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<h2 id="73c8f4aa-a5a5-4cfa-bd3d-447c3f1a6371" data-indent="0" data-toc-id="73c8f4aa-a5a5-4cfa-bd3d-447c3f1a6371">Introduction to Tokenised Deposits</h2>
<h3 data-indent="0">Tokenised deposits are reshaping institutional banking.</h3>
<h4 data-indent="0">In this article, we cover how regulated, blockchain-based deposits enable instant settlement, compliance automation, and a new foundation for the future of digital finance.</h4>
The global financial system is moving toward a new digital foundation. Traditional bank deposits, long confined within proprietary systems, are being redefined through tokenisation, where each deposit becomes a digital token recorded on distributed ledger technology (DLT).
A tokenised deposit represents a claim on fiat money held at a regulated bank, but exists in programmable digital form. It maintains the same legal and regulatory status as conventional deposits while introducing features such as instant settlement, automation, and improved interoperability.
For financial institutions, tokenised deposits signal a transition from siloed legacy infrastructure to modern, connected financial architecture, one where regulated money operates natively in digital environments.
&nbsp;
<h3 id="97fbde64-1025-4da4-8f58-e1bb9c27c281" data-indent="0" data-toc-id="97fbde64-1025-4da4-8f58-e1bb9c27c281">Value Proposition of Tokenised Deposits</h3>
Tokenised deposits offer banks and financial institutions the ability to innovate without stepping outside the boundaries of trust and regulation. They preserve the stability of traditional deposits while unlocking new efficiencies through programmable money and distributed settlement.
Institutions can use tokenised deposits to streamline treasury operations, enable real-time cross-border payments, automate compliance processes, and participate in emerging digital financial ecosystems, without relying on unregulated stablecoins or third-party platforms. At a strategic level, understanding tokenised deposits allows organisations to stay aligned with the future direction of banking and payment infrastructure. It bridges the gap between today&rsquo;s regulated systems and tomorrow&rsquo;s interoperable financial markets.
&nbsp;
<h3 id="1247e5cc-fbdd-412c-bf81-d119d919cce3" data-indent="0" data-toc-id="1247e5cc-fbdd-412c-bf81-d119d919cce3">Benefits of Understanding Tokenised Deposits for Organisations</h3>
Understanding tokenised deposits is not just about keeping pace with innovation, it&rsquo;s about shaping how your institution participates in the next generation of financial infrastructure.
<ol>
<li data-indent="0">
Informed Integration and Risk Control
Institutions that understand the technical and regulatory design of tokenised deposits can integrate them responsibly. Education enables risk-based decision-making, ensuring operational readiness and compliance alignment before adoption.
</li>
<li data-indent="0">
Strategic Positioning for the Future of Banking
As financial markets evolve toward tokenised money and on-chain settlement, early understanding allows organisations to anticipate regulatory shifts, collaborate with central banks, and influence emerging industry standards.
</li>
<li data-indent="0">
Competitive and Operational Efficiency
Teams who grasp how tokenised deposits function can identify process inefficiencies ripe for automation. From real-time reconciliation to liquidity optimisation, this knowledge turns innovation into measurable outcomes.
</li>
<li data-indent="0">
Enhanced Governance and Compliance Awareness
Understanding tokenised deposits improves communication between technology, compliance, and executive teams. A shared understanding reduces implementation friction and improves governance over digital asset initiatives.
</li>
</ol>
&nbsp;
<h3 id="76fffe38-eef1-49f0-af69-5f4659b696aa" data-indent="0" data-toc-id="76fffe38-eef1-49f0-af69-5f4659b696aa">Risks and Cautions of Not Understanding Tokenised Deposits</h3>
Adopting or evaluating tokenised financial technologies without sufficient understanding carries significant risk.
<ol>
<li data-indent="0">
Misguided Implementation
Without clear comprehension, organisations risk treating tokenised deposits like other digital assets or stablecoins, potentially introducing governance gaps, compliance breaches, or accounting inconsistencies.
</li>
<li data-indent="0">
Strategic Blind Spots
A lack of understanding limits an institution&rsquo;s ability to identify emerging opportunities in programmable finance, interoperability, and digital settlement systems. This can lead to lost competitive ground.
</li>
<li data-indent="0">
Reputational and Regulatory Exposure
Institutions that pursue tokenisation initiatives without deep knowledge may struggle with regulatory expectations or public trust. Poorly designed or misunderstood pilots can damage brand credibility and stakeholder confidence.
</li>
<li data-indent="0">
Fragmented Internal Knowledge
</li>
</ol>
When teams lack education on tokenised deposit frameworks, internal divisions emerge between business, technology, and compliance units, slowing transformation and increasing project failure risk.
&nbsp;
<h3 id="894788d3-a938-4222-a83b-84c4a6a1a965" data-indent="0" data-toc-id="894788d3-a938-4222-a83b-84c4a6a1a965">Learn more about Tokenised Deposits with uCubed</h3>
Tokenised deposits are redefining how money moves, settles, and operates in regulated finance. For organisations, the question is not whether this transformation will happen, but whether teams will understand it in time to benefit from it.
uCubed delivers tailored institutional training and strategy programs designed to help banks, financial institutions, and corporate teams understand blockchain-based financial infrastructure with clarity and confidence.
uCubed publishes educational posts to help organisations to become aware of Blockchain, Digital Assets, Tokenisation and Web3 technologies that may be applicable to their team. To be notified of new publications, subscribe to our newsletter. Or, to dive deeper into concepts like Tokenised Deposits and explore opportunities with your team through bespoke training, <a href="https://ucubed.au/contact">reach out</a> to us to have a free, no-obligation consult.

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The impact of Tokenised Deposits on Banking

<h2 dir="ltr">New regulatory framework progress from the Australian Securities &amp; Investments Commission (ASIC)</h2>
&nbsp;
In what can be called an ambitious move, on October 29, 2025, the Australian Securities and Investments Commission (ASIC) released a comprehensive regulatory framework, dealing with some classes of digital assets. Among the addresses are stablecoins, wrapped tokens, tokenised securities, and digital wallets. Together with the INFO 225, ASIC also brought a no-action letter.
&nbsp;
Though what is the primary aim of the release? According to the document, INFO 225 focuses on "businesses and people offering products and services in relation to digital assets generally". This is more important if your business is involved with digital assets, whether there are elements that are decentralised or not (e.g. exchanges, intermediaries, digital asset wallet providers, operators of decentralised finance platforms, asset managers and custodians.
&nbsp;
This release aims to help everyone understand their obligations under the Corporations Act 2001 and the ASIC Act 2001.&nbsp;The importance of this release also extends to individuals who are "considering, issuing or selling digital assets, dealing or advising on digital assets (whether to raise funds or otherwise), or offering other products or services related to digital assets". Let's&nbsp;take a deeper look at some of the big entrants of this new INFO 225 regime.&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">ASIC Updated Guidance (INFO 225)</h2>
&nbsp;
Among the most recent introductions is the Updated Information Sheet 225 (INFO 225). The information sheet is majorly ASIC&rsquo;s primary interpretative guidance for the financial services regime. First produced in 2017, since then, the INFO guidance has been updated&nbsp; in 2018, 2019, and 2021.
&nbsp;
<h3 dir="ltr">What are the latest updates in this guidance?&nbsp;</h3>
&nbsp;
A <a href="https://www.asic.gov.au/about-asic/news-centre/find-a-media-release/2025-releases/25-250mr-updated-asic-guidance-supports-digital-asset-innovation-and-boosts-investor-protection/">media release</a> statement accompanying INFO 225 notes that under the existing law: &ldquo;Stablecoins, wrapped tokens, tokenised securities and digital asset wallets are among the digital asset products that ASIC considers to be financial products&rdquo;.&nbsp;In the statement, you will also find some 18 worked examples displaying the applications of ASIC&rsquo;s financial product definition to the different use cases of digital assets. However, the document noted that this was not an exhaustive list, stating: "The 18 hypothetical worked examples in Part A of this information sheet are not exhaustive. They are designed to help you think about these issues, but each product needs to be assessed on its own facts and circumstances."
&nbsp;
ASIC&rsquo;s latest updates advise entities to separately analyse individual tokens and see if they qualify as financial products. Look into the rights and benefits attached, including the uses of the product. According to the document:&nbsp; "This analysis is critical to determining whether the digital asset, and/or arrangement related to the digital asset, is a financial product".&nbsp;
&nbsp;
The production of this document aligns with the Digital Assets and Payment reforms proposed by the Australian Government. However, since the Australian Government is already in consultations "on an exposure draft for amendments to introduce digital asset platforms and tokenised custody platforms as new financial products" newer updates could come sooner than later.&nbsp;
&nbsp;
&nbsp;
<h3 dir="ltr">What are the practical implications of the new INFO 225 updates?</h3>
&nbsp;
If a product falls under the definition of a financial product, its issuance requires licensing and approval from regulators. By encouraging issuers to understand regulatory status before providing tokens, these updates promote compliance. Although there has been a wave of regulatory ambiguity in various jurisdictions. These new ASIC updates provide more clarity, eventually encouraging institutional participation.&nbsp;
&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">Class No-Action Letter Details</h2>
&nbsp;
In its INFO 225 update, ASIC also issued a class<a href="https://download.asic.gov.au/media/3q3jwena/asic-class-no-action-letter-for-digital-asset-businesses-published-29-october-2025.pdf"> no-action letter</a> to balance innovation and the protection of investors. A no-action letter is a policy where a regulator outrightly says they will not take action against a certain conduct for a given duration. As per ASIC INFO 225: &ldquo;This is a letter in which we state to a particular person that we do not intend to take regulatory action over a particular state of affairs or particular conduct&rdquo;.&nbsp;However, this does not mean that laws are changing. And, it will not protect the organisation from other third-party suits. This policy took effect from October 29, 2025, and will operate until June 30, 2026.
&nbsp;
&nbsp;
<h3 dir="ltr">Why the need for No-Action?&nbsp;</h3>
&nbsp;
The primary aim of the No-Action letter is to provide industry participants with a transitional period to adhere to the changes in direction. But this does not give companies a pass. And, as per the letter, "It is not a guarantee that we will not take action in the future, nor is it intended to affect the rights of third parties to take action in relation to any contravention. It is not legal advice and may be withdrawn at any time".
&nbsp;
<h3 dir="ltr">Scope and eligibility</h3>
&nbsp;
As per reports, the No-Action letters will target:
<ul>
<li dir="ltr" aria-level="1">
Firms that provide financial services (AFS)
</li>
<li dir="ltr" aria-level="1">
Firms operating in financial markets
</li>
<li dir="ltr" aria-level="1">
Firms operating clearing/settlement facilities associated with digital assets are categorised as financial products.
</li>
</ul>
Crypto lending/earn products, non-cash payment facilities (except stablecoins) are not within the scope of the no-action letter. Moreover, the target group must have begun its activities on or before December 31, 2025, if the relief is to apply. And, the firms must take actions to apply for the AFSL, or other variations, by June 30, 2026.&nbsp;For those applying for a market licence, and even clearing and settlement facilities, you must make a formal notification to ASIC by June 30, 2026, and take action within 12 months.&nbsp;
&nbsp;
<h3 dir="ltr">Conditions for No-Action</h3>
&nbsp;
For firms providing services to retail clients, they must be members of the Australian Financial Complaints Authority (AFCA) before applying. And, they should remain members of the same for at least 12 months after ending their services. Foreign entities are also allowed to register in Australia as foreign companies. However, the condition is appointing a local agent. A non-Australian company must &ldquo;have been registered as a registered foreign company and have appointed a person as a local agent under section 601CF of the Act.&rdquo;
&nbsp;
&nbsp;
<h2 dir="ltr">RBA&rsquo;s Project Acacia Announcements</h2>
&nbsp;
<a href="https://www.rba.gov.au/media-releases/2025/mr-25-18.html">Project Acacia</a> is a collaborative research initiative between the Reserve Bank of Australia (RBA) and Digital Finance Cooperative Research Centre (DFCRC) to explore how tokenised asset infrastructure could support Australian wholesale markets. This project puts keen eyes on the &lsquo;WHOLESALE&rsquo; tokenised asset market, including different forms of digital money like stablecoins, bank-deposit tokens, and a pilot wholesale CBDC.&nbsp;As per Project Acacia consultation papers, there are five settlement models, including:
<ul>
<li dir="ltr" aria-level="1">
Exploring delivery-versus-payment (DvP)
</li>
<li dir="ltr" aria-level="1">
Atomic settlement
</li>
<li dir="ltr" aria-level="1">
Synchronisation of money and asset transfer
</li>
<li dir="ltr" aria-level="1">
Feeder systems
</li>
<li dir="ltr" aria-level="1">
Batch-flow alternatives
</li>
</ul>
Considering the settlement models, on July 10, 2025, RBA, together with DFCRC, announced that they had settled on "24 innovative use cases from a diverse range of organisations" These use cases include 19 pilot use cases and five proof-of-concept use cases with simulated transactions.&nbsp;According to the RBA, the tests of the use cases would take a 6-month duration beginning mid-2025, and the results will be produced in Q1 2026.&nbsp;
&nbsp;
While <a href="https://www.rba.gov.au/media-releases/2025/mr-25-18.html">commenting</a> on this, the Assistant Governor (Financial System) at the RBA, Brad Jones, said: "The use cases selected in this project will help us to understand better how innovations in central bank and private digital money, alongside payments infrastructure, might help to uplift the functioning of wholesale financial markets in Australia".
&nbsp;
In a mission to support the new innovative class, ASIC reduced the licensing burdens for participants in Project Acacia. Kate O&rsquo;Rourke, ASIC Commissioner, said: "ASIC sees useful applications for the technologies underlying digital assets in wholesale markets. The relief from regulatory requirements that we have announced today will allow these technologies to be sensibly tested &mdash; to explore opportunities and identify and tackle risks". An inter-regulator collaboration in Australia is clear testimony that tokenised assets are not a mere sideshow, but an entire evolution. With Project Acacia, Australia towers above many other jurisdictions as a leader in creating and testing the next generation of finance.&nbsp;&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">Final Thoughts</h2>
ASIC&rsquo;s latest developments, the INFO 225 update, and the no-action letter bring a dawn to a new digital asset regime in the country. The former represents clarity of the regulations, while the latter enables time for cooperation. It seems Australia aims to be among the pioneers of proper financial designs and testing, especially with the recent growth in tokenisation.
 ASIC&rsquo;s significance extends beyond Australian borders. It's a signal to global markets that tokenised assets and stablecoins are going into mainstream adoption. Businesses enjoy less regulatory friction, hence build without fear of enforcement disruptions. Individuals enjoy clarity in rules, which translates to safer platforms.&nbsp;The move will speed up capital inflows, strengthen institutional participation, and encourage proper testing across both the crypto industry and the broader financial sector.
&nbsp;
The transition means businesses and investors who come early and understand the implications of these developments will get ahead of this the new chapter. uCubed gives founders and investors a suitable environment for understanding new rules and navigating tokenised markets.&nbsp;

asic.webp

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ASIC No-Action Letter: Boosting Digital Asset Innovation 2025

In October 2025, while speaking at the Token2049 crypto conference in Singapore, Vlad Tenev, the CEO of Robinhood, made comments about tokenisation,&nbsp;<a href="https://www.cnbc.com/2025/10/02/tokenization-of-assets-is-freight-train-coming-to-markets-robinhood-ceo.html">saying</a>:&nbsp;
<blockquote>
"Tokenisation is like a freight train. It can't be stopped, and eventually it's going to eat the entire financial system."
</blockquote>
For many already in the train, the comments were positive, a signal of a dynamic shift in global finance. But, for a bigger lot, Tenev's words were a wake-up call.
&nbsp;
<h3 dir="ltr">The big question: what is tokenisation?&nbsp;</h3>
&nbsp;
Tokenisation is the creation of digital, blockchain-based tokens that represent assets in the real world. With tokenisation, anything can be sold or held on blockchain ledgers. Imagine holding equities, bonds, real estate, private credit, infrastructure, and even commodities as tokens on the ledger.
&nbsp;
The relevance of tokenisation lies in the perks it brings, including 24/7 markets, global asset accessibility, and efficiency.
&nbsp;
&nbsp;
<h2 dir="ltr">Robinhood Markets and Tokenisation</h2>
&nbsp;
True to Tenev's words, Robinhood is already leading the tokenisation journey. In June this year, news of Robinhood launching tokenised versions of over 200 U.S stocks for EU-based customers rocked the finance space. Some of the already listed tokenised stocks included those of Nvidia<a href="https://www.reuters.com/markets/companies/NVDA.O"> (NVDA.O)</a>, Apple <a href="https://www.reuters.com/markets/companies/AAPL.O">(AAPL.O)</a>, and Microsoft <a href="https://www.reuters.com/markets/companies/MSFT.O">(MSFT.O</a>).
&nbsp;
While Tenev believes tokenisation would allow markets to operate 24/7, the tokenised versions of the 200 stocks began trading 24 hours a day, for 5 days a week. But Robinhood's journey would not end with the 200 tokens. Speaking at an earlier event in France, Robinhood's top executives mentioned that the platform is already planning to offer tokens linked to stocks of some private companies, including Elon Musk's SpaceX and Sam Altman's OpenAI.
&nbsp;
While the offering of U.S. equities in the form of tokens is a service only for the E.U., others across the globe showed interest, as a way to gain exposure.
&nbsp;
&nbsp;
<h2 dir="ltr">Interview Highlights: Tenev's Key Messages at Token2049</h2>
&nbsp;
During his interview, Tenev made powerful comments on how tokenisation would be a central innovation in the finance space. Speaking about Robinhood's decision to offer tokenised U.S. stock in the EU, Tenev highlighted that they want to reach global markets. According to the Robinhood boss, the exchange aims to bring exposure to international markets through tokenisation. He said:
<blockquote>
"Tokenised stocks will become the default way for people outside the U.S. to get exposure to American equities."
</blockquote>
Tokenisation, according to Tenev, is the key to marrying the worlds of traditional finance and crypto. He stated:
<blockquote>
"Crypto and traditional finance have been living in separate worlds, but they'll fully merge. In the future, everything will be on-chain in some form, and the distinction will disappear."
</blockquote>
Although he firmly believes that tokenisation is the future, Tenev argues that it will take time for everyone to be comfortable with it. Major markets will introduce proper regulatory and infrastructural frameworks for tokenisation within the next five years, according to Tenev. But full adoption of this new model in all asset classes will happen within the next decade.
&nbsp;
&nbsp;
<h2 dir="ltr">Robinhood and the CEO's Vision</h2>
&nbsp;
Robinhood's vision was primarily to expand into an untapped market, where global investors can trade U.S.-based equity. And, according to many, Robinhood has a competitive advantage when compared to others. But why?
&nbsp;
The equities exchange enjoyed a massive user base, coming primarily from its days in TradFi. In 2024, Robinhood had 25.2 million funded accounts, with the preceding year reporting about 23.2 million users. The number of monthly active users as of 2023 stood at 10.6 million. The new Robinhood, a tokenisation-focused platform, inherits all these users.&nbsp;
&nbsp;
The CEO wants to see Robinhood create a new record in the Guinness Book of World Records for being the first to tokenise SpaceX and OpenAI equity. Their strategy? Tenev says it is to work closely with companies to make sure they see tangible benefits and welcome tokenisation. In the end, according to Tenev, Robinhood is definitely going to be a leader in private markets.
&nbsp;
&nbsp;
<h2 dir="ltr">The Challenges Ahead?</h2>
&nbsp;
<h3 dir="ltr">Private Companies Pushing Back?&nbsp;</h3>
&nbsp;
While Robinhood intends to tokenise private companies, Tenev argues that many are still uncomfortable with the idea. Case point is OpenAI. Following Robinhood's claims to tokenise OpenAI, the company released a public statement saying:
<blockquote>
"We did not partner with Robinhood, we're not involved in this, and do not endorse it. Any transfer of OpenAI equity requires our approval, we did not approve any transfer&hellip;&nbsp; please be careful."
</blockquote>
Robinhood's response was:
<blockquote>
"To cap off our recent crypto event, we announced a limited stock token giveaway on OpenAI and SpaceX to eligible European customers. These tokens give retail investors indirect exposure to private markets, opening up access, and are enabled by Robinhood's ownership stake in a special purpose vehicle."
</blockquote>
And the Robinhood CEO actually noted that the tokens are not "equity" but give exposure to private assets. It is clear, based on the OpenAI-Robinhood back and forth, that markets are still not entirely comfortable with the idea. But the wave is here.&nbsp;
&nbsp;
<h3 dir="ltr">Regulatory Clarity</h3>
&nbsp;
The lack of regulatory clarity in some regions, including the U.S., means tokenisation will be slower. According to U.S. regulators, any token representing securities will still fall under the securities laws. Hester Peirce of the US SEC actually&nbsp;<a href="https://www.reuters.com/sustainability/boards-policy-regulation/secs-crypto-mom-says-tokenized-securities-are-still-securities-2025-07-09/">emphasised</a> that "tokenised securities are still securities." However, the regulatory frameworks are still in their infancy.
&nbsp;
Earlier, Tom Farley, the ex-NYSE president and current head of crypto exchange Bullish, said something similar about the U.S. and its lagging pace in regulations.&nbsp;
&nbsp;
Despite the U.S. thriving as a financial powerhouse, jurisdictions that already have regulations will attract innovation. For instance, the Markets in Crypto-Assets (MiCA) is already operational in the E.U., setting the region ahead of others.
&nbsp;
&nbsp;
<h2 dir="ltr">How Will The Financial Market React</h2>
&nbsp;
The &ldquo;freight train&rdquo; analogy by Vlad Tenev is a clear expression of the dynamic reshaping of the global financial system. Early proof is already here with EU investors accessing tokenised stock of U.S equities. Amidst the regulatory gap, the train is already on the move based on the developments.&nbsp;
&nbsp;
The immediate market reaction after Tenev&rsquo;s freight train comment was nothing short of fascinating. For Robinhood, the initial response was a slight dip of about 2.8% on the announcement day, breaking a month-long rally. This was perhaps a show of investors' caution with regulatory and legal clarity around crypto.
&nbsp;
However, the long-term implications of the statement can't be matched. After launching 200 tokenised stocks, Robinhood&rsquo;s market <a href="https://www.cnbc.com/2025/10/02/tokenization-of-assets-is-freight-train-coming-to-markets-robinhood-ceo.html">price surged</a>, reaching a 179% year-to-date gain at one point. Other companies in the tokenisation field reported gains on news that tokenisation was going more mainstream.
&nbsp;
Analysts have been joining the conversation on asset tokenisation. For instance, Tiger Research, <a href="https://x.com/tiger_research/status/1949718240261034263">on X</a>, predicts that by 2030, the tokenisation world&rsquo;s market value will be $1.34 trillion, a 2680x growth. Tiger Research believes that by 2030, the tokenisation space will have reached at least 1% of global stock.&nbsp;
&nbsp;
With all this positivity, there is no better time for TradFi institutions to jump into the &ldquo;freight train&rdquo; than now. When the market is still young and the market value hasn't yet cracked a trillion, it's time for companies to learn about tokenisation. For investors and companies looking to know more about tokenisation, how it works, and what its future holds, <a href="https://ucubed.co/">uCubed</a> is a good place to find all the tools you need to start.&nbsp;

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Robinhood CEO Vlad Tenev calls tokenisation a “freight train” set to transform global equity and private markets.

Robinhood CEO Vlad Tenev Says Asset Tokenisation Is Inevitable

Tokenisation of assets is a freight train coming to markets, says Vlad Tenev, CEO of Robinhood Markets

On November 5, 2025, the&nbsp;<a href="https://www.bma.bm/">Bermuda Monetary Authority</a> (BMA) published a discussion paper on the growing relevance of tokenisation to various global institutions. The <a href="https://www.bma.bm/viewPDF/documents/2025-11-05-17-14-16-Discussion-Paper---Asset-Tokenisation-5-November-2025.pdf">Authority</a> notes in the paper:
"Asset tokenisation&hellip; is gaining significant attention globally from prominent international organisations&hellip; underscoring the need to understand the far-reaching implications of tokenisation, including its risks and opportunities."
In the documentation, the BMA goes on to highlight its intention to rewrite the rulebook in anticipation of the systemic shift brought by tokenisation. In fact, the Authority announced the start of a comprehensive consultation program to assess the need for new rules, updated definitions, and clearer supervisory expectations in the asset tokenisation space.
&nbsp;
&nbsp;
<h2 dir="ltr">Rewriting the Playbook for Tokenised Assets</h2>
&nbsp;
The Authority believes that the necessary foundations for a proper regulatory regime are already in place. In fact, the Authority wrote, citing the&nbsp;<a href="https://www.bma.bm/viewPDF/documents/2023-11-14-11-11-48-Digital-Asset-Business-Act-2018.pdf">Digital Asset Business Act (DABA) of 2018</a>, Bermuda's digital asset framework already provides the legal basis for tokenisation by classifying it as a regulated digital asset business activity."
Yet, the regulator notes that existing laws do not capture the actual rights and obligations when assessing the risks of on-chain assets. Every other cycle, the crypto space adds more functionality that exceeds the original vision of digital assets as payment tokens and crypto commodities.
For instance, the rise in tokenised bonds, fund shares, commodities, and even reinsurance contracts to global investors prompted the BMA to re-examine its existing policies and whether they need to be changed.&nbsp;
The regulator also speaks of a dual licensing conundrum, in which tokenised assets may fall under both digital-asset and investment legislation. The Authority noted that:&nbsp;
"Tokenised investments will inherently qualify as 'digital assets' under [DABA]&hellip; However, depending on their specific features, they may also simultaneously qualify as 'investments' under the Investment Business Act."
Overlapping regulations could create unnecessary complexity and even duplication. And as such, the BMA is seeking to determine whether to:&nbsp;
<ul>
<li dir="ltr" aria-level="1">
Introduce specialised and simplified licensing for tokenised structure
</li>
<li dir="ltr" aria-level="1">
Expand and redefine investment categories
</li>
<li dir="ltr" aria-level="1">
Create more direct parameters for providers of tokenisation services
</li>
<li dir="ltr" aria-level="1">
Guide on the distinction and treatment of digital twins and on-chain assets.
</li>
</ul>
Yet, even as the framework continues to evolve, the BMA intends to "focus on the substance rather than the form of tokenised investments." This inherently means that the digital assets that come as tokens will be treated as financial instruments, regardless of whether they use blockchain or traditional registries.
&nbsp;
&nbsp;
<h2 dir="ltr">On-Chain and Off-Chain Finance</h2>
&nbsp;
The paper highlighted the need to distinguish between on-chain and off-chain finance for regulatory purposes. Since both assets, Digital twins and native tokens, have unique challenges, it is necessary to treat each of them separately.&nbsp;
"While tokenisation arguably exists along a spectrum with varying degrees of DLT integration, for the purpose of this DP, we will distinguish between two primary modes: off-chain (or digital twins) and on-chain (or native tokens)," the paper notes.
As per the paper, Digital twins are assets representing legal rights to real-world assets. While assets are traded on chain, they exist off-chain. Among assets falling into this category are financial instruments, real estate, funds, metals, and environmental credits. But oracles are needed if these assets are to be traded on-chain with accuracy.
BMA's paper actually notes that the "existing digital asset framework is sufficiently broad to encompass tokenisation activities." The paper further explains that native on-chain tokens live entirely on the blockchain, with their entire life cycle being on-chain.&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">The Re/Insurance Opportunity: A $2 Trillion Market Meets Blockchain</h2>
&nbsp;
One of the largest markets in Bermuda, poised for a significant shift with tokenisation, is reinsurance. According to reports, the global reinsurance sector, now valued at $784 billion, is likely to reach $2 trillion over the next decade. Tokenisation brings the much-needed speed, precision, and liquidity, which are assets in the reinsurance space.
In 2025, Bermuda remains the global re-insurance hub with over 1200 registered insurers. Based on another report, "Member companies of the Association of Bermuda Insurers and Reinsurers (ABIR) reported a 10% year-over-year increase in premium written for 2024, along with an 8.5% rise in total equity."
The BMA discussion paper noted that Bermuda currently already recognises "innovative Insurer" Classifications that accommodate blockchain assets. The BMA believes insurance-linked securities should be given priority in modernising tokenisation.&nbsp;
The statement reads:
"Bermuda's established regulatory frameworks for innovative insurers (Classes IIGB, IILT, along with Sandbox classes IGB and ILT) and digital assets (DABA), combined with the Segregated Accounts Companies Act 2000 and Incorporated Segregated Accounts Companies Act 2019, have created a proven foundation for insurance tokenisation, with existing licensees successfully demonstrating and operationalising DLT-based insurance products supervised under bespoke prudential capital requirements."
The convergence between Bermuda's ILS sector and tokenisation opens more opportunities to enhance liquidity, reduce transaction costs, and expand access to insurance risks.
&nbsp;
&nbsp;
<h2 dir="ltr">Risks, Cybersecurity, and the Path to Regulatory Clarity</h2>
&nbsp;
Even while widely praising tokenised finance, the BMA also highlights the risks of this space. While proper tokenisation reduces operational friction and enhances transparency, it carries technological risks. Cyber threats like smart contract vulnerabilities and even oracle manipulation, to name a few.
The paper said tokenisation can "enable potential integration of features such as whitelisting, Know-Your-Client (KYC) gating and transfer controls directly into token architecture." Yet all mechanisms must still adhere to Financial Action Task Force standards.
Another issue with tokenisation is volatility amplification. Since assets are now available in markets 24/7, the volatility exposure increases.&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">What Experts Say</h2>
&nbsp;
The BMA, while talking of the relevance of the discussion paper, said:
"Tokenisation can embed regulatory requirements directly into smart contracts, offering 'programmable compliance' that may enforce transfer restrictions, investor qualifications, reporting obligations, and disclosures."
Other experts also agree that Bermuda's new approach to tokenisation is a positive signal. When responding to a question about Bermuda's first tokenised bond, Steve Rees Davies, a partner at a legal service provider Carey Olsen, Bermuda, noted:&nbsp;
<a href="https://www.careyolsen.com/insights/articles/bermudas-blockchain-edge-redefining-global-digital-asset-regulation">"It shows Bermuda's readiness for serious capital markets innovation.</a> The issuance demonstrates how structured, governed digital debt can thrive under Bermuda law, paving the way for yield-generating stablecoins and hybrid digital securities backed by traditional assets."
JFSA Analysis on Bermuda Paradigm:
"<a href="https://www.mfsa.mt/wp-content/uploads/2025/08/JFSA-Volume-1-A-Regulatory-Blueprint-for-Tokenization-The-Bermuda-Paradigm-2025.pdf">Bermuda's digital asset legal and regulatory framework</a>... successfully marries the principles-based and rules-based approaches... a fit-for-purpose regulatory blueprint, as pertains to asset tokenisation." Experts note its hybrid model balances flexibility with proportionality via tiered licensing.
&nbsp;
&nbsp;
<h2 dir="ltr">Bermuda: Global Regulatory Leader of Tokenised Assets?</h2>
&nbsp;
Tokenisation is going fast mainstream, with trillions of dollars' worth of assets potentially moving to digital ledgers in the near future. Bermuda's Monetary Authority sees the potential of tokenised assets and is already taking steps towards friendly regulation. Its discussion paper is not just a request for feedback; it marks a new phase in the modernisation of regulations.
For investors, Bermuda's move is a signal of regulatory and institutional clarity to come. Clearer regulations mean better investment channels and greater security on the way. Regulatory evolution adds a layer of confidence for investors.&nbsp;
Businesses will also benefit. Clarity in regulations allows them to gain exposure to tokenised assets without fear of regulatory scrutiny. This exposes enterprises to a whole new class of opportunities in tokenised assets. <a href="https://ucubed.au/">uCubed</a> aims to help businesses and organisations navigate these tough and fast-evolving markets. They offer education, insights, research, and a technological foundation to stay ahead in this market.

tokenisation-is-going-mainstream-bermudas-regulator-looks-to-rewrite-the-rulebook-for-on-chain-assets.webp

Bermuda’s regulator launches consultation to modernise tokenisation rules for on-chain and digital twin assets.

Bermuda Moves to Modernise Tokenisation Rules for On-Chain Assets

Tokenisation Is Going Mainstream: Bermuda's Regulator Looks to Rewrite the Rulebook for On-Chain Assets

Dinari, a tokenised equity provider, announced a collaboration in early November with Chainlink in a bid to bring a blockchain-focused equities index on-chain. The two, together with S&amp;P Dow Jones Index, aim to create a tokenised index that tracks crypto-oriented companies and cryptocurrencies in one benchmark.
&nbsp;
The announcement of this collaboration between <a href="https://dinari.com/business">Dinari</a>, <a href="https://chain.link/">Chainlink</a>, and <a href="https://www.spglobal.com/spdji/en/">S&amp;P Dow Jones Index</a> gave way to a new financial product, the S&amp;P Digital Markets 50 index. According to <a href="https://decrypt.co/347442/sp-digital-markets-50-index-gain-blockchain-verifiability-chainlink">reports</a>, it is expected to go live on the chain by the end of the year. Combining traditional equities with digital assets.
&nbsp;
As per the announcement, the main parties in this collaboration play a significant role in the product release. For instance, S&amp;P Dow Jones Indices will offer the methodology and composition of the new product.
&nbsp;
Dinari will play the role of tokenizing the Index using its dShares infrastructure. Chainlink balances everything through its <a href="https://chain.link/education/blockchain-oracles">oracles</a> by offering real-time pricing data and verifiable updates. This will be the first time&nbsp; S&amp;P brings real-time pricing using a decentralised oracle network.&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">Chainlink's Role in Price Feeds: Verifiability</h2>
&nbsp;
As already mentioned, Chainlink will handle the&nbsp;<a href="https://blockchaineventsgroup.com/2025/11/sp-digital-markets-50-index-will-gain-blockchain-verifiability-via-chainlink/">technical side</a> of the collaboration, mainly because of its oracle network. In this new Index, Chainlink's responsibility includes:&nbsp;
<ul>
<li dir="ltr" aria-level="1">
Real-time pricing data
</li>
<li dir="ltr" aria-level="1">
Performance updates
</li>
<li dir="ltr" aria-level="1">
Cross-asset market data for both traditional and digital sectors
</li>
<li dir="ltr" aria-level="1">
Verifiable on-chain attestations enabling users to confirm every update independently
</li>
</ul>
This collaboration is a benchmark with no delays, misrepresentations, and manipulations. With Chainlink&rsquo;s presence, the initial darkness of traditional finance is turned into full transparency. Investors and institutions will rely on a transparent data layer that circulates seamlessly into Web3 platforms.
&nbsp;
When speaking about Chainlink's role in the collaboration, the Chief Product &amp; Operations Officer at S&amp;P Dow Jones Indices, Cameron Drinkwater.
<blockquote>
<a href="https://www.globenewswire.com/news-release/2025/11/05/3181567/0/en/Dinari-Announces-Collaboration-With-Chainlink-To-Bring-Real-Time-Verifiability-to-the-S-P-Digital-Markets-50-Index.html">"The integration of Chainlink's decentralised oracle network provides a crucial intermediary for the soon-to-be-launched S&amp;P Digital Markets 50 Index.</a> This collaboration ensures data integrity and connectivity that will bring the S&amp;P Digital Markets 50 Index to market in a transparent, reliable, and efficient manner."
</blockquote>
Fernando Vazquez from Chainlink also added more info on the role of the decentralised oracle provider:&nbsp;
<blockquote>
"Chainlink is enabling one of the first indexes to operate on-chain with verifiable, real-time data spanning both traditional and digital assets."
</blockquote>
The evidence of Chainlink's reliability in on-chain data provision can be seen in the products it already supports. , Only a few days before the announcement of the S&amp;P index collaboration, <a href="https://www.prnewswire.com/news-releases/chainlink-collaborates-with-ftse-russell-to-publish-global-indices-onchain-for-the-first-time-via-datalink-302601997.html">Chainlink and FTSE Russell partnered</a> to publish global indices on-chain through Datalink, a Chainlink product.
&nbsp;
&nbsp;
<h2 dir="ltr">Index Composition and Process</h2>
&nbsp;
The Index, born out of collaboration, represents the best of TradFi and blockchain technology industries. For instance, this Index comes with 35 US-listed equities with solid activity in the digital finance space. While, S&amp;P brings 15 top digital assets, though the Index's actual assets involved have not been disclosed.
&nbsp;
As Dinari is into turning real-world assets into tokens on a 1:1 basis, shares backing the tokens are usually held via a regulated custodian. Once S&amp;P Dow Jones Indices creates the composition of the Index, Dinari tokenises the entire product, Chainlink will power pricing and operational transparency by publishing the data on chain. Dinari's CEO, Gabe Otte summarised the importance of tokenised benchmarks:
<blockquote>
"For the first time, investors can access both US equities and digital assets in a single, transparent product. On-chain standards expand the reach of trusted financial benchmarks."&nbsp;
</blockquote>
After creation and tokenisation,people will be able to trade the tokenised version of the Index 24/7.
&nbsp;
&nbsp;
<h2 dir="ltr">What Are KOLs Saying About The New Product</h2>
&nbsp;
Key opinion leaders in the crypto world and finance weighed in on this new developments.&nbsp;
&nbsp;
While announcing the collaboration, Fiona Bassett, the CEO of FTSE Russell in her words;&nbsp;
<blockquote>
"DataLink allows FTSE Russell to securely distribute underlying data of some of our most trusted benchmarks across global on-chain markets, giving institutions and developers the same high-quality data that powers traditional finance."
</blockquote>
Furthermore, Chainlink is already working with the U.S. Department of Commerce to publish macroeconomic data on Bitcoin, Ethereum, and Solana.&nbsp;In a statement, Cameron Drinkwater talked of the transformation:&nbsp;
<blockquote>
<a href="https://press.spglobal.com/2025-10-07-S-P-Global-to-Launch-Innovative-Crypto-Ecosystem-Index,-a-New-Way-to-Combine-Cryptocurrencies-and-Crypto-Linked-Equities?ref=blockhead.co">"Independent, reliable, and user-friendly benchmarks are a key component of financial markets</a>. As with traditional financial markets, independent benchmarks can help bring transparency and accessibility to the digital asset ecosystem."
</blockquote>
Drinkwater, the industry leader, also talked of how cryptocurrencies have evolved from the sidelines into the mainstream. Now, market participants are starting to treat virtual assets as part of their portfolios, according to Drinkwater.&nbsp;Gabe Otte, the Dineri CEOsaid:
<blockquote>
"Financial systems depend on trusted data and transparent infrastructure. Working with S&amp;P Dow Jones Indices and Chainlink allows us to bring that same standard of reliability to tokenised benchmarks, ensuring the S&amp;P Digital Markets 50 operates with integrity and verifiability on-chain."
</blockquote>
Dinari's Chief Business Officer Anna Wroblewska also added:
<blockquote>
"This launch shows how on-chain technology can expand the reach of established financial standards, making them more efficient and globally relevant."&nbsp;
</blockquote>
&nbsp;
&nbsp;
<h2 dir="ltr">A Broader Look At The Tokenisation Wave</h2>
&nbsp;
Tokenisation, traditional assets turning into tokens, is fast expanding into the mainstream. Many platforms like Backed Finance and Robinhood have been actively issuing tokenised versions of equities.
&nbsp;
A few months ago, <a href="https://backed.fi/news-updates/xstocks-are-going-live-tokenized-stocks-for-the-defi-era">Backed Finance announced the dawn of xStocks</a>, a product that includes tokenised shares of Tesla, Apple, Nvidia, Circle, and even the S&amp;P 500. In just about 1 month, the xStocks trading volume peaked at $2 billion.&nbsp;Soon after, Kraken and Backed collaborated to expand xStocks from just Solana into BNB Chain. Kraken CEO Arjun Sethi commented:
<blockquote>
"The response to xStocks has made one thing increasingly clear &mdash; the future of capital markets will be chain-neutral, composable, and multichain by design."
</blockquote>
Robinhood, a titan in the TradFi space, has also been speedily rushing into the tokenisation space. The network launched 200 tokenised versions of some of the most popular stocks in the US to EU customers.
&nbsp;
The CEO of BlackRock is also in favor of tokenisation. Larry Fink actually said that the US Securities and Exchange Commission should "rapidly approve the tokenisation of bonds and stocks. Also, Coinbase, a giant in the crypto business, is already planning to expand its tokenised assets strategy.&nbsp;&nbsp;
&nbsp;
&nbsp;
<h2 dir="ltr">Verifiability is the New Standard</h2>
&nbsp;
The dawn of the S&amp;P Digital Markets 50 Index is the dawn of a new era for capital markets. It presents a preview of what is to come when global financial data will be verified and distributed, but all on-chain.
&nbsp;
Through their collaboration, S&amp;P DJI, Dinari, and Chainlink introduced a new standard that unites digital assets and traditional equities within a single economy, marking a true innovation.
&nbsp;
As 2025 nearly comes to an end, the gap between TradFi and digital markets is closing, with the two becoming one. The team-up of S&amp;P Dow Jones Indices, Chainlink, and Dinari has significant implications for enterprises and investors. The partnership opens the door to hybrid traditional-digital products backed by S&amp;P&rsquo;s credibility. Moreover, this partnership lowers operational risks and brings 24/7 access to Wall Street-level benchmarks.&nbsp;
&nbsp;
Tokenised benchmarks like the new S&amp;P Digital Markets 50 mark only the start. Businesses and institutions that understand these mechanics early will likely be among the leaders in the tokenisation wave. <a href="https://www.ucubed.au">uCubed</a> is helping founders, enterprises, and investment leaders with tools to understand tokenisation and its possible future financial impact.&nbsp;

sp-digital-markets-50-tokenised-index-chainlink.webp

S&P, Dinari and Chainlink launch the Digital Markets 50, a tokenised index combining equities and digital assets on-chain.

S&P Digital Markets 50 Index Launches On-Chain With Chainlink

S&P Digital Markets 50 Index: Chainlink Verifiability

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News and educational resources for the banking and finance sector. Explore how digital assets and tokenisation are shaping financial services, alongside regulatory, market and technology updates.

Digital Assets & Tokenisation in Banking & Finance | uCubed Insights

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