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title: "China Crypto Regulation Monitor | cryptoassets.gi"
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source_html: /jurisdictions/china/index.html
description: "China crypto asset regulation: 9 categories, 33 sourced findings, updated 2026-11-04. Licensing, token classification, stablecoins, tax treatment."
generated_at: 2026-11-07T14:19:44Z
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# China Crypto & Digital Asset Regulation

schema crypto-v2.0.0
trajectory: not yet assessed prohibited overlaps: [Sentinel (AML/CFT)](https://sentinel.gi/jurisdictions/china/), [World Payments](https://payments.gi/jurisdictions/china/)

Last updated 2026-11-04 · 9 categories · 33 sourced
findings · 36 sources in the cumulative register

Download report (PDF) Expand all

Evidence re-verified: 2026-11-04 · Position last changed: 2026-11-04 · Record history & provenance ▾ Methodology & record provenance: Module confidence is derived from the underlying claims (source tier and primary excerpt retention), while statutory legal force is tracked independently.

Review status: AI-synthesised · Tier-1/2 verified · As-of date: 2026-10-26

[Open in Co-Pilot ↗](/reports/?type=copilot&j=CHINA)[Build Report](/reports/?j=CHINA)[Compare](/compare/?j=CHINA)

Framework posture Prohibited 8 of 9 modules populated · AI-synthesised · Tier-1/2 verified

Lead supervisory authority People's Bank of China (PBOC)-led ten-agency Notice Primary statutory & supervisory perimeter

Next milestone (> 2026-10-26) None scheduled No dated future statutory milestone on record

Module coverage & confidence 8 / 9 modules assessed 0 Confirmed · 8 Probable · 0 Uncertain · 1 Not yet assessed

9 Categories

0 Moved this cycle 0 Key judgments 4 Open gaps 33 Findings

0 Tier-1 sources

Confidence mix 9 unpopulated
(sums to 9 rendered categories; click to filter)

No categories moved this cycle.

## Jurisdiction lead brief

###### Latest update · 25 October 2026

#### Lead Signal

China's digital-asset prohibition regime was reaffirmed and materially extended through a 2026 People's Bank of China-led joint circular that repealed the 2021 Circular on Further Preventing and Disposing of Speculative Risks in Virtual Currency Trading and replaced it with a broader instrument. The new circular reaffirms that virtual currencies, stablecoins and tokenised assets carry no legal-tender status and that related trading, issuance and intermediary services constitute illegal financial activity absent explicit approval. The most consequential addition is the explicit closure of what market commentary had termed an offshore issuance loophole: domestic firms and their overseas branches are now barred from issuing or facilitating RMB-pegged stablecoins without explicit government approval, regardless of where the issuing entity is incorporated.

#### Other Developments

Stablecoin prohibition now extends to real-world-asset tokenisation. The 2026 circular classifies most real-world asset tokenisation as illegal absent approval, placing it within the same prohibition framework previously applied to cryptocurrency trading and mining. This treats fiat-referenced stablecoins and tokenised real-world assets as a monetary-sovereignty risk rather than as a distinct product category to be separately licensed.

Cross-border tokenisation activity faces increased scrutiny. Chinese companies seeking to tokenise assets overseas, along with their financial or technology partners, now face a regime with no approval route and an explicit ban on unapproved RMB-stablecoin issuance abroad. This extends the prohibition's practical reach to offshore structures previously seen as outside the mainland regulatory perimeter.

Peer-to-peer stablecoin usage reported to be growing despite prohibition. Reported Chainalysis data carried via secondary outlets found that unique peer-to-peer stablecoin wallets inside mainland China grew forty-three-fold from the first quarter of 2024 to the second quarter of 2026. This data point has not been independently corroborated and should be read as an uncertain-confidence indicator of a widening gap between the formal prohibition and on-the-ground usage.

#### Cross-Monitor Connections

The extension of the stablecoin and cross-border prohibition connects directly to the sanctions-architecture and conflict-finance territory covered by financial-integrity monitoring, insofar as a jurisdiction with a comprehensive and recently tightened digital-asset prohibition is simultaneously reported to be hosting substantial growth in peer-to-peer stablecoin usage, a channel that sits outside conventional correspondent-banking and cross-border-payments visibility.

#### Outlook

The closure of the offshore RMB-stablecoin issuance route and the extension of scrutiny to overseas tokenisation activity are structural tightening measures that are already in force as. The open question going forward is whether the reported growth in peer-to-peer stablecoin usage prompts a visible enforcement response from the People's Bank of China or allied authorities, which would be the clearest test of whether the February 2026 circular's extended prohibition is being actively applied against informal usage rather than only against formal issuance and exchange activity.

3 earlier updates not shown here.

###### Standing brief · as of 3 August 2026

Written before the update above. Where they differ, the update is the more recent position.

#### Lead Signal

Mainland China's crypto prohibition regime deepened materially in February 2026. An eight-agency joint notice -- fronted by the People's Bank of China alongside the China Securities Regulatory Commission, the National Development and Reform Commission, the Ministry of Public Security, the State Administration of Foreign Exchange and other agencies -- reasserted the blanket ban on crypto trading and stablecoins first imposed by the September 2021 ten-agency Notice, while extending the perimeter of prohibition to two previously undercovered activity types: real-world-asset (RWA) tokenization and unauthorized offshore renminbi-pegged stablecoin issuance. The new instrument states plainly that no entity or individual, whether located inside or outside China, may issue offshore stablecoins pegged to the renminbi without prior regulatory approval, and it imposes strict controls on RWA tokenization, permitting only limited exceptions.

Two corrections carried into this cycle materially change how that broadened prohibition should be read. First, legal-advisory reporting (Norton Rose Fulbright; Lexology/Han Kun Law) establishes that the February 2026 notice supersedes the 2021 Notice outright rather than sitting alongside it as a co-equal, independently-operative instrument -- the 2021 Notice's prohibitions on exchange services, token-to-token conversion and related intermediary/financing activity now flow forward through the 2026 instrument as the sole current primary framework. Second, and more consequentially, the same reporting indicates the February 2026 notice does not impose a flat, undifferentiated ban on RWA tokenization. Alongside prohibiting unauthorized onshore and offshore tokenization, it establishes -- for the first time -- a licensed offshore pathway comprising three regulator-defined categories under CSRC, NDRC and SAFE oversight, applying a same-business-same-risk-same-rules principle, paired with a same-day CSRC filing regime (2026 Announcement No. 1) for offshore asset-backed tokenized securities. This is a materially more nuanced regime than the flat-ban framing that a reading of the prohibition language alone would suggest, though it does not disturb the underlying red-light rating for onshore crypto activity generally.

Both the broadened prohibition and the newly identified licensed pathway rest on T3/T4 secondary reporting -- no primary-source PBOC, CSRC, NDRC or SAFE text has been directly retrieved and verified against an official .gov.cn portal this cycle, and even the notice's exact promulgation date (reported only as "Friday" in underlying coverage) is an approximation. Confidence across the affected claims has accordingly been held at Probable rather than Confirmed.

#### Other Developments

Beyond the headline February notice, several standing planks of the mainland regime remain in force and were reaffirmed this cycle. The People's Bank of China continues to deny virtual currencies any legal-tender status, stating they should not and cannot be used as currency in the market -- a position the February 2026 notice explicitly extends to stablecoins including USDT. NFTs, marketed domestically as "digital collectibles," continue to occupy an unresolved regulatory gray zone: not formally banned, but structurally distanced from crypto through permissioned rather than public blockchain architecture and a prohibition on cryptocurrency-denominated purchase. Industry associations covering internet finance, banking and securities have separately warned against the financialization and speculative marketing of digital collectibles, without this rising to a formal ban.

On-chain activity remains comprehensively restricted: the National Development and Reform Commission's September 2021 notice barring new mining investment and requiring wind-down of existing projects as a designated "outdated" industry remains the operative mining framework, and the underlying exchange ban extends beyond simple fiat-crypto conversion to capture crypto-to-crypto exchange and decentralized-exchange-type activity.

China's Supreme People's Court has confirmed that civil legal acts involving cryptocurrency investment are deemed invalid, with resulting losses borne by investors themselves -- leaving no civil remedy pathway for mainland crypto investors, consistent with the underlying prohibition on the activity itself.

Tax treatment remains an open question rather than a resolved gap-by-design: no dedicated crypto-specific tax framework or guidance -- whether addressing income tax on gains or VAT treatment -- has been identified for mainland China, and it remains unclear whether general PRC tax law has been formally applied to crypto-related transactions in any published ruling.

#### Cross-Monitor Connections

Two overlap surfaces were flagged this cycle. On the financial-integrity surface, the PBOC's characterization of stablecoins as failing KYC/AML standards -- flagging money-laundering, illegal cross-border transfer and underground-payment risk, and describing stablecoins as a threat to financial security -- is treated here as subscribed AML/CTF content routed to the fleet's financial-integrity monitor rather than independently analyzed within this crypto baseline; the crypto consumer's own AML/CTF module accordingly defers to that subscription rather than asserting independent findings. The same financial-integrity surface is also implicated by the cross-border and offshore-structure tightening described above: the 2021 Notice's treatment of offshore-exchange services to mainland residents as illegal activity, and the February 2026 notice's increased scrutiny of overseas crypto/tokenization activity by Chinese entities, both touch cross-border AML/CTF and capital-control enforcement questions that sit partly outside this monitor's own scope.

On the world-payments surface, the PBOC's stablecoin risk framing and the offshore RMB-pegged stablecoin issuance ban -- read alongside earlier documented interventions to stop Chinese technology firms from issuing stablecoins via Hong Kong -- bear on payment-system stability questions that are properly a world-payments framing matter rather than a crypto-licensing one.

#### Outlook

The evidentiary base for this cycle rests entirely on T4 secondary news reporting, with the licensed-offshore-pathway correction resting on T3 legal-advisory commentary; zero primary regulator sources have been directly retrieved and verified. The most consequential open research task is direct retrieval of the February 2026 eight-agency joint notice text from an official .gov.cn portal, both to confirm its exact promulgation date and to upgrade sourcing above T4, alongside confirmation of the CSRC's companion 2026 Announcement No. 1 filing regime for offshore asset-backed tokenized securities. Absent that primary verification, the newly identified licensed offshore RWA-tokenization pathway -- while a materially important qualification to a flat-ban framing -- remains capped at Probable confidence. The tax-treatment gap and the recurring question of whether Hong Kong's separate jurisdiction record should be more extensively cross-referenced against Beijing's documented interventions into HK-based stablecoin and tokenization plans both remain open boundary questions for future cycles.

Read full brief · 1456 words

Key regulatory facts for China Regulatory Dimension China Standing Position

Jurisdiction China (CN)

Regulatory Scope Crypto & Digital Asset Regulation (9 modules, 33 sourced findings)

Crypto Licensing Mainland China maintains a blanket prohibition on crypto exchange, trading, and related intermediary/financing services, originally declared illegal by the 15 September 2021 ten-agency Notice and now carried forward...

Token Classification No positive legal taxonomy confers lawful-asset or currency status on any crypto-asset category.

On-Chain Activity Regime Mining, exchange (including crypto-to-crypto/DEX activity) and now RWA tokenization are captured by standing prohibition.

Stablecoin Regime The February 2026 joint notice expressly bars unapproved offshore RMB-pegged stablecoin issuance by any entity or individual, onshore or offshore.

Primary Instruments Cited People's Bank of China (PBOC)-led ten-agency Notice, Eight-agency joint notice (PBOC, CSRC, NDRC, MPS, SAFE et al.), CCP Central Committee Fifth Plenary resolution, 2026 PBOC-led joint circular, Ministry of Public Security (China)

Last Confirmed / Updated 2026-11-04 (36 sources in cumulative register)

9 of 9 categories

Signal
Moved
Judgment
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Density
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Compact

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Selections OR within a group, AND across groups. Press / to search.

### China: C1 Crypto LicensingRedEnacted in forceModule confidence: Probable▾

Mainland China maintains a blanket prohibition on crypto exchange, trading, and related intermediary/financing services, originally declared illegal by the 15 September 2021 ten-agency Notice and now carried forward and extended by the February 2026 eight-agency joint notice, which per T3 legal-advisory reporting supersedes the 2021 instrument as the sole operative primary framework. No onshore licensing or registration pathway exists for these activities.

Open gap — crypto-int-1 CCDI/Xinhua full resolution text not retrieved; unclear whether any operative clause beyond the reported investigative-focus language exists. no under-indexing note recorded

#### Crypto Licensing

Mainland China maintains a comprehensive licensing prohibition for crypto exchange, trading and related financial-services activity, now consolidated under a single operative primary instrument. The 15 September 2021 ten-agency Notice, led by the People's Bank of China, declared virtual currency exchange, token-to-token exchange, and related intermediary and financing services illegal financial activities across mainland China. Per legal-advisory reporting from Norton Rose Fulbright and Lexology/Han Kun Law, that 2021 Notice has since been superseded by a February 2026 eight-agency joint notice -- again fronted by the PBOC and joined by the China Securities Regulatory Commission, the National Development and Reform Commission, the Ministry of Public Security, the State Administration of Foreign Exchange and other agencies -- which reasserted the underlying 2021 ban on crypto trading and stablecoins, including cross-border activity, while extending strict controls to RWA tokenization subject only to limited exceptions. The 2026 notice is now treated as the sole current operative primary instrument carrying forward the prohibitions the 2021 Notice originally established, rather than the two instruments standing as co-equal, independently-in-force frameworks.

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.

Read full sub-brief · 487 words Periodic update · new data 2026-09-28

#### Crypto Licensing

China's crypto-licensing landscape remains one of comprehensive prohibition rather than any form of licensing regime. PBOC-led Notice Yin Fa [2026] No.42 restates this prohibition, covering onshore cryptocurrency exchange, trading and related financial-services activity, all treated as illegal financial activities. The notice's most significant lifecycle event is procedural rather than substantive in the narrow sense: it expressly repeals the 2021 virtual-currency prohibition circular (Yin Fa [2021] No.237), consolidating what had been the operative legal basis for the prohibition into a single new instrument that also broadens scope. This repeal-and-restate pattern means the underlying prohibition itself is not new, but its legal basis, and its explicit coverage of instruments that did not exist or were not clearly addressed in 2021, principally RMB-pegged stablecoins and RWA tokenization, is materially updated.

Both the prohibition claim and the repeal claim are assessed at Probable confidence, reflecting that this cycle's evidence base rests on law-firm and trade-press secondary commentary (Lexology, CryptoSlate) rather than a directly-retrieved PBOC primary text. The gaps register for this cycle flags an open question as to whether the seed-listed pbc.gov.cn/en URL remains the correct live host for the full text of Notice No.42, or whether it has moved to a dedicated notice page, an open sourcing question rather than a substantive doubt about the notice's existence or effect.

#### Outlook

Retrieval of a Tier-1 PBOC primary text for Notice No.42 remains the single most consequential open item for this module; until that occurs, confidence in the specific scope and wording of the restated prohibition is capped at Probable notwithstanding consistent secondary-source corroboration.

2 earlier distinct update(s) Periodic update · new data 2026-09-04

#### Crypto Licensing

Notice Yin Fa [2026] No.42, effective 6 February 2026, reaffirms and extends China's comprehensive prohibition on virtual-currency-related business activity. The notice declares exchange services, central-counterparty trading, pricing services, token-issuance financing and derivatives all illegal financial activities in mainland China (CLM-CN-001). This is a Confirmed, Tier-1-sourced finding directly from the People's Bank of China. The notice expressly repeals the 2021 PBOC-led virtual-currency trading-speculation notice that preceded it, an architecture-level instrument replacement rather than an incremental amendment (CLM-CN-002), though this repeal claim itself rests on Tier-3 secondary sourcing rather than a directly quoted primary repeal clause.

No licensing pathway exists, or is contemplated, for domestic virtual-currency exchange, trading or token-issuance activity under this framework. The instrument's approach is prohibition, not licensing-with-conditions; there is no application process, no fit-and-proper test, and no compliance pathway by which a domestic or foreign entity could lawfully operate an exchange, trading platform or token-issuance business onshore.

#### Outlook

The most significant open question is whether any enforcement action materialises against an entity attempting to exploit ambiguity at the margins of the notice's scope — for instance, an entity structuring activity as something other than 'exchange' or 'trading' in form while achieving the same substantive effect. No such action has been reported this cycle; the notice's practical deterrent effect remains, for now, an architecture-level inference rather than an enforcement-tested one.

Periodic update · new data 2026-08-25

#### Crypto Licensing

China's licensing posture for virtual-currency business activity remains what it has been since 2021: a blanket prohibition rather than a licensing regime, now reaffirmed and re-issued under a fresh instrument. PBOC's Circular Yin Fa [2026] No. 42 explicitly states that all virtual-currency-related business activities constitute illegal financial activities in mainland China, and reporting describes this circular as repealing and replacing the 2021 circular that previously carried this designation. There is no indication in this cycle's research of any carve-out, sandbox, or conditional-licensing pathway being introduced alongside the reaffirmation; the instrument's function is to consolidate and restate the prohibition under new cover rather than to soften or refine it. What makes this cycle material for the licensing module specifically is less the restatement of the domestic ban -- which is, on its own, an unchanged fact -- and more the fact that the same instrument extends the prohibition's practical reach to categories (stablecoins, real-world-asset tokenization, and outbound service provision to Chinese entities) that previously sat only within the general prohibition's broad language rather than being named explicitly. The supervisory authority remains PBOC, acting through a formal internal circular rather than through a public law or regulation subject to separate legislative process, which is itself a structural feature of how Chinese financial-sector prohibitions of this kind have historically been issued and amended. The primary sourcing for the core prohibition claim sits at a mid-tier level (T3, trade press), with the extension provisions corroborated at a stronger tier through a Library of Congress legal-monitor summary; the underlying Chinese-language circular text itself has not been independently retrieved this cycle, which the monitor is treating as an open verification item rather than as grounds to discount the substance of the reporting.

#### Outlook

No change to the licensing module's fundamental character is anticipated absent a change in Beijing's underlying policy stance, which this cycle's research gives no indication of shifting. The most likely source of further material development in this module going forward is not a loosening of the prohibition but continued specification of its reach -- further named categories, further extraterritorial provisions, or enforcement actions taken under the new circular's authority. Independent retrieval of the primary Chinese-language text remains the single highest-value verification step outstanding for this module, since it would allow the monitor to move from reporting-based corroboration to primary-source confirmation of the exact scope of the 2026 restatement relative to the 2021 instrument it replaces.

Sources and findings (5)
- T4 · CoinDesk[People's Bank of China (PBOC)-led ten-agency Notice](https://www.coindesk.com/policy/2021/09/24/china-tightens-crypto-mining-crackdown-bans-trading) — Virtual currency exchange, token-to-token exchange, and related intermediary and financing services are illegal financial activities in mainland China (15 September 2021 Notice).
- T4 · CoinDesk[Eight-agency joint notice (PBOC, CSRC, NDRC, MPS, SAFE et al.)](https://www.coindesk.com/policy/2026/02/06/china-expands-crypto-crackdown-to-stablecoins-asset-tokenization) — The February 2026 joint notice reasserted the 2021 ban on crypto trading and stablecoins, including cross-border activity, and imposed strict controls on RWA tokenization with only limited exceptions.
- T3[CCP Central Committee Fifth Plenary resolution](https://www.chinatechnews.com/2026/11/01/131660-china-calls-for-tougher-crackdown-on-crypto-bribes-corruption) — Officials, businesspeople and intermediaries using virtual currencies, blockchain and cross-border capital flows to conceal bribes or move illicit wealth
- T2[2026 PBOC-led joint circular](https://www.loc.gov/item/global-legal-monitor/2026-05-21/china-cryptocurrency-ban-extended-to-stablecoins-and-rwa-tokenization) — virtual currencies, stablecoins, and tokenized assets have no legal-tender status; related trading, issuance, and intermediary services constitute illegal financial activity unless explicitly approved
- T3[Ministry of Public Security (China)](https://www.mexc.com/news/652005) — the crypto prohibition, bundled with broader financial-crime, fraud, and underground-banking enforcement

### China: C2 Token ClassificationRedEnacted in forceModule confidence: Probable▾

No positive legal taxonomy confers lawful-asset or currency status on any crypto-asset category. The PBOC denies virtual currencies legal-tender status, and the February 2026 notice extends non-fiat-currency-status language explicitly to stablecoins including USDT. NFTs ('digital collectibles') remain in an unresolved regulatory gray zone, distanced from crypto exposure via permissioned-chain architecture and a bar on cryptocurrency-denominated purchase.

Periodic update · new data 2026-09-28

#### Token Classification

Two distinct token-classification developments arise from this cycle's evidence. First, under Notice No.42, RMB-pegged stablecoins are treated as performing a legal-tender-adjacent function, and on that basis no onshore or offshore entity may issue a CNY-pegged stablecoin without explicit approval from relevant PRC authorities, an approval regime that functions in practice as a prohibition given that no such approval has been granted to any private issuer. This is assessed at Probable confidence, sourced from Lexology's law-firm commentary characterising the notice's operative text.

Second, and distinctly, a CSRC guideline issued the same day as Notice No.42 creates a new supervisory classification for offshore-circulated real-world-asset tokens that function as securities or debt-financing tools, bringing them under PRC regulatory oversight via a dedicated guideline. This is explicitly a newly-created supervisory lane rather than a licensing pathway or an affirmative legalisation, and confidence here is Uncertain, reflecting both the narrower and newer nature of the underlying source (Library of Congress Global Legal Monitor reporting, itself secondary to the PRC instruments) and the absence of detail on how this oversight lane will operate in practice.

The distinction between these two classification treatments matters: RMB-pegged stablecoins face an outright prohibition-with-approval-gate model that functions as a ban, while offshore RWA securities tokens face a supervisory-oversight model that, while restrictive, is conceptually different, a lane for regulatory visibility rather than a blanket prohibition.

#### Outlook

Watch for any further guidance clarifying how the CSRC's offshore RWA securities-token oversight lane will operate in practice, and whether any entity applies for, or is denied, approval to issue a CNY-pegged stablecoin under the Notice No.42 approval-gate mechanism.

Periodic update · new data 2026-09-04

#### Token Classification

Notice 42 restates and specifies China's token-classification approach with renewed clarity. Bitcoin, Ether, Tether and similar virtual currencies are confirmed not to be legal tender and must not circulate or be used as currency in China (CLM-CN-003), a Confirmed finding though sourced at Tier-3 in this cycle's evidence rather than a directly quoted primary-text classification clause. Separately, and this is the more substantively new element, the notice establishes that no entity — Chinese or foreign, including overseas branches of domestic firms — may issue an offshore stablecoin linked to the renminbi without prior government approval (CLM-CN-004). This is a narrow, dynamically-assessed approval-gate posture specific to offshore RMB-pegged stablecoins, not a general licensing regime extended to stablecoins as a token category, and not an authorisation of onshore stablecoin issuance in any form.

The classification architecture therefore now distinguishes at least three token categories in practical effect: general virtual currencies (Bitcoin, Ether, and similar), which are comprehensively prohibited from circulation and use as currency; offshore RMB-pegged stablecoins specifically, which face a narrow approval gate rather than an outright ban; and real-world-asset tokens, which the notice extends scrutiny to without necessarily prohibiting outright. This differentiated treatment is a meaningful refinement over a single undifferentiated prohibition category.

#### Outlook

Whether the offshore-stablecoin approval gate is ever actually granted to any applicant — as opposed to functioning as a de facto prohibition through non-approval — is the key open question for this classification category going forward. No approval grant has been reported this cycle.

Periodic update · new data 2026-08-25

#### Token Classification

This cycle marks the first instrument identified in this monitor's research that sets out China's stance on stablecoins and real-world-asset tokenization in named, rather than merely inferred, terms. Circular Yin Fa [2026] No. 42 addresses two token categories directly. First, it prohibits any entity -- Chinese or foreign -- from issuing a stablecoin linked to the renminbi abroad without government approval, a formulation that functions as an approval-gated prohibition given the absence of any described approval pathway or precedent for such approval being granted. Second, it requires Chinese firms seeking to tokenize real-world assets overseas to obtain approvals or file with regulators, and imposes heightened compliance standards on the partners those firms work with in doing so. Both provisions bring stablecoins and RWA tokenization into a defined regulatory perimeter for the first time in this monitor's coverage of the jurisdiction, even though that perimeter is restrictive rather than enabling. The supervisory authority for this module is attributed to PBOC together with CSRC, reflecting the joint monetary and securities-market dimensions of stablecoin and tokenized-asset activity respectively. Both claims underlying this module carry high materiality ratings and are treated as new rather than restated developments, distinguishing this module's status this cycle from the largely unchanged licensing and on-chain-activity modules.

#### Outlook

The explicit naming of stablecoins and RWA tokenization as restricted categories, rather than leaving them to be inferred from the general prohibition, is likely to be the most consequential structural change in this jurisdiction's token-classification posture for some time. Because the provisions are framed as approval-gated rather than as an outright unconditional ban, there is a narrow theoretical possibility that an approval pathway could eventually be specified in implementing guidance; nothing in this cycle's research indicates that such guidance exists yet, and the monitor is not asserting one. Continued monitoring should watch specifically for any implementing rules that would give operational content to the approval-and-filing requirements described here, since their absence to date leaves the practical scope of permitted activity, if any, undefined.

C2 · Token Classification — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### China: C3 On-Chain Activity RegimeRedEnacted in forceModule confidence: Probable▾

Mining, exchange (including crypto-to-crypto/DEX activity) and now RWA tokenization are captured by standing prohibition. A Challenger-driven correction identifies that the February 2026 notice simultaneously created a licensed offshore RWA-tokenization pathway (three CSRC/NDRC/SAFE-overseen categories, same-business-same-risk-same-rules, same-day CSRC filing regime), differentiating RWA tokenization from the undifferentiated prohibition still applied to mining and general exchange.

C3 · On-Chain Activity — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-11-04

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### China: C4 Stablecoin RegimeRedEnacted in forceModule confidence: Probable▾

The February 2026 joint notice expressly bars unapproved offshore RMB-pegged stablecoin issuance by any entity or individual, onshore or offshore. PBOC separately frames stablecoins as failing KYC/AML standards and posing money-laundering, cross-border-transfer and underground-payment risks. No onshore reserve-requirement regime exists, reflecting prohibition of issuance itself rather than an unregulated gap.

Periodic update · new data 2026-10-25

#### Stablecoin Regime

China has no lawful pathway for private stablecoin issuance on the mainland, and the regime tightened further. A 2026 People's Bank of China-led joint circular, which repealed and replaced the 2021 Circular on Further Preventing and Disposing of Speculative Risks in Virtual Currency Trading, explicitly prohibits any entity, whether located in China or overseas, from issuing an RMB-linked stablecoin without explicit government authorisation. This treats fiat-referenced stablecoins as a monetary-sovereignty risk rather than a payments-innovation product to be licensed and supervised.

The most significant element of the development is the closure of what market commentary had termed an offshore loophole. Prior to the 2026 circular, there was reported ambiguity about whether a Chinese-affiliated entity could issue an RMB-pegged stablecoin through an overseas branch or subsidiary structure, outside direct PBOC supervision. The 2026 circular closes that route explicitly: domestic firms and their overseas branches are now barred from issuing or facilitating RMB-pegged stablecoins without explicit government approval. This extends the prohibition's reach beyond the mainland perimeter and treats offshore structuring as within scope rather than as a workaround.

The circular also extends to real-world-asset tokenisation, classifying most such activity as illegal absent approval. This places tokenised real-world assets within the same prohibition framework previously reserved for cryptocurrency trading, rather than carving out a separate, potentially more permissive, regulatory lane for asset-backed tokens. No distinction is drawn in the available material between fully-collateralised asset-backed tokens and algorithmic or other stablecoin designs; the prohibition appears to apply uniformly to RMB-referenced value tokens regardless of backing mechanism.

Against this tightened formal architecture sits a reported usage data point that complicates the picture. Chainalysis data carried via a secondary analytics outlet found that unique peer-to-peer stablecoin wallets inside mainland China grew forty-three-fold between the first quarter of 2024 and the second quarter of 2026. This figure has not been independently corroborated from a primary source, and the underlying confidence assigned to it is accordingly uncertain. If directionally accurate, it suggests that retail or quasi-retail peer-to-peer stablecoin usage inside China is growing substantially even as the formal issuance and intermediation prohibition is being extended and tightened, a structural tension between declared architecture and apparent on-the-ground practice.

No primary PBOC enforcement statistics or statements addressing this reported usage growth were located, and no primary Chinese-language text of the February 2026 circular itself was independently retrieved; the record rests on secondary English-language legal and news commentary. This is a documented sourcing gap rather than a substantive finding about enforcement intent.

#### Outlook

The closure of the offshore RMB-stablecoin issuance loophole and the extension of the prohibition to real-world-asset tokenisation are now in force as. The principal matter to watch going forward is whether Chinese authorities respond visibly to the reported growth in peer-to-peer stablecoin usage, which would indicate the prohibition is being enforced against informal usage channels and not only against formal issuance and exchange infrastructure.

Periodic update · new data 2026-09-28

#### Stablecoin Regime

China's stablecoin regime under Notice Yin Fa [2026] No.42 rests on a specific legal rationale: because stablecoins are treated as performing the functions of legal tender, no onshore or offshore entity is permitted to issue a CNY-pegged stablecoin without explicit approval. This rationale is the operative core of the prohibition-with-approval-gate model that governs stablecoins in China, and it is assessed at Probable confidence based on Lexology's characterisation of the notice's substantive text. In practice, because no such explicit approval has been granted to any private issuer, the effect is a de facto prohibition rather than a functioning approval pathway.

This stablecoin-specific treatment sits within, and is reinforced by, the notice's broader repeal-and-restate of the 2021 prohibition circular, meaning the stablecoin prohibition is not a standalone rule but part of a single consolidated instrument covering the full range of virtual-currency-related activity. The rationale grounding the prohibition, that stablecoins functionally substitute for legal tender, is analytically significant because it explains why China's approach diverges from jurisdictions that regulate stablecoins as a licensed payment instrument: the PRC's monetary-sovereignty framing treats any privately-issued RMB-referenced stablecoin as a threat to currency-issuance authority rather than as a payment innovation to be channelled through licensing.

#### Outlook

The key indicator to watch is whether any entity, onshore or offshore, is granted the explicit approval contemplated by the notice's text, which would be the first test of whether the approval gate is a genuine (if narrow) pathway or purely nominal. No such approval has been identified this cycle.

Periodic update · new data 2026-09-04

#### Stablecoin Regime

Notice 42 creates China's first explicit stablecoin-specific regulatory posture, distinct from its general virtual-currency prohibition. Rather than an outright ban, the notice establishes a narrow, dynamically-assessed approval gate solely for offshore RMB-pegged stablecoin issuance under Article 1: no entity, Chinese or foreign, including overseas branches of domestic firms, may issue such an instrument without prior government approval (CLM-CN-004). No domestic stablecoin issuance of any kind is authorised under this or any other located instrument.

The regulatory rationale behind this approach is explicit in the evidence: regulators warned that stablecoins can duplicate critical functions of sovereign money, and thus pose a threat to monetary control (CLM-CN-007). This is a non-binding guidance-level framing statement rather than an operative legal provision, but it explains why the approval-gate mechanism specifically targets RMB-pegged instruments rather than stablecoins generally — the monetary-sovereignty concern is specific to instruments referencing China's own currency, which could otherwise function as parallel, less-controllable RMB-denominated payment rails outside PBOC's direct oversight.

This stablecoin-specific posture should be read as prohibition-plus-narrow-approval-gate, not as an emerging licensing framework. There is no indication in this cycle's evidence of any published criteria, application process, or approval granted under this gate.

#### Outlook

The test of whether this approval gate functions as a genuine (if narrow) pathway or as a de facto absolute prohibition will only become clear if and when an application is filed and either approved or rejected. No such case has been reported this cycle, leaving the gate's practical operation untested.

Periodic update · new data 2026-08-25

#### Stablecoin Regime

Stablecoin regulation in China is best characterised this cycle as an approval-gated prohibition rather than as a functioning issuance-and-reserve regime of the kind seen in jurisdictions that have adopted licensing frameworks for fiat-referenced tokens. Circular Yin Fa [2026] No. 42 prohibits domestic or foreign entities and individuals from issuing yuan-pegged stablecoins abroad without government approval, a provision that the underlying reporting -- corroborated at a comparatively strong sourcing tier through a Library of Congress legal-monitor summary -- frames explicitly in monetary-sovereignty and capital-flight-risk terms rather than in consumer-protection or market-integrity terms. This is the first cycle in this monitor's coverage of the jurisdiction to identify an explicit, stablecoin-specific regulatory stance, closing what had previously been an area addressed only by inference from China's general virtual-currency prohibition. The claim underlying this module carries the highest materiality rating used in this cycle's set, reflecting its significance both as a standalone provision and as a signal of how Beijing intends to treat renminbi-referenced instruments issued outside its direct jurisdiction. Supervisory authority sits with PBOC, consistent with the monetary-policy framing of the underlying concern.

#### Outlook

Given the explicit framing of offshore RMB-stablecoin issuance as a monetary-sovereignty and capital-control concern, this module is unlikely to move toward a licensing model in the near term; the more probable trajectory is continued and possibly expanded restriction, potentially extending to enforcement actions against specific offshore issuers or intermediaries as they are identified. The open verification question carried from this cycle -- confirming the approval-and-filing mechanics against the primary Chinese-language circular text -- is particularly consequential for this module, since the practical difference between an approval-gated regime and an unconditional prohibition turns on details not yet independently confirmed.

C4 · Stablecoins & EMTs — Full Module Record 0 sub-modules · 180 words · 5 traced claims · Re-verified 2026-11-04

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### China: C5 Consumer ProtectionRedEnacted in forceModule confidence: Probable▾

China's Supreme People's Court has confirmed that civil legal acts involving cryptocurrency investment are invalid, with investors bearing resulting losses themselves and no civil remedy available. Industry associations have separately warned against NFT financialization and speculative marketing on a non-binding basis.

#### Consumer Protection

Consumer protection in mainland China's crypto space is defined less by protective scaffolding than by the explicit foreclosure of legal remedy for market participants. China's Supreme People's Court has confirmed that civil legal acts involving cryptocurrency investment are deemed invalid, with resulting losses borne by investors themselves. In practice, this means mainland investors engaging in crypto-related transactions -- transactions that are themselves prohibited activity under the broader Crypto Licensing framework -- cannot rely on the civil courts to recover losses arising from those transactions, reinforcing the prohibition regime through the denial of an ordinary private-law remedy rather than through a distinct consumer-protection statute.

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.

Read full sub-brief · 300 words Periodic update · new data 2026-09-28

#### Consumer Protection

China's consumer-protection posture with respect to crypto assets operates almost entirely through marketing and registration-wording suppression rather than through affirmative consumer-facing rights or disclosure obligations. Under Notice No.42, market regulators (SAMR) have been directed to control business-registration wording and advertising connected to virtual currency, crypto assets, stablecoins, RWA and related terminology. This is assessed at Probable confidence, based on CryptoSlate's reporting of the notice's provisions.

The analytical significance of this mechanism is that it achieves a consumer-protection-adjacent outcome, limiting consumer exposure to crypto-related products and marketing claims, through a suppression-of-supply mechanism (restricting how businesses may register and advertise) rather than through a rights-based framework (such as mandatory disclosures, cooling-off periods, or a right of redress specific to crypto-asset products). This is consistent with the broader prohibition architecture: because the underlying activity is illegal rather than licensed, there is no regulatory apparatus through which affirmative consumer protections of the kind seen in licensed markets could attach.

#### Outlook

Watch for enforcement activity testing the scope of the business-registration and advertising restriction, for example, actions against companies found to be using restricted terminology in registration filings or marketing materials, which would be the first indicator of how actively this suppression mechanism is being applied in practice.

1 earlier distinct update(s) Periodic update · new data 2026-08-25

#### Consumer Protection

Consumer protection in China's crypto space continues to operate through prohibition and enforcement rather than through any disclosure, custody, or suitability regime of the kind found in licensing jurisdictions. This cycle's principal development is reporting that banks and payment institutions are officially barred from accepting crypto-related transactions, framed as a continuation of longstanding enforcement practice against speculative virtual-currency activity rather than as a newly introduced restriction. The claim is sourced to a single trade-commentary source rated at a lower sourcing tier than the stronger-tier sourcing available for this cycle's stablecoin and cross-border provisions, which limits the confidence that can be placed in the precision of this specific formulation relative to the better-corroborated core prohibition. Supervisory authority for this module is attributed to PBOC, consistent with the module's framing of consumer protection as an extension of the general financial-prohibition regime rather than as a distinct regulatory function with its own institutional home.

#### Outlook

Because this module's protective function operates through prohibition rather than through a positive consumer-protection framework, further developments are more likely to take the form of enforcement reporting -- specific institutions or transactions being named as having been blocked or penalised -- than the introduction of disclosure or suitability rules. The comparatively thin sourcing behind this cycle's specific claim means this module's content should be treated as provisional pending stronger corroboration in a subsequent cycle, notwithstanding the high confidence attached to the general bank-and-payment-institution restriction as a continuation of established policy.

Sources and findings (5)
- T4 · The Block[Supreme People's Court of the PRC](https://www.theblock.co/post/402692/china-crypto-judicial-rules) — Civil legal acts involving cryptocurrency investment are deemed invalid; resulting losses are borne by investors themselves.
- T4 · CoinDesk[Internet Finance Association, Banking Association, Securities Association (China)](https://www.coindesk.com/policy/2022/04/13/chinese-banking-associations-target-nfts) — Jointly called to curb financialization/securitization tendencies of NFTs and warned against speculative marketing of digital collectibles.
- T3[Mainland China crypto-custody regime](https://www.charltonslaw.com/chinas-regulatory-position-on-virtual-currencies-and-rwa/) — No licensed crypto-custody regime exists onshore; the question is not applicable to this jurisdiction's regime
- T2[Mainland Chinese crypto marketing regime](https://www.lexology.com/library/detail.aspx?g=bb22aa79-75b4-44cb-8509-709fd2c2dd52) — to market crypto-asset services to mainland Chinese consumers; promotion of an unlawful offer is addressed via the underlying prohibition
- T2[Crypto-asset custody in mainland China](https://cryptoslate.com/crypto-laws/china-pboc-virtual-currency-rwa-notice-no-42-2026/) — no custody, segregation, or insolvency-treatment regime was located

### China: C6 Tax TreatmentAmberEnacted in forceModule confidence: Probable▾

No dedicated crypto-specific tax framework or guidance has been identified for mainland China. It remains unclear whether general PRC income tax or VAT law has been formally applied to crypto-related gains in any published ruling; this is treated as a genuine ambiguity given the underlying prohibition, not a resolved gap-by-design.

C6 · Tax Treatment — Full Module Record 0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04

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### China: C7 Cross-Border TransferRedEnacted in forceModule confidence: Probable▾

The 2021 Notice treats offshore-exchange services provided to mainland residents, including overseas technical-support activity, as illegal activity subject to investigation. The February 2026 notice further tightens the offshore-structure perimeter, barring unauthorized foreign provision of RWA tokenization services to domestic counterparties and increasing scrutiny of overseas crypto/tokenization activity by Chinese entities.

Periodic update · new data 2026-10-25

#### Cross-Border Transfer

Cross-border crypto-related activity touching mainland China was brought further within the prohibition's scope by the 2026 People's Bank of China-led joint circular. The circular increases scrutiny on Chinese companies seeking to tokenise assets overseas, as well as on their financial or technology partners, and provides no approval route for such activity. It also extends the ban on unapproved RMB-pegged stablecoin issuance explicitly to overseas branches of domestic firms, closing a structuring route that had previously been understood to sit outside direct mainland supervision.

This matters for cross-border transfer analysis because it signals that Chinese authorities regard offshore structuring, whether through overseas branches, subsidiaries, or partner entities, as within the regulatory perimeter rather than as a jurisdictional escape valve. A Chinese-affiliated entity cannot rely on incorporation or operation outside the mainland to issue an RMB-referenced stablecoin or to conduct real-world-asset tokenisation without explicit approval, and its financial and technology partners face increased scrutiny as a consequence of that affiliation.

This cross-border tightening sits alongside, but is formally distinct from, the standing domestic prohibition on cryptocurrency trading and exchange activity administered by the PBOC and the separate NDRC-led restriction on cryptocurrency mining. Taken together, these measures describe a comprehensive approach in which the prohibition's reach is not confined to activity physically occurring within mainland China but extends to the overseas conduct of Chinese-affiliated entities and their partners.

No primary PBOC or State Administration of Foreign Exchange guidance specifically addressing cross-border capital-flow mechanics for crypto-adjacent activity, as distinct from the stablecoin-specific prohibition, was located. The analysis here is accordingly confined to what the February 2026 circular itself addresses: stablecoin issuance and real-world-asset tokenisation by Chinese-affiliated entities operating offshore.

#### Outlook

The extension of scrutiny to overseas tokenisation activity by Chinese companies and their partners is now in force as. Going forward, the question is whether this scrutiny translates into identifiable enforcement actions against specific overseas structures or partner entities, which would be the clearest signal of how seriously the extraterritorial reach of the February 2026 circular is being applied in practice, as distinct from its reach on paper.

Periodic update · new data 2026-09-28

#### Cross-Border Transfer

Notice Yin Fa [2026] No.42 explicitly prohibits overseas entities or individuals from providing virtual-currency-related services to domestic entities in China, an extraterritorial restriction assessed at Probable confidence based on Lexology's characterisation of the notice's text. This explicit prohibition sits atop, and reinforces, a pre-existing structural backdrop: China's foreign-exchange rules, sourced here from a Tier-1 FinCEN advisory, cap individual RMB-to-foreign-currency conversion at approximately US$50,000 per year. That FX cap is independently identified by FinCEN as a structural driver of demand for informal cross-border value-transfer channels, a finding that, while sourced from a US-government advisory rather than PRC-domestic material, corroborates the broader picture of tightly-constrained legal channels for moving value out of China.

Read together, these two elements describe a cross-border transfer environment where the crypto-specific prohibition (no offshore entity may serve domestic PRC entities with virtual-currency services) and the pre-existing general capital-control regime (the FX cap) reinforce each other, closing off both the crypto-specific and the general-currency avenues that might otherwise be used to move value across the PRC border outside official channels. A gap register entry flags that this cycle located no explicit judicial interpretation directly classifying stablecoin-based gambling settlement as illegal foreign-exchange trading; that characterisation remains solely a matter of secondary trade-press commentary rather than a primary-source legal determination.

#### Outlook

Watch for whether any primary judicial or regulatory text emerges classifying stablecoin-based cross-border settlement activity, including but not limited to gambling-linked settlement, as illegal foreign-exchange trading, which would convert this cycle's uncorroborated trade-press characterisation into a confirmed legal-classification finding.

Periodic update · new data 2026-09-04

#### Cross-Border Transfer

Notice 42's central new contribution to China's crypto regulatory architecture is an expanded extraterritorial scope, addressing both inbound and outbound dimensions of cross-border virtual-currency activity. On the inbound side, overseas entities and individuals are now explicitly prohibited from providing virtual-currency-related services to domestic entities in China (CLM-CN-010), a Confirmed, Tier-2-sourced finding. This closes what had previously been a comparatively less explicit gap: a foreign-domiciled exchange or service provider targeting mainland users now faces an unambiguous prohibition text rather than an inferred extension of domestic prohibition principles.

On the outbound side, Chinese firms seeking to tokenise assets overseas must obtain approvals or filings from regulators, and financial and technology partners involved in such structures must meet heightened compliance standards (CLM-CN-009), also Confirmed at Tier-2. This restricts the ability of domestic entities to route real-world-asset tokenisation activity through offshore structures as a means of circumventing onshore restrictions.

Together, these two provisions represent the most substantively new extraterritorial expansion within Notice 42, strengthening China's asserted reach over virtual-currency activity in both directions simultaneously — inbound service provision into China, and outbound tokenisation activity by Chinese entities operating abroad.

#### Outlook

Enforcement follow-through against an offshore service provider found to be serving mainland users, or against a domestic firm found to have tokenised assets overseas without the required approval or filing, would be the clearest signal that these provisions carry practical teeth beyond their text. No such enforcement action has been reported this cycle.

Periodic update · new data 2026-08-25

#### Cross-Border Transfer

The cross-border transfer module records this cycle's most explicitly extraterritorial development: Circular Yin Fa [2026] No. 42 bars overseas entities and individuals from providing virtual-currency-related services to domestic entities within China, a formulation that reporting describes as reaching beyond China's borders to constrain how foreign-domiciled service providers -- including, by implication, stablecoin settlement providers -- may interact with Chinese counterparties. This is treated as a new provision rather than a restatement, corroborated through a Library of Congress legal-monitor summary at a comparatively strong sourcing tier, and carries the highest materiality rating used in this cycle's claim set alongside the core licensing and stablecoin-issuance provisions. The provision's practical significance lies in its attempt to project China's domestic prohibition outward onto counterparties who are not themselves subject to Chinese jurisdiction in the ordinary course, which distinguishes it from the largely domestically-scoped provisions found elsewhere in the circular. Supervisory authority for this module sits with PBOC.

#### Outlook

Extraterritorial provisions of this kind are inherently difficult to enforce directly against foreign entities that have no domestic presence, so the more likely enforcement path is indirect -- action against domestic counterparties, payment channels, or intermediaries found to have facilitated prohibited cross-border service provision, rather than direct action against the overseas provider itself. Continued monitoring should watch for any such indirect enforcement actions as the clearest signal of how seriously this provision is being operationalised, since the provision's text alone does not indicate an enforcement mechanism against parties outside PBOC's direct reach.

C7 · Cross-Border & Travel Rule — Full Module Record 0 sub-modules · 180 words · 4 traced claims · Re-verified 2026-11-04

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### China: C8 AML/CFT RegimeAmberEnacted in forceModule confidence: Probable▾

AML/CFT obligations applicable to crypto activity in this jurisdiction are governed under the fleet's financial-integrity aml_ctf module and are not independently asserted in this crypto baseline; this module carries only a disambiguation claim confirming that subscription relationship.

C8 · AML/CFT Regime — Full Module Record 0 sub-modules · 180 words · 1 traced claims · Re-verified 2026-11-04

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### China: C9 Commercial Activity unpopulated ▾

No standing position recorded for this category.

Open gap — crypto-int-2 Unclear whether the Tianjin confiscation proceeding interacts with the PBOC Notice 42 [2026] offshore-RWA framework. no under-indexing note recorded

No sub-brief written this cycle The module carries open gaps but no narrative analysis was authored this cycle. Flagged for the next research pass.

No periodic updates recorded in this cycle

Sources and findings (3)
- T2[Ant Group and JD.com Hong Kong stablecoin plans](https://www.cnbc.com/2026/02/11/hong-kong-stablecoin-licenses-china-crypto-ban-usdt-usdc-cny-cnh-rmb-usd-fiat-currency.html) — Chinese regulators, including PBOC, advised against Ant Group's and JD.com's Hong Kong stablecoin plans around October 2025, halting progress for both mainland-headquartered groups.
- T3[Tianjin No. 2 Intermediate People's Court](https://www.theblock.co/news/regulation/2026-10-13-uk-high-court-rules-chinese-law-governs-claims-over-5-billion-in-seized-bitcoin-418409) — Approximately 61,896 BTC (plus BCH/BTG/BSV/XRP/DOGE) seized in the UK from Zhimin Qian; UK High Court ruled Chinese law governs victims' property claims; appeal reported pending
- T3[P2P stablecoin wallets inside mainland China](https://www.yicaiglobal.com/news/shanghai-court-discloses-usd905-million-illegal-stablecoin-exchange-case) — reportedly 43-fold from Q1 2024 to Q2 2026 (Chainalysis data via Cointelegraph), despite the standing prohibition