China’s Virtual Asset Policy Enters a New Era: Why the November 28, 2025 Meeting Marks a Structural Turning Point for the Mining Industry

Over the past several years, China’s regulatory approach toward virtual assets has moved through multiple phases—some focused on trading, some on mining, and others on payment channels and capital flows. Each policy shift has directly influenced market confidence and the expectations of miners.
But compared with the past, the meeting led by the People’s Bank of China on November 28, 2025, carries fundamentally different significance.

This was not merely another policy reminder or routine warning. Instead, it was the most comprehensive and impactful regulatory mobilization in the virtual asset sector in nearly four years—featuring:

• Higher department-level involvement

• Larger participation scope

• Clearer and more direct policy positions

More importantly, it signals a long-term national governance framework in which non-sovereign virtual assets will be managed under a structure that expands from financial risk prevention to financial security + social governance + coordinated multi-agency management.

For the mining industry, this is not a minor “change in policy atmosphere,” but a structural turning point that will shape long-term industry pathways.

1. From Reminder-Based Regulation to Top-Level Coordination: Three Key Signals

Compared with the well-known “9·24” policies of 2021, the most important part of the November 28 meeting was not any single sentence—but who was sitting at the table.

1.1 Upgraded departmental lineup: From multi-agency participation to top-level orchestration

• 2021: Ten agencies jointly issued a policy notice.

• 2025: Thirteen agencies participated directly in a centrally coordinated meeting.

Three newly highlighted participants reveal clear new priorities:

• Central Financial Commission (Central Financial Office):
  Indicates that virtual assets are now viewed as part of national financial security and strategic design—not merely industry-specific risk.

• Judicial authorities:
  Signals potential future development of judicial interpretations, unified standards, and clearer legal boundaries.

• National Development and Reform Commission (NDRC):
  No longer focused solely on “mining rectification,” but now involved in comprehensive governance of the broader virtual asset ecosystem. This has a direct and practical impact on the mining and computing-power industry.

Key Signal #1:
China is shifting from dispersed departmental oversight to centralized coordination + integrated governance.

1.2 Virtual assets are no longer treated as a temporary issue

Many industry participants once believed policies might “gradually loosen” over time.
However, the latest signals instead show that virtual assets are now seen as:

• Long-term governance objects

• Structurally important

• Closely tied to financial and national security

Relying on “policy reversals” or “gray zones” will only grow more dangerous.

1.3 The computing-power sector is now part of the core governance map

The inclusion of the NDRC in this integrated framework means:

• Mining-related computing power will be reviewed alongside capital pathways and trading behavior.

• Key areas—IDC filings, data center legitimacy, industrial electricity consumption, energy approvals—will be examined more strictly.

• Using labels like “cloud computing” or “big data” to conceal mining activity will face increasing scrutiny.

This marks a significant shift: computing power is now a core component of virtual asset governance, not a peripheral issue.

2. Stablecoins Highlighted: Capital Channels Enter High-Intensity Oversight

For the first time, stablecoins such as USDT and USDC were explicitly identified as regulatory priorities at a national level.

This development cannot be overstated.

2.1 Stablecoins now directly intersect with foreign exchange management

As RMB cannot directly enter virtual asset trading environments, a common path emerged:

RMB → Stablecoin → Virtual assets / overseas assets

This pathway:

• Bypasses traditional FX quota controls

• Avoids trade-background verification

• Enables fast, opaque cross-border movement

Stablecoins have thus become a key vehicle for cross-border capital flows, bringing them directly into conflict with China’s FX regulatory framework.

Regulators formalizing stablecoins as a governance priority is, therefore, both expected and necessary.

2.2 A concentrated crackdown on high-risk capital activities

Recent enforcement cases often highlight stablecoins as core intermediaries due to their:

• Low cost

• High liquidity

• Fast settlement

• Difficult traceability

Regulating stablecoin channels allows authorities to:

• Target cross-border abnormal fund flows

• Combat specific illicit financial activity

• Strengthen financial and social security

This is not a temporary campaign—it is the beginning of long-term, systemic governance of stablecoin pathways.

3. The Digital RMB and the Timing of Policy Acceleration

To understand why the meeting occurred now, one must consider the development of the digital RMB (e-CNY).

By Q3 2025:

• e-CNY applications expanded across public services, retail payments, and government processes

• Transaction volumes increased

• Cross-border pilots accelerated

As e-CNY becomes foundational digital financial infrastructure, its goals inevitably overlap with some real-world functions of stablecoins:

• Cross-border settlement

• Value storage

• Intermediary currency use

Thus, in a critical development phase of China’s sovereign digital currency, stablecoins—anchored to foreign currencies and outside domestic oversight—naturally meet stricter regulatory scrutiny.

This explains:

• Why the November 28 meeting named stablecoins so directly

• Why the regulatory strategy evolved into a long-term, coordinated framework

• Why financial security and digital currency strategy are now addressed together

4. The Mining Industry’s Risk Map: A Practical, Non-Official Classification

Disclaimer: The following is not legal advice, only risk education.

Low Risk: Passive holding and small personal transactions

Generally not the focus of enforcement.
But risks include:

• Poor civil protection of virtual asset rights

• Bank account monitoring

• Freezing or prolonged account investigation

“Low risk” does not mean “safe.”

High Risk Category 1: OTC conversion and channel services

Providing RMB ⇄ USDT/USDC conversion or match-making services may involve:

• Unlicensed financial activity

• Entanglement with others’ illegal fund flows

• Being swept into criminal investigations

This sector is expected to undergo severe compression.

High Risk Category 2: Using stablecoins for foreign trade settlements

Even with legitimate trade, long-term use of stablecoins for cross-border settlement can be interpreted as:

• Evading FX controls

• Disrupting financial administration

• In severe cases, violating financial management laws

This area is now explicitly “red-lighted.”

High Risk Category 3: Token issuance and fundraising models

Including:

• Issuing tokens to raise capital

• Promises of guaranteed returns, high yields

• Structures dependent on new participant funds

Such models carry extreme legal risk and are frequently reclassified as serious financial or economic crimes.

High Risk Category 4: Domestic mining disguised as cloud computing or data services

With NDRC and other departments aligned, inspections will target:

• Abnormal commercial electricity patterns

• Data center filings inconsistent with actual server use

• Mismatch between declared business and computing-power scale

Running disguised domestic mining operations faces rising and unpredictable risk.

5. A Structural Shift: Mining Moves from Domestic Model to Global Computing Power

From 2021–2025, an industry consensus has formed:

• Achieving full domestic compliance for virtual asset mining is extremely difficult

• Overseas regions with energy advantages offer realistic alternatives

• Hong Kong provides a clear licensing framework, but not a bypass for mainland restrictions

After the November 28 meeting, this trend becomes irreversible.

5.1 Domestically: Do not rely on “policy easing expectations”

The era of gray zones, tolerance windows, or regional differences is ending.
Future decisions must be based on:

• Compliance

• Long-term stability

• Avoiding regulatory red lines

5.2 Hong Kong & global jurisdictions: Innovation must follow compliance

Hong Kong's regulatory systems aim to attract global capital—not serve as a detour for mainland participants.

Attempts to build “Mainland → Hong Kong → Virtual asset/overseas funds” loops will trigger multi-jurisdictional scrutiny.

Hong Kong is a platform, not a shortcut.

5.3 Global mining deployment: Compliance is the foundation

Regions like the Middle East, Central Asia, North America, and Latin America offer:

• Competitive energy resources

• Favorable climates

• Pro-mining policies in certain jurisdictions

But success requires full compliance with local:

• Energy rules

• Taxation

• Financial regulations

• Business licensing

China’s miners have strong engineering and deployment advantages—but the winning factor in the next decade will be:

Who can build legally recognized, long-term, stable computing power infrastructure worldwide.

Regulation will not make exceptions.
The industry’s future belongs to those who can comply, adapt, and rebuild within global rules.