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CSRC (China Securities Regulatory Commission)

Regulator

The China Securities Regulatory Commission is mainland China's lead securities and capital-markets regulator, with a tokenisation perimeter shaped by the structural prohibition on virtual-asset trading and security-token issuance in mainland China and by CSRC's coordination role with the SFC HK and other regional regulators on cross-border securities and capital-markets work. CSRC supervises mainland securities firms (including CITIC Securities and China Merchants Securities), mainland fund managers, and the mainland exchanges (Shanghai Stock Exchange, Shenzhen Stock Exchange, Beijing Stock Exchange), with mainland tokenisation activity sitting inside the structural prohibition on virtual-asset and security-token issuance for the foreseeable horizon. For an APAC tokenisation operator, CSRC is the policy counterparty that sets the boundary on mainland-domestic security-token activity and that coordinates with SFC HK on Hong Kong-mainland cross-border securities programmes.

Role in tokenisation

CSRC's tokenisation surface has three load-bearing components, all structurally distinctive in the APAC regional regulatory map. First, the structural prohibition on virtual-asset trading and security-token issuance in mainland China. The mainland Chinese position has been that virtual-asset trading is prohibited under PBoC and CSRC policy, with the September 2021 joint statement from PBoC, CSRC, and other Chinese regulators (banning all virtual currency-related business activity in mainland China) as the most recent and comprehensive expression of the position. Mainland-domestic security-token issuance is similarly not permitted under current CSRC policy, with no public liberalisation track in current raw entries.

Second, the e-CNY supervisory perimeter for the securities-and-capital-markets side. CSRC supervises mainland securities firms' interaction with the e-CNY infrastructure, with the structural choice that e-CNY operates inside a separate regulatory perimeter from the security-token and stablecoin regulatory framework that applies in other jurisdictions. The e-CNY operational framework places the issuance and supervision functions at PBoC, with CSRC's role limited to securities-and-capital-markets-side supervision of e-CNY-adjacent activity.

Third, Hong Kong VATP coordination and cross-border securities programmes. CSRC coordinates with SFC HK on the broader Hong Kong-mainland cross-border securities and capital-markets framework, including the Stock Connect programme (Shanghai-Hong Kong Stock Connect, Shenzhen-Hong Kong Stock Connect), the Bond Connect programme, and selected other cross-border programmes. The connection to tokenisation activity is structural rather than direct: any future Hong Kong-mainland cross-border tokenised-securities programme would need CSRC and SFC HK coordination, although no such programme is in current raw entries.

Operating model

CSRC's regulatory toolkit on tokenisation runs through three distinct routes. The mainland-domestic securities-and-capital-markets route covers mainland securities firms, mainland fund managers, and the mainland exchanges, with the structural prohibition on virtual-asset trading and security-token issuance as the binding constraint. The e-CNY-adjacent route covers mainland securities firms' interaction with the e-CNY infrastructure, with PBoC as the principal regulatory counterparty and CSRC's role limited to securities-and-capital-markets-side supervision. The Hong Kong-mainland cross-border route covers CSRC's coordination with SFC HK on the Stock Connect, Bond Connect, and adjacent programmes.

The CSRC supervisory examination cycle for mainland securities firms has continued under the conventional securities-firm examination cadence, with virtual-asset-related activity prohibited under the September 2021 joint statement. The mainland-affiliated securities firms operating in Hong Kong (CITIC Securities International, China Merchants Securities (HK), and others) operate under SFC HK supervision for their Hong Kong activity, with CSRC's role limited to home-country supervision of the parent securities firm.

The international coordination function runs through CSRC's bilateral and multilateral engagement with other securities regulators globally. CSRC participates in IOSCO working groups and bilateral dialogues with the SEC, SFC HK, FSA Japan, MAS, and other regional and global securities regulators, with the cross-border tokenisation policy coordination as one component of the broader international coordination work.

Why it matters

Three structural reasons. First, CSRC sets the binding constraint on mainland-domestic security-token issuance and virtual-asset trading. The structural prohibition is the load-bearing fact about the mainland Chinese tokenisation market, and any tokenisation operator considering mainland distribution or mainland-issuer engagement needs to clear the CSRC perimeter as the gating policy question. The prohibition has been remarkably stable since September 2021, and there is no public liberalisation track in current raw entries.

Second, CSRC's coordination with SFC HK on the Hong Kong-mainland cross-border securities programmes is the structural lever for any future Hong Kong-mainland tokenised-securities connectivity. The Stock Connect, Bond Connect, and adjacent programmes have given mainland investors access to Hong Kong-listed securities and Hong Kong-issued bonds, and any future tokenised-securities programme that would extend that connectivity to tokenised products would run through CSRC-SFC HK coordination. No such programme is in current raw entries.

Third, CSRC's policy stability matters for the broader regional tokenisation regulatory map. The mainland Chinese position has been a structural anchor for the broader regional regulatory architecture, with the Hong Kong permissive perimeter operating as the structurally distinctive APAC alternative inside Greater China. The contrast is one of the load-bearing pieces of the APAC tokenisation regulatory map.

The competitive frame is partly the SEC (which operates a fragmented framework with overlapping CFTC perimeter and substantial state-level activity, structurally different from CSRC's consolidated mainland perimeter), partly the SFC HK (which operates the permissive Hong Kong perimeter under the broader Greater China regulatory architecture), partly the FSA Japan (which operates the FIEA security-token regime as the closest APAC peer to a permissive security-token perimeter inside an integrated regulator).

Recent moves

  • 2024-2025. CSRC supervisory examination cycle on mainland securities firms has continued under the conventional securities-firm examination cadence.
  • 2024-2025. Hong Kong-mainland cross-border securities programme coordination with SFC HK has continued under the Stock Connect, Bond Connect, and adjacent programmes.
  • September 2021. Joint statement from PBoC, CSRC, and other Chinese regulators banning all virtual currency-related business activity in mainland China. The most recent and comprehensive expression of the mainland Chinese position on virtual-asset trading.
  • No major CSRC-led tokenisation policy announcement has been recorded in current raw entries for the April 2026 period. The mainland prohibition on virtual-asset trading and security-token issuance has remained stable.

Open questions

  • Whether CSRC publishes any limited liberalisation track for mainland-domestic security-token issuance, with the FSC's "innovative financial services" sandbox in Korea as a possible reference model.
  • The CSRC supervisory framework for mainland securities firms' Hong Kong-subsidiary tokenisation activity, including the broader question of how mainland parent supervision interacts with Hong Kong-subsidiary tokenisation work.
  • The coordination framework between CSRC and SFC HK on any future Hong Kong-mainland cross-border tokenised-securities programme.
  • CSRC's positioning on cross-border RMB tokenisation, including any potential connection to the broader e-CNY cross-border pilot work that PBoC has been advancing.
  • The CSRC and PBoC coordination on any future stablecoin or tokenised-asset framework that may emerge from the broader Chinese state-owned financial-services reform agenda.

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