Comparison of Global RWA Regulatory Classifications: Differences between Singapore, the United States, and Hong Kong

In November 2025, the Monetary Authority of Singapore (MAS) released the “Guidelines on Tokenization of Capital Market Products,” providing a clear regulatory framework for the RWA industry through 17 specific case studies, marking a new phase in RWA regulation in Asia. This 34-page document adopts a “technology-neutral” principle, with the core logic being “same activity, same risk, same regulatory outcome,” focusing on the economic substance rather than the technological form of the Token.

1. Singapore: Technology Neutrality and Economic Substance Principle

Regulatory Classification System

MAS classifies tokens into two main categories: tokens that constitute CMPs (Capital Market Products) (9 types of cases)

• Equity Token: A token representing ownership in a company, requires a prospectus and Capital Market service license.
• Bond Tokens: Including lending-type, repurchase-type, stablecoins, and packaged structures, as long as the economic substance is a debt relationship, they are regulated as bonds even if packaged through an SPV.
• CIS Unit Token: tokenized fund shares, subject to regulatory oversight according to the collective investment plan, and the manager must be licensed.
• Derivative Tokens: Tokens linked to the price of securities are regarded as securities derivatives and require a derivatives trading license.

Tokens that do not constitute CMPs (8 types of cases)

• Functional Token: A pure platform usage credential, not regulated by SFA but may require a license.
• Governance Token/Meme Coin: Only grants voting rights or is purely for entertainment purposes; if there is no expectation of investment returns, it may not be considered a security.
• NFT/Data Token: Represents ownership of artwork or is used solely for data recording, not involving financial returns may not be classified as CMPs.

Representative Case

• Pure utility token case: Company K developed a “computing power sharing platform” and issued Token K for payments within the platform. The sole function of Token K is to rent computing power, with no investment, dividends, or other financial attributes. MAS determined that Token K is not a CMP and is not subject to securities law regulation.
• Bond Token Case: Company B builds a “decentralized lending platform”, establishes SPVs for each startup, investors provide loans to the SPVs, and the SPVs issue Token B as a loan certificate. Although blockchain technology is used, MAS determines that the economic substance of Token B is a debt relationship, therefore it is regulated as a bond.

2. United States: Penetrative Regulation and the Howey Test

Regulatory Classification System

The United States adopts the principle of “penetrative regulation,” and the SEC uses the Howey test as a criterion.

The four conditions of the Howey test include: investment of money, common enterprise, reasonable expectation of profits derived from the efforts of others, and reliance on the efforts of others.

The vast majority of RWA projects, especially those representing rights to income, are very likely to fall under the Howey test and must strictly comply with SEC regulations.

Representative Case

• BlackRock BUIDL Fund: Launched in March 2024, by June 2025, the managed scale exceeded $3 billion, capturing 34%-37% of the tokenization market for U.S. Treasuries, becoming an industry benchmark. The value of BUIDL is pegged to the U.S. dollar at a 1:1 ratio, with monthly allocated accrued dividends to investors, and an annualized yield of approximately 4.8%-5.2%.
• Ondo Finance: An institutional-level protocol registered in the United States, the flagship product OUSG (Ondo Short-Term U.S. Government Bond Fund) allows investors to purchase tokenized versions of U.S. short-term government bonds through blockchain, with the minimum investment threshold lowered from $5 million to $5,000. In 2024, the number of holders of the platform's tokenized government bonds OUSG surged by 780%, skyrocketing from 1,376 at the beginning of the year to 12,141, occupying 82% market share in the field.

3. EU: MiCA Framework and Unified Standards

Regulatory Classification System

The EU has established the world's first comprehensive regulatory framework for crypto assets through the Markets in Crypto-Assets Regulation (MiCA), classifying tokens into three categories:

• Electronic Money Token (EMT): Pegged to a single fiat currency, analogous to electronic money, requiring at least 30% of reserve assets to be held within the EU central banking system.
• Asset Reference Token (ART): Pegged to a basket of assets or commodities, subject to daily liquidity pressure testing.
• Other crypto assets: utility tokens, subject to light regulation

representative case

Société Générale EURCV: The first euro stablecoin issued by a regulated bank under the MiCA framework in the EU, utilizing a “permissioned whitelist” mechanism, used as a “atomic settlement” tool in the European Investment Bank (EIB) digital bond issuance.

4. Hong Kong: Dual-track Regulation and Sandbox Pilot

Regulatory methods and specific measures

• Principle of Transparency: Determine the regulatory approach based on the underlying nature of the assets and associated risks.
• Licensed Operations: Trading platforms for RWA Tokens need to apply for a license from the SFC in accordance with the “Guidelines for Virtual Asset Trading Platforms”, such as Type 1 (Securities Trading), Type 4 (Providing Advice), Type 7 (Automated Trading Services) or Type 9 (Asset Management).
• Regulatory Sandbox: Allows testing of innovative RWA products, such as tokenized bonds and real estate securitization projects, in a controlled environment.
• Risk Disclosure: Requires comprehensive disclosure of the technical, legal, custodial, and other risks associated with tokenization products.
• Investor Protection: Prohibit the use of misleading promotions, such as “high returns” or “capital preservation,” and emphasize user protection.
• Cross-border compliance: Provides a compliance path for domestic enterprises to participate in the RWA market, such as through the “Ensemble” sandbox program and the construction of SPV structures.

Asset Classification

Hong Kong adopts a “translucent” regulatory principle, classifying RWA into three categories:

• Green Light Assets: Traditional financial assets such as securities, funds, green bonds, etc., need to be approved by the Hong Kong Securities and Futures Commission (SFC)
• Yellow Light Assets: Trade financing, supply chain bills, etc., need to connect to the Hong Kong Monetary Authority's wholesale Central Bank Digital Currency (wCBDC) system.
• Red light assets: Involving money laundering, illegal fundraising, or pure crypto assets, are directly prohibited.

Representative Case

• Taiji Capital Prince Real Estate STO: In September 2023, 100 million HKD was issued, with underlying assets being the rental income rights of 5 retail properties in the Kowloon Prince tourism hotspot, using the ERC-1400 standard, traded through the HKbitEX platform, becoming the first real estate security token (STO) in Hong Kong, obtaining SFC license numbers 4 and 9.
• Huaxia Fund Hong Kong Dollar Digital Currency Fund: Issuing $110 million in February 2025, with underlying assets being Hong Kong dollar short-term deposits and money market instruments, issued on the Ethereum blockchain, distributed by OSL exchange, becoming the largest retail tokenization fund in the world.

V. The Impact of Regulatory Differences

Differences in Regulatory Philosophy

• Singapore: Emphasizes “technology neutrality”, focuses on economic substance analysis, and provides clear classification standards for various types of Tokens.
• United States: Adhere to “penetrative regulation”, using the Howey test for case-by-case judgment, with relatively strong regulatory flexibility but insufficient certainty.
• Hong Kong: Adopts a “dual-track mechanism” to maintain regulatory rigidity while reserving space for innovation, encouraging pilot projects through a sandbox mechanism.

Liquidity Differentiation

• The tokenization scale of U.S. Treasury bonds reached $7.37 billion, with an annual growth of 415%, benefiting from the SEC's clear regulatory framework.
• Hong Kong has implemented the Ensemble sandbox mechanism, allowing the sharing of global order books with overseas platforms to enhance liquidity. Different jurisdictions have significant differences in the qualification, taxation, and data storage requirements for RWA, and businesses need to guard against compliance “gray areas”.

compliance cost differences

• Singapore: The total cost of the RWA project starts at approximately 2.5 million Singapore dollars, and the approval process is relatively transparent.
• United States: Compliance costs are the highest, legal advisor fees are expensive, and there is a significant risk of regulatory uncertainty.
• Hong Kong: The cost is between that of the US and the new, but the initial investment can be reduced through the sandbox mechanism.

Investor Protection Standards

Hong Kong requires a “green light fast review” for compliant assets such as green bonds and trade receivables. The EU MiCA emphasizes data security and cross-border compliance, requiring cryptocurrency service providers to meet prudent regulatory standards.

7. Market Size and Future Trends

Market size explosive growth

In the first half of 2025, the RWA market size grew from $8.6 billion at the beginning of the year to $23 billion, an increase of 260%. Tokenization of private credit holds the largest market share (58%), followed by tokenization of U.S. Treasury bonds (34%). As of June 2025, the total market capitalization of the global RWA market has exceeded $24 billion, an increase of 380% compared to 2022.

Future Development Trends

• Regulatory convergence accelerates: The compliance interface between DeFi and TradFi is taking shape, with RegTech becoming a new infrastructure. Hong Kong and Singapore have clearly stated that they will strengthen coordination on RWA regulation and jointly promote the standardized development of the RWA market in the Asia region.
• Technical Regulation Upgrade: With the increasing complexity of RWA projects, regulatory agencies will increasingly utilize blockchain technology itself for regulation. The application of privacy protection technologies such as zero-knowledge proofs will meet regulatory transparency requirements while ensuring data security.
• Diversification of asset types: Expanding from current government bonds, real estate, and private credit to a broader range of asset classes, including intellectual property, data assets, carbon credits, and other new types of assets. According to a forecast by the Boston Consulting Group, the global asset tokenization market is expected to reach $16.1 trillion by 2030.
• Cross-border regulatory competition and cooperation coexist: Countries compete to attract RWA innovation and investment, but also recognize the necessity of cross-border regulatory cooperation. International collaborative projects such as Project Guardian indicate that future RWA regulation will place greater emphasis on cross-border coordination.

Conclusion

The release of Singapore's “Guidelines on Tokenization of Capital Market Products” provides a clear template for global RWA regulation. The regulatory differences across various jurisdictions present both challenges and opportunities. For RWA project parties, the key lies in selecting the appropriate compliance path and technical architecture based on the target market, asset type, and business model. As the regulatory framework gradually becomes clearer and technology continues to mature, RWA is expected to unleash its innovative value on a regulated development track, becoming an important bridge between traditional finance and digital finance.