and VPN-Based Activity
A vibrant underground market exists. Collectors and enthusiasts trade through peer-to-peer networks, private forums, and encrypted messaging apps. Some Chinese users employ VPNs and pseudonymous wallets to participate in global NFT and crypto markets.
This activity operates in a legal gray area. Participants take on significant risk, including potential detection through enhanced banking surveillance and the possibility of financial restrictions or penalties.
Hong Kong as a Regulatory Arbitrage Opportunity
Hong Kong's Special Administrative Region status creates a unique opportunity. While mainland China prohibits crypto, Hong Kong has established a regulated framework through the Hong Kong Monetary Authority (HKMA) and Securities and Futures Commission (SFC).
In August 2025, Hong Kong implemented the Stablecoin Ordinance, establishing a licensing regime for stablecoin issuers. This creates interesting possibilities for enterprises that can structure operations to leverage Hong Kong's more permissive environment while maintaining compliant operations in the mainland.
Filing Requirements and Compliance
For enterprises operating permissible blockchain applications in China, compliance requires understanding the registration framework.
CAC Filing Requirements
The Blockchain Provisions require service providers to file a recordal with the Cyberspace Administration of China within ten working days from the commencement of blockchain services. Importantly, this is a filing requirement, not a permit requirement—blockchain services don't require special operating permits from regulators.
What Must Be Filed
Blockchain service providers must register:
- Basic company information
- Service description and scope
- Technical architecture details
- Data handling procedures
- Security measures
Ongoing Compliance
Beyond initial filing, enterprises must maintain:
- Compliance with cybersecurity laws
- User real-identity verification
- Transaction record keeping
- Cooperation with regulatory inquiries
Potential Policy Evolution
While 2025 has seen enforcement strengthen rather than relax, some signals suggest future policy evolution is possible.
In July 2025, the Shanghai State-owned Assets Supervision and Administration Commission indicated that the rapid evolution of digital assets could result in softening of China's strict position on crypto. This is notable as an official acknowledgment that the current framework may need adjustment.
However, any policy changes would likely maintain the fundamental distinction between:
- Prohibited: Decentralized, permissionless cryptocurrency
- Permitted: State-controlled or enterprise blockchain with proper oversight
Strategic Recommendations for Builders
For developers and enterprises looking to operate in China's blockchain ecosystem, here are the key strategic considerations:
Do:
- Focus on enterprise blockchain applications with clear business utility
- Use BSN infrastructure for cost-effective, compliant deployment
- Structure digital collectibles projects within established guidelines
- Maintain comprehensive compliance documentation
- Consider Hong Kong structures for crypto-adjacent activities