Compliance Path for Overseas Issuance of RWA of Chinese Assets

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At the beginning of 2026, the Chinese government officially opened a regulatory pathway for the overseas issuance of RWA. The People’s Bank of China, together with seven ministries, jointly issued Document No. 42, which reaffirmed the continued strict prohibition of virtual currency-related activities while innovatively introducing a regulatory logic of “same business, same risk, same rules.” This creates a clear compliance pathway for domestic assets to issue RWA tokens abroad.

To this end, the China Securities Regulatory Commission issued the “Regulatory Guidelines for Domestic Asset-Backed Securities Token Issuance Overseas” [〔2026〕1] (“Regulatory Guidelines”) along with the supporting “Notice No. 1 — Content and Format of Filing Materials” (“Filing Notice”). Under this regulatory framework, qualified domestic entities can achieve compliant overseas RWA issuance by fulfilling the relevant filing procedures.

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