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Bank of China

GSIB

Bank of China is the most internationally oriented of the four largest Chinese state-owned commercial banks, with a meaningfully larger overseas franchise than ICBC, China Construction Bank, or Agricultural Bank of China. The Hong Kong-listed subsidiary Bank of China (Hong Kong) Limited (BOC HK) is the territory's note-issuing bank alongside HSBC and Standard Chartered Bank (Hong Kong), and it has been the most operationally engaged of the mainland-affiliated banks on Hong Kong tokenisation activity, with HKD note-issuance authority that gives the franchise a structurally distinctive position on any HKD-denominated tokenised-cash work. For an APAC tokenisation operator, Bank of China is the mainland Chinese GSIB whose Hong Kong franchise sits closest to the centre of the local tokenisation ecosystem, with cross-border RMB tokenisation work as the second structural angle.

Tokenisation positioning

Bank of China's tokenisation posture is shaped by the same mainland-Hong Kong asymmetry that constrains ICBC and China Construction Bank, but with a structurally distinctive position on the Hong Kong side through BOC HK's note-issuing-bank status. The mainland parent operates inside the closed e-CNY perimeter and the conventional banking and capital-markets licences, while BOC HK operates inside the Hong Kong tokenisation ecosystem with the structurally distinctive HKD note-issuance authority that places the bank inside the wholesale HKD plumbing.

The HKD note-issuance authority matters operationally for tokenisation. The three Hong Kong note-issuing banks (HSBC, Standard Chartered Bank (Hong Kong), and BOC HK) issue physical HKD banknotes against US dollar reserves held with the HKMA under the linked exchange rate system. Any HKD-denominated tokenised-cash programme that requires note-issuing-bank involvement would naturally engage BOC HK as one of three available counterparties. The bank's role inside the HKMA Project Ensemble sandbox and any HKD-denominated tokenised-deposit pilot work runs through that structural footprint.

The cross-border RMB tokenisation angle is the second consequential piece. Bank of China has long been the principal Chinese commercial bank on offshore RMB clearing and settlement work, and the firm's positioning on cross-border RMB tokenisation activity sits inside that broader offshore RMB infrastructure footprint. The firm has been adjacent to the mBridge cross-border CBDC pilot programme alongside ICBC and other Chinese commercial banks before mBridge graduated from the BIS Innovation Hub in mid-2024.

Named products and pilots

  • e-CNY operating-bank participation. Bank of China is one of the principal commercial-bank operators in the People's Bank of China e-CNY two-tier issuance model alongside ICBC, China Construction Bank, Agricultural Bank of China, and selected other large Chinese commercial banks.
  • HKD note-issuance and HKMA Project Ensemble adjacency. BOC HK's note-issuing-bank status places the firm inside the HKD wholesale plumbing, with the HKMA Project Ensemble sandbox as the relevant tokenisation pilot channel. Named participation status on specific Project Ensemble cohorts is not consistently surfaced in current raw entries.
  • HKMA tokenised bond programme syndicate participation. BOC HK has been a syndicate member on selected tranches of the HKSAR multi-currency green bond and digital-bond programme, with a particular concentration on the offshore RMB tenors that the firm's broader offshore RMB infrastructure footprint supports.
  • Cross-border RMB tokenisation. Bank of China has been adjacent to the broader cross-border RMB tokenisation discussion through the firm's offshore RMB infrastructure footprint, although named participation in any specific RMB tokenisation pilot outside the mBridge legacy is not consistently surfaced in current raw entries.
  • Project mBridge legacy participation. Bank of China was a named commercial-bank counterparty in the mBridge cross-border CBDC pilot programme before mBridge graduated from the BIS Innovation Hub in mid-2024. Post-graduation governance status is not consolidated in current raw entries.
  • Hong Kong tokenised authorised funds adjacency. BOC HK has been adjacent to the Hong Kong tokenised authorised funds distribution network, with the firm's wealth and corporate banking franchises as the natural distribution footprint.

Institutional partnerships

The Hong Kong note-issuing-bank cohort with HSBC and Standard Chartered Bank (Hong Kong) is the most operationally consequential cross-bank relationship in Hong Kong tokenisation context. The three banks share the HKD note-issuance authority and the related wholesale HKD plumbing role, and any HKMA-led tokenisation programme that involves note-issuing-bank participation engages all three as counterparties.

In the broader mainland-affiliated commercial-bank cohort in Hong Kong, BOC HK operates alongside ICBC (Asia), China Construction Bank Asia, Bank of Communications HK, China Merchants Bank HK, and selected other mainland-affiliated banking franchises. BOC HK's positioning has been the most operationally aggressive of the mainland-affiliated cohort on Hong Kong tokenisation activity, consistent with the firm's broader leadership position in the offshore RMB infrastructure footprint.

The cross-border RMB infrastructure relationships are the second consequential piece. Bank of China has long been a principal Chinese commercial bank on offshore RMB clearing and settlement work, including roles on the People's Bank of China RMB clearing bank arrangements in major offshore centres (Hong Kong, Singapore, London, Frankfurt, Tokyo, Seoul, others). The cross-platform tokenisation partnership map across these offshore centres is not consolidated in current raw entries.

Regulatory perimeter

Bank of China operates under People's Bank of China supervision for monetary and payment-system policy, and under the National Financial Regulatory Administration (NFRA) for prudential supervision. Securities and investment-banking activity sits under CSRC supervision through BOC International (the firm's investment-banking subsidiary). BOC HK operates under HKMA supervision for banking activity, including the note-issuing-bank role under the HKMA-administered linked exchange rate system, and SFC HK supervision for securities and asset-management activity.

For tokenisation activity, the relevant mainland frameworks are the e-CNY operational framework, the conventional banking and capital-markets licences, and the structural prohibition on virtual-asset trading and security-token issuance in mainland China. The Hong Kong subsidiary's tokenisation activity sits under the HK Stablecoins Ordinance perimeter for any stablecoin-adjacent activity, the SFC framework for tokenised authorised funds and tokenised investment products, the HKMA-supervised perimeter for tokenised deposits and other bank-money tokenisation work, and the Project Ensemble sandbox for any wholesale CBDC and tokenisation pilot work.

For prudential capital treatment, the Basel SCO60 standard applies through the local supervisors. The GHOS-endorsed March 2026 targeted review (see Basel Committee) is the relevant ongoing process.

Recent activity

  • Bank of China has continued to operate as one of the principal commercial-bank operators in the e-CNY two-tier issuance model through 2024 and 2025. Specific volumes are not consolidated in current raw entries.
  • BOC HK has continued to participate as a syndicate member on the HKMA tokenised bond programme, particularly on offshore RMB tenors. Deal-by-deal participation is not consolidated in current raw entries.
  • BOC HK's note-issuing-bank role has continued under the HKMA-administered linked exchange rate system through 2024 and 2025.
  • mBridge graduated from the BIS Innovation Hub in mid-2024. Bank of China's post-graduation participation status is not consolidated in current raw entries.

Open questions

  • BOC HK's specific role on HKMA Project Ensemble cohorts: tokenised-deposit lane, tokenised-asset lane, or both.
  • The deal-by-deal participation map for BOC HK on the HKMA tokenised bond programme, with a particular focus on offshore RMB tenors.
  • Whether Bank of China is positioning for any role in the offshore RMB stablecoin design conversation under the HK Stablecoins Ordinance perimeter, including the firm's note-issuing-bank role.
  • Bank of China's participation status in mBridge under post-graduation governance, and named cross-border tokenisation pilot work through the offshore RMB infrastructure footprint.
  • The cross-platform tokenisation activity at Bank of China's other offshore RMB clearing centres (Singapore, London, Frankfurt, Tokyo, Seoul, others).
  • The relationship between mainland e-CNY operations and the Hong Kong subsidiary's tokenisation activity.

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