Hong Kong Declaration 2.0: Recasting Digital Asset Rules, Who Will Dominate the New RWA Ecosystem?

Text|RWA Knowledge Circle

Compile|RWA Knowledge Circle

1. Three-Year Transformation: Opportunities and Solutions under Hong Kong's New RWA Policy

As the "Hong Kong Digital Asset Development Policy Declaration 2.0" unveils, the market focuses on two core propositions: what kind of enterprises can cross the threshold for stablecoin issuance? And how can those who do not meet the standards leverage external forces to seize opportunities?

Three years later, the "Declaration 2.0" released by Hong Kong marks the entry of digital asset development into deep waters. Compared to the "Declaration 1.0" in 2022, which focused on the basic compliance framework, the new policy directly addresses three key areas: asset liquidity, product diversification, and market efficiency. In this round of upgrades, the tokenization of real-world assets (RWA) has moved from concept to implementation stage, while stablecoins, as the "value bridge" connecting various RWAs, face the core issue of issuance thresholds and participation paths that companies must solve.

II. RWA: From Marginal Experiment to Market Engine

"Manifesto 2.0" brings the tokenization of real-world assets (RWA) into the spotlight, clearly demonstrating Hong Kong's key transformation from "sandbox experimentation" to "scaled application:"

Breakthrough Expansion of Asset Territory: The policy clearly establishes a normalized issuance mechanism for tokenized government bonds, and incorporates real economy assets such as precious metals, non-ferrous metals, and renewable energy into the tokenized landscape, thoroughly surpassing the early exploration of a single asset type.

Revolutionary evolution of liquidity mechanisms: Open RWA circulates in the secondary market through licensed trading platforms, breaking the closed model of traditional fund underwriting and injecting market vitality into digital assets.

This not only represents a quantitative change in asset types, but also a qualitative change in the value exchange mechanism. However, for most eager enterprises, to truly participate in this transformation and achieve an improvement in capital efficiency, they must first overcome a critical threshold: how to build a compliance system that aligns with the "Declaration 2.0" and the "Stablecoin Regulations" and other supporting regulations? This involves complex organizational restructuring, robust blockchain technology support, and stringent KYC/AML risk control capabilities.

3. Practical Pathways for Compliance Challenges: Insights from Sandbox Testing Cases on Corporate Layouts

In response to the high compliance thresholds, large enterprises have explored reusable path models. Taking JD, which was among the first to enter the Hong Kong Monetary Authority's stablecoin sandbox testing, as an example, it showcased a viable path to meet high compliance thresholds through proactive layout: in 2018, it established an independent entity "JD Coin Chain Technology" in Hong Kong, creating an independent board structure and asset isolation mechanism that complies with the "Stablecoin Ordinance," and relying on a global business network to meet high standards of technological capacity and KYC/AML risk control. The core value of such cases lies in validating the key capability model required by enterprises under the new policy—independent compliance entities, robust risk control systems, and sufficient resource investment. However, for small and medium-sized enterprises with limited resources, building a compliant system of the same scale on their own is like "building a bridge in the deep sea"; it is costly and time-consuming. This is precisely the value of the RWA Accelerator—it provides enterprises (especially small and medium-sized enterprises) with a "shortcut" by presetting legal frameworks, connecting exchange resources, and compliance technology modules, significantly reducing trial-and-error costs and shortening the market entry period.

4. Stablecoins: High-threshold "Digital Pass"

The "Declaration 2.0" positions stablecoins with stringent requirements for "digital currency"—100% fiat currency reserves, high-quality liquid asset anchoring, and a triple compliance barrier (asset liquidity/territorial compliance/system stability)—making them the core hub connecting RWA, but also building a high wall that is difficult for small and medium-sized enterprises to cross: Triple compliance barrier.

1. Asset liquidity: Reserves must be in highly liquid assets such as Hong Kong dollars/government bonds, and a dedicated segregated custody account must be established;

2. Territorial compliance: Mandatory Hong Kong registered entity + localized audit + cross-border regulatory coordination;

3. System Stability: Must satisfy both anti-attack technology and real-time redemption mechanism.

Faced with such a complex compliance system, large technology groups can gradually break through thanks to resource accumulation (for example, JD.com relies on its cross-border clearing and settlement capabilities to complete its layout), while small and medium-sized enterprises wishing to build a similar system is akin to asking startups to establish a global clearing network.

At this time, the value of the RWA Accelerator is highlighted - by using a pre-established legal framework and compliance technology modules (such as standardized custody interfaces), the issuance compliance cycle is compressed from 18 months to 6 months.

V. LEAP Framework: Strategic Opportunities for Ecological Builders

The "LEAP" plan (Legal Optimization - Product Expansion - Application Promotion - Partner Collaboration) launched by "Manifesto 2.0" is upgrading Hong Kong from a regulatory testing ground to an institutional open hub. In this ecological blueprint, the RWA Accelerator plays a key catalytic role:

Connect licensed exchange liquidity pools for small and medium-sized enterprises.

Provide blockchain on-chain solutions for traditional asset parties

Build a compliant entry and exit channel for cross-border capital

As Hong Kong writes "tokenization of precious metals" into policy texts, and the RWA accelerator opens up the secondary market for assets like solar panels, a trillion-level digital asset ecosystem is taking shape — has your enterprise already secured a position in the value chain?

The ultimate revelation of "Manifesto 2.0" is that Hong Kong should not be a spectator on the sidelines, but a co-builder of the ecosystem. The RWA Accelerator is precisely the strategic hub that connects real assets with the digital future, and it is also the only shortcut for small and medium-sized enterprises to seize the high ground of new finance.