1. Comprehensive Upgrade and Precise Definition: All Paths to Block Systemic Risks

The “Notice” first demonstrates a strategic expansion of the regulatory scope and an unprecedented strengthening of qualitative measures. Its most significant feature is the explicit inclusion of “Real World Asset Tokenization” (RWA) into the regulatory core and placing it under the same stringent scrutiny as virtual currencies. This measure holds forward-looking and decisive significance. RWA, as a global fintech trend that digitizes and trades traditional assets (such as bonds, real estate income rights, commodities, etc.) through blockchain, is essentially an iteration of asset securitization technology. If left unchecked, it is highly likely to evolve into a “technical bypass” that circumvents existing regulatory frameworks, including securities issuance review, information disclosure, and investor suitability management, leading to more complex issues like illegal fundraising, fraud, and intermingled financial risks. The “Notice” clearly states that undertaking unauthorized RWA activities within the territory is suspected of illegal token issuance, unauthorized public securities issuance, and illegal futures operations, and constitutes illegal financial activities. This definition thoroughly eliminates any fantasies of attempting regulatory arbitrage under the guise of “technological innovation” and establishes the unwavering fundamental principle that “regardless of how technology evolves, financial activities must be licensed and regulated.”

Meanwhile, the “Notice” also takes a more resolute and thorough stance in defining existing risks. It not only reiterates the non-monetary nature of virtual currencies like Bitcoin but also creatively identifies “stablecoins pegged to fiat currencies” as “effectively fulfilling part of the functions of legal tender” and strictly prohibits the issuance of any unapproved RMB-pegged stablecoins. This provision is strategically insightful, aiming to preemptively counter any potential threats that may erode the sovereign status of the RMB and build parallel settlement systems in the digital space. By categorically identifying virtual currency-related business activities (including exchanges, market making, information intermediation, derivatives trading, etc.) as “illegal financial activities” and repealing the old notice from 2021, the regulatory authority conveys a firm determination to eliminate existing risks without leaving any grey areas.

2. Building a Comprehensive Chain-linked “Firewall”: Three-dimensional Isolation from Fund to Information

If defining is declaring a position, then the regulatory execution framework created in the “Notice” embodies a powerful systematic capability to convert that position into reality. It deploys a comprehensive chain-linked, penetrating regulatory network covering “capital flow, information flow, and technology flow” aimed at physically isolating risks.

At the level of capital flow, the regulatory requirements have reached an unprecedented strictness. All financial institutions and non-bank payment institutions are completely prohibited from providing any form of service for related activities, from account opening and fund transfers to clearing and settlement, product issuance, inclusion of collateral, and conducting insurance business, effectively closing the financial channel. This is equivalent to cutting the “umbilical cord” between the digital asset domain and the mainstream financial system, making it impossible to obtain legitimate liquidity input and credit support.

At the information flow and marketing end, regulations work synchronously online and offline. Online, internet companies are strictly prohibited from providing online venues, commercial displays, marketing promotions, and paid traffic diversion, and are required to report leads and provide technical assistance actively. Offline, market regulators prohibit the use of terms like “virtual currency,” “RWA,” etc., based on the enterprise registration names and operational scopes, while enhancing advertising regulation. This combination aims to eliminate the “visibility” and “implied legitimacy” of digital assets in the public domain, thereby reducing speculative enthusiasm and participation willingness from a social cognition perspective, which is a risk prevention strategy delving into societal psychology.

On the technical and physical level, the regulation of virtual currency “mining” activities continues to deepen, clarifying the overall responsibility of provincial governments, strictly prohibiting new projects and cleaning up existing ones. More critically, the policy innovatively introduces a “foreign service blocking” clause. It clearly states that “foreign entities and individuals must not illegally provide virtual currency-related services to domestic subjects in any form” and stipulates that domestic accomplices will be held accountable. This extraterritorial clause, combined with strict control over cross-border payment channels, essentially establishes a “financial digital border” against the global internet, posing a strong legal deterrent to any foreign exchanges or DeFi agreements attempting to serve Chinese users.

3. Opening the Sole “Compliance Narrow Gate”: The Strategic Intent of the CSRC’s “Guidelines”

While the “Notice” erects a tightly sealed wall, the CSRC’s “Guidelines” meticulously design and open a highly restricted but profoundly significant “door.” This door leads only to a specific destination: allowing asset-backed securities (ABS) tokens to be issued overseas backed by domestic assets or cash flows.

This is by no means a softening stance towards the speculation on virtual currencies, but a precisely crafted “diversion,” reflecting exceptionally high strategic consideration. Firstly, its business model is strictly limited: the underlying assets must be domestic entities or their income rights that generate stable cash flows (such as infrastructure toll rights, trade receivables, leasing assets, etc.), the issued tokens must be ABS tokens consistent with financial logic, and the issuance market and investors must be strictly restricted to overseas. This ensures that the innovative activity is tightly anchored to the real economy, serving the genuine needs of enterprises for cross-border financing, and is completely isolated from the domestic retail speculative market.

Secondly, the regulatory approach is exceptionally strict: employing a “domestic entity must file with the CSRC beforehand” model, rather than simple post-reporting. The filing entity must submit the full set of issuance materials from abroad and undergo a comprehensive review of the authenticity of the underlying assets, compliance of the transaction structure, and effectiveness of risk isolation. This is earlier and deeper than the traditional regulatory intervention in overseas bond issuance or listings, embodying the regulatory principle of “same business, same risk, same rules,” ensuring that innovation does not escape regulatory oversight.

The opening of this “narrow gate” carries at least three strategic intentions: first, facilitating real economy financing: creating a pilot channel for quality domestic companies to utilize blockchain technology to enhance cross-border asset securitization efficiency and reduce costs, directly reflecting the empowerment of the real economy by fintech. Second, accumulating regulatory experience and talent: in the “overseas sandbox” with controllable risks, regulatory bodies, financial institutions, and legal intermediaries can closely observe, understand, and master the entire process of asset tokenization, accumulating valuable regulatory experience and cultivating professional talent for potential larger-scale financial digital transformations in the future. Third, participating in the shaping of international rules: through proactive regulation and practice, China can accumulate a voice in the global financial frontier of asset tokenization, avoiding being passive in the future process of forming international rules, which is a far-reaching layout in major country financial competition.

4. The Emergence of a “Dual-track” Ecology and Global Regulatory Divergence

The combined effect of the “Notice” and the “Guidelines” will profoundly shape the future digital financial ecology in China and may accelerate the differentiation of global regulatory frameworks.

Within China, a clear outline of a “dual-track” digital financial ecology has already imperceptibly begun to take shape. The first track is the “completely closed retail track”: any activities related to cryptocurrencies and speculative tokens aimed at domestic ordinary investors will be completely and thoroughly prohibited long-term, forming a “domestic circulation” safety zone essentially isolated from the global public chain-dominated crypto ecology. The second track is the “limited open institutional and cross-border track”: applications based on alliance chain or permissioned chain technology, aimed at serving the real economy and cross-border capital flows, will be encouraged and developed. The research and application of the digital RMB (e-CNY) and the blockchain infrastructure for the registration, trading, and settlement of specific financial assets, possibly established under state leadership in the future, will become the core pillar of this track. Innovation in RWA can only proceed strictly along the path delineated by the “Guidelines” within the second track.

From a global perspective, China’s regulatory path fundamentally diverges from the compliance paths being explored by major economies such as the United States and the European Union, which are “incorporating crypto assets into existing securities or commodity regulatory frameworks.” China has chosen a unique model of “sovereignty priority, risk isolation, and pilot innovation.” This is not only driven by financial stability considerations but also stems from a deeper defense of national core interests, including monetary sovereignty, capital account management, data security, and cross-border flows. This divergence indicates that the global digital asset market may become further fragmented, forming regional markets with various technological standards, asset types, and investor structures. China’s choice provides another potential regulatory paradigm reference for other emerging economies that prioritize financial sovereignty and control capabilities.

5. Far-reaching Impacts and Future Prospects: Redefining Red Lines and Navigation Lines

In summary, the set of policy documents released in early 2026 will have far-reaching and complex impacts. For market participants, this is a definitive “clearing signal.” All business operations related to virtual currencies and unauthorized digital assets within the territory no longer have any space for survival, and individuals involved also face extremely high legal and property risks. The fantasy of a “policy warming” is no longer realistic. Real opportunities only exist on one path: namely, to completely abandon short-term speculative thinking, deeply understand national strategic intentions, and engage in long-term and arduous technological and model innovation in directions that serve the real economy, comply with cross-border capital management policies, and rely on officially recognized technical pathways.

From a national strategic perspective, this policy combo is a proactive “de-mining” and “foundational laying” of financial infrastructure. It has swept away the “weeds” that could disrupt the stability of the core financial system, erode monetary sovereignty, and trigger social risks with unprecedented intensity, clearing the ground for the next step of “planting” autonomous and controllable national-level financial digital infrastructure. The strictest prohibitions often herald the most prudent preparations. It is foreseeable that in the future, China’s key focus in the blockchain financial field will center on areas led by the “national team,” such as central bank digital currency, trade finance blockchain platforms, and standardized asset digitization transactions.

Ultimately, this set of policies has redefined the non-negotiable red lines for China amidst the turbulent global digital financial transformation—namely, national security, financial stability, and the safety of people’s property; it has also re-identified the navigable lines for exploration—specifically, technology must empower the real economy, innovation must comply with regulation, and development must serve strategy. It heralds that China will independently and autonomously shape its digital financial future landscape according to its own rhythm and logic. The establishment of this new paradigm is not only an upgrade of regulation but also a profound national financial strategic choice, the effects of which will continue to manifest in the next decade and even longer.

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