CBSR · evidence library
Mainland China stablecoin regulation evidence | CBSR historical snapshot
Explore 12 Mainland China stablecoin regulatory records with source locators, issuer pathways, reserve and yield rules, legal-force and review status in the 20 August 2026 CBSR snapshot.
Read this jurisdiction in context
The Mainland China dossier records a prohibition framework rather than an issuer-licensing menu. It separates domestic virtual-currency activity, unauthorised overseas RMB-pegged issuance, PRC-controlled offshore entities, and the additional data and capital-flow constraints relevant to cross-border analysis. A Hong Kong licence does not erase the destination prohibition.
Coverage and unresolved review work
Four regulatory questions and their evidence
Issuer pathway
cn-prc-issuer_pathway-001
Snapshot record wording · not a statutory quotation
There is no domestic stablecoin issuance pathway. The 2017 ICO Notice (94公告) policy continues, and the 2026 Notice (银发〔2026〕42号, which repealed the 2021 Notice) treats token issuance and virtual-currency business activity as prohibited, upgrading the banned act from token-offering financing to issuing virtual currency. The live regulatory questions for PRC-connected groups therefore concern the indirect pathway through Hong Kong and the cross-border data, capital, and disclosure constraints that condition it, not a domestic licence. The behavioural boundary observed in 2025 tracks a private/state distinction: private internet groups (Ant, JD) applied for HK licences and then withdrew in October 2025; state-linked banks expressed interest and paused; and no PRC-affiliated applicant received a licence in the April 2026 first round.Reserve and backing
cn-prc-reserve_backing-001
Snapshot record wording · not a statutory quotation
Reserve requirements are not applicable to domestic issuance, which is prohibited. On the indirect pathway through Hong Kong, HKMA reserve requirements apply to the HK-licensed entity; the PRC-connected parent holds no reserve obligation directly under PRC law but faces consolidation treatment under A-share listing rules.Permitted activity and yield
cn-prc-permitted_activity_yield-001
Snapshot record wording · not a statutory quotation
Because private token issuance and related fundraising are prohibited, there is no lawful domestic issuer that could pay yield; the yield question does not arise within a permitted perimeter.Monetary sovereignty
cn-prc-monetary_sovereignty-001
Snapshot record wording · not a statutory quotation
Mainland China occupies the prohibitive pole of the monetary-sovereignty constraint. The eight-ministry Notice 银发〔2026〕42号 (in force 6 Feb 2026) reaffirms that virtual currencies have no legal-tender status and adds an explicit WRITTEN prohibition on overseas issuance of RMB-pegged stablecoins without lawful approval (未经许可，境内外任何主体不得在境外发行挂钩人民币的稳定币), plus an extraterritorial ban on PRC-controlled entities issuing virtual currencies abroad and restrictions on RWA tokenisation.Complete record inventory
| Record / dimension | Recorded source locator | Binding status | Freshness | Source check date |
|---|---|---|---|---|
| AML and KYC | AML — PRC AML Law; PBOC AML/CFT; crypto AML scrutiny under 94 公告 | in_force_enacted | unknown | Not evidenced |
| Bank and non-bank routing | Absence of a compliant issuance/routing architecture | prohibition | unknown | Not evidenced |
| Capital requirements | Capital — N/A domestically; indirect HK HK$25m + SAFE registration + consolidation | prohibition | unknown | Not evidenced |
| Cross-border data | PIPL three-gate outbound transfer; DSL important-data review; March 2024 threshold relief; FTZ negative lists | in_force_enacted | unknown | Not evidenced |
| Distribution | Domestic distribution prohibited; three indirect-pathway constraint layers (A-share / SAFE / PBOC-CAC) | prohibition | unknown | Not evidenced |
| Implementation status | Implementation timeline — stable prohibition; 2017-2026 milestones | no_regime | unknown | Not evidenced |
| Issuer pathway | 银发〔2026〕42号 (virtual-currency-related business activities in the PRC are illegal financial activities, strictly prohibited; the prohibited act is upgraded from '代币发行融资' (token-offering financing, 2021) to '发行虚拟货币' (issuing virtual currency), now reaching non-fundraising / airdrop / utility issuance) | prohibition | unknown | Not evidenced |
| Monetary sovereignty | 银发〔2026〕42号 — 未经许可，境内外任何主体不得在境外发行挂钩人民币的稳定币 (no entity, domestic or overseas, may issue RMB-pegged stablecoins overseas without approval); 境内主体及其控制的境外主体不得在境外发行虚拟货币 (PRC-controlled entities may not issue virtual currencies abroad); RWA tokenisation restrictions | prohibition | unknown | Not evidenced |
| Permitted activity and yield | Prohibition context — no permitted issuer to which a yield rule could attach | prohibition | unknown | Not evidenced |
| Regulatory authority | 银发〔2026〕42号 (a coordinated multi-agency prohibition perimeter; eight ministries plus the cyberspace administration and the two supreme judicial organs) | prohibition | unknown | Not evidenced |
| Reserve and backing | Reserve — N/A domestically; indirect HK pathway + A-share consolidation | prohibition | unknown | Not evidenced |
| Securities classification | 银发〔2026〕42号 (token issuance treated as illegal public fundraising / illegal financial activity); CSRC 公告〔2026〕1号 (RWA asset-backed-securities-token guidance: filing system + negative list for onshore-asset offshore ABS-token issuance) | prohibition | unknown | Not evidenced |