【首席观察】银发42号文的红线、锚点与双轨试验

Core Viewpoint - The regulatory framework is not targeting a specific technology but is centered around three fundamental lines: monetary function, financial activity attributes, and cross-border accountability [1][8]. Regulatory Developments - The issuance of Document No. 42 marks a significant regulatory restructuring in the digital asset space, coinciding with the launch of interest-bearing digital RMB [3][4]. - Document No. 42 defines the tokenization of real-world assets (RWA) and integrates it into a systematic regulatory framework, expanding the regulatory focus from "virtual currency speculation" to the entire chain of "asset tokenization" [4][5]. Compliance and Exceptions - Activities related to RWA tokenization within the domestic market are generally prohibited unless approved by relevant authorities, while exceptions exist for specific financial infrastructure [5][6]. - The document explicitly prohibits any entity from issuing RMB-linked stablecoins abroad without approval, emphasizing the importance of monetary sovereignty [5][12]. Comparative Regulatory Approaches - In contrast to the mainland's "principle of prohibition," Hong Kong is accelerating RWA tokenization, with a regulatory framework that encourages the tokenization of government bonds, carbon credits, and other assets [6][11]. - The regulatory landscape in Hong Kong is designed to facilitate compliance and innovation, while the mainland focuses on maintaining financial security through a negative list approach [6][12]. Market Dynamics and Opportunities - The market is reassessing the viability of RWA from three dimensions: structural asset selection, geographical strategy, and deeper monetary competition logic [10][12]. - The global trend favors the tokenization of standardized financial assets like money market funds and bonds, while non-standard assets like real estate have seen limited success [10][11]. Future Outlook - The regulatory framework allows for "controlled pilot" possibilities, indicating that compliance pathways exist but are not automatically accessible to all market participants [13][16]. - The emphasis is on ensuring that any digital asset initiatives do not mimic monetary functions, act as financial intermediaries, or create unaccountable cross-border financial flows [12][17]. Conclusion - The regulatory environment is shifting towards a more structured approach, where the focus is on compliance and accountability rather than outright prohibition, creating a landscape for potential innovation within defined boundaries [18].