Global RWA Regulatory Classification Comparison: Differentiation 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 sector through 17 specific case studies, marking a new phase in the regulation of RWA in Asia.

This 34-page document adopts the principle of "technological neutrality", with the core logic being "same activity, same risk, same regulatory outcome". It does not consider the technological form of the token, but rather its economic substance.

1. Singapore: Technology Neutrality and Economic Substance Principle Regulatory Classification System MAS categorizes tokens into two main categories: tokens constituting CMPs (Capital Market Products) (9 case types)

• Equity Tokens: Tokens that represent ownership in a company, requiring a prospectus and a 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 SPV.

•CIS Unit Token: Tokenized fund shares, subject to regulatory oversight under collective investment schemes, and managers must be licensed.

• Derivative Tokens: Tokens linked to the price of securities are regarded as securities derivatives and require a derivatives trading license. They do not constitute CMPs (8 types of cases).

• Functional tokens: Pure platform usage credentials, not subject to SFA regulation but may require a license payment. • Governance tokens/Meme coins: Only grant voting rights or are purely for entertainment purposes; if there is no expectation of investment return, they may not be classified as securities.

•NFT/Data Tokens: Represent ownership of artworks or are solely used for data recording, without involving financial returns, which may not be representative cases of CMPs.

• Pure utility token case: Company K developed a "computing power sharing platform" and issued Token K for payments within the platform.

The only function of Token K is to rent computing power, with no investment, dividends, or other financial attributes. MAS determines that Token K is not a CMP and is not subject to securities law regulation.

• Bond Token Case: Company B established a "decentralized lending platform" and set up an SPV for each startup. Investors provide loans to the SPV, which issues Token B as a loan certificate. Despite using blockchain technology, the MAS determined that the economic substance of Token B is a creditor relationship, and therefore it is regulated as a bond.

2. United States: Penetrating Regulation and Howey Test Regulatory Classification System. The United States adopts the principle of "penetrating regulation," and the SEC uses the Howey Test as the standard for judgment. The four conditions of the Howey Test include: investment of money, a common enterprise, a reasonable expectation of profits to be 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 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, it had managed over $3 billion, capturing 34%-37% of the tokenized U.S. Treasury market, becoming an industry benchmark. The value of BUIDL is pegged to the U.S. dollar at a 1:1 ratio, with monthly distributions of accrued dividends to investors, yielding an annualized return of approximately 4.8%-5.2%.

•Ondo Finance: An institution-level protocol registered in the United States, its flagship product OUSG (Ondo Short-Term U.S. Government Bond Fund) allows investors to purchase tokenized versions of U.S. short-term government bonds via blockchain, lowering the minimum investment threshold from $5 million to $5,000.

In 2024, the number of holders of the platform's tokenized national debt OUSG surged by 780%, skyrocketing from 1,376 at the beginning of the year to 12,141, capturing 82% of the market share in this sector. 3. European Union: MiCA framework and unified standard regulatory classification system The European Union has established the world's first comprehensive regulatory framework for crypto assets through the "Markets in Crypto-Assets Regulation" (MiCA), categorizing tokens into three types:

• Electronic Money Token (EMT): Pegged to a single fiat currency, analogous to electronic money, requires at least 30% of reserve assets to be held within the EU central bank system.

• Asset Reference Token (ART): Anchored to a basket of assets or commodities, it is subject to daily liquidity stress testing.

• Other crypto assets: Utility tokens, a representative case of light regulation is Societe Generale EURCV: the first euro stablecoin issued by a regulated bank under the MiCA framework in the EU, utilizing a 'permissioned whitelist' mechanism, used as an 'atomic settlement' tool in the issuance of digital bonds by the European Investment Bank (EIB).

4. Hong Kong: Dual-track regulation and sandbox pilot regulatory methods and specific measures • Penetrating principle: Determine the regulatory approach based on the underlying nature of the assets and associated risks.

• Licensed Operation: The trading platform for RWA tokens needs to apply for a license from the SFC in accordance with the "Guidelines for Virtual Asset Trading Platforms", such as Class 1 (Securities Trading), Class 4 (Providing Advice), Class 7 (Automated Trading Services), or Class 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: A comprehensive disclosure of the technical, legal, custody, and other risks associated with tokenized products is required.

• Investor protection: Prohibit misleading promotions, such as "high returns" or "capital protection," and emphasize user protection.

• Cross-border compliance: provides a compliant pathway for domestic enterprises to participate in the RWA market, such as through the "Ensemble" sandbox program and the construction of SPV structures. Asset classification in Hong Kong adopts a "penetrative" regulatory principle, dividing 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 notes, etc., need to be integrated into the Hong Kong Monetary Authority's wholesale Central Bank Digital Currency (wCBDC) system.

• Red Light Assets: Involves money laundering, illegal fundraising or pure cryptocurrency assets, directly prohibits representative cases.

• Taiji Capital Prince Real Estate STO: In September 2023, issued 100 million HKD, 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 Hong Kong's first real estate security token offering (STO), obtained SFC licenses 4 and 9.

• Huaxia Fund Hong Kong Dollar Digital Currency Fund: Issued $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 world's largest retail tokenized fund. V. Impact of Regulatory Differences on Regulatory Philosophies.

•Singapore: Emphasizes "technology neutrality" and focuses on economic substance analysis, providing clear classification standards for various types of tokens.

• United States: Adhere to "penetrating 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" that maintains regulatory rigidity while allowing space for innovation, encouraging pilot projects through a sandbox mechanism. Liquidity differentiation.

• The tokenization scale of US 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 a global order book with overseas platforms to enhance liquidity. There are significant differences in the qualitative, tax, and data storage requirements for RWA across different jurisdictions, and enterprises need to guard against compliance "gray areas." Compliance cost variations.

•Singapore: The total cost of the RWA project starts at approximately 2.5 million SGD, and the approval process is relatively transparent.

•United States: Compliance costs are the highest, legal advisory fees are expensive, and there is a greater risk of regulatory uncertainty.

• Hong Kong: Costs are between those of the US and the new US, but the sandbox mechanism can reduce initial investment. The investor protection standards in Hong Kong require 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 crypto asset service providers to meet prudent regulatory standards.

7. Market Size and Future Trends
The market size has experienced 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%. Tokenized private credit holds the largest market share (58%), followed by tokenized U.S. Treasury bonds (34%).

As of June 2025, the global RWA market's total market value has surpassed $24 billion, an increase of 380% compared to 2022. Future development trends.

• Accelerated Regulatory Integration: Compliance interfaces between DeFi and TradFi are forming, and regulatory technology (RegTech) is becoming a new infrastructure. Hong Kong and Singapore have clearly stated that they will strengthen coordination in RWA regulation and jointly promote the standardized development of the RWA market in the Asia region.

• Technology regulation upgrade: As the complexity of RWA projects increases, regulatory agencies will increasingly utilize blockchain technology itself for supervision. 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 like Project Guardian indicate that future RWA regulation will place greater emphasis on cross-border coordination.

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