Behind the Hainan Huatie Case: Opportunities and Challenges for RWA Compliance Implementation in Domestic Enterprises

1. RWA Window Open: How Far Can SMEs' "on-chain financing" Go?

Against the backdrop of the continuous deepening of the global digital economy, the on-chain of real world assets (Real World Asset, abbreviated as RWA) is becoming an important exploratory direction for traditional industries to embrace blockchain technology and expand financing channels.

In recent years, several industries in China have attempted this. For example, the Malu Grape Specialized Cooperative in Shanghai once packaged agricultural products and their related production data as underlying assets and listed them for circulation on a digital asset trading platform. Recently, the listed company Hainan Huatie sparked a new round of discussion about whether enterprises can issue RWA in compliance with regulations with a non-financial RWA project of 10 million yuan, also providing valuable reference directions for small and medium-sized enterprises.

2. The on-chain transformation of Hainan Huatie: The combination strategy of NFT + RWA

Hainan Huatie is a publicly listed company with a background in Hainan state-owned assets, mainly engaged in equipment leasing business, with a market share among the top in the country. The company disclosed data shows that its cumulative online equipment assets have reached 26 billion yuan, and it is exploring how to digitally map and transform these assets into rights products with circulation attributes, in order to optimize asset structure and improve usage efficiency.

In the Web3 direction, Hainan Huatie is divided into two paths: NFT and RWA.

In the NFT sector, the company launched the "Wasp Brother" digital collectible, granting cardholders the identity of brand ambassadors, and incentivizing participants through card locking to receive benefits equivalent to stock dividends. Although the model is innovative, it has also sparked some discussions, such as whether user speech is restricted and whether the profit design confuses with financial products. However, from a compliance perspective, the current project process has not yet crossed policy red lines.

For most small and medium-sized enterprises, NFT projects themselves have technical barriers and promotion difficulties. Not only do they need to be familiar with blockchain technology, but they also need to possess certain market organization capabilities and user operation abilities. This also means that it is challenging for internal teams to independently complete the construction of an NFT incentive project.

(Image sourced from the internet, for case demonstration only: does not constitute any investment advice)

3. How to Avoid Pitfalls? Key Design Concepts of RWA Compliance Structure

Unlike NFTs, the core of RWA lies in the direct linkage between on-chain tokens and the value of real-world assets. This also makes it easier to approach the financial regulatory red line. For example, if the usage rights or ownership of an asset are directly split and sold, it may constitute a de facto issuance of securities.

Hainan Huatie's strategy on the RWA path is relatively robust: the project design does not directly sell the ownership of equipment, but instead digitizes the usage rights and operational interests of the equipment in the form of a "membership card" and achieves transfer and circulation through on-chain mapping. This model retains the anchored value of the assets while avoiding high-risk operations involving securities law.

In addition, Hainan Huatie has introduced the licensed partner organization Weiyi Digital Technology Company. The membership card features consignment and transfer functions, while the dual-track system of on-chain registration + offline redemption avoids the speculation risks caused by "digital tokens." This creates a relatively balanced combination between compliance, digitalization, and market mechanisms.

This model combines NFT incentive mechanisms, on-chain registration technology, and operational asset management experience, forming a unique structure for Hainan Huatie. However, it also reminds us that not all enterprises possess such resource integration capabilities and regulatory communication abilities.

(Image sourced from the internet, for case demonstration only: does not constitute any investment advice)

4. It's not that it can't be understood, but that it can't be accomplished: RWA threshold breakdown

The attempt by Hainan Huatie demonstrates the potential of RWA, but also reaffirms a reality: for small and medium-sized enterprises, the lack of resources, technology, and compliance capability is the real barrier.

On one hand, many enterprises do have on-chain assets: equipment, inventory, accounts receivable, etc. all have the basis for digital mapping;

On the other hand, most enterprises lack compliance teams familiar with regulatory policies and do not have the capability to design suitable digital asset structures or user incentive models;

Not to mention, completing on-chain deployment, verifying asset anchoring, launching on-chain issuance, and establishing market circulation mechanisms, each step poses significant challenges to the team's capabilities.

In addition, regulatory risks cannot be ignored. Since the joint issuance of the "Announcement on Preventing Risks of Token Issuance and Financing" by seven ministries in 2017, enterprises that raise funds from the public in the name of tokens without permission are likely to be deemed as illegal fundraising. Therefore, the compliant issuance of RWA is not only a technical issue but also a systematic issue of legal boundaries and market mechanisms.

5. It's not that it can't be done, but how it should be done: Professional solutions for RWA implementation.

In this case, for small and medium-sized enterprises intending to explore RWA, it is better to seek collaboration with institutions that possess professional capabilities, rather than blindly "developing and launching" on their own, to jointly complete the entire process from asset selection to on-chain mapping, from compliance design to market promotion.

Currently, experienced RWA accelerators have begun to provide full-process support for small and medium-sized enterprises in exploring RWA pathways, including:

Asset modeling and mapping solutions tailored to the specific business characteristics of enterprises;

Suggestions for the issuance structure design that complies with the coverage policy.

Complete on-chain deployment and cross-chain support services;

User incentive mechanism construction;

Support for market-oriented issuance, community operation, and other later circulation strategies.

With the capabilities of professional institutions, small and medium-sized enterprises can explore RWA issuance in phases and with low risk, avoiding compliance pitfalls and resource waste, while striving for early dividends in the wave of digital assetization.

The digitalization of real-world assets is not just the exclusive path of a few large enterprises. In fact, small and medium-sized enterprises that truly own assets and businesses may be the most explosive participants in this transformation. The key lies in how to find the right methods, mitigate risks, and take the first step.