Threefold Path Game of RMB Stablecoin: From the Gray Area of CNHt to the Sovereign Wall of Digital RMB

In early 2025, the RMB stablecoin market is showing a dual variation of official regulation and market innovation: the regulatory authorities in mainland China have turned on the "caution signal light" for Hong Kong's stablecoin license applications, while the AxCNH offshore RMB stablecoin under Kazakhstan's regulatory framework aims to open up side paths for "Belt and Road" trade settlement. This retreat and advance reflect the core contradiction: how to meet the global market's demand for programmable digital RMB while maintaining financial sovereignty and capital control red lines. Market analysis indicates that in the future, a threefold development path will form: a sovereign wall for digital RMB, a limited open sandbox in Hong Kong, and deep cultivation in specific scenarios.

The Evolution of the RMB Stablecoin: From Gray Area to Official Exploration

The development of the renminbi stablecoin has clearly gone through distinct phases. Early on, market-driven offshore renminbi stablecoins such as CNHt primarily served to provide a channel for capital inflow and outflow for Chinese-speaking region users. Their existence itself proves the enormous demand for digital renminbi in the market, but due to a lack of regulatory transparency and sensitivity to capital flow issues, they have always struggled to gain sovereign recognition. Meanwhile, the digital renminbi (e-CNY) launched by the People's Bank of China, positioned as an optimization tool for the domestic retail payment system, cautiously advances its cross-border payment functionality through multilateral central bank digital currency bridge projects such as mBridge. These two paths represent the bottom-up innovation of the market and the top-down design of the national team, together forming the prelude to the development of the renminbi stablecoin.

The Ideals and Realities of Hong Kong's Experimental Zone: The Innovative Boundaries Under Regulatory Red Lines

The construction of the virtual asset center in Hong Kong was once seen as an ideal testing ground for offshore RMB stablecoin, but the recent regulatory attitude has shifted to caution. The "window guidance" from mainland China's regulators is mainly based on three major concerns: the potential circumvention of capital controls through the free circulation of public chains, issues related to monetary sovereignty, and the potential conflict with the strategic positioning of e-CNY. This essentially reflects the "Mundell's Impossible Trinity" in the digital age—China's choice to maintain exchange rate stability and an independent monetary policy inevitably limits the free movement of capital. Therefore, before ensuring absolute controllability, regulators will not easily open the floodgates that may threaten capital controls. Hong Kong's stablecoin sandbox is currently more focused on HKD stablecoin, while offshore RMB products will have to wait for a more mature regulatory framework.

Insights from Emerging Models: AxCNH's Flanking Breakthrough Strategy

AxCNH has chosen Kazakhstan as its registration location to avoid mainstream regulatory areas such as Hong Kong and Singapore, demonstrating a unique adaptive strategy. The project positions itself as a B-end fintech tool for servicing "Belt and Road" trade settlements, rather than as a speculative asset for retail investors, thereby reducing the potential for risk spillover by limiting its business scope. This model reflects a pragmatic path for the private sector to explore the use of the Renminbi stablecoin under a strong regulatory environment: abandoning the goal of a universal currency and focusing on specific industrial scenarios. However, its long-term sustainability still depends on key variables such as cross-border settlement connectivity and compliance with foreign exchange controls, and whether this sideline path can go far remains to be seen.

Future Outlook: A Threefold Path for Parallel Development

The RMB stablecoin will present three parallel development paths: the official sovereign layer of e-CNY "walled garden" continues to dominate domestic retail payments, while cross-border applications are promoted through a central bank-led multilateral clearing network; the offshore compliance layer may see a highly restricted CNH stablecoin emerge in Hong Kong after the regulatory framework matures, serving institutional-level financial market operations; the market application layer will see more scenario-based projects like AxCNH emerging, deeply cultivating specific industrial chains. This trio pattern reflects the dynamic balance between global liquidity and national financial sovereignty in the digital age, and the game between innovation and regulation will continue to shape the market ecology.

Conclusion

The development trajectory of the Renminbi stablecoin clearly demonstrates the complex interaction between financial innovation and sovereign regulation. From the wild growth of early CNHt to the national will of e-CNY, and then to the institutional exploration in Hong Kong and the side breakthroughs of market entities, this field has always been seeking a balance between risk control and innovative vitality. In the coming years, with the improvement of regulatory technology and the deepening of market demand, there may be more intersections among three paths, but "stability" and "controllability" will still be the core principles guiding this process.

Disclaimer: This article is for informational purposes only and does not constitute any investment advice. The crypto market experiences significant fluctuations, and investors should make decisions cautiously.