China (mainland)

No registration, licensing, or authorization pathway exists onshore for crypto exchange or related intermediary activity; the regime is best characterized as a blanket prohibition rather than a permissive-but-restricted licensing regime. The People's Bank of China remains the lead supervisory authority driving this prohibition, with the National Development and Reform Commission, Ministry of Public Security and State Administration of Foreign Exchange operating as co-signatories with distinct enforcement remits (industrial-policy/mining, public-security enforcement, and foreign-exchange/cross-border control respectively).

The entire evidentiary basis for this module's claims -- both the underlying 2021 prohibition and its February 2026 reassertion and extension -- rests on T4 secondary news reporting (CoinDesk, The Block); no primary-source PBOC or joint-agency text has been directly retrieved and verified against an official .gov.cn portal this cycle. Confidence on both the 2021 Notice's declaration of illegality and the 2026 notice's reassertion has accordingly been held at Probable, downgraded from an initial Confirmed rating, reflecting the systemic absence of T1-T3 corroboration across nearly all binding claims in this jurisdiction this cycle. The exact calendar date of the February 2026 notice is itself an approximation (2026-02-06) drawn from secondary reporting that described the notice's issuance only as occurring on "Friday."

Outlook

The trajectory here is unambiguously tightening: the February 2026 notice both reaffirms and materially broadens the scope of the standing prohibition, rather than signaling any move toward a licensing pathway. The most consequential near-term research task is direct primary-source retrieval of the February 2026 joint notice text from an official .gov.cn portal, which would both confirm the exact promulgation date and allow sourcing to be upgraded above T4 for this module's core claims. Until that verification occurs, this module's claims should be read as resting on a well-corroborated but exclusively secondary evidentiary base, with the 2021-to-2026 supersession relationship itself now confirmed by independent T3 legal-advisory sources even though the underlying regulatory text remains unretrieved in primary form.

NFTs occupy a distinct and only partially resolved position within this classification landscape. Marketed domestically as "digital collectibles," NFTs are not formally banned and exist in a regulatory gray area without comprehensive rules specific to the asset class. Market participants have structurally distanced NFT products from cryptocurrency exposure -- these products cannot be purchased with cryptocurrency and are typically built on permissioned rather than public blockchains, an architecture choice that appears designed specifically to avoid association with the broader crypto prohibition rather than reflecting any formal regulatory carve-out.

Outlook

Token classification in mainland China should be read as a stable but entirely negative landscape: there is no positive taxonomy under which any crypto-asset acquires lawful status, and the February 2026 notice's extension of non-fiat-status language to stablecoins forecloses any near-term prospect of a differentiated stablecoin classification pathway opening onshore. The NFT gray zone remains the one area of this module carrying genuine classification ambiguity rather than settled prohibition, and its trajectory depends on whether Chinese regulators move to formalize rules for permissioned-chain digital collectibles or instead fold them into the broader prohibition architecture -- neither of which has yet occurred as of this cycle. Sourcing for the core legal-tender-denial claims rests on T4 secondary reporting only; the NFT gray-zone characterization similarly rests on T4 reporting with no primary regulatory guidance identified.

The February 2026 eight-agency joint notice extended this on-chain prohibition architecture to RWA tokenization, prohibiting the conversion of ownership or income rights into token-like certificates via cryptography and distributed-ledger technology unless conducted on approved financial infrastructure with regulatory authorization. Read in isolation, this reads as a further extension of the flat prohibition model applied to mining and exchange. However, a Challenger-driven correction to this cycle materially qualifies that reading: the same February 2026 notice simultaneously established, for the first time, a licensed offshore pathway for RWA tokenization. That pathway comprises three regulator-defined categories overseen jointly by the CSRC, NDRC and SAFE under a same-business-same-risk-same-rules principle, and is accompanied by a same-day CSRC filing-based regime -- 2026 Announcement No. 1 -- specifically covering offshore asset-backed tokenized securities. This is a materially different regulatory posture than a flat, undifferentiated ban: mainland China has, for RWA tokenization specifically, begun differentiating between unauthorized activity (prohibited) and a defined, licensed, offshore-facing channel (permitted subject to regulator oversight and same-day filing), even as onshore, unauthorized tokenization and crypto-to-crypto exchange remain squarely prohibited.

This distinction does not extend to mining or general exchange activity, both of which remain subject to undifferentiated prohibition with no comparable licensed pathway identified this cycle. It is also worth noting that the licensed-offshore-pathway correction itself rests on a narrower and generally higher-tier evidentiary base than the rest of this module: it draws on T3 legal-advisory commentary (Norton Rose Fulbright, Han Kun Law) rather than the T4 news-tier reporting underlying the mining and exchange-prohibition claims, though even this T3 commentary has not yet been corroborated against directly-retrieved primary CSRC/NDRC/SAFE text.

Outlook

The on-chain activity regime's trajectory remains tightening overall -- mining and exchange prohibitions are undisturbed and RWA tokenization has newly been brought within the prohibition perimeter -- but the module now carries a genuine structural nuance that a simple red/tightening label risks obscuring: RWA tokenization specifically has acquired a licensed, offshore, regulator-overseen channel that does not exist for crypto mining or exchange activity. Future cycles should watch for primary-source confirmation of the three CSRC/NDRC/SAFE-defined tokenization categories and the mechanics of the same-day CSRC filing regime, and for whether this differentiated treatment of RWA tokenization signals a broader willingness to extend similarly licensed, offshore-facing channels to other on-chain activity types, or whether it remains confined to the RWA-tokenization use case specifically. Given that the underlying correction rests on secondary legal-commentary sourcing rather than directly-retrieved primary regulatory text, this module's confidence should remain capped at Probable pending that verification.

The People's Bank of China has separately articulated a risk-based rationale for this position, identifying stablecoins as failing to meet KYC/AML standards and flagging money-laundering, illegal cross-border transfer, and underground-payment risks associated with stablecoin use -- framing stablecoins generally as a threat to financial security rather than treating them as a distinct, lower-risk asset subcategory relative to other crypto-assets. This risk-based framing supplies the policy rationale underlying the February 2026 notice's explicit offshore-issuance ban.

No onshore reserve-requirement regime for stablecoin issuers currently exists in mainland China, but this absence should be read as a function of the prohibition itself rather than as an unregulated gap in a permissive framework: stablecoin issuance onshore is not merely unregulated, it is prohibited absent case-by-case regulatory approval that has not, on the evidence gathered this cycle, been documented as granted to any issuer. This is a materially different characterization than would apply in a jurisdiction where issuance is legal but reserve requirements simply have not yet been specified.

Outlook

The stablecoin regime's trajectory is tightening, and the February 2026 notice's explicit, named prohibition on offshore RMB-pegged stablecoin issuance closes a specificity gap that previously existed in the broader mainland prohibition architecture. This module also carries a cross-monitor dimension worth tracking: PBOC's AML/KYC risk framing for stablecoins sits partly on the financial-integrity monitor's subscribed surface, and the stablecoin risk-to-payment-systems framing implicates world-payments considerations, particularly given separately documented interventions to prevent Chinese technology firms from issuing stablecoins via Hong Kong. Sourcing across this module's core claims remains T4 secondary reporting only, with the reserve-requirement characterization held at Uncertain confidence reflecting the absence of any documented approval precedent to confirm the absence-by-prohibition reading.

A narrower and more targeted intervention addresses NFT marketing specifically. China's Internet Finance Association, Banking Association and Securities Association jointly called to curb financialization and securitization tendencies in NFTs and warned against speculative marketing of digital collectibles. This is a non-binding, associational warning rather than a formal regulatory prohibition, and it sits alongside -- rather than resolves -- the broader NFT classification gray zone addressed under the Token Classification module.

Outlook

The consumer-protection trajectory is tightening, consistent with the broader prohibition architecture: the Supreme People's Court's civil-invalidity position removes rather than strengthens investor recourse, and it should not be read as a consumer-protection framework in the conventional sense of disclosure requirements, custody safeguards, or complaint-resolution mechanisms. Because the underlying activity is prohibited, mainland China's regime effectively substitutes prohibition-plus-remedy-denial for the affirmative consumer-protection scaffolding found in jurisdictions with legal, licensed crypto markets. The NFT-marketing warning from industry associations remains the one area where a distinct, targeted consumer-facing intervention exists independent of the broader prohibition, though its non-binding character limits its practical force. Sourcing for both claims in this module is T4 secondary reporting; no primary Supreme People's Court judicial-interpretation text has been directly retrieved this cycle.

The February 2026 eight-agency joint notice tightened this offshore-structure perimeter further. It bars foreign entities and individuals from illegally providing RWA tokenization services to domestic counterparties, and subjects overseas crypto and tokenization activity conducted by Chinese entities to increased scrutiny. Read alongside the on-chain activity regime's newly-identified licensed offshore RWA-tokenization pathway (CSRC/NDRC/SAFE-overseen, same-business-same-risk-same-rules), this suggests mainland regulators are simultaneously tightening unauthorized cross-border channels while formalizing a narrow, licensed, offshore-facing route specifically for RWA tokenization -- a differentiation not evident for crypto exchange or trading activity generally, where the cross-border prohibition remains comprehensive and undifferentiated.

Outlook

Cross-border transfer trajectory is tightening, with the State Administration of Foreign Exchange positioned as a lead enforcement authority for outbound and offshore-facing capital-control dimensions of this prohibition. This module carries a direct cross-monitor connection: offshore-structure enforcement and capital-control questions implicate the financial-integrity monitor's cross-border AML/CTF surface, and this cycle's findings have been flagged there accordingly rather than independently analyzed in full on that dimension within this crypto baseline. A recurring open question for this module is whether Hong Kong -- a separate jurisdiction record within this monitor -- should be more extensively cross-referenced given Beijing's documented interventions into Hong Kong-based stablecoin and tokenization plans; this remains unresolved as of this cycle. Sourcing for both claims in this module is T4 secondary reporting only.