The two regulatory policy documents from February 6, 2026, aim not to decide whether Chinese assets can be put on-chain, but to define the financial framework within which this process must be completed. Between 2023 and 2025, the global RWA market grew from approximately $30 billion to over $120 billion, with more than 80% of the underlying assets being debt-based products, including U.S. Treasury bonds, corporate credit, and real estate income rights. In other words, the primary function RWA has assumed globally is not "trading," but "financing." When a tool's core function is financing, it inevitably falls under the securities regulatory system. Therefore, these policies complete a functional shift: the growth model centered on trading is being compressed, while the financial path centered on assets is being reconstructed. **Why Cross-Border RWA is Being Brought Under the Securities Regulatory Framework** 1. **Its essence is cross-border financing.** Whether it's accounts receivable or cash flow from photovoltaic power stations, RWA transforms future cash flow into financial products that can be subscribed to by investors. This process corresponds to ABS, REITs, and corporate bond issuance in the traditional financial system. In 2024, the scale of overseas bond issuance by Chinese enterprises exceeded $580 billion, with the vast majority completed through Hong Kong. RWA simply moves this structure onto the chain. 2. **It must enter the securities system.** Any product that raises funds from unspecified investors falls under securities regulation globally. Tokenized Treasury bonds in the U.S., issued through cooperation between Securitize and BlackRock, rely on an SEC-regulated securities issuance system. In Singapore's Project Guardian, tokenized bonds are issued and custodied through licensed financial institutions. These cases demonstrate that securitization is the only viable path for RWA to enter mainstream capital markets. 3. **It corresponds to the era of licensed institutions.** Once RWA is incorporated into securities logic, the core competitiveness of the market is no longer technical development capability, but asset selection ability, issuance structure design capability, and compliance issuance ability. Among the top ten global RWA issuance projects in 2024, over 70% were led by licensed financial institutions, not native crypto teams. When RWA enters securities logic, the protagonists become financial institutions, not tech teams. **Hong Kong's Role is Changing** Hong Kong's critical role in the cross-border RWA structure arises not because it is more "friendly" to Web3, but because it already possesses a complete set of systems and infrastructure capable of handling security-type asset issuance. 1️⃣ **Institutional Layer: A Tiered Regulatory System is Taking Shape** Since the implementation of the Virtual Asset Trading Platform (VATP) licensing regime in June 2023, Hong Kong has effectively established a tiered regulatory system highly isomorphic with the traditional securities market: strict restrictions on the retail market, gradual opening of the professional investor market, and prioritized development of institutional-grade products. This is completely consistent with the regulatory logic of traditional financial markets. By the end of 2025, the SFC had issued 11 VATP licenses. A system of licensed custodians is forming, and existing securities firms are allowed to apply for upgrades to include virtual asset businesses. This means the basic systems for securities issuance, custody, and trading required for RWA issuance are now in place. 2️⃣ **Infrastructure Layer: Settlement, Custody, and Trading are Forming a Closed Loop** Stablecoin legislation is the most critical variable. The *Stablecoins Ordinance* officially took effect in August last year, and the HKMA will issue the first batch of stablecoin licenses in March this year. This provides, for the first time, a compliant path for RWA fund settlement to enter the mainstream financial system. On the custody front, OSL and HashKey established institutional-grade digital asset custody services long before the system was implemented, serving multiple traditional financial institutions. The key change on the trading front is the entry of traditional securities firms. Internet brokerages like Futu and Tiger Brokers have obtained or are applying for upgrades to include virtual asset-related businesses. Several local brokers are applying through the SFC's existing licensing system to provide virtual asset trading and distribution services. Viewed together, this three-layer structure perfectly mirrors the "clearing-custody-trading" system of traditional capital markets. 3️⃣ **Functional Layer: From Trading Center to Asset Issuance Center** In the global financial system, markets with true pricing power are never those with the largest trading volume, but those with the strongest asset generation capabilities. New York's importance comes from IPOs and U.S. Treasury issuance, not secondary market trading; London's core status comes from the international bond market, not spot trading. Hong Kong is replicating this very structure. Currently, over 70% of offshore bond issuance by Chinese enterprises is completed through Hong Kong, the vast majority of red-chip listings are completed there, and offshore REITs and structured financing also rely on Hong Kong's legal and intermediary systems. When RWA must be issued within a securities structure, this entire system can be directly migrated onto the chain. In other words, Hong Kong is transitioning from a "virtual asset trading center" to an "on-chain asset issuance center." **Who Will Be the Core Beneficiaries?** 1. **Licensed Securities Firms: Core of Issuance and Distribution** In traditional capital markets, securities firms handle underwriting and sales. Once RWA becomes a security-type asset, this model will not change. For example, HashKey is not just a trading platform; it also holds Type 1 (dealing in securities) and Type 7 (automated trading services) licenses, enabling it to undertake the distribution of RWA products in the future. OSL, backed by its listed parent company BC Technology Group, provides brokerage and custody services to institutional clients, essentially possessing the capability of an on-chain asset primary/secondary market intermediary. Future genuine RWA issuance channels will likely appear not on pure crypto platforms, but within the system of intermediary institutions holding securities licenses. 2. **Investment Banks: Leaders in Structuring and Credit Enhancement** The core of RWA is not "going on-chain," but transforming cash flow into marketable financial products. This involves SPV setup, senior/subordinate tranching, credit enhancement, and rating introduction – all typical investment banking activities. The world's largest tokenized treasury project, completed jointly by BlackRock and Securitize, is essentially an on-chain fund structure design, not a technical issuance. Therefore, in Hong Kong's RWA system, those with true pricing power will be licensed securities firms and banks with investment banking business lines. 3. **Asset Management Institutions: The Gateway for Long-Term Capital** For RWA to enter the mainstream market, it must solve the problem of long-term capital allocation. Hong Kong currently manages over HKD 31 trillion in assets, with more than two-thirds coming from overseas institutional funds, including sovereign wealth funds, pension funds, and insurance funds. The legal pathway for these funds into the market can only be through licensed asset management institutions. This means that once RWA products enter the compliant distribution system, asset management companies will become the largest gateway for capital. 4. **Structuring Specialists: The Rarest Cross-Disciplinary Capability** The first type exists within large securities firms, investment banks, and asset management institutions, in the form of structured finance departments or digital asset business units. These roles will become core competitive advantages. The second type consists of independent professional service firms, similar to structured finance advisors and SPV managers in traditional markets, responsible for connecting asset owners and issuers. This role is scarce because it requires three simultaneous abilities: understanding underlying asset cash flows, understanding cross-border regulatory structures, and understanding on-chain mapping methods. Very few people currently possess this composite capability. The core of industry competition is shifting from "who owns the users" to "who can complete asset pricing." **Profound Impact on Industry Participants** This round of change has a far more profound impact on industry participants than on market size. In the past decade, the crypto industry's growth mainly relied on trading volume expansion, so the most valuable capabilities were traffic acquisition and market gaming. But as the industry enters an asset-driven phase, the source of value creation has shifted. In the future, only two types of people will be truly scarce. The first type is on the asset side. Those who can continuously provide standardized cash-flow assets will become the source of the entire RWA market. The second type is on the structuring side. Professionals who can complete cross-border compliance framework design, securitization structure setup, and on-chain mapping will become the key nodes connecting Chinese assets with global capital. As the industry moves from being trading-driven to asset-driven, the digital asset world is operating in a complete financial form for the first time. RWA is no longer just a technical concept, but a new way of organizing global capital. For Chinese assets, this path begins on the mainland, is structured in Hong Kong, and has investors globally.