研究 | 《关于境内资产境外发行资产支持证券代币的监管指引》的分析及解读

Core Viewpoint - The China Securities Regulatory Commission (CSRC) has established a dual-line regulatory framework for the issuance of asset-backed security tokens based on domestic assets in overseas markets, emphasizing strict compliance and pre-filing requirements to mitigate risks associated with the rapid growth of Real World Assets (RWA) tokenization [1][10][59]. Group 1: Background and Development of RWA Tokenization - The rapid development of RWA tokenization globally has been facilitated by blockchain technology, enhancing efficiency and transparency in asset securitization [3]. - The history of RWA tokenization can be divided into several phases: - The nascent stage (2014-2016) saw the emergence of Realcoin (later Tether) [5]. - The exploratory stage (2017-2019) included significant projects like Polymath and RealT, focusing on compliance and real estate tokenization [5][6]. - The initial development stage (2020-2022) featured projects like Centrifuge and MakerDAO integrating RWA into DeFi ecosystems [6][7]. - The rapid development stage (2023-2025) highlighted Hong Kong's leadership in issuing tokenized green bonds and regulatory frameworks [8][9]. Group 2: Regulatory Framework and Guidelines - The CSRC's regulatory guidelines, released on February 6, 2026, require pre-filing for the issuance of asset-backed security tokens based on domestic assets in overseas markets, marking a shift from a previously unregulated environment [10][11]. - The guidelines emphasize a dual regulatory approach: a complete ban on RWA tokenization activities within China and strict oversight for overseas issuance [13][59]. - The guidelines also introduce a negative list of prohibited activities and entities, ensuring compliance with various legal and regulatory requirements [41][42]. Group 3: Practical Cases of RWA Tokenization in China - Several practical cases of RWA tokenization have emerged in China, particularly in the renewable energy sector, showcasing the integration of RWA technology with national strategies [14][17]. - Notable projects include: - Longxin Technology's charging pile RWA project, which raised approximately 100 million RMB [17]. - GCL-Poly's photovoltaic RWA project, which raised over 200 million RMB [18]. - Xunying Group's battery swap asset RWA project, exploring new financing paradigms for renewable infrastructure [19]. Group 4: Market Size and Future Outlook - According to Boston Consulting Group, the market size for tokenized assets is expected to reach $16 trillion by 2030, significantly increasing from $310 billion in 2022 [13]. - The introduction of the pre-filing system is anticipated to open up the RWA tokenization market while maintaining a cautious regulatory stance to prevent cross-border financial risks [59]. - The unique focus on renewable energy assets in China's RWA tokenization reflects a policy direction towards green finance and the integration of real economy [23].