China outlaws every private crypto business activity, yet its state-run digital yuan has processed 3.48 billion cumulative transactions worth 16.7 trillion yuan (approximately $2.37 trillion) through the end of November 2025, according to Xinhua figures the People’s Bank of China released via the State Council. The paradox defines the picture. The PBoC treats crypto business as illegal while the Hong Kong Monetary Authority and the Securities and Futures Commission issue their own licences.
The PBoC’s latest statement reaffirmed that virtual currency business activities are “illegal financial activities” in mainland China, and stablecoins were flagged as posing risks of “money laundering, fundraising fraud, and illegal cross-border transfer of funds”. Hong Kong, meanwhile, holds 13 SFC-licensed virtual asset trading platforms as of February 2026 and is finishing a consultation on adding licences for dealers, custodians, advisers and portfolio managers.
Key Takeaways
- Mainland China has recorded 3.48 billion e-CNY transactions worth about $2.37 trillion, and the January 1, 2026 framework upgrade added interest-bearing wallet balances backed by deposit insurance. The PBOC framework upgrade classifies e-CNY held in commercial bank wallets as bank deposit liabilities, protected by deposit insurance.
- Hong Kong’s Chainalysis 2025 Global Crypto Adoption Index rank climbed to #5 worldwide, jumping from 17 in the prior year to 5 in 2025 and marking one of the sharpest one-jurisdiction moves in the index.
- Shanghai’s Jing’an District court sentenced five defendants to two and a half to six years for a crypto-linked foreign exchange scheme that moved more than 200 million yuan (about $29.4 million) abroad across three years, showing the current enforcement priority is cross-border FX, not retail trading.
- Cambridge data still frames the mining shock: China’s share of global Bitcoin hashrate fell from 75.5% in September 2019 to 46% in April 2021 before the June 2021 crackdown collapsed reported share to zero.
- SAFE reported more than 400 foreign-exchange-related illegal cases in the first half of 2025 and worked with police to penalise more than 180 underground banking cases in the same period.
- Hong Kong’s Stablecoins Ordinance took effect on 1 August 2025, and the HKMA closed a September 30, 2025 first-batch application window.
Editor’s Choice
- e-CNY cumulative value, per Atlantic Council analysis of PBoC data: Over 800% growth since 2023, with cumulative value about $2.3 trillion by late 2025.
- Project mBridge transaction volume: $55.49 billion, a 2,500-fold increase over early-2022 pilots.
- e-CNY dominance inside mBridge: Over 95% of total settlement volume.
- APAC growth: 69% year-over-year increase in on-chain value received; APAC transaction volume grew from $1.4 trillion to $2.36 trillion.
- Hong Kong licensed VATPs, according to Fintech Hong Kong’s SFC register roll-up: 13 SFC-authorised platforms as of February 2026.
- Personal FX quota: $50,000 per person per year, the limit that has made crypto-hidden transfers a persistent enforcement target.
China’s Crypto Ban at a Glance
The mainland regulatory posture today treats virtually every private crypto activity as illegal, with the digital yuan reserved as the only permitted digital currency form. The PBoC meeting statement made the framing explicit: “cannot be used as legal tender in the market,” the central bank said, adding that digital asset business activities remain “illegal financial activities.”
- Retail trading of Bitcoin, Ether and other virtual currencies is banned; domestic exchanges cannot operate.
- Initial Coin Offerings (ICOs) and token financing platforms have been banned since September 2017 under the joint PBoC “ICO Ban” Announcement.
- Payment institutions have been barred from processing virtual currency transactions since the January 2018 PBoC Notice on Self-Inspection.
- Bitcoin mining has been treated as an eliminated industry since the National Development and Reform Commission’s September 24, 2021 notice, and industrial-scale operations were shut down in Sichuan, Xinjiang, Inner Mongolia and Yunnan during June 2021.
- Stablecoins were named as an area of “particular concern” in the PBoC’s latest statement for failing to meet customer identification and anti-money laundering requirements.
| Activity | Mainland China status (2026) | Hong Kong SAR status (2026) |
|---|---|---|
| Retail spot trading | Illegal | Permitted on SFC-licensed VATPs |
| ICOs and token sales | Illegal (2017 ban) | Restricted; SFC guidance applies |
| Bitcoin mining | Eliminated industry (2021) | Not restricted (limited scale) |
| Stablecoin issuance | Illegal (2025 reaffirmation) | Regulated by HKMA under Stablecoins Ordinance |
| Payment services for crypto | Prohibited (2018 notice) | Permitted where AMLO compliance met |
| Cross-border crypto transfers | Prosecutable as FX evasion | Regulated |
Source: PBoC 2013/2017/2018/2021 notices, HKMA and SFC 2025-2026 rulemaking
Digital Yuan (e-CNY) Adoption Statistics
The e-CNY has become the world’s largest live central bank digital currency by transaction count and value. Five years after the first pilot, it remains “the world’s largest live central bank digital currency experiment”. The State Council’s late-December announcement laid out the shift toward deposit-money mechanics that took effect at the start of the year.
- The PBOC announced that an upgraded framework for digital yuan management would take effect on Jan. 1, 2026, moving the e-CNY beyond a cash-like instrument toward a form of digital deposit money.
- Commercial banks are required to pay interest on digital yuan wallet balances in accordance with prevailing deposit rate regulations.
- Wallet balances held with authorized commercial banks are counted toward the reserve requirement calculation base, while non-bank payment institutions must deposit 100% reserves against the digital yuan they manage.
- Cumulative transaction value has grown more than 800% since 2023, according to Atlantic Council analysis of PBOC data released at the end of December 2025.
- Cross-border settlement via Project mBridge has scaled sharply: transaction volume has surged to $55.49 billion, a 2,500-fold increase over early-2022 pilots, with the e-CNY making up over 95% of total settlement volume.
| Metric | Value |
|---|---|
| Cumulative e-CNY transactions | 3.48 billion |
| Cumulative e-CNY value (yuan) | 16.7 trillion |
| Cumulative e-CNY value (dollars) | 2.37 trillion |
| Growth in transaction value since 2023 | 800% |
| Project mBridge cumulative value | 55.49 billion |
| e-CNY share of Project mBridge settlement | 95% |
Source: People’s Bank of China via State Council press release, December 29, 2025; Atlantic Council analysis, January 2026
The interest-bearing pivot is the headline on the ban-versus-CBDC axis. Beijing has defined every private stablecoin as an AML risk while building a sovereign alternative that pays yield inside the deposit insurance perimeter.
Recent Developments in China’s Crypto Policy
- July 1, 2026 (2026-07-01): A Shanghai court sentenced five defendants in a crypto-linked foreign exchange case, with terms ranging from two and a half years to six years and fines of 300,000 yuan (about $44,150) to 1.5 million yuan (about $220,780).
- February 6, 2026 (2026-02-06): PBoC Notice No. 42 took effect, superseding the earlier virtual-currency notice and expanding the framework to cover real-world asset tokenisation and RMB-pegged stablecoins, a category the broader algorithmic stablecoins picture also tracks.
- January 23, 2026 (2026-01-23): Hong Kong’s one-month public consultation on VA dealer, custodian, adviser and portfolio manager licensing closed.
- January 1, 2026 (2026-01-01): The upgraded e-CNY management framework took effect, treating commercial-bank e-CNY balances as deposit liabilities protected by deposit insurance.
- November 28, 2025 (2025-11-28): PBoC held a multi-agency meeting with the Ministry of Public Security, Cyberspace Administration of China, Central Financial Office, Supreme People’s Court, Ministry of Justice and the China Securities Regulatory Commission to discuss combating speculation in digital currency transactions.
- August 1, 2025 (2025-08-01): Hong Kong’s Stablecoins Ordinance took effect, bringing stablecoin issuers under an HKMA licensing regime.
Regulatory Timeline: PBoC Actions on Crypto
Mainland China’s crypto framework has been tightened by each new notice since the December 2013 PBoC Bitcoin circular. The current wave is the tightest to date, naming stablecoins directly.
| Date | Instrument | Key restriction |
|---|---|---|
| December 2013 | PBoC + 4 authorities: Circular on the Prevention of Risks from Bitcoin | Financial institutions barred from Bitcoin-related business |
| September 2017 | PBoC + 6 authorities: ICO Ban Announcement | ICOs and token exchange services prohibited |
| January 2018 | PBoC Notice on Self-Inspection | Payment institutions must not service virtual currency trades |
| May 2021 | State Council Financial Stability Committee | Announced mining crackdown |
| September 24, 2021 | PBoC + 9 authorities: Circular 237 | All virtual-currency-related business activities declared illegal |
| September 24, 2021 | NDRC + 10 agencies: Mining Notice | Bitcoin mining classified as eliminated industry |
| June 2023 | HKMA / SFC | Hong Kong VASP licensing regime takes effect |
| August 1, 2025 | Hong Kong Legislative Council: Stablecoins Ordinance | HKMA-administered stablecoin issuer licensing |
| November 28, 2025 | PBoC multi-agency meeting | Reaffirmation of ban; stablecoins flagged as AML risk |
| January 1, 2026 | PBoC | e-CNY management framework upgraded to interest-bearing model |
| February 6, 2026 | PBoC + 7 authorities: Notice No. 42 | Extends framework to RWA and RMB-pegged stablecoins |
Source: CMS legal expert guide summary of PBoC notices; State Council Xinhua release; HKMA press releases
In September 2021, the PBOC and nine other central authorities released the Circular on Further Preventing and Resolving the Risks of Speculation in Virtual Currency Trading (“Circular 237”). The document hardened the framework the November PBoC meeting reaffirmed. Circular 237 declared all crypto-related business activities illegal without distinguishing between onshore or offshore venues. The recent Notice from the PBoC layered Initial Coin Offerings (ICOs) restrictions plus RWA and stablecoin categories on top.
Bitcoin Mining Ban and Global Hashrate Impact
The mining crackdown produced the most measurable regulatory shock in Bitcoin’s history, and Cambridge’s Centre for Alternative Finance datasets are still the standard reference. The share numbers frame the shift precisely.
- China’s share of total Bitcoin mining power declined from 75.5% in September 2019 to 46% in April 2021, before the crackdown was even imposed.
- In the same period, the United States’ share of total Bitcoin hashrate increased from 4.1% to 16.8%, putting it in second place.
- Kazakhstan’s share rose from 1.4% in September 2019 to 8.2% in April 2021, catapulting it to third place globally.
- China’s reported share went to zero in August 2021 following the June crackdown; miners either exited the country or masked their locations, and CCAF cautions that its own methodology cannot see through VPN and proxy relays.
- Bitcoin’s hashrate hit new all-time highs just months after the ban, and available geolocational data indicated the network became more decentralized as hashrate spread more evenly. Bitcoin Policy Institute’s post-ban assessment.
The 2020 seasonal migration inside China was itself unusual, with Sichuan’s share of China’s mining rising from 14.9% at the beginning of the wet season to 61.1% at peak, and Xinjiang’s coal-powered share falling from 55.1% to 9.6% in the same period.
Readers tracking longer-run Bitcoin mining hashrate data should treat the current China-share number on CCAF’s charts as a floor rather than a fact.
Worth noting: Cambridge itself warns that its own methodology cannot see through VPN-relayed IP addresses, and that mining shares attributed to countries with little visible industrial infrastructure (Germany, Ireland) are likely inflated by redirected traffic. The mainland ban was real and the reported share is honest; the underground rebound is real too and not fully measured.
Hong Kong VATP Licensing Regime
Hong Kong’s Securities and Futures Commission runs the virtual asset trading platform licence, distinct from the HKMA’s stablecoin regime. The regime has been live for several years, and the SFC has issued a concentrated slate of platform licences.
- As of February 2026, the Securities and Futures Commission (SFC) has granted licences to 13 VATPs, according to Fintech Hong Kong’s roll-up of the SFC register.
- The regime combines the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (AMLO) framework with SFC investor-protection rules.
- Hong Kong VATP licences authorise services to retail customers and professional investors after platform-level ISO 27001 (Information Security) and ISO 27701 (Data Privacy) accreditation.
- Licensed platforms include OSL Digital Securities Limited (OSL Exchange, part of OSL Group) and Hash Blockchain Limited (HashKey Exchange), among 11 others.
- The Hong Kong government intends to finalise legislative proposals under the AMLO and introduce a bill to the Legislative Council in 2026 to extend licensing to VA dealers, custodians, advisers and portfolio managers.
- The one-month public consultation on the extended regime ended on January 23, 2026.
Hong Kong’s SFC licences sit alongside mainland crypto restrictions with no formal reciprocity, which is why cross-boundary trading remains a live compliance question for crypto exchanges that serve mainland users through Hong Kong entities.
Hong Kong Stablecoin Ordinance
The Stablecoins Ordinance is Hong Kong’s structural answer to the private-stablecoin market that Beijing treats as illegal. The HKMA’s supervisory approach is closer to a bank-issuer model than to a technology-neutral registration.
- The Hong Kong Monetary Authority (HKMA) published documents on 29 July 2025 for the implementation of the regulatory regime for stablecoin issuers, which came into effect on 1 August 2025.
- The regime covers issuance of fiat-referenced stablecoins in Hong Kong and issuance of Hong Kong-dollar-pegged stablecoins outside Hong Kong.
- Parties interested in applying were asked to contact the HKMA via stablecoin_licensing@hkma.gov.hk by 31 August 2025, and the first-batch application deadline was set at 30 September 2025 (Tuesday).
- The HKMA published finalised guidelines on supervision of licensed stablecoin issuers and on anti-money-laundering and counter-financing of terrorism obligations.
- As of the July 29, 2025 press release, no licence had been issued by the HKMA; the register of licensed stablecoin issuers is maintained on the HKMA website.
- The Ordinance covers “in-scope” stablecoins including governance, issuance, redemption, reserve management and wallet arrangements.
By the numbers: Hong Kong’s HKMA regime, effective on 1 August 2025, gave interested issuers a single application window closing on 30 September 2025 and a first-batch decision timeline pointed at early 2026. The framework’s core scope is fiat-referenced CBDC-adjacent stablecoin issuance, not custody, not trading, not payments infrastructure.
Enforcement: Foreign Exchange and Underground Banking
Enforcement patterns show a shift from banning trading platforms to prosecuting the crypto-hidden foreign-exchange chains individuals use to move money past the annual FX quota. The Shanghai case is the clearest current example.
- A Shanghai court sentenced five Chinese individuals to prison terms ranging from two and a half years to six years in a crypto-linked foreign exchange case.
- Prosecutors said the group helped domestic clients transfer more than 200 million yuan, or about $29.4 million, abroad over three years.
- One defendant surnamed Gao helped process more than 170 million yuan, or about $25 million, in illegal foreign exchange transactions before starting a separate currency conversion business.
- The State Administration of Foreign Exchange said it investigated more than 400 foreign exchange-related illegal cases in the first half of 2025, and worked with law enforcement to penalise more than 180 underground banking cases in the same period.
- China’s annual personal foreign currency quota stands at the equivalent of $50,000 per person, a rule that has made underground transfer networks a long-running target.
| Enforcement metric | H1 2025 figure | Source |
|---|---|---|
| Foreign-exchange-related illegal cases investigated | 400+ | SAFE |
| Underground banking cases penalised | 180+ | SAFE + police |
| Personal annual FX quota | $50,000 | SAFE |
| Shanghai crypto-FX case value | $29.4 million | Shanghai Jing’an District Procuratorate |
| Shanghai case prison terms | 2.5 to 6 years | Shanghai Jing’an District Procuratorate |
Source: State Administration of Foreign Exchange, Shanghai Jing’an District People’s Procuratorate, July 2026
Prosecutors built the case on on-chain evidence plus wallet-and-agent-network mapping. It lines up with China’s broader blockchain forensics and illicit transaction data analysis discipline.
Mainland China vs Hong Kong: Two-Track Adoption Data
Chainalysis’s index shows the sharpest single-country regulatory-outcome divergence anywhere in the ranking. Hong Kong SAR sits well up the list; mainland China does not appear at all.
- Hong Kong SAR, China ranked 5th globally in the 2025 index, up from 17th in the prior year.
- Ukraine, Moldova, Georgia and Jordan hold the top four positions, with Vietnam at 6, Latvia at 7, Montenegro at 8, Venezuela at 9 and Slovenia at 10.
- In the twelve months ending June 2025, APAC emerged as the fastest-growing region for on-chain crypto activity, with a 69% year-over-year increase in value received.
- Total crypto transaction volume in APAC grew from $1.4 trillion to $2.36 trillion, driven by India, Vietnam, and Pakistan.
- Latin America’s crypto adoption grew by 63%, close behind APAC.
- Mainland China does not appear in the 2025 top 20; the “Hong Kong SAR, China” entry does not include mainland activity.
The Chainalysis split is unusually clean: the same country produced one jurisdiction ranked in the top five and another that did not qualify for the top 20, in the same reporting window. That is what “two-track” means for on-chain activity.
Is crypto legal in mainland China?
No private crypto trading, mining, or payment activity is legal on the mainland today. The PBoC’s November statement and the February Notice No. 42 both reiterate that virtual currency business activities are “illegal financial activities,” and stablecoins fail AML standards. Only the state-issued e-CNY, now moving beyond a cash-like instrument toward a form of digital deposit money under the Jan. 1, 2026 framework, is permitted.
Individual possession is not itself a crime, but converting crypto into yuan can trigger frozen accounts and prosecution once it crosses the annual FX quota of about $50,000 per person.
Can Hong Kong residents trade crypto legally?
Yes, through the SFC-licensed VATP regime. 13 platforms hold SFC licences today, and Hong Kong residents can trade on those platforms subject to platform onboarding rules for retail versus professional investors. Hong Kong is separately building a licensing framework for virtual asset dealers, custodians, advisers and portfolio managers, with the public consultation ending on January 23, 2026 and legislation targeted for later in the year. The HKMA’s Stablecoins Ordinance covers stablecoin issuance, effective on 1 August 2025.
Conclusion
China’s regulatory picture sits on two axes that both point outward from the mainland ban. The e-CNY has processed 3.48 billion transactions worth approximately $2.37 trillion and now pays interest on wallet balances, positioning itself as the sovereign alternative to the private stablecoins Beijing has named as an AML risk. Hong Kong holds 13 SFC-licensed VATPs and a live HKMA stablecoin regime, and the Chainalysis 2025 index ranks Hong Kong SAR fifth while mainland activity stays off the ranking.
Enforcement priority has moved from spot-trading crackdowns to prosecuting crypto-hidden FX chains. Data points to watch next: the PBoC Notice’s practical implementation, the first HKMA stablecoin licences, and Hong Kong’s expected legislative bill for VA dealer and custodian licensing.