The emergence of digital assets marks a significant evolution within the data-driven industry ecosystem, representing a high-value segment in new digital economy sectors, particularly those built on blockchain-based business models. Against the backdrop of national policies like The Opinions on Establishing Data Infrastructure Systems to Better Leverage the Role of Data Elements and the Three-Year Action Plan for "Data Elements ×" (2024–2026), which emphasize building a "trusted data circulation system," Shanghai has taken concrete steps to foster digital innovation. The city’s 14th Five-Year Plan for Digital Economy Development explicitly encourages “accelerating the exploration of digital transformation and digital technology applications in areas such as virtual digital assets,” providing both support and demand for regulated digital asset trading.
In this context, the Shanghai Data Exchange recently released the Shanghai Data Exchange Digital Asset Trading Management Specification (Trial) (hereinafter referred to as the Specification). As one of the most forward-looking attempts in China to realize the value of digital assets, it offers a structured entry point for asset issuers to register and display their assets. More importantly, it provides clear guidance to all market participants, establishing a scientifically designed regulatory framework and robust infrastructure to facilitate compliant and risk-aware digital asset transactions.
Core Structure and Key Components of the Specification
The Shanghai Data Exchange launched a trial operation for digital asset trading on February 18, 2024. This was preceded by extensive research and preparatory work focused on institutional design and infrastructure development, forming a solid foundation for practical implementation.
Progress in Building the Digital Asset Trading Service Platform
Several digital assets have already been traded on the Shanghai Data Exchange’s platform. Notable examples include:
- “Light-Chasing Dragon, Bright Reservation” issued by Bright Food Group’s subscription service.
- A commemorative digital medal for “Beijing CBD International Group — Marking the First Batch of Data Asset Capitalization.”
- A public welfare-themed digital asset named “Bringing Light to Children of the Stars — First Autism Charity Theme.”
These assets attracted significant market attention, with many selling out shortly after listing. They have not only facilitated liquidity and value recreation in the digital asset space but have also enhanced the brands of their issuers and generated positive social impact.
During the trial phase, the Shanghai Data Exchange has been selectively inviting high-quality digital assets into the trading market. Participation for issuers, data merchants, and other entities is currently based on an invitation-only mechanism to ensure market integrity.
Main Provisions of the Specification
A defining feature of Shanghai’s approach to building a data elements market has been its commitment to operating within a legal framework. The Interim Measures for the Administration of Data Trading Venues in Shanghai highlight that data exchanges must formulate trading rules and other relevant business regulations in accordance with the law. Similarly, Article 67 of the Shanghai Data Regulations mandates that “data exchanges shall establish data transaction rules and other related operational guidelines.”
The newly released Specification is the first self-regulatory standard specifically targeting the digital asset sector. It consists of 33 articles organized into five chapters:
- General Provisions
- Trading Participants
- Trading Procedures
- Self-Regulatory Management
- Supplementary Provisions
Key aspects covered include:
- Defining the roles and responsibilities of all parties involved in digital asset transactions.
- Outlining prerequisites for digital asset trading.
- Establishing supporting systems to ensure secure and orderly transactions.
- Specifying the Shanghai Data Exchange’s authority to regulate and supervise illicit trading activities.
Overall, the Specification offers a comprehensive, practical, and forward-looking self-regulatory framework. It supports the development of an ecological, efficient, and well-regulated digital asset market.
It is important to note that the Shanghai Data Exchange does not serve as a platform for issuing digital assets. Instead, it provides display and registration services. According to the Specification, issuers must complete both issuance registration and trading registration before their assets can be displayed and circulated. The process is structured as follows:
Issuance Phase:
The issuer independently selects a publishing platform and applies to the Shanghai Data Exchange for issuance registration via the Digital Asset Issuance Registration System. Once approved, the issuer receives a Digital Asset Issuance Registration Certificate, and the asset information is displayed on the China Digital Asset Network. The initial purchase can then be made on the issuing platform.
Trading Phase:
After obtaining the issuance certificate, the issuer may apply for trading registration. The asset becomes eligible for trading only after passing the exchange’s review and upon receipt of a Digital Asset Trading Registration Certificate. Trading participants must open accounts on the digital asset trading market to engage in transactions.
These rules, supported by the exchange’s technological infrastructure, contribute to the stable operation of the digital asset market and provide safeguards during the trial phase.
The Specification as a Formalization of Shanghai’s Evolving Practice
Digital assets represent a critical link in the value chain of data elements. The circulation and trading of digital assets constitute an essential component of the data要素 market and play a positive role in empowering the real economy.
The pilot initiative in digital asset trading is a courageous exploration aligned with national data要素 policies and a direct outcome of guidance from Shanghai’s regional government. In July 2022, the Shanghai Municipal Government’s Action Plan for Cultivating the ‘Metaverse’ New Track (2022–2025) explicitly proposed “launching a digital asset trading section on a trial basis at the Shanghai Data Exchange to cultivate a sound digital asset要素 market.” This was further reinforced in July 2023 by the Action Plan for Promoting the Innovative Development of the Data要素 Industry Based on the New Digital Economy Track (2023–2025), which supports the Shanghai Data Exchange in researching and implementing digital asset issuance and trading mechanisms integrated with the real economy.
Emphasizing the Commodity Nature of Digital Assets
Nationally, regulatory measures have been implemented to prevent and address risks associated with virtual currency speculation. A joint notice issued by ten authorities, including the Supreme People’s Procuratorate, emphasized “cracking down on illegal financial activities related to virtual currencies.”
In this context, digital assets in China differ significantly from crypto-assets on international public blockchains. While global platforms often explore financial applications such as cryptocurrencies and decentralized finance (DeFi), China maintains a strict stance against currency speculation, explicitly prohibiting the issuance and trading of cryptocurrencies and resolutely curbing tendencies toward financialization and securitization of digital assets.
The Shanghai Data Exchange’s Specification actively promotes self-regulatory norms for digital asset trading while strictly adhering to national policies. A fundamental measure is defining digital assets as commodities, emphasizing value creation through virtual-real integration and minimizing potential risks.
“Virtual-real integration” is a core value orientation in Shanghai’s metaverse industry development strategy. The Action Plan for Cultivating the ‘Metaverse’ New Track highlights the importance of understanding the metaverse’s laws of evolution—virtual mapping, virtual interaction, and virtual-real integration—and leveraging it to enhance the productivity of the real economy.
The Specification aligns closely with this vision. It grounds digital assets in their commodity attributes, emphasizing that the fundamental purpose of digital asset trading lies in their use value and exchange value within the real economy. Accordingly, it establishes trading rules similar to those governing physical commodities.
Specifically, Article 3 of the Specification clearly states that “digital assets are digital commodities with creative input, value, and exchangeability, characterized by encryption, uniqueness, and traceability.” This definition indicates that:
- Digital assets are minted by issuers on blockchains via publishing platforms and delivered between storage accounts based on blockchain technology.
- The primary functional orientations, such as brand marketing and commemoration, highlight that digital assets are intended for utility rather than investment.
This approach helps prevent misconduct—such as market manipulation through misinformation—during circulation, trading, or brand promotion, thereby maintaining market stability. Currently, most digital assets are brand-oriented, allowing issuers to enhance their influence. Through digital asset circulation, companies can not only increase visibility but also attract potential customer groups by attaching specific rights to purchases, ultimately boosting the development of their real-world industrial operations.
Prioritizing Risk Control and Security in Transactions
Risk prevention is a fundamental principle embedded throughout the Specification, reflected not only in the definition of digital assets as commodities but also in the design of specific trading rules. The management framework imposes distinct risk control requirements on various participants:
Risk Prevention:
- The Shanghai Data Exchange is obligated to inform users of trading risks during the account opening and permission granting process and must establish a margin system to mitigate trading risks.
- Issuers and data merchants are required to ensure that all disclosed digital asset information is truthful, accurate, complete, and timely.
- Traders must undergo a suitability assessment to confirm their risk-bearing capacity.
- Data merchants, including issuing platforms and blockchain service providers, must guarantee technically reliable transactions.
Risk Response:
- The Shanghai Data Exchange may suspend or terminate transactions involving entities that pose risks.
- Issuers are required to arrange for proper custodianship or other effective measures throughout the trading and life cycle of the digital asset to protect participants’ legitimate rights and interests.
Furthermore, the continuous improvement of digital infrastructure in recent years forms the foundation of risk management. Blockchain technology, as one of the underlying technologies of the metaverse, is crucial for enabling trusted transactions. It supports the issuance and market trading of digital assets, helping to unlock their potential in the real economy.
Technologies like blockchain enable the objective statistical tracking of digital assets and the recording and querying of their full life cycle activities. A robust technological foundation not only facilitates trusted transactions but also supports decentralized identity authentication, protecting privacy while ensuring secure transactions. Additionally, the digital yuan—China’s legal digital currency—can be used as a payment method in on-chain contracts, simplifying processes and reducing transaction costs.
The regulatory function of this technological infrastructure imposes strict constraints on the transfer and trading of digital assets, fundamentally helping to avert market risks and maintain order.
In summary, the Specification emphasizes transaction stability, incorporating both front-end risk prevention and back-end risk response. Through systematic institutional innovation, it promotes the secure circulation and trading of digital assets, ultimately enabling value creation, brand building, and marketing empowerment.
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Frequently Asked Questions
What is the main goal of the Shanghai Data Exchange’s new Specification?
The primary goal is to provide a regulated, self-regulatory framework for digital asset trading. It aims to standardize market participant behavior, ensure secure transactions, and integrate digital assets with the real economy while minimizing financial risks.
How does the Specification define digital assets?
It defines digital assets as encrypted, unique, and traceable digital commodities possessing creative input, value, and exchangeability. They are intended mainly for brand marketing and commemorative purposes—not as investment instruments.
Who can currently participate in trading on the Shanghai Data Exchange?
During the trial phase, participation is by invitation only. The exchange selects high-quality digital assets and invites issuers, data merchants, and traders to ensure market integrity and controlled growth.
What are the key risks the Specification seeks to mitigate?
It focuses on preventing market manipulation, ensuring information transparency, verifying participant suitability, and technical security. The framework includes measures like mandatory disclosures, risk assessments, and transaction safeguards.
How does blockchain technology support this trading framework?
Blockchain enables tamper-proof recording, traceability, and decentralized authentication. It helps create a trusted environment for issuing, transferring, and tracking digital assets throughout their life cycle.
Can digital assets be used for investment or speculation under these rules?
No. The framework strictly emphasizes the utility and commodity nature of digital assets, discouraging financialization or speculative use. Its goal is value-creation in the real economy, not investment-driven trading.