I. Comprehensive Upgrade and Precise Definition: Blocking All Paths of Systemic Risk

The "Notice" first showcases a strategic expansion of the regulatory scope and an unprecedented strengthening of qualitative measures. Its most significant feature is the explicit inclusion of "Real World Asset Tokenization" (RWA) into the regulatory core, placing it under the same stringent scrutiny as virtual currencies. This initiative is both forward-looking and decisive. RWA, as a global fintech trend that digitalizes and trades traditional assets (such as bonds, real estate income rights, commodities, etc.) through blockchain, essentially represents an iteration of asset securitization technology. If left unchecked, it is likely to evolve into a "technical loophole" that bypasses existing core regulatory frameworks such as securities issuance review, information disclosure, and investor suitability management, leading to more complex issues like illegal fundraising, fraud, and cross-contamination of financial risks. The "Notice" clearly states that conducting unapproved RWA activities domestically, such as illegal token sales, unauthorized public securities issuance, and illegal futures operations, constitutes illegal financial activities. This definition completely extinguishes any fantasies of "regulatory arbitrage" under the guise of "technological innovation," establishing the unshakeable fundamental principle that "regardless of how the technological form changes, financial activities must be licensed and subject to regulation."

At the same time, the "Notice" also takes a more resolute and thorough stance on existing risks. It not only reiterates the non-monetary nature of virtual currencies like Bitcoin but also creatively identifies "stablecoins pegged to fiat currency" as "effectively fulfilling part of the functions of fiat currency," and strictly prohibits the issuance of any unapproved stablecoins pegged to the Renminbi. This provision is strategically insightful, aiming to preemptively counter any potential challenges that may undermine the sovereign status of the Renminbi and construct parallel settlement systems in the digital space. By categorically defining all virtual currency-related business activities (including exchange, market making, information intermediation, derivatives trading, etc.) as "illegal financial activities," and abolishing the old notice from 2021, the regulatory authorities convey a firm determination to eliminate existing risks without leaving any gray areas.

II. Building a Comprehensive Penetrative "Firewall": Three-Dimensional Isolation from Funds to Information

If the qualitative definition is a declaration of stance, then the regulatory enforcement framework constructed in the "Notice" reflects a powerful systematic capability to translate that stance into reality. It deploys a comprehensive, penetrative regulatory network covering "fund flows, information flows, and technology flows," aiming to physically isolate risks.

In terms of fund flows, the regulatory requirements have reached an unprecedented level of strictness. All financial institutions and non-bank payment institutions are completely prohibited from providing any form of service for related activities, from account opening, fund transfers, and clearing and settlement, to product issuance, collateral inclusion, and insurance operations, achieving a thorough closure of financial channels. This effectively severs the "umbilical cord" between the digital asset sector and the mainstream financial system, preventing it from obtaining legitimate liquidity inputs and credit support.

On the information flow and marketing front, regulation is enforced both online and offline. Online, internet companies are strictly prohibited from providing online venues, commercial displays, marketing promotions, and paid traffic diversion, and are required to proactively report leads and provide technical assistance. Offline, market regulatory authorities prohibit the use of terms like "virtual currency" and "RWA" from the source of business registration names and scopes, and strengthen advertising supervision. This set of measures aims to eliminate the "visibility" and "legitimacy implication" of digital assets in the public domain, reducing speculative enthusiasm and participation willingness from a social cognition perspective, serving as a deep-seated risk prevention strategy.

At the technical and physical level, the rectification of virtual currency "mining" activities continues to deepen, clearly assigning overall responsibility to provincial governments, prohibiting new projects, and cleaning up existing ones. More critically, the policy innovatively introduces a "foreign service blockade" clause. It explicitly states that "foreign entities and individuals shall not illegally provide virtual currency-related services to domestic subjects in any form," and stipulates that domestic facilitators will be held accountable. This extraterritorial clause, combined with strict controls on cross-border payment channels, effectively constructs a "financial digital boundary" against the global internet, posing a strong legal deterrent to any foreign exchanges or DeFi protocols attempting to serve Chinese users.

III. Opening the Only "Compliance Narrow Door": The Strategic Intent of the CSRC's "Guidelines"

While the "Notice" erects a tight wall, the CSRC's "Guidelines" carefully design and open a highly restricted yet significant "door." This door leads only to a specific destination: allowing the issuance of asset-backed securities (ABS) tokens abroad, supported by domestic assets or cash flows.

This is not a concession to the speculation of virtual currencies, but a precise "guidance" that reflects high strategic consideration. First, its business model is strictly limited: the underlying assets must be domestic entity assets or their income rights that generate stable cash flows (such as infrastructure toll rights, trade receivables, leasing assets, etc.), and the issued tokens must conform to financial logic as ABS tokens, with the issuance market and investors strictly limited to abroad. This ensures that the innovative activity is closely anchored to the real economy, serving the genuine needs of enterprises for cross-border financing, and is completely isolated from the domestic retail speculative market.

Secondly, the regulatory approach is extremely strict: it adopts a "domestic entity must file with the CSRC in advance" model, rather than a simple post-reporting. The filing entity must submit a complete set of issuance materials for abroad and undergo a penetrative review of the authenticity of the underlying assets, compliance of the transaction structure, and effectiveness of risk isolation. This is earlier and deeper than traditional regulatory interventions in overseas bond issuance or listings, reflecting the regulatory concept of "same business, same risk, same rules," ensuring that innovation does not escape regulatory oversight.

The opening of this "narrow door" carries at least three strategic intentions: First, serving real financing: it opens a pilot channel for quality domestic enterprises to utilize blockchain technology to enhance the efficiency of cross-border asset securitization and reduce costs, directly reflecting the empowerment of the real economy by fintech. Second, accumulating regulatory experience and talent: in the controllable risk "overseas sandbox," regulatory agencies, financial institutions, and legal intermediaries can closely observe, understand, and manage the entire process of asset tokenization, accumulating valuable regulatory experience and cultivating professional talent for potentially larger-scale financial digital transformations in the future. Third, participating in the shaping of international rules: through proactive regulation and practice, China can accumulate discourse power in the global financial frontier of asset tokenization, avoiding passivity in the future formation of international rules, which is a profound layout in the competition of major powers in finance.

IV. The Emergence of a "Dual-Track" Ecosystem and Global Regulatory Divergence

The combined effect of the "Notice" and the "Guidelines" will profoundly shape China's future digital financial ecosystem and may accelerate the differentiation of the global regulatory landscape.

Domestically in China, a clear outline of a "dual-track" digital financial ecosystem has begun to emerge. The first track is a "completely closed retail track": any trading, financing, or derivatives activities related to cryptocurrencies and speculative tokens aimed at ordinary domestic investors will be permanently and thoroughly prohibited, forming a "self-circulating" safe zone that is essentially isolated from the globally public chain-dominated crypto ecosystem. The second track is a "limited open institutional and cross-border track": applications based on alliance chains or permissioned chains aimed at serving the real economy and cross-border capital flows will be encouraged and developed. The research and application of the digital Renminbi (e-CNY), as well as the blockchain infrastructure for the registration, trading, and settlement of specific financial assets that may be constructed under state leadership in the future, will become the core pillars of this track. Innovations in RWA can only proceed strictly within the second track, following the paths delineated by the "Guidelines."

From a global perspective, China's regulatory path fundamentally diverges from the compliance paths being explored by major economies like the United States and the European Union, which aim to "incorporate crypto assets into existing securities or commodity regulatory frameworks." China has chosen a unique model of "sovereignty priority, risk isolation, and pilot innovation." This is not only due to considerations of financial stability but also a deeper defense of national core interests such as monetary sovereignty, capital account management, data security, and cross-border flows. This divergence suggests that the global digital asset market may further fragment, forming regional markets with differing technological standards, asset categories, and investor structures. China's choice provides another potential regulatory paradigm reference for other emerging economies that prioritize financial sovereignty and control capabilities.

V. Far-reaching Impact and Future Outlook: Redefining Red Lines and Navigation Routes

In summary, the set of policy documents released in early 2026 has profound and complex implications. For market participants, this is a definitive "clearing signal." There is no longer any survival space for all business operations related to virtual currencies and unapproved digital assets domestically, and individuals involved face extremely high legal and financial risks. The fantasy of "policy warming" is no longer realistic. The real opportunities exist on only one path: to completely abandon short-term speculative thinking, deeply understand the national strategic intent, and engage in long-term and arduous technological and model innovation in directions that serve the real economy, comply with cross-border capital management policies, and rely on officially recognized technological paths.

From the perspective of national strategy, this policy combination is a proactive "mine clearance" and "foundation laying" for financial infrastructure. It has unprecedentedly cleared away the "weeds" that could disrupt the stability of the core financial system, undermine monetary sovereignty, and trigger social risks, paving the way for the next step of "sowing" a controllable national-level financial digital infrastructure. The strictest prohibitions often signal the most cautious preparations. It is foreseeable that in the future, China's efforts in the blockchain financial sector will focus on areas led by the "national team," such as central bank digital currency, trade finance blockchain platforms, and standardized asset digital transactions.

Ultimately, this set of policies redefines the non-negotiable red lines for China in the turbulent global digital financial transformation—namely, national security, financial stability, and the safety of people's property; it also reorients the navigable routes for exploration—namely, technology must empower the real economy, innovation must comply with regulation, and development must serve strategy. It declares that China will independently shape its digital financial future according to its own pace and logic. The establishment of this new paradigm is not only an upgrade of regulation but also a profound national financial strategic choice, whose impact will continue to manifest over the next decade and beyond.