The tokenisation of real-world assets (RWAs) — from bonds and fund units to real estate and private credit — is shifting from pilots and proofs-of-concept toward real market offerings. But technology alone won’t make markets liquid or trusted: regulation will. Over 2024–2025, jurisdictions worldwide have moved to clarify legal status, licensing, custody, and investor-protection rules that determine whether tokenised assets can be issued, listed, and actively secondarily traded. It is a major step on the path towards market maturity for tokenization of real estate is FIBREE’s believe.
This updated briefing tracks the latest regulatory direction in Europe, North America, Asia-Pacific, the Middle East, LATAM and Africa and points to the policy signals that will decide whether tokenisation scales across borders or remains regionally fragmented.
Europe: From Pilot Regimes Toward a Permanent Framework
Europe is arguably the most systematic laboratory for regulated RWA tokenisation. The EU’s DLT Pilot Regime — created to test tokenised trading and settlement — has been the centrepiece. In 2024–2025, ESMA proposed concrete amendments intended to increase capacity and operational clarity, even recommending the evolution of the Pilot into a permanent framework to support tokenised listings and trading across the Single Market. Those recommendations aim to reduce frictions (e.g., transaction caps, clearing/settlement requirements) while keeping investor safeguards in place.
Parallel action on MiCA (Markets in Crypto-Assets) means national regulators are also publishing implementing guidance that affects how tokenised instruments are classified and which firms fall into regulated perimeters. The European Commission has signalled it may follow up the DLT Pilot with legislative proposals that further harmonise tokenisation rules across member states — a potential game-changer for EU cross-border secondary trading.
At the national level, regulators are translating EU signals into practice: France’s AMF has published legal analyses clarifying how security tokens interact with prospectus and securities law, Luxembourg granted the first “control-agent” license for tokenised funds, BaFin in Germany refined token classification and supervisory expectations, and the Dutch authorities (AFM/DNB) issued MiCA implementation notes that affect where tokenised trading can lawfully be offered. Switzerland — while outside the EU — continues to operate a permissive, clear supervisory approach (FINMA), attracting market infrastructure projects and hosted trading systems.
In the UK, the FCA’s DP25/1 consultation sets out a roadmap to bring crypto activities into a tailored regulatory perimeter; the FCA has also published practical guidance for fund tokenisation. Taken together, EU and UK activity shows a strong policy intent: encourage experimentation, but anchor it under existing investor-protection, anti-money-laundering (AML) and market-integrity rules.
United States & Canada: Cautious Decisive Steps
The U.S. remains the most consequential jurisdiction by market size, and therefore regulatory ambiguity there matters. In early 2025, the SEC’s revocation of SAB 121 removed a significant accounting obstacle that had discouraged banks from offering custody for cryptoassets — a pragmatic step that reduces a major operational barrier for tokenised RWAs. Meanwhile, high-profile industry filings (for example, Coinbase’s requests to offer blockchain-based stocks) demonstrate strong market demand for regulated tokenised trading venues — even as the SEC’s overall stance remains cautious and case-by-case.
In Canada, provincial securities regulators (notably the OSC) and the Canadian Securities Administrators have shown a more enabling posture, opening pathways for tokenised long-term funds and clarifying custody/investor protection rules — positioning Canada as an early regulated market for institutional RWA tokenisation in North America.
Asia-Pacific: Sandboxes and Commercialisation Roadmaps
Asia-Pacific regulators have been among the most proactive in converting pilots into commercial programmes. Singapore’s MAS moved Project Guardian beyond laboratory testing and toward a commercialisation roadmap that supports tokenised bonds, deposits and funds — an explicit signal that Singapore wants to be a global hub for regulated token issuance and trading. Hong Kong’s SFC and HKMA likewise published roadmaps and launched regulatory facilitation (ASPIRe and settlement initiatives) aimed at allowing authorised tokenised fund products and integrated trading rails. Japan’s FSA advanced consultations to classify token-based instruments more clearly under existing securities law and tighten custody and outsourcing standards to bolster investor protection. Australia’s ASIC updated digital-asset guidance and consulted on policy changes to move tokenisation from sandbox status to mainstream regulated products. These moves point to a region converging on clearer, accessible regimes that support secondary trading.
Middle East: Purpose-Built Regimes
The UAE — through ADGM, DFSA, and VARA — has built dedicated digital-asset rulebooks that explicitly enable licensing, custody, secondary trading, and market-infrastructure activities for tokenised securities. These free-zone regimes combine a permissive commercial stance with prudential safeguards, attracting funds, exchanges and tokenisation platforms that need legal certainty.
Latin America (LATAM): Rapid Policy Moves and Commodity Tokenisation
Latin America shows a clear pattern: strong market demand + growing regulatory engagement. A few country highlights:
- Argentina has taken explicit steps to legalise tokenisation of goods and warrants: Decree updates in 2024 modernised electronic registration and allow blockchain-based negotiation of warrant instruments — a practical measure that can unlock commodity-backed token financing and on-chain trading of agricultural/product inventories. This is a concrete, near-term enabling move for tokenised supply-chain financing.
- Brazil: the Central Bank has repeatedly signalled that stablecoins and asset tokenisation should be regulated (with consultations and a staged rule-making agenda culminating in 2025 proposals). Brazil’s approach is strategic — balancing risks (AML, tax, illicit finance) with the potential to modernise capital markets and payment rails.
- Mexico and Colombia are advancing consultations and draft frameworks for VASPs and tokenised assets; Mexico has been running public consultations about tokenisation frameworks and peso-backed stablecoins, while Colombia balances sandbox pilots (including tokenised bonds) with draft licensing regimes for VASPs. These national initiatives reflect a region where tokenisation use-cases (remittances, commodity financing, SME access to capital) are pressing and regulators are responding pragmatically.
Overall, LATAM’s regulatory stance is one of pragmatic inclusion: regulators are seeking to capture economic benefits (financial inclusion, cheaper capital, commodity finance) while tightening AML and consumer protections — an approach that can make tokenised listings and secondary trading viable if supported by clear licensing and custody rules.
Africa: Fast-Moving Legal Recognition and Market Infrastructure
Africa’s regulatory movement in 2024–2025 has accelerated, with some jurisdictions creating genuinely enabling frameworks:
- Nigeria enacted a modernised Investments and Securities Act (ISA) (2024/2025 reform) that explicitly recognizes digital assets as securities, giving the authorities clear supervisory powers over digital asset offerings and platforms; the Act mandates licensing, custody standards and disclosure for digital securities — a foundational step that legitimises tokenised RWA markets and encourages regulated secondary venues.
- South Africa has taken an operational regulatory route: the FSCA declared crypto assets as financial products under existing law and implemented the CASP licensing framework; the Financial Intelligence Centre issued a Travel Rule directive and AML obligations for CASPs. These rules create a supervised environment where tokenised funds and securities could be offered subject to existing financial-product safeguards and AML controls.
- Across the continent, other regulators are studying or piloting tokenisation as a way to unlock capital markets and increase inclusion. Observers note that Nigeria’s legal recognition and South Africa’s licensing regime create a template for neighbouring markets, while pan-African and international actors are discussing harmonised approaches to cross-border token trading.
The policy takeaway for Africa is that legal recognition + licensing + AML controls are the pillars that will determine whether tokenised assets can be listed and traded in regulated secondary markets. Countries moving quickly on these pillars stand to attract issuance and liquidity.
Global Standard-Setters: Convergence Pressure
Global standard setters (BIS/BCBS, FSB, IOSCO, OECD, WEF) have been explicit: tokenisation presents opportunities but also systemic and operational risks (interoperability, custody, third-party dependencies, market integrity). Their recent 2024–2025 publications urge regulators to harmonise rules where possible — on classification, custody standards, disclosure and cross-border supervisory cooperation — otherwise fragmentation will impede liquidity and cross-listing. These high-level outputs are already influencing national rule-making and the design of safe market infrastructure.
What This Means for Market Participants
- Issuers & Asset Managers: Choose domiciles that balance commercial access and legal certainty (Luxembourg, Singapore, UAE, Switzerland and specific LATAM/African jurisdictions are positioning themselves to attract issuance). Expect to adapt prospectuses, custody arrangements and AML processes for token formats.
- Exchanges & Trading Venues: Licensing and settlement interoperability will be decisive. Venues that secure regulator recognition and clear custody models will draw institutional flows. EU DLT Pilot evolution and national licenses (Luxembourg control-agent, Swiss FINMA approvals) are early test cases.
- Custodians & Banks: The revocation of accounting constraints (e.g., SAB 121 in the U.S.) and clearer custody expectations in places like Nigeria or Canada materially improve the business case for custody services — a prerequisite for institutional secondary trading.
- Regulators & Policymakers: The balancing act continues: permit innovation while enforcing investor protection, AML and systemic resilience. Cross-border cooperation and standards alignment will be required if liquid, cross-listed secondary markets are to develop.
Conclusion — Fragmented Today, Interoperable Tomorrow?
The 2024–2025 regulatory wave shows diverse paths to the same goal: legal clarity, investor protections and infrastructure that permit issuance, custody and secondary trading of tokenised RWAs. Europe’s methodical pilot-to-framework route, Asia’s commercialisation push, the UAE’s bespoke regimes, LATAM’s commodity- and inclusion-driven moves, and Africa’s legal recognition and licensing momentum together suggest a global market that is fragmented but fast converging.
If regulators focus on common building blocks — clear asset classification, custody standards, AML controls, disclosure regimes, and cross-border supervisory cooperation — tokenised RWAs can evolve from local experiments to interconnected, regulated markets.
For market participants, the immediate task is pragmatic: pick compliant domiciles, design token structures that meet existing securities law, and build custody and operational robustness — because the regulatory floor is rising fast.