Tokenisation — Where Other Jurisdictions Stand

Jurisdiction

Where they are

United States

The Clarity Act failed Senate cloture in mid-September 2026, so there is still no durable federal statute for crypto trading venues. The SEC has used temporary tools instead: a September 2026 Innovation Exemption lets certain permissioned venues trade tokenised listed stock for five years, and proposed transfer-agent rules would recognise blockchain-based shareholder records if finalised.

Tokenised securities can already be done under ordinary securities law plus these agency measures, but permanent legislation and true native company-share registers remain unfinished. Rough position: mid.

United Kingdom

The UK is among the furthest along on wholesale infrastructure. The FCA and Bank of England run a live Digital Securities Sandbox for issuing, trading and settling real tokenised securities, with a stated path toward permanent authorisation.

Equities are in scope, but company-law ownership still turns on the statutory register, not a wallet alone. The sandbox is time-limited into late 2028 / early 2029. Rough position: advanced on infrastructure; native share registers still partial.

European Union

Non-security crypto sits under MiCA. Tokenised financial instruments sit under MiFID II and the DLT Pilot Regime, which already authorises several DLT market infrastructures (including shares, with size caps). A March 2026 Commission proposal (“EU Inc.”) would allow DLT company-share registers if enacted — still a proposal, not law.

Europe is strong on pilot infrastructure; MiCA does not govern securities. Permanence of the Pilot and native share-register reform are still political. Rough position: advanced on infra; mid on native company shares.

Japan

Japan has a clear FIEA box for Electronically Recorded Transferable Rights and a live secondary venue (Osaka Digital Exchange START) since late 2023. Public offerings of asset-backed and fund-interest tokens are underway.

The market is still dominated by trust and fund structures. Direct company-share tokens must align with shareholder-register rules, so true native listed equity remains constrained. Rough position: mid–advanced.

China

Onshore crypto activity remains illegal. A February 2026 multi-regulator notice opened a regulated offshore path for tokenising Chinese assets (including ABS-style structures), while the e-CNY stays the state digital-money track.

Domestic RWA tokenisation on public chains is banned except via designated infrastructure. Implementing detail is thin; domestic company shares on public chains are not on the table. Rough position: early.

Singapore

Singapore is technology-neutral: tokenised capital-markets products generally follow the same SFA rules as paper or book-entry instruments, backed by MAS guidance and Project Guardian. Institutional tokenised securities, funds and bonds are live.

Company-share ownership still depends on the Companies Act register, not the token alone. Public equity tokenisation is less commercialised than fixed income and funds. Rough position: advanced.

Canada

Canada has no dedicated tokenisation statute. The CSA launched Project Tokenization in March 2026, and early tokenised-bond tests (Project Samara) have regulatory approval. Tokenised securities generally fit existing rules with case-by-case relief.

Live tests centre on bonds and settlement tokens, not routine on-chain company shares. Still exploration and pilot mode relative to the UK, EU and Singapore. Rough position: early–mid.

Korea (context)

Statute is largely written. Electronic Registration Act amendments for security tokens take effect on 4 February 2027, with an FSC three-phase roadmap from September 2026. Phase 1 points to institutional products, unlisted shares via trust, and public fractional products.

Live conventional-security tokenisation is not yet open. Native company shares remain a longer horizon. Detail is in Parts 1–3. Rough position: mid — law ahead of market go-live.