# COSIMO Digital — Full Site Text for LLMs > The regulated infrastructure for the digital-asset market. This file concatenates the readable text of every page on cosimodigital.com so an AI can ingest the whole site in one fetch. Structured index: https://cosimodigital.com/llms.txt Status discipline (do not overstate): LIVE = Regulated Issuance (Black Manta), Asset Management (COSIMO X), Development and Consumer (Amplify). PENDING / IN AUTHORIZATION (not yet effective) = Custody and Payments (Fortuna, Central Bank of Ireland). MAINNET-READY (not live at scale) = Settlement and Identity (Revolution Network). INFRASTRUCTURE-READY (built, not operational) = Digital Asset Treasury (CDAT). Pending authorizations are not effective until granted. Nothing here is an offer of securities or a projection of returns; third-party figures (e.g. Boston Consulting Group) are attributed to their sources. Generated 2026-07-21. ======================================================================== # COSIMO Digital — Home URL: https://cosimodigital.com/ ======================================================================== COSIMO Digital The regulated infrastructure for the digital asset market. We build and operate the licensed rails that take real-world assets from issuance through custody, settlement, and asset management. Integrated, not assembled from vendors. Explore the platform Investor inquiries BaFin-regulated, MiFID II passported LIVE Central Bank of Ireland, MiCA custody and related payments IN AUTHORIZATION PROCESS EEA passport LIVE One firm, six connected layers Most of the market sells one piece: an issuer here, a custodian there, a chain somewhere else. We operate the layers together, under regulated control, so an asset can move through the system without leaving it. LIVE Regulated Issuance A BaFin-regulated Financial Services Institution (WpIG) for tokenized securities, passported across the EEA under MiFID II. Read more → IN AUTHORIZATION PROCESS Custody and Payments In the authorization process with the Central Bank of Ireland for MiCA custody and related payments approvals. Read more → INFRASTRUCTURE READY Digital Asset Treasury Validator-treasury infrastructure across 40-plus networks, with Dual-Rail redemption built in. Read more → MAINNET-READY Settlement and Identity A zkStack Ethereum Layer-2 for real-world assets, with compliant on-chain identity. Read more → LIVE Asset Management What we believe to be the world's first tokenized evergreen venture fund. Read more → LIVE Development and Consumer COSIMO's in-house development company, and the bridge to end users through Amped.Bio. Read more → The integrated stack One firm, six connected layers. Most of the market sells one. We operate the stack. An asset can be originated and issued under a live European license, then move through custody, settlement, identity, and treasury, with asset management providing operating visibility across every layer. Live layers are drawn solid. Layers in authorization, infrastructure-ready, or mainnet-ready are drawn outlined, never as live. [diagram] Live In authorization process · infrastructure-ready · mainnet-ready Why now Europe reset the market. The licensed players capture the transition. MiCA raised the bar overnight. The market went from thousands of loosely-supervised firms to a short list of authorized ones. The institutions now entering tokenization need licensed rails they do not have time to build. Up to $88 trillion Tokenized real-world assets by 2035, in the progressive scenario. Source: Boston Consulting Group, 2026. About 1 in 6 Of more than 1,200 firms that held pre-MiCA registrations, roughly 210 have secured MiCA CASP authorization across the EU. Source: ESMA MiCA register, 2026. Read the opportunity → Track record We ran a fund on tokenization rails before it was comfortable to do so. COSIMO X is the world's first tokenized evergreen venture fund, launched in 2019, and Securitize's first paying customer. It gives us operating visibility into every layer we now build. Insights From the desk. View all insights → Article · Markets The NAV discount problem Why digital asset treasuries trade below their own assets, and the structural fix that closes the gap. July 2026 Article · Markets The equity layer: the fat protocol trade is dead Value accrues to regulated operating companies with enforceable claims on cash flows, not to tokens. July 2026 Article · Regulation MiFID II or MiCA? Which license actually lets you issue tokenized securities in Europe, and why the distinction decides everything. July 2026 Talk to us about what we have built. We speak with qualified investors and institutional partners under NDA. Make an inquiry ======================================================================== # Platform overview URL: https://cosimodigital.com/platform ======================================================================== Home / Platform Platform One integrated platform, six connected layers. Tokenization is usually sold as point solutions. We operate the layers together, under regulated control, so a real-world asset can move from issuance to custody to settlement to management without leaving the system. That integration is the product. The stack BMCP Regulated Issuance LIVE Origination and issuance of tokenized securities under a live MiFID II authorization, passported across the EEA. View fact sheet → Fortuna Custody and Payments IN AUTHORIZATION PROCESS On authorization, institutional custody including non-EVM chains, staking and DeFi, and full token lifecycle services. View fact sheet → CDAT Digital Asset Treasury INFRASTRUCTURE READY Validator-treasury infrastructure across more than 40 proof-of-stake networks, with Dual-Rail redemption as a structural design. View fact sheet → Revolution Network Settlement and Identity MAINNET-READY A zkStack Ethereum Layer-2 built for real-world assets, with a privacy-preserving, KYC-grade identity layer. View fact sheet → COSIMO X Asset Management LIVE The firm's origin: the world's first tokenized evergreen venture fund. View fact sheet → Amplify Development and Consumer LIVE COSIMO's development company. Builds the proprietary stack and operates Amped.Bio, a live consumer platform. View fact sheet → The asset lifecycle How an asset moves through the system. Issuance is live today. Custody and payments, settlement, and treasury complete the path as each is authorized or brought into operation. Conditional handoffs are drawn outlined. [diagram] The host model Regulated rails others can plug into. Under MiFID II, tied-agent agreements let firms operate under a licensed umbrella. We already host regulated issuance and live tied-agent distribution through Black Manta. On Fortuna's authorization, the model extends to custody and euro payments. Partners keep their brand. We run the compliant rails. "The scarce asset in tokenization is not technology. It is regulated distribution. We own the origination and the rails to move value."COSIMO Digital [diagram] Live On authorization See the standing behind every layer. See the regulatory standing Investor inquiries ======================================================================== # Regulated Issuance — Black Manta Capital Partners URL: https://cosimodigital.com/platform/regulated-issuance ======================================================================== Home / Platform / Black Manta Capital Partners Regulated Issuance Black Manta Capital Partners LIVE A BaFin-regulated Financial Services Institution (Finanzdienstleistungsinstitut) under the German Investment Firm Act (WpIG), running an investment banking business for tokenized securities. It holds passporting notifications under MiFID II to provide investment services across the European Economic Area (EEA). Visit blackmanta.capital ↗ What it does Originates and issues tokenized real-world assets across real estate, private credit, funds, and structured products, under a live European authorization. Distributes through live tied-agent relationships (e.g., KuCoin, Bitget). Gives issuers and institutions a regulated home for issuance they can plug into, without building a license of their own. Regulatory status and permitted activities BMCP is authorized and supervised by BaFin as a Financial Services Institution (Finanzdienstleistungsinstitut) under the German Investment Firm Act (Wertpapierinstitutsgesetz, WpIG). Its permitted activities include Investment Brokerage (Anlagevermittlung) and Placement Business without firm commitment (Platzierungsgeschäft). BMCP holds passporting notifications under MiFID II to provide these investment services across the European Economic Area (EEA). The issuance infrastructure: a dedicated securitization vehicle Issuance is supported by BMCP Securities S.à r.l., a dedicated Luxembourg securitization vehicle. It provides the issuing infrastructure and the management of the assets brought into it. Fully segregated compartments with no spillover risk, structured by asset class. Feeder structuring into a client fund or SPV, with offering documentation tailored per compartment. BMCP Securities S.à r.l. acts as token registrar for instruments issued on the platform. Legal and audit support from established Luxembourg service providers, including Centralis and Atwell. This gives the issuance layer a regulated home for both bringing assets to market and managing them across their life, separate from the fund-level asset management provided elsewhere in the stack. Proprietary platform and multi-chain integration BMCP runs its own issuance IP and platform, with multiple integrated blockchains. Instruments can be issued and settled across several networks, and BMCP is a featured app on Canton, Stellar, and EVM chains. This multi-chain reach is BMCP's own platform capability. It is separate from Revolution Network, COSIMO's Ethereum Layer-2 for settlement and identity. By the numbers Over 4 billion euro in completed tokenized securities issuances. Issuance only. Not custody, and not distribution volume. The issuance flow From asset to regulated distribution. A real-world asset is structured, issued as tokenized securities under MiFID II, and distributed through live tied agents (e.g., KuCoin, Bitget). The flow ends at distribution. Safekeeping is a separate layer. [diagram] Live Pending · in authorization / ready Global footprint BMCP operates regulated activity and business development across Europe, Asia, and North America, including registration with the China Securities Regulatory Commission (CSRC) as a foreign broker-dealer. Issuance is one layer. Custody, settlement, and management are the others. Explore the stack. --- How issuance works (https://cosimodigital.com/platform/regulated-issuance/how-issuance-works) How an issuance runs. A disciplined, time-boxed path from onboarding to distribution, executed through a regulated Luxembourg securitization structure. The structure: Each transaction is issued through a dedicated, segregated compartment of BMCP Securities S.à r.l., the Luxembourg securitization vehicle. Compartments are ring-fenced by asset class, so no compartment carries the risk of another. The vehicle can act as a feeder into a client fund or SPV, with offering documentation tailored per compartment. The timeline: A typical issuance runs on an eight-week projected timeline across four phases. 1. Onboarding (Weeks 1-2): client questionnaire, KYC, and data-room creation; each transaction is subject to an internal board resolution of BMCP Securities S.à r.l. 2. Transaction structuring (Weeks 1-4): compartment setup, transaction flows, and agreement of terms. 3. Legal structuring (Weeks 3-5): preparation of the Private Placement Memorandum (PPM), subscription agreements, and regulatory documents. 4. Commercial execution (Weeks 4-8): investor approach, roadshow, and marketing materials, through to distribution. Timeline is indicative and varies by asset class and transaction complexity. Distribution: Instruments are distributed to professional and, where permitted, retail investors through BMCP's tied-agent network (e.g., KuCoin, Bitget). Distribution is the end of the issuance flow. Custody and settlement are separate layers of the COSIMO stack. --- Global footprint (https://cosimodigital.com/platform/regulated-issuance/global-footprint) A regulated presence across three continents. BMCP runs regulated activity and business development from Europe, Asia, and North America, with regulated substance in each location. Luxembourg - Holding and securitization vehicle (BMCP Securities S.à r.l.). Munich - BaFin-regulated activities (WpIG): investment brokerage and placement. Vienna - Advisory and capital-market listing. Cork - Technology and business development. Shanghai - Regulated foreign broker, registered with the China Securities Regulatory Commission (CSRC) since September 2023. Hong Kong - Business development for the Asian market. Toronto and Boston - Business development for the North American market. Why it matters: Regulated substance in each jurisdiction, not a letter-box. BMCP was the first regulated financial services provider for the tokenization of securities in Europe, and it extends that reach into Asia and North America through licensed and registered channels. --- Custody and payments Investor inquiries ======================================================================== # Custody and Payments — Fortuna URL: https://cosimodigital.com/platform/custody-payments ======================================================================== Home / Platform / Fortuna Digital Custody Custody and Payments Fortuna Digital Custody IN AUTHORIZATION PROCESS In the authorization process with the Central Bank of Ireland for MiCA custody and related payments approvals. Visit fortuna.solutions ↗ Where it stands Fortuna is in the authorization process with the Central Bank of Ireland for an EU MiCA and related payments approvals. The team builds from a foundation of strong local substance, which is essential for EU regulatory approval. What it will do, on authorization Custody and related payments services, including a broad range of non-EVM chains. Extensive staking and DeFi capability. Full token lifecycle services for foundations and token issuers. On authorization What Fortuna will operate, on authorization. Drawn entirely in the conditional treatment. Every capability is pending Central Bank of Ireland authorization and is not provided until granted. [diagram] Live Pending · in authorization / ready Custody is the hardest piece to build and the one institutions most need. We built it to the standard, and we are seeing it through authorization. Standing legend Fortuna's MiCA custody and related payments approvals are in process with the Central Bank of Ireland and are not yet in effect. The services described are not provided until authorization is granted. The regulatory standing Investor inquiries ======================================================================== # Digital Asset Treasury — CDAT URL: https://cosimodigital.com/platform/digital-asset-treasury ======================================================================== Home / Platform / CDAT Digital Asset Treasury CDAT INFRASTRUCTURE READY Multicoin validator-treasury infrastructure, built across more than 40 proof-of-stake networks, with Dual-Rail redemption as a structural design feature. What it is The infrastructure is built and ready across more than 40 proof-of-stake networks. Diversified by design, rather than concentrated in a single token. Dual-Rail The structural answer to the treasury discount. Single-coin treasuries can trade below the value of what they hold. Dual-Rail makes the tokenized rail redeemable by smart contract for the underlying assets, so value cannot drift away from the holdings. The mechanism Dual-Rail redemption and validator diversification. Redeemability links the tokenized rail to the underlying assets; the treasury is spread across more than 40 networks rather than a single token. No yield or return is shown. [diagram] Live Pending · in authorization / ready The infrastructure is ready. Operational go-live is a decision we are setting deliberately. Standing legend CDAT is infrastructure-ready and not yet operational. It does not currently generate treasury income. No yield or return is implied. Settlement and identity Investor inquiries ======================================================================== # Settlement and Identity — Revolution Network URL: https://cosimodigital.com/platform/settlement-identity ======================================================================== Home / Platform / Revolution Network Settlement and Identity Revolution Network MAINNET-READY A zkStack Ethereum Layer-2 purpose-built for real-world assets, with RNS, a privacy-preserving, KYC-grade on-chain identity layer. Visit revolutionnetwork.io ↗ What it does Provides compliant settlement rails for tokenized assets and stablecoins. RNS verifies identity on-chain without exposing it, so regulated assets can move within the rules. Built to align with GDPR. Own the rail Own the rail. Do not rent it. When you operate the settlement layer, transaction, staking, and protocol economics accrue to you as volume scales, instead of leaking to someone else's chain. L2 and identity architecture A settlement layer with compliant identity. An RNS identity layer sits above a zkStack Ethereum Layer-2. Regulated assets and stablecoins transact within the rules. Marked mainnet-ready; no live volume is shown. [diagram] Live Pending · in authorization / ready Mainnet-ready. Scale follows launch. Asset management Investor inquiries ======================================================================== # Asset Management — COSIMO X URL: https://cosimodigital.com/platform/asset-management ======================================================================== Home / Platform / COSIMO X Asset Management COSIMO X LIVE What we believe to be the world’s first tokenized evergreen venture fund — and the origin of the firm. COSIMO X invests in the infrastructure of tokenized capital markets. We ran a fund on tokenization rails before it was comfortable to do so — and everything COSIMO Digital now builds traces back to what that portfolio taught us. OverviewStrategyPortfolioStructureTrack Record What the fund invests in Four pillars. One transition. Capital markets are moving from traditional rails to tokenized rails — a dual-rail transition that will run for a decade. COSIMO X invests in the companies building the infrastructure of that transition, across four pillars. Each pillar maps directly to a layer of the platform COSIMO Digital operates. RWA Tokenization The platforms that bring real-world assets on-chain: issuance, servicing, and lifecycle infrastructure for tokenized securities. Platform counterpart: Regulated Issuance — Black Manta Capital Partners. How we invest here → Payments & Stablecoins The settlement money of tokenized markets: stablecoin rails, payment infrastructure, and the bridges between bank money and on-chain money. Platform counterpart: Custody and Payments — Fortuna. How we invest here → Private Credit Origination, servicing, and financing infrastructure that moves private credit onto programmable rails — the largest early RWA category by volume. Platform counterpart: Regulated Issuance and Custody — origination-to-servicing rails. How we invest here → Equity & Capital Markets Dual-rail equity systems, digital securities exchanges, and the market structure of tokenized capital formation. Platform counterpart: Settlement and Identity — Revolution Network. COSIMO X itself is a working example. How we invest here → The convergence pillar AI & Blockchain How we invest here → Where autonomous AI meets on-chain finance: AI agents that hold wallets and transact machine-to-machine, agentic payment rails settled in stablecoins, on-chain identity and reputation for agents, and the AI systems that price, monitor, and keep tokenized assets compliant in real time. Platform counterpart: Settlement and Identity — Revolution Network (compliant identity for autonomous agents), with Custody and Payments — Fortuna for stablecoin settlement. By the numbers 2019 fund launched 20+ portfolio investments ~$22M AUM First paying Securitize customer Figures as of June 30, 2025. AUM reflects gross net asset value of fund holdings. The ecosystem loop We invest in the market we build. That is not a coincidence. The fund invests across the layers of tokenized capital markets. The portfolio gives COSIMO operating visibility into every layer — regulation, custody, market structure, adoption. That visibility shaped the platform COSIMO Digital now operates. And the platform, in turn, informs every new investment. [diagram] Explore COSIMO X Strategy The dual-rail thesis, the four pillars in depth, and how we allocate capital. Open → Portfolio Selected investments across the four pillars, active and realized. Open → Structure What “tokenized evergreen” means, mechanically. Open → Track Record A decade of operating history, and the team behind it. Open → Talk to us about the fund. We speak with qualified investors under NDA. Complete offering materials, performance data, and the portfolio schedule are available in the data room. Investor inquiries → This page is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security. Interests in COSIMO X LP are offered solely to qualified investors through the Fund’s confidential offering documents, pursuant to exemptions under Regulation D and Regulation S of the U.S. Securities Act, which control in all respects. Figures are as of the date stated and unaudited. Past performance is not indicative of future results. ======================================================================== # COSIMO X — Strategy URL: https://cosimodigital.com/platform/asset-management/strategy ======================================================================== Home / Platform / COSIMO X / Strategy Strategy The dual-rail transition Financial markets are not flipping from traditional rails to tokenized rails overnight. They are running both — in parallel — for years. OverviewStrategyPortfolioStructureTrack Record Financial markets are not flipping from traditional rails to tokenized rails overnight. They are running both — in parallel — for years. The winners of this transition are not the loudest protocols. They are the companies building the infrastructure that lets assets, payments, credit, and equity move compliantly between both systems. That is what COSIMO X owns. Up to $88 trillion Tokenized real-world assets by 2035, in the progressive scenario. Source: Boston Consulting Group, 2026. The four pillars Where the capital goes. Pillar RWA Tokenization What we invest in. Issuance platforms, tokenization-as-a-service infrastructure, asset servicing, and lifecycle management for tokenized securities — the picks and shovels of bringing real-world assets on-chain. Why it matters to COSIMO Digital This is the front door of the platform. Black Manta Capital Partners, a BaFin-regulated Financial Services Institution (WpIG), operates regulated issuance with a €10B+ tokenization pipeline. Every issuance-layer investment sharpens what we know about where that market is going — and every platform lesson sharpens the portfolio. Pillar Payments & Stablecoins What we invest in. Stablecoin infrastructure, payment rails, and on/off-ramps — the settlement money of tokenized markets. Regulatory clarity in the EU (MiCA) and the US (GENIUS Act) is converting this category from speculation into regulated market plumbing. Why it matters to COSIMO Digital Fortuna is in the authorization process for EU MiCA and related payments license approval. The fund’s payments portfolio and the platform’s payments layer read the same market from two sides. Pillar Private Credit What we invest in. Origination platforms, servicing infrastructure, and financing rails that move private credit on-chain — the largest early real-world-asset category by tokenized volume. Why it matters to COSIMO Digital Private credit is where issuance, custody, and servicing must work together or not at all. It is the sharpest test of an integrated stack — and the clearest demand signal for the rails COSIMO operates. Pillar Equity & Capital Markets What we invest in. Dual-rail equity systems, regulated digital securities exchanges, and the market structure of tokenized capital formation. Portfolio positions include Archax, the first FCA-regulated digital securities exchange, broker, and custodian. Why it matters to COSIMO Digital COSIMO X is itself a tokenized fund — a working instance of the category it invests in. Revolution Network’s settlement and identity layer is being built for exactly this market. Pillar AI & Blockchain What we invest in. The infrastructure where autonomous AI meets on-chain finance: agentic payment rails and stablecoin settlement for machine-to-machine transactions, on-chain identity, reputation, and authorization for AI agents — a “Know Your Agent” layer — verifiable compute and data provenance, and the AI systems that value, monitor, and keep tokenized assets compliant in real time. Open agentic-payment standards and machine-to-machine stablecoin settlement moved from demonstrations into production across 2025 and 2026, turning this from a narrative into measurable, utility-driven transaction volume. Why it matters to COSIMO Digital Autonomous agents cannot open bank accounts. They transact through wallets, stablecoins, and verifiable on-chain identity — the exact rails COSIMO operates. Regulated settlement, compliant identity, and euro payment infrastructure are what let institutions put agents to work without losing control of compliance. The fund invests in this convergence from inside the licensed layer that has to underwrite it. How we allocate Three tiers, one discipline. Primary60–70% of capital Series A–B infrastructure companies at $10M–$100M entry valuations. Live products, institutional customers, regulatory posture in place. This is the core of the fund. Secondary20–30% of capital Seed to Series A positions, frequently accessed through secondary purchases where the evergreen structure lets us be a patient, flexible buyer. Opportunistic10–15% of capital All stages, where ecosystem insight gives us conviction ahead of consensus. What we look for Investment criteria. Financial $500K+ ARR for infrastructure companies, or clear institutional pilot traction with named customers. Path to profitability within 24 months. Real runway. Team Founders with dual expertise — traditional finance plus blockchain engineering. A regulatory-first mindset. Existing institutional relationships. In-house technical depth. Product Live and generating revenue from multiple customers, or in advanced institutional pilots. Licensed, registered, or supported by legal opinion. Infrastructure with network effects — value that compounds with adoption. How we work with founders We co-invest alongside larger funds rather than competing with them. What we add is not just capital: portfolio companies get access to regulated issuance through Black Manta, a custody pathway through Fortuna, settlement on Revolution Network, and guidance across MiFID II, MiCA, FCA, and SEC frameworks — from a team that has operated a tokenized fund since 2019. See the portfolio → Investor inquiries → This page is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security. Interests in COSIMO X LP are offered solely to qualified investors through the Fund’s confidential offering documents, pursuant to exemptions under Regulation D and Regulation S of the U.S. Securities Act, which control in all respects. Figures are as of the date stated and unaudited. Past performance is not indicative of future results. ======================================================================== # COSIMO X — Portfolio URL: https://cosimodigital.com/platform/asset-management/portfolio ======================================================================== Home / Platform / COSIMO X / Portfolio Portfolio Selected investments Twenty-plus positions across the infrastructure of tokenized capital markets — equity stakes in regulated operators, positions in the networks assets settle on, and realized exits. Selected investments are shown below; a complete portfolio schedule is available to qualified investors in the data room. OverviewStrategyPortfolioStructureTrack Record AllRWA TokenizationPayments & StablecoinsPrivate CreditEquity & Capital MarketsNetworks & ProtocolsAI & BlockchainRealized Featured Archax Equity & Capital MarketsEquity The first FCA-regulated digital securities exchange, broker, and custodian. A front-row position in institutional tokenization and UK regulatory development. Visit site ↗ RWA TokenizationEquity BaFin-regulated Financial Services Institution (WpIG) for tokenized securities, passported across the EEA under MiFID II. Held by COSIMO X as a portfolio investment; COSIMO Digital is separately the company’s largest shareholder. Visit site ↗ Payments & StablecoinsEquity Digital money platform serving 10M+ users across 150+ countries — “anything to anything” conversion between currencies, crypto, and commodities. Visit site ↗ Networks & ProtocolsEquity Blockchain infrastructure firm: hardware procurement, colocation, and professional mining and staking operations. Visit site ↗ Networks & ProtocolsRealized Enterprise-grade public network with a governing council that has included Google and IBM. Position realized. Visit site ↗ Equity & Capital MarketsRealized Liquidity and trading infrastructure for security tokens and tokenized RWAs. Position realized. Visit site ↗ Additional selected positions Networks & ProtocolsToken & Network Privacy-preserving zkStack Ethereum Layer-2 for real-world assets, with compliant on-chain identity (RNS). On the platform → Equity & Capital MarketsToken & Network Privacy-preserving Layer-1 designed for regulated financial applications and compliant token issuance. Visit site ↗ Networks & ProtocolsToken & Network Enterprise-focused proof-of-stake Layer-1 with upgradable contracts. Visit site ↗ Private CreditToken & Network Bitcoin-native lending, borrowing, and margin trading protocol. Visit site ↗ Networks & ProtocolsEquity COSIMO’s in-house development company, building the proprietary stack and operating the consumer platform Amped.Bio. On the platform → Selected investments shown for illustration of strategy; inclusion is not based on performance. A complete schedule of investments, including position sizes and valuations, is available to qualified investors under NDA. Request data room access → This page is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security. Interests in COSIMO X LP are offered solely to qualified investors through the Fund’s confidential offering documents, pursuant to exemptions under Regulation D and Regulation S of the U.S. Securities Act, which control in all respects. Figures are as of the date stated and unaudited. Past performance is not indicative of future results. ======================================================================== # COSIMO X — Structure URL: https://cosimodigital.com/platform/asset-management/structure ======================================================================== Home / Platform / COSIMO X / Structure Structure What “tokenized evergreen” means Evergreen in duration, tokenized in form — structured on both axes in 2019, before either was fashionable. OverviewStrategyPortfolioStructureTrack Record Most venture funds are ten-year boxes: raise, deploy, harvest, dissolve. Infrastructure does not build on that clock. COSIMO X was structured differently on both axes — evergreen in duration, tokenized in form — in 2019, before either was fashionable. Evergreen Capital without a countdown. A conventional fund’s clock starts pressuring exits around year seven, whether or not the timing serves the company or the investor. COSIMO X is an evergreen vehicle: it deploys continuously, holds through cycles, and exits when the exit is right. Infrastructure companies typically take five to seven years to reach scale — our structure is aligned with that reality rather than fighting it. Continuous deployment new capital goes to work as it arrives; no artificial vintage pressure. Aligned holding periods exits driven by company milestones, not fund expiry. Compounding insight one permanent portfolio, one deepening view of the market. Tokenized The fund is built on the rails it invests in. COSIMO X LP is a Cayman Islands exempted limited partnership whose limited partnership interests are represented by digital tokens — issued and administered through Securitize, where COSIMO X was the first paying customer. Tokenization gives investors a digital ownership record on institutional infrastructure, and it gives the fund something rarer: firsthand operating knowledge of tokenized fund administration, transfer restrictions, compliance workflows, and investor onboarding, accumulated since 2019. The structure is designed to support transferability of interests in the future, subject at all times to applicable securities laws and the transfer restrictions in the fund documents. No assurance can be given that any secondary market will develop or be maintained. The dual-rail fund We operate what we underwrite. Every portfolio company building dual-rail infrastructure — traditional compliance on one side, on-chain operations on the other — is solving problems this fund has solved for itself. That is the underwriting edge: we have run the custody question, the transfer-agent question, the investor-onboarding question, in production, with real LPs. Cayman Islands exempted LPTokenized LP interests via SecuritizeEvergreen durationOffered under Reg D / Reg S to qualified investors Complete terms — including fees, minimums, redemption mechanics, and risk factors — are set out exclusively in the confidential offering documents. Investor inquiries → This page is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security. Interests in COSIMO X LP are offered solely to qualified investors through the Fund’s confidential offering documents, pursuant to exemptions under Regulation D and Regulation S of the U.S. Securities Act, which control in all respects. Figures are as of the date stated and unaudited. Past performance is not indicative of future results. ======================================================================== # COSIMO X — Track Record URL: https://cosimodigital.com/platform/asset-management/track-record ======================================================================== Home / Platform / COSIMO X / Track Record Track Record We were early. Deliberately. Built on tokenization rails from launch, with one continuous strategy since: own the infrastructure of the transition. OverviewStrategyPortfolioStructureTrack Record COSIMO X was not repositioned into tokenization when it became consensus. The fund was built on tokenization rails from launch, and the strategy has been continuous since: own the infrastructure of the transition. Timeline 2014 COSIMO founded. Rob Frasca and Ciarán Hynes establish COSIMO to invest in and operationally build early-stage technology companies across Ireland, the UK, and the US. 2019 COSIMO X launches. The fund goes live as what we believe to be the world’s first tokenized evergreen venture fund — and becomes Securitize’s first paying customer. 2019–2024 Building through cycles. The fund deploys across tokenization platforms, payment rails, networks, and regulated market operators — through a full market cycle — while accumulating the operating knowledge that would define COSIMO Digital. 2025 The stack takes shape. COSIMO Digital assembles the integrated platform: regulated issuance (Black Manta), custody and payments in authorization (Fortuna), settlement and identity (Revolution Network), and digital asset treasury (CDAT). 2026 The licensed era. MiCA resets the European market. The fund’s decade of positioning meets the moment it was positioned for. The team RF Rob Frasca Founder & Managing Partner Multi-decade entrepreneur with exits to Intuit, Lycos, and Nielsen. Early blockchain investor since 2014. CH Ciarán Hynes Co-Founder & Operating Partner Leads execution, operations, and institutional strategy across COSIMO Digital. CC Connor Cantwell Partner Venture investor focused on blockchain infrastructure, with deep European market expertise. Collectively: 13 companies founded · 40 US patents · decades of operating experience across finance and technology. Performance The numbers are in the data room. Fund performance — NAV history, portfolio-level detail, vintage analysis, and LP capital accounts — is available to qualified investors under NDA. We would rather walk you through the workbook than put a teaser on a webpage. Request data room access → This page is for informational purposes only and does not constitute an offer to sell, or a solicitation of an offer to buy, any security. Interests in COSIMO X LP are offered solely to qualified investors through the Fund’s confidential offering documents, pursuant to exemptions under Regulation D and Regulation S of the U.S. Securities Act, which control in all respects. Figures are as of the date stated and unaudited. Past performance is not indicative of future results. ======================================================================== # Development and Consumer — Amplify Digital URL: https://cosimodigital.com/platform/amplify ======================================================================== Home / Platform / Amplify Digital Development and Consumer Amplify Digital LIVE COSIMO's in-house development company, and the bridge from institutional infrastructure to end users. Visit ampedbio.com ↗ What it does Builds COSIMO's proprietary technology, including the settlement infrastructure behind the platform. Operates Amped.Bio, a live consumer platform that onboards users to the ecosystem. Bridges institutional rails to retail, so the regulated infrastructure reaches real end users. The development and consumer layer Build the stack, reach the user. Amplify builds the proprietary stack, including the settlement infrastructure behind the platform, and connects the platform to end users through Amped.Bio. [diagram] Live Pending · in authorization / ready The rails only matter if they reach people. Amplify is how we build, and how we connect the platform to end users. Explore the platform Investor inquiries ======================================================================== # The Opportunity URL: https://cosimodigital.com/opportunity ======================================================================== Home / The Opportunity The Opportunity Europe reset the market. The licensed players capture the transition. The reset MiCA changed the bar overnight. Before MiCA, Europe's digital asset market was fragmented and loosely supervised, with thousands of firms operating under varying standards. With MiCA in full effect, the bar rose sharply. Most firms now face a choice: achieve authorization, exit, or partner with a regulated player. About 1 in 6 of the firms that held pre-MiCA registrations have crossed the new bar — of more than 1,200 such firms, roughly 210 have secured MiCA CASP authorization across the EU. Source: ESMA MiCA register, 2026. [diagram] The wave The prize is large, and it is early. Boston Consulting Group sizes tokenized real-world assets at roughly 30 billion dollars today, growing to as much as 88 trillion dollars by 2035 in its progressive scenario, about 16 percent of all global investable assets. The same shift puts up to 30 percent of bank profits at risk as value migrates to whoever owns the rails. [diagram] "I do believe we are just at the beginning of the tokenization of all assets, from real estate to equities to bonds, across the board."Larry Fink · October 2025 The bottleneck The scarce asset is regulated distribution. Technology is not the constraint. Regulated origination, custody, and settlement are. The firms that own those at the start of the curve capture the transition, not the firms that arrive with software once the rails already exist. Our position We hold a live MiFID II issuance license, custody and payments in authorization, treasury infrastructure ready, and a settlement layer mainnet-ready. We were early to the asset class, and we are licensed where it is hard to be. Forward-looking note This page contains forward-looking statements and third-party market figures attributed to their sources. Pending items are not live until completed. Explore the platform Investor inquiries ======================================================================== # Regulatory URL: https://cosimodigital.com/regulatory ======================================================================== Home / Regulatory Regulatory and Compliance Built regulated, by design. Our standing, stated plainly and by entity. Where something is in process, we say so. Standing by entity Entity Regulator / framework Status Description Black Manta Capital Partners BaFin, MiFID II LIVE BaFin-regulated Financial Services Institution (WpIG) for tokenized securities. Permitted activities: investment brokerage (Anlagevermittlung) and placement without firm commitment (Platzierungsgeschäft). MiFID II passporting across the EEA. Fortuna Digital Custody Central Bank of Ireland, MiCA custody and related payments IN AUTHORIZATION PROCESS In the authorization process. Not yet live. Revolution Network (RNS) GDPR-aligned MAINNET-READY Privacy-preserving, KYC-grade on-chain identity for regulated assets. COSIMO X Regulated fund structure LIVE Tokenized evergreen venture fund. The frameworks, in plain language MiCA The EU regime for markets in crypto-assets. A single authorization standard for crypto-asset service providers across the bloc. MiFID II The EU framework for investment firms and financial instruments, including tokenized securities. PSD2 The EU payment-services framework, relevant to Fortuna's related payments approvals. GDPR The EU data-protection regime, which our identity layer is built to respect. The host model, in compliance terms Under MiFID II, tied-agent agreements let firms operate under a licensed umbrella. Under MiCA, unlicensed providers can plug in through licensed entities. We run the model with genuine operating substance, not as a letter-box, and not by renting a license. Standing legend Regulatory authorizations are described as of the date stated. Pending authorizations are not effective until granted. [All regulatory copy counsel-reviewed before launch.] Investor inquiries ======================================================================== # About URL: https://cosimodigital.com/about ======================================================================== Home / About About We build the regulated rails for how real-world assets come on-chain. Origin COSIMO Ventures became COSIMO Digital. We started by running a fund on tokenization rails in 2019, before it was comfortable to do so, and used that vantage point to build the regulated infrastructure the market would need next. Today we operate across issuance, custody and payments, treasury, settlement and identity, and asset management. Milestones 2014 Founded as COSIMO Ventures. The firm begins. 2019 Launched COSIMO X LIVE The world's first tokenized evergreen venture fund. Securitize's first paying customer. BMCP Black Manta LIVE MiFID II issuance at scale, over 4 billion euro completed. Fortuna Custody and payments IN AUTHORIZATION PROCESS In authorization with the Central Bank of Ireland. CDAT Digital Asset Treasury INFRASTRUCTURE READY Validator-treasury infrastructure ready across more than 40 networks. Revolution Revolution Network MAINNET-READY zkStack Ethereum Layer-2, mainnet-ready. What we believe Regulated by design. The license is the moat. We build to the standard first, and claim only what is real. Integrated, not assembled. The layers are worth more operated together than bought from six vendors. Early, and disciplined. We move before the category is comfortable, and we say plainly what is live and what is in process. Meet the team Investor inquiries ======================================================================== # Team URL: https://cosimodigital.com/team ======================================================================== Home / About / Team and Governance Team and Governance Investors buy the team. The people behind the licenses and the infrastructure. Rob Frasca Managing Partner and Co-Founder A technology and capital-markets operator who has lived multiple platform shifts: the early commercial internet, AI, and now digital assets. More than thirty years building, scaling, and exiting companies, with venture-backed exits to Intuit, Lycos, and Nielsen. A US Navy veteran and decorated Naval Flight Officer. BS in Engineering from Rochester Institute of Technology, and an MBA from Carnegie Mellon's Tepper School of Business. LinkedIn ↗ Ciaran Hynes Managing Partner and Co-Founder Co-founder of COSIMO Digital, and the founder of COSIMO X. A serial entrepreneur who has founded seven companies and launched 25-plus products across technology and finance, with deep international regulatory, tax, and legal experience and a background in mergers and acquisitions and deal structuring. LinkedIn ↗ Connor Cantwell Partner, Europe; Chief Executive, Fortuna Digital Custody Former Managing Director for Ireland at Nielsen, and co-founder of 20-20 Insights (acquired by Swiss Post). A career across research, analytics, and blockchain, with extensive experience in the MiFID, VASP, and MiCA regulatory environments. Leads COSIMO's European expansion and Fortuna's path to authorization with the Central Bank of Ireland. LinkedIn ↗ Founder track record · across prior ventures 13 companies 125+ products $500M+ raised 63 board roles Governance and control functions Fortuna was built by a team holding all seven pre-approved control-function roles its regime requires, each individually vetted and approved by the Central Bank of Ireland under the Fitness and Probity regime: Chief Executive, Executive Director, Head of Risk, Head of Compliance, Chief Information Officer, Internal Audit, and Money Laundering Reporting Officer. Regulatory depth is not a marketing line for us. It is who is on the team. Chief Executive Executive Director Head of Risk Head of Compliance Chief Information Officer Internal Audit Money Laundering Reporting Officer Investor inquiries ======================================================================== # Insights URL: https://cosimodigital.com/insights ======================================================================== Home / Insights Insights From the desk. Notes on tokenization, regulation, and the build of digital-asset market infrastructure. TypeAllArticlesPressVideo FeaturedArticle · Markets The Equity Layer: Why the Fat Protocol Trade Is Dead The 2016 fat protocol thesis said value would accrue to tokens. This cycle proved it accrues to the equity layer: regulated operating companies with enforceable claims on cash flows. Read more → July 2026 · 7 min read Article · Markets The end of trust intermediaries AI supplies trustless judgment, blockchain supplies trustless verification. Together they make the institutional trust layer economically unnecessary. July 2026 Article · Markets The NAV discount problem Why digital asset treasuries trade below their own assets, and the structural fix that closes the gap. July 2026 Article · Markets The ETF playbook for tokenization The wrapper wins, not the asset. The same trade the ETF ran thirty years ago, one layer down. July 2026 Article · Tokenization Issuance is solved. Distribution is the constraint. Minting is a commodity. Licensed reach and real secondary liquidity are the scarce, value-capturing layer. July 2026 Article · Regulation MiFID II or MiCA? Which license actually lets you issue tokenized securities in Europe, and why the distinction decides everything. July 2026 Article · Regulation MiCA reset the market Of 1,200-plus pre-MiCA firms, roughly 210 secured authorization. The gap is the moat. June 2026 ======================================================================== # The End of Trust Intermediaries: What AI and Blockchain Do Together URL: https://cosimodigital.com/insights/end-of-trust-intermediaries ======================================================================== Home / Insights / Article Article · Markets The End of Trust Intermediaries: What AI and Blockchain Do Together By Rob Frasca and Dr. Zdenka Cumano · July 2026 · 8 min read Picture a Tuesday a few years out. A homeowner in Austin has not opened a bank account in two years. Overnight, her household AI settled eleven thousand micro-transactions with the regional energy grid, netting her power bill to eleven cents. It rebalanced her real-estate exposure in under a second when foot-traffic sensors in one market turned down. And it did something that would have been impossible a few years earlier: it identified a risk that no existing financial instrument addressed, so it designed one, negotiated the terms with the AI agents of the counterparties, verified the structure on-chain, and activated it before she finished her coffee. No broker. No exchange. No clearinghouse. No bank. Every piece of that morning is a logical extension of technology that exists today in early form. The question is not whether this world is possible. It is how quickly it arrives, and what happens to the institutions it renders unnecessary. Why every financial institution exists Start with a claim that sounds larger than it is: every major financial institution in human history exists for one reason. Two strangers could not trust each other. Banks, insurers, exchanges, clearinghouses, title companies, credit bureaus, notaries, rating agencies. These are not features of a modern economy. They are workarounds for a constraint. They verify who you are, confirm that an asset is real, judge whether you are good for the money, and enforce the deal when parties cannot see into each other’s ledgers. They are trust intermediaries, and they have always charged a fee for the service. The economics here are settled. Ronald Coase showed in 1937 that institutions emerge when transacting directly, finding the counterparty, checking their claims, enforcing the terms, costs more than paying a third party to handle it. Oliver Williamson named the specific costs: search, bargaining, monitoring, enforcement. The implication is precise. When a technology drives all of those costs below the overhead of maintaining the intermediary, the institution does not become obsolete in principle. It becomes obsolete in arithmetic. Here is the number that should hold a financial executive’s attention. Thomas Philippon’s work in the American Economic Review found that the unit cost of financial intermediation has sat at roughly two percent of intermediated assets for 130 years. Every advance in information technology over that span, and institutions absorbed the efficiency gains rather than passing them through. Across hundreds of trillions in intermediated assets, that two percent is an implicit tax on trust, embedded in every transaction. The two problems, solved separately, then together What makes this moment different is not one technology. It is two, each solving half of a problem neither could finish alone. Blockchain solves trustless verification. It proves that something happened, exactly as specified, without relying on a third party to vouch for it. What it cannot do is decide whether the thing should happen. It gives you verifiable but unintelligent rails. AI solves trustless judgment. It assesses whether the risk is priced correctly, whether the counterparty is creditworthy, whether the asset is fairly valued, without a human in the loop. What it cannot do is prove its own work. An AI decision is a black box, and a black box is itself a trust problem. Put them together and you get something no institution has ever been able to offer: a system that can assess a complex condition, render a judgment, execute a binding action, and produce a cryptographically immutable record proving that every step, from the data going in to the logic to the execution, happened as specified. Call it verifiable intelligence. It is the first technology that can decide and prove at the same time, judge and verify, reason and enforce. When an AI agent can assess creditworthiness, encode the terms in a self-executing contract, settle on a verified ledger, and hand back an immutable audit trail, the economic case for the bank in the middle does not weaken. It collapses. The costs that justified the intermediary have fallen below the cost of keeping it. This arrives in stages, not all at once The popular version of this story is agents with digital wallets making payments. That is real, and it is early. Autonomous payment rails are live now: one agent-commerce protocol processed over 100 million transactions by late 2025, and Visa has aligned its own agent protocol with that infrastructure. But payments are one stage of a longer arc, and the later stages look nothing like today’s financial plumbing. The near term is contracts assembled dynamically by AI from libraries of audited, verified modules. Further out, contracts stop being documents and become continuous computations: an adaptive loan has no fixed rate, only a rate function that optimizes in real time against income, collateral value, and macro conditions. Further out still, AI systems begin inventing structures with no human precedent, and the neat taxonomy of finance, debt versus equity versus derivative versus insurance, starts to blur into a single category: computationally optimized, verifiable economic relationships, each adapting continuously, each provable on-chain. You can already see the direction in the data. Tokenized real-world assets grew from under 5 billion dollars in 2022 to over 26 billion in early 2026. BlackRock’s tokenized liquidity fund reached 18 billion across nine networks in under two years. BCG and others put the longer-run market in the tens of trillions. These are measured trajectories, not forecasts. The objections worth taking seriously An argument this large has to meet its strongest counterarguments honestly, and there are real ones. Incumbents co-opt disruption rather than dying to it. True, and it is already happening. JPMorgan’s settlement network, BlackRock’s tokenized fund, Visa’s agent protocol are incumbent adaptations. But co-option does not preserve the institution. It transforms it. The banks building blockchain rails are funding their own reinvention, whether they frame it that way or not. People distrust algorithms, especially after watching one err. Also true, and well documented. But the same research shows most people choose the algorithm when they have not seen it fail, and the pattern across analogous shifts is consistent: index funds, algorithmic pricing, the disappearance of the travel agent. Behavioral resistance yields to demonstrated performance, usually over a five-to-ten-year cycle. Correlated AI agents could fail together at machine speed. This is the objection that matters most, and it is not hypothetical. It is the dynamic behind the 2010 Flash Crash, the Knight Capital failure, and the August 2024 carry-trade unwind. Dissolving trust intermediaries does not remove the need for systemic oversight. It changes its shape, from regulating institutions to regulating protocols: diversity in agent training, circuit breakers at the infrastructure layer, real-time monitoring for correlated behavior before it cascades. Whoever builds this system carries a real obligation to engineer resilience into the substrate, not just efficiency. None of these are reasons the transition will not happen. They are reasons to build it with the same rigor as the technology itself. What this means for the people building it Three implications stand out. For financial institutions: separate your function from your form. The function, manufacturing trust between parties, is not going away. The form is. The institutions that survive will understand they are in the trust business, not the banking or insurance business, and will move from sitting atop the rails as gatekeepers to building and maintaining the rails themselves. For investors: position for the substrate, not the application. The market for agents that make payments is interesting. The market for the infrastructure that replaces the entire institutional trust layer is something else. Application-layer tools commoditize. The verification and settlement infrastructure underneath does not. For regulators: regulate the protocol, not the ghost of the institution. Oversight built for entities that mediate between actors does not fit a world where the protocol is the institution. That means algorithmic auditing over financial auditing, continuous monitoring over periodic examination, protocol-level standards over entity-level licenses. The regulators who adapt will set the parameters the whole system runs inside. Back to Tuesday That Tuesday does not exist yet. Its foundations are being poured now. Five thousand years of building trust through institutions, and the observable trajectories, AI compute scaling several-fold a year, tokenized assets past 26 billion and accelerating, autonomous transaction infrastructure already in production, point to a decade or less to build the substrate that makes those institutions economically unnecessary. The question is no longer whether. It is who builds the new infrastructure, who designs its ethical constraints, who ensures its resilience, and who gets left behind when Tuesday arrives. Rob Frasca is co-founder and managing partner of COSIMO Digital. Dr. Zdenka Cumano is Chief AI Officer at AI Leader Edge and professor of AI and Big Data for Executive Education at Florida Atlantic University. This article is adapted from their working paper, The End of Trust Intermediaries. Sources Ronald Coase, “The Nature of the Firm,” 1937. Thomas Philippon, “Has the US Finance Industry Become Less Efficient?”, American Economic Review. Boston Consulting Group and others, tokenized real-world asset projections and market data, 2025 to 2026. Agent-commerce transaction figures and tokenized-asset totals, per public reports, 2025 to 2026. This article is for informational purposes only. It is not investment advice, an offer to sell, or a solicitation of an offer to buy any security. Third-party figures are attributed to their sources and have not been independently verified. ← All insights · Share LinkedIn X Copy link ======================================================================== # The Equity Layer: Why the Fat Protocol Trade Is Dead URL: https://cosimodigital.com/insights/equity-layer-fat-protocol-trade-is-dead ======================================================================== Home / Insights / Article Article · Markets The Equity Layer: Why the Fat Protocol Trade Is Dead By Rob Frasca · July 2026 · 7 min read In 2016, Joel Monegro wrote the piece that defined a decade of crypto investing. The argument was clean. On the old internet, value pooled in the application layer. TCP/IP and HTTP carried the traffic and captured none of the money, while Google and Meta captured almost all of it. Web3 would invert that. Shared open protocols would hold the data and the value, applications would be thin and interchangeable, and the token, not the equity, would be the asset that appreciated. Fat protocols, thin applications. A generation of funds allocated behind that sentence. It was a good thesis. It was also, this cycle, wrong. Look at June 2026 as a natural experiment. Tokenized equity trading volume set a monthly record near 3.86 billion dollars. Over the same window, one of the largest smart-contract tokens traded roughly seventy percent below its own peak. The rails carried more real financial activity than ever, and the base-layer token that was supposed to capture that activity did not. When the infrastructure works harder and the token works less, the thesis that ties value to the token is the thing that broke. This is not a crypto problem. It is a capital-markets problem. Value accrues to whoever holds an enforceable claim on cash flows. That claim lives on a cap table, not in a protocol’s incentive schedule. Follow the money, not the narrative The cleanest evidence sits inside the products themselves. When a large retail broker launched its own chain in 2025, the on-chain revenue split told the whole story. The great majority of the economics went to the broker’s own operating entity. A modest share went to the layer-2 the chain was built on. The base layer that secured it received a rounding error, a few figures a month. The party with the license, the customers, and the distribution kept the money. The protocol kept the prestige. Now watch where actual dollars changed hands. This cycle’s defining transactions were equity acquisitions of regulated and infrastructure businesses, not token buys. A leading payments network acquired a stablecoin infrastructure firm in a deal reported near 1.8 billion dollars. A major processor acquired a stablecoin platform for roughly 1.1 billion. A large exchange group and a large brokerage each paid billions to acquire regulated venues and clearing capability. And a tokenization platform completed a New York Stock Exchange listing in July 2026, raising around 400 million dollars at a pre-money valuation near 1.25 billion. Every one of those value events settled in equity. None of them settled in a token. When you list the moments where sophisticated buyers wrote the largest checks, and every single one is an equity claim on a regulated operating business, the market has already voted. It is pricing cash flow quality, not crypto exposure. This rhymes with the fiber glut I have seen this pattern before, with different technology. Between 1999 and 2005, carriers laid an enormous amount of fiber on the belief that owning the pipe was owning the future. Most of those companies did not survive. The fiber did. The infrastructure was real and necessary, and the value it created was captured almost entirely by the layer built on top of it: the broadband economy, the application companies, and the equity holders in the businesses that used the pipe to reach customers. Base-layer crypto protocols are the fiber. They are genuinely useful, often essential, and structurally poor at capturing the value they enable. The token secures the network. The equity captures the economics. Confusing the two is the mistake the fat protocol thesis made, and it is the mistake that repriced a lot of portfolios in 2025 and 2026. The public market ran the audit Nothing tests a thesis like a listing. The 2025 to 2026 crypto IPO cohort separated cleanly into two groups. Names with recurring, regulated, fee-based revenue held their value after listing. Names whose economics were levered to trading volume and token price repriced hard once public-market discipline arrived and quarterly numbers had to clear an audit. The market was not pricing whether a company touched crypto. It was pricing whether the cash flow was durable and whether the claim on it was enforceable. That is the same question a credit committee asks about any operating business. The wrapper changed. The question did not. Where value actually pools Four things follow from the evidence. First, value pools in enforceable claims on cash flows, which means equity, not tokens. A token can capture value when a protocol has a live fee mechanism and the discipline to route revenue to holders. Most do not, and even those that do sit downstream of the operating companies that own the customer. Second, issuance is largely solved and distribution is the binding constraint. Minting a tokenized security is close to a commodity now. Reaching qualified buyers through licensed channels, and giving them a place to trade with real secondary liquidity, is the scarce capability. Tokenization without distribution is theater. Third, the scarce asset is regulated infrastructure, and its value is set by replacement cost. A MiFID II investment firm, a MiCA custody and payments authorization, a compliant settlement and identity layer: these take years and real capital to build, and they cannot be forked over a weekend. That is why the acquisition premiums land on regulated entities and not on protocols. Fourth, the demand curve behind all of this is large and early. Boston Consulting Group projects tokenized real-world assets growing from roughly 30 billion dollars today toward as much as 88 trillion dollars by 2035. Whatever the exact number, the direction is clear, and most of the layer that captures it is still private. What this means for how the market gets built The investable layer shifted from tokens to regulated operating companies, and most of that layer has not yet come public. That is the opportunity and the reason the next consolidation wave targets licensed entities rather than protocols. It is also the thesis COSIMO Digital was built on, before it was comfortable to say so. We run a regulated stack rather than a token: a BaFin-regulated MiFID II issuance and distribution business, custody and euro payments in authorization with the Central Bank of Ireland, validator-treasury infrastructure ready across proof-of-stake networks, a mainnet-ready settlement and identity layer, and the first tokenized evergreen venture fund providing operating visibility across every layer. We own the rails rather than rent them, because owning the claim is the only position that holds through an audit. The fat protocol trade is dead. What replaces it is not a better token. It is the equity layer: regulated companies with enforceable claims on real cash flows, built to carry institutional capital safely on-chain. Institutions do not adopt narratives. They adopt infrastructure. Rob Frasca is Managing Partner and Co-Founder of COSIMO Digital. Sources Joel Monegro, “Fat Protocols,” Union Square Ventures, 2016. Boston Consulting Group, tokenized real-world asset projections, 2026. Company disclosures and reported transaction values for the cited acquisitions and the referenced NYSE listing, 2024 to 2026. This article is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorizations are described as of the date stated; pending authorizations are not effective until granted. Third-party figures are attributed to their sources and are not COSIMO projections. ← All insights · Share LinkedIn X Copy link ======================================================================== # The NAV Discount Problem URL: https://cosimodigital.com/insights/nav-discount-digital-asset-treasuries ======================================================================== Home / Insights / Article Article · Markets The NAV Discount Problem: Why Digital Asset Treasuries Trade Below Their Own Assets By Rob Frasca · July 2026 · 7 min read Here is a question that should not have an interesting answer. A company holds a billion dollars of a liquid, publicly priced asset. What is the company worth? In a functioning market, about a billion dollars, plus or minus the value of the operating business around it. Yet across the digital asset treasury sector, the answer has repeatedly been: less. Sometimes far less. Companies whose entire purpose is to hold a transparent, around-the-clock priced asset have traded at persistent discounts to the very thing they hold. That is not a market anomaly. It is a structural flaw. And once you see the cause, you stop being surprised by it. The canonical case The clearest example is the Grayscale Bitcoin Trust. From February 2021 through August 2022, GBTC traded at an average discount of roughly 25 percent to its Bitcoin net asset value, reaching a low near negative 49 percent in July 2022. This was not a brief dislocation on a bad afternoon. It was an eighteen-month structural mispricing that affected more than 20 billion dollars in shareholder value. Why did it persist? Because GBTC shareholders had no redemption mechanism. They could not convert their shares into Bitcoin. They were locked in a closed-end structure where the only exit was selling to another investor at whatever discount the market offered that day. Arbitrageurs could not close the gap, because there was no pathway from cheap shares to the underlying asset. In a normal market, arbitrage enforces convergence. Here the arbitrage was structurally impossible, so the discount simply sat there, quarter after quarter, destroying value that was real on paper and unreachable in practice. Even an operating company is not immune The response I hear is that GBTC was a passive trust, and an operating company is different. It is, but not enough. Consider the best-known corporate Bitcoin holder. In strong markets it has traded at a large premium to its Bitcoin holdings. But during crypto corrections it has periodically fallen below net asset value, briefly trading under one times its Bitcoin NAV as recently as November 2025. Because it is an operating company with cash flows and strategic optionality, the discounts are shallower and shorter than GBTC’s. But they occur. And when they do, shareholders have no mechanism to force convergence. They can only wait, or sell. The pattern holds across the sector. When confidence is high, these vehicles trade at a premium. When it falters, the discount returns. The equity behaves like a sentiment-driven derivative of the asset rather than a direct claim on it. The structural cause The reason is mechanical, not psychological. Traditional equity cannot interact with a crypto asset. Think about what it would take to hand the underlying to a shareholder. A retail investor holds ten shares through a brokerage app. Their proportional claim might be a tiny fraction of a coin. The brokerage does not custody the asset. The investor may not have a wallet. The chain of intermediaries between that shareholder and the asset runs through the broker, the central depository, the company, and its custodian. Five links, each adding friction, and at the end of it there is still no clean, compliant, low-cost way to deliver the asset itself. Distributing crypto to shareholders also raises unresolved tax and securities questions that most boards will not touch. So the equity becomes a synthetic derivative of asset ownership rather than a direct claim on it. When market confidence drops, the derivative can trade at a persistent discount to the underlying, and there is no arbitrage pathway to force it back. That is the whole problem in one sentence. If you cannot redeem, you do not have price discipline. Why the usual fixes fail Companies have tried to manage the discount, and the tools all fall short in the same way. Buybacks are slow, capital-intensive, and consume balance sheet that could otherwise compound. Dividends require converting the asset to cash first, which triggers a taxable event and surrenders the compounding that was the point of holding the asset. Management intervention is discretionary. It cannot be relied on as systematic protection, because it depends on a decision each time rather than a mechanism that runs on its own. Every one of these is an attempt to patch a structural flaw with activity. Markets do not fix structural flaws with activity. Architecture fixes them. The structural fix: two rails, one security The answer is to design the discount out of the instrument from the start. That means issuing equity that exists simultaneously on two rails: a conventional listed share, and an economically and legally identical share that lives on-chain. Same voting rights, same economic interest, same instrument, two settlement environments. On the on-chain rail, the share can carry a redemption path to the underlying asset basket at net asset value. That single design change restores the arbitrage that GBTC never had. If the listed share trades below NAV, an arbitrageur can buy the cheap share, move to the on-chain version, redeem for the underlying at NAV, and capture the difference. That activity closes the discount mechanically, without management having to do anything. The escape hatch is built into the security rather than promised by a press release. This is the architecture COSIMO built into its digital asset treasury infrastructure. To be precise about status: that infrastructure is ready, not operational. It is not generating yield, and nothing here is a return projection. The point is narrower and more durable than any yield number. It is that the NAV discount, the flaw that has cost digital asset treasury shareholders billions, is not a law of nature. It is a consequence of using equity rails that cannot touch the asset, and it can be engineered away. Why this matters now The digital asset treasury category has gone from a novelty to a crowd. Hundreds of public companies now hold digital assets on their balance sheets, the large majority concentrated in a single asset. Most of them carry the exact structural flaw described above, because they were assembled from conventional equity rails that were never designed to settle or distribute a programmable bearer asset. As the category grows, the discount problem grows with it. The firms that solve it will not be the ones with the loudest treasury strategy. They will be the ones whose equity can actually reach the asset. Markets do not reward intentions. They reward instruments that behave correctly when confidence breaks. Architecture is the difference between a treasury that holds value and one that leaks it. Rob Frasca is Managing Partner and Co-Founder of COSIMO Digital. Sources Grayscale Bitcoin Trust discount data, February 2021 to August 2022, per public market records. Reported market-to-NAV levels for the referenced corporate Bitcoin holder, including November 2025. Public company disclosures on digital asset treasury holdings, 2024 to 2026. This article is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. References to COSIMO infrastructure describe capabilities that are infrastructure-ready and not operational; pending authorizations are not effective until granted. Nothing here is a projection of yield or return. Third-party figures are attributed to their sources. ← All insights · Share LinkedIn X Copy link ======================================================================== # The ETF Playbook for Tokenization URL: https://cosimodigital.com/insights/etf-playbook-tokenization-wrapper-wins ======================================================================== Home / Insights / Article Article · Markets The ETF Playbook for Tokenization: The Wrapper Wins, Not the Asset By Rob Frasca · July 2026 · 7 min read The most useful thing you can do to understand tokenization is to stop staring at the token and study the ETF. The argument being had about tokenized assets right now, that they are redundant because they deliver the same exposure as the traditional version, is not a new argument. It was had thirty years ago about exchange-traded funds. The people who lost that argument were sophisticated incumbents. The people who won it are, today, the three largest asset managers on earth. That is worth understanding before you decide which side you are on this time. The argument the incumbents lost The first ETF launched in 1993. For most of the decade that followed, it grew steadily but unremarkably. Global ETF assets were still below 100 billion dollars by 2000. To the incumbents running index mutual funds, this was confirmation of what they already believed: the product was economically redundant. An S&P 500 ETF gave an investor exactly the same exposure as an S&P 500 index fund. Same holdings, same benchmark, same returns. Why would a wrapper around identical exposure ever matter? They were completely right about the exposure. They were completely wrong about everything that turned out to matter. What they dismissed as redundant carried a structural advantage that had nothing to do with what the fund held: intraday liquidity, in-kind creation and redemption, tax efficiency, and exchange-based tradability. The innovation was never the asset. It was the operating model wrapped around the asset. And the operating model was better in ways that compounded. The inflection was distribution, and then it was scale The ETF did not go vertical because the market suddenly appreciated its cleverness. It went vertical when it was integrated into distribution: model portfolios, advisory platforms, and retirement accounts. Once the wrapper was embedded in the channels through which capital actually moves, adoption accelerated. Global ETF assets went from roughly 400 billion dollars in 2005 to around 7 trillion by 2020 and to something like 11 to 12 trillion by 2025. In US equities, ETFs now routinely account for 40 to 50 percent of daily trading volume. The redundant wrapper became the market. Then came the part that should hold every builder’s attention. The first movers captured the upside, and they kept it. State Street, iShares, now part of BlackRock, and Vanguard together control roughly 75 to 80 percent of global ETF assets. Early scale created advantages that fed on themselves: tighter spreads, deeper liquidity, inclusion in model portfolios, and lower unit costs, each of which attracted more assets, which tightened spreads further. The wrapper stopped being a product and became core infrastructure, and the firms that built it early own it in a way latecomers have never been able to dislodge. Those figures and history are drawn from Boston Consulting Group’s work on the sector. Now run the same tape on tokenization The dismissal today is word for word the one the ETF received. A tokenized bond is just a bond. A tokenized fund is just a fund. Same exposure, same cash flows, so what is the point. And once again, the objection is right about the exposure and blind to the operating model. What tokenization changes is the same category of thing the ETF changed: how the instrument settles, trades, and moves. Programmable settlement instead of a multi-day cycle. Trading that is not confined to market hours. Atomic settlement that removes counterparty risk from the exchange of value. Composability, so an instrument can plug directly into other on-chain systems. And, where it is built correctly, a genuine secondary market with liquidity the traditional private version never had. None of that changes what the asset is. All of it changes what the asset can do. That is exactly the move the ETF made, one layer down. The innovation is the wrapper. Again. What this predicts I try not to make predictions. I try to identify inevitabilities, which are just patterns that have already resolved once and are resolving again. Here is the one this points to. The value will not accrue to the asset, because the asset does not change. A tokenized treasury bill is the same treasury bill. The value will accrue to the operating layer that owns the better wrapper and the distribution around it, precisely as it did with the ETF. And the concentration pattern will repeat. The firms that build regulated tokenization infrastructure early, the licensed rails for issuing, distributing, custodying, and trading these instruments, will hold a disproportionate and self-reinforcing share, for the same compounding reasons the early ETF providers did. Liquidity attracts liquidity. Distribution attracts assets. Regulatory standing, in this version, is the moat that early scale was in the last one, and it is harder to replicate than scale ever was. Set that against the demand curve. Boston Consulting Group projects tokenized real-world assets growing from roughly 30 billion dollars today toward as much as 88 trillion by 2035 in its progressive scenario. Whether the number is 88 trillion or a fraction of it, the shape is the same shape the ETF drew: a slow start that incumbents mistake for a ceiling, an inflection driven by distribution, and a small group of early builders capturing most of the durable value. The takeaway The ETF did not win by changing the asset. It won by changing the operating model around the asset, and then by being integrated into distribution before the incumbents took it seriously. Thirty years of value flowed to the firms that saw the wrapper for what it was and built it first. Tokenization is the same trade, one layer down, and it is early enough that the wrapper is still being built. So the question to ask about any tokenization business is not what asset it puts on-chain. It is whether it owns the operating model and the distribution that the value will actually pool into. Study the wrapper, not the token. That is where this went last time, and markets do not usually change their mind about where value lives just because the technology has a new name. Rob Frasca is Managing Partner and Co-Founder of COSIMO Digital. Sources Boston Consulting Group, ETF market history and tokenized real-world asset projections, 2026. Public market data on ETF assets and US equity trading volume, per BCG and market records. This article is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Third-party figures are attributed to their sources and are not COSIMO projections. Regulatory authorizations referenced elsewhere on this site are described as of their stated date; pending authorizations are not effective until granted. ← All insights · Share LinkedIn X Copy link ======================================================================== # Issuance Is Solved. Distribution Is the Binding Constraint. URL: https://cosimodigital.com/insights/issuance-solved-distribution-binding-constraint ======================================================================== Home / Insights / Article Article · Tokenization Issuance Is Solved. Distribution Is the Binding Constraint. By Rob Frasca · July 2026 · 7 min read Ask most people what is hard about tokenization and they will describe the token. The standard, the smart contract, the chain, the wrapper. It is where the engineering attention goes and where most of the pitch decks spend their pages. It is also, at this point, the solved part. Minting a tokenized security in 2026 is close to a commodity. The standards exist, the platforms exist, the legal structures are known, and the marginal cost of issuing one more instrument keeps falling. The hard part is the part almost no one talks about. Once you have issued the token, who is allowed to buy it, how do you reach them, and where do they go to sell it? That is distribution, and distribution is the binding constraint on this entire market. Issuance is solved. Distribution is not. Everything that matters about whether tokenization succeeds lives in that gap. This is a capital-markets problem, not a crypto problem The confusion comes from treating tokenization as a technology story. It is a capital-markets story wearing new technology, and capital markets already settled this question a century ago. Printing a security was never the business. Any competent lawyer can paper a bond. The franchise, the thing investment banks are actually paid for, is underwriting, placement, and making a secondary market. The value was always in reaching the buyers and standing behind the liquidity, not in producing the certificate. That is why the league tables rank distribution, not document preparation. Tokenization changed the printing. It did not change the economics of who gets paid. The instrument is easier to create than ever, which means creating it is worth less than ever. The scarce capability moved to exactly where it has always been in capital markets: getting the instrument into the right hands and giving those hands a place to trade. Why distribution is genuinely hard Distribution in this market is not a marketing budget. It is three regulated, scarce things stacked together. First, you need licensed channels. You cannot email a security token to retail investors and call it distributed. Reaching buyers with a financial instrument is a regulated activity, and doing it across a market the size of Europe requires authorizations that most issuance platforms do not hold. The permission to distribute is itself the scarce asset. Second, you need reach to qualified buyers at scale. A single issuance placed with a handful of funds is not distribution, it is a private placement with extra steps. Real distribution means access to a large, addressable base of eligible buyers, which very few platforms can assemble. Third, and hardest, you need a venue with genuine secondary liquidity. This is the promise tokenization makes and the part it most often fails to deliver. A token that can be issued but not readily traded is a worse version of a private placement: illiquid, but now also on a blockchain. Liquidity is not a feature you bolt on afterward. It is the whole reason an investor accepts a tokenized instrument over a traditional one, and it is the single most difficult thing to build. Miss any one of these and you do not have a tokenization business. You have a minting service. Tokenization without distribution is theater I use that line often because it keeps being true. The industry has produced an enormous volume of issuances that went nowhere, because the teams behind them solved the easy problem and assumed the hard one would take care of itself. It never does. An asset that is tokenized but cannot be distributed to buyers or traded in a secondary market has gained nothing from being on-chain. It has taken on new operational complexity in exchange for a liquidity promise it cannot keep. The tell is always the same. When a firm leads with the sophistication of its issuance technology and goes quiet on where the buyers come from and where they trade, the distribution is not there. And if the distribution is not there, the tokenization is decoration. What solving it actually looks like Solving distribution means building the licensed reach and the trading access that issuance-only platforms cannot. It is slow, regulated work, which is exactly why it is scarce and exactly why it is where the value pools. This is the part of the stack COSIMO built for directly. Black Manta Capital Partners operates as a BaFin-regulated Financial Services Institution (WpIG), with MiFID II passporting across the EEA, and has completed more than 4 billion euros in tokenized issuance. But the issuance figure is not the differentiator. The differentiator is the distribution network built around it: a tied-agent structure that extends reach to exchange-scale audiences, with agents live on KuCoin and Bitget and a further relationship in negotiation. That is distribution at a scale a pure issuance platform cannot reach, connected to the licensed permission that makes distributing a security lawful in the first place. The point is not the specific names. It is the shape of the thing. An authorization that permits distribution, plus a network that delivers reach, plus the venues where instruments can actually trade. That combination is rare because each piece is hard, and the combination is harder than the sum. Where this leaves the market If issuance is commoditized and distribution is scarce, then value accrues to whoever controls distribution, not to whoever can issue. That is the strategic conclusion, and it predicts the direction of the next consolidation wave. The acquisitions worth making are not for better minting technology, which is abundant and cheapening. They are for licensed distribution and for liquidity venues, which are neither. For allocators and institutions evaluating this space, the diligence question is simple and clarifying. Do not ask what a firm can issue. Ask who it can reach, under what authorization, and where those instruments trade once issued. The answer to that question separates the tokenization businesses from the minting services, and it is the only part of the story that was ever going to be hard. Issuance is solved. Distribution is the binding constraint. It is also the whole game. Rob Frasca is Managing Partner and Co-Founder of COSIMO Digital. Sources COSIMO Digital and Black Manta Capital Partners regulatory authorizations and issuance figures, described as of the date stated. This article is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorizations are described as of the date stated; pending authorizations are not effective until granted. ← All insights · Share LinkedIn X Copy link ======================================================================== # MiFID II or MiCA: Which License Lets You Issue Securities in Europe URL: https://cosimodigital.com/insights/mifid-ii-or-mica-tokenized-securities ======================================================================== Home / Insights / Article Article · Regulation MiFID II or MiCA: Which License Actually Lets You Issue Securities in Europe By Ciarán Hynes · July 2026 · 7 min read The most expensive misunderstanding in European tokenization is a licensing one. A firm decides to tokenize a bond, a fund, or an equity, secures a MiCA authorization, and believes it is cleared to issue and distribute the instrument across Europe. It is not. A MiCA authorization does not permit you to issue a security. The two regimes govern different things, and confusing them puts everything downstream on the wrong legal footing. This is not a technicality. It is the first competence test in this market, and a surprising number of well-funded firms fail it. What MiCA actually covers, and what it deliberately does not The Markets in Crypto-Assets Regulation, which began applying across the EU through 2024, was written to bring order to a category that previously had almost none. It covers crypto-assets that are not already financial instruments: utility tokens, asset-referenced tokens, and e-money tokens, along with the services around them such as custody, exchange, and transfer. A firm that provides those services registers as a Crypto-Asset Service Provider, a CASP. The crucial word in that description is “not.” MiCA was drafted to sit alongside the existing financial regulatory framework, not to replace it. So it carves out, explicitly, any crypto-asset that already qualifies as a financial instrument. If your token is a security, MiCA steps back by design and hands the question to the regime that already governs securities. A security token is a security first, and a token second This is the point the market keeps missing. When you tokenize a bond, the tokenization does not change what the instrument is. It is still a bond. It is still a transferable security, which means it is a financial instrument under the Markets in Financial Instruments Directive, MiFID II. The blockchain is the settlement and record-keeping technology. It is not a new legal category that escapes securities law. So a tokenized equity, a tokenized fund interest, a tokenized note: each is a financial instrument, and each is governed by MiFID II. Issuing, arranging, placing, and distributing those instruments requires the authorizations that MiFID II defines, held by an authorized investment firm. A CASP authorization does not grant any of those permissions, because a CASP, by definition, deals in the crypto-assets that are not financial instruments. It is the correct license for the wrong asset. Put plainly: if you can only offer a MiCA CASP authorization and your product is a security token, you are not authorized to do the thing you are selling. Why the passport makes this decisive rather than academic Both regimes share one powerful feature. They passport. A single authorization in one member state extends across the EEA, without re-authorizing country by country. This is what makes Europe a genuine single market for these activities, and it is why holding the right license is such a durable advantage. But the passport only carries the permissions the license actually contains. A MiCA CASP passport lets you provide crypto-asset services across the Union. A MiFID II passport lets you conduct investment services in financial instruments across the Union. One authorization, twenty-seven markets, in each case. What one cannot do is stand in for the other. A firm passporting a CASP authorization across Europe still cannot issue or distribute a security token anywhere in Europe, because that permission was never in the license to begin with. For an issuer, this is the difference between a product you can lawfully bring to market across the EU and one you cannot bring to market at all. The two regimes are complementary, not interchangeable None of this means MiCA is unimportant to a securities business. It means the two regimes do different jobs, and a complete tokenized-securities operation needs both. MiFID II governs the security itself: the issuance, the arranging, the placement, the distribution. MiCA and the payments framework govern the crypto-asset layer around it: the custody of crypto-assets and the euro on-ramps and off-ramps that let value move on-chain and settle in fiat. A firm that can issue a tokenized bond under MiFID II but cannot custody crypto-assets or settle in euros under the right authorizations has only half the stack. A firm with the crypto authorizations but no MiFID II permission has the other half, and cannot touch a security. The regimes are two halves of one operation. Understanding that is the difference between assembling a compliant tokenized-securities business and discovering, after the build, that the licenses do not connect. How this looks when it is built correctly At COSIMO Digital we structured for both regimes deliberately, because the distinction above is not abstract to us. It is the architecture. Black Manta Capital Partners is a BaFin-regulated Financial Services Institution (WpIG), with MiFID II passporting across the EEA. That is the authorization that permits the issuance and distribution of tokenized securities across Europe, and it is the reason the group can bring security tokens to market as securities, under the regime that actually governs them. Its authorization is for the investment activity; securities custody is arranged through partner custodian arrangements rather than held as a standalone service. Fortuna Digital Custody sits on the other half. It is progressing through authorization with the Central Bank of Ireland, which has indicated it is minded to authorize the firm for MiCA CASP status and as a payment institution under PSD2. Those authorizations are pending and not yet effective. When granted, they would provide crypto-asset custody and euro payment rails, the crypto-asset layer that complements the MiFID II securities activity. We describe them as pending because they are, and because the distinction between a granted authorization and a promised one is exactly the kind of precision this whole subject demands. Two regimes, two authorizations, one integrated operation. That is not redundancy. It is what issuing tokenized securities in Europe actually requires. The takeaway Before a single token is minted, the first question is not technical. It is legal. What is the asset, and which regime governs it? If it is a financial instrument, MiFID II applies and a crypto authorization will not substitute. If it is a crypto-asset that is not a financial instrument, MiCA applies. Most real tokenization businesses touch both, and need authorizations under both. Get that first question right and the rest of the build has a foundation. Get it wrong and you have licensed the wrong activity, at real cost, before you have issued anything at all. Ciarán Hynes is Managing Partner and Co-Founder of COSIMO Digital. Sources Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), application through 2024. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II). COSIMO Digital regulatory authorizations, described as of the date stated. This article is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorizations are described as of the date stated; pending authorizations are not effective until granted. This article is a general description of the regulatory framework and is not legal advice. ← All insights · Share LinkedIn X Copy link ======================================================================== # MiCA Reset the Market URL: https://cosimodigital.com/insights/mica-reset-licensed-minority ======================================================================== Home / Insights / Article Article · Regulation MiCA Reset the Market. The Licensed Minority Captures the Transition. By Ciarán Hynes · June 2026 · 6 min read MiCA is usually described as the moment Europe gave crypto a rulebook. That is true, but it understates what actually happened. The Markets in Crypto-Assets Regulation did not simply write rules for the firms already operating. It reset the population of firms permitted to operate at all. The market that existed before MiCA and the market that exists after it are not the same market with better paperwork. They are two different markets, and most of the first one did not make it into the second. That transition, from a crowded field to a short authorized list, is the single most important fact about the European digital asset market today. It decides who captures the wave of institutional tokenization now arriving. The number that tells the story Before MiCA, thousands of firms operated across the EU under a patchwork of national registrations of varying rigor. After MiCA, the picture is far narrower. Of more than 1,200 firms that held pre-MiCA registrations, roughly 210 have secured MiCA CASP authorization across the Union, according to the ESMA register. Approximately one in six. The instinct is to read that as attrition, a sector shrinking. It is the opposite. The authorized firms are not a smaller version of the old market. They are the firms that could meet a standard the old market never had to. The five out of six that did not clear the bar were not unlucky. They were operating models that the new regime does not permit. The gap between 1,200 and 210 is not a loss. It is the moat. What the bar actually filters for A MiCA authorization is not a registration you file for and receive. It is a standard you have to meet and keep meeting. It requires real capital, defined governance, and a set of control functions staffed by individuals who are themselves vetted and approved: risk, compliance, information security, internal audit, anti-money-laundering, and the senior executives accountable for all of it. Regulators assess the people, not just the entity. This is where the depth is easy to underestimate. It is one thing to describe a compliance function on a slide. It is another to have each control-function role individually assessed and approved by a national competent authority under a fitness-and-probity standard, before the firm is authorized to operate. That process takes years and cannot be compressed with capital alone, because the regulator sets the pace. It is precisely the kind of work that does not photograph well and cannot be skipped. That is the real reason the authorized list is short. The bar was never the application. It was the institution behind it. Why the timing makes this decisive A scarce authorization would matter less if demand were flat. It is not. The institutions now entering tokenization, the banks and asset managers moving real assets on-chain, need licensed rails, and they need them faster than they can build them. Building an authorized European operation from scratch is a multi-year process even for a large institution, and it runs at the regulator’s speed rather than the market’s. Set that against the demand curve. Boston Consulting Group projects tokenized real-world assets growing from roughly 30 billion dollars today toward as much as 88 trillion dollars by 2035 in its progressive scenario. Whatever the precise figure, the direction is not in doubt, and the capital behind it is institutional. So the market is arriving at a moment when demand for compliant infrastructure is accelerating and the supply of firms authorized to provide it is, by design, small and slow to grow. Scarce supply, rising institutional demand, a passport that turns one authorization into access across 27 markets. That is the structure of the opportunity, and it favors the firms already inside the authorized list rather than those still queuing to join it. Replacement cost, not revenue multiple The right way to value a position in this market is not by projecting near-term revenue. It is by asking what it would cost a competitor to replicate the regulatory standing, in years and in capital, assuming they could get the vetted people at all. A MiCA authorization is not a product feature. It is a replacement-cost asset. Its scarcity is enforced by the regulator, which is the most durable moat there is, because no amount of funding lets a competitor move faster than the authorization process allows. This reframes what the licensed minority actually owns. It is not a head start on a product. It is a position that the majority of the market is structurally barred from occupying. Where COSIMO sits in this We built for this regime deliberately, and we did the work before it was required. Within the group, Black Manta Capital Partners operates as a BaFin-regulated Financial Services Institution (WpIG), with MiFID II passporting across the EEA, which is the authorization that governs tokenized securities. Fortuna Digital Custody is progressing through authorization with the Central Bank of Ireland, which has indicated it is minded to authorize the firm for MiCA CASP status and as a payment institution under PSD2. Those authorizations are pending and not yet effective, and we describe them that way because the difference between granted and pending is the whole point of a regime like this one. The relevant fact is directional. The group is positioned inside the licensed layer, not waiting outside it, at a moment when that layer is where the transition concentrates. The takeaway MiCA did not slow the European market. It concentrated it. The firms that treated regulation as a feature rather than an obstacle, and did the long, unglamorous authorization work ahead of the deadline, now sit in a short list that the arriving institutional capital has to go through. The transition belongs to the licensed minority. That was always the design, and it is now the reality. Ciarán Hynes is Managing Partner and Co-Founder of COSIMO Digital. Sources ESMA MiCA register, 2026, for authorized CASP figures. Boston Consulting Group, tokenized real-world asset projections, 2026. COSIMO Digital regulatory authorizations, described as of the date stated. This article is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorizations are described as of the date stated; pending authorizations are not effective until granted. Third-party figures are attributed to their sources and are not COSIMO projections. ← All insights · Share LinkedIn X Copy link ======================================================================== # Learn — How tokenization actually works in Europe URL: https://cosimodigital.com/learn ======================================================================== Home / Learn Learn How tokenization actually works in Europe. Tokenization in Europe is not one regime. Securities sit under MiFID II. Crypto-assets that are not securities sit under MiCA. Custody, settlement and fund administration each carry their own permissions. This section explains each piece plainly, one question at a time, and states what is live and what is pending. Last updated: 28 July 2026 Jump to Tokenized funds and private markets European regulation Custody, settlement and operations Digital asset treasury Glossary Reference 30 terms Tokenization glossary: MiCA, MiFID II and digital asset terms defined Thirty definitions covering the vocabulary of European tokenization, from asset-referenced token to on-chain register, each written to be read in isolation. Open the glossary → Tokenized funds and private markets How a fund becomes a token, and what stays exactly the same when it does. How does fund tokenization work in Europe? The mechanics end to end: legal wrapper, manager, register, transfer restrictions and settlement. Updated 28 July 2026 What is the difference between a tokenized fund and an ETF? Both are wrappers. They differ in who can hold them, how they trade and how title moves. In preparation How do subscriptions and redemptions work in a tokenized fund? Where the NAV strike, the cash leg and the on-chain register meet, and where they still do not. In preparation What does a four-year-old tokenized fund prove? COSIMO X has been live since 2021 and listed on Securitize Markets since December 2021. What that record shows. In preparation European regulation Which regime applies, who has to be authorised, and what is still pending. Does MiCA apply to tokenized securities? No. Security tokens are financial instruments under MiFID II. MiCA excludes them by its own terms. In preparation What is a MiCA CASP authorisation and who needs one? The services in scope, the passport it carries, and why a national VASP registration is not the same thing. In preparation What is the DLT Pilot Regime and who is using it? The exemptions it grants, the volume caps it imposes, and what it was built to prove. In preparation How many firms have MiCA authorisation? Roughly 210 of approximately 1,200 pre-MiCA firms, about one in six. What happened to the rest. In preparation Custody, settlement and operations The unglamorous layer that decides whether an institution can hold any of it. Who can custody tokenized securities in Europe? Custody of a financial instrument and custody of a crypto-asset are different permissions. Which one applies. In preparation What is atomic settlement and does it work today? Delivery versus payment inside one transaction, and the reason the cash leg is the hard part. In preparation How is investor identity checked before a token transfer? Whitelisting, permissioned transfer and the standards that enforce eligibility at the token level. In preparation What does a transfer agent do for a tokenized fund? The register still needs an accountable owner. On-chain does not mean unowned. In preparation Digital asset treasury Balance-sheet discipline for digital assets, and how the market prices it. What is a digital asset treasury? A policy, a custody framework and a reporting line, not a product. In preparation Why do digital asset treasuries trade below NAV? What mNAV measures, and the structural reasons a discount opens and persists. In preparation What belongs in a digital asset treasury policy? Custody, counterparty limits, liquidity ladders, valuation and disclosure. In preparation Where these explanations come from COSIMO Digital builds and operates licensed rails that take real-world assets from issuance through custody, settlement and asset management. Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities. It is live today. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process. COSIMO X, a tokenized evergreen venture fund, has been live since 2021 and listed on Securitize Markets in December 2021. These pages describe the framework we work inside every day. Read the group's regulatory authorisations and their exact status , how BaFin-regulated issuance of tokenized securities works in practice, or the market notes in Insights . COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ======================================================================== # How does fund tokenization work in Europe? URL: https://cosimodigital.com/learn/how-fund-tokenization-works ======================================================================== Home / Learn / Fund tokenization Tokenized funds and private markets How does fund tokenization work in Europe? A tokenized fund is a fund whose register of holders is kept on a distributed ledger. The legal wrapper, the manager's authorisation and the investor-protection obligations are unchanged. What changes is how title moves, how fast it settles, and how continuously the register can be reconciled. Last updated: 28 July 2026 By Ciarán Hynes · 9 min read On this page How does fund tokenization work in Europe? Does tokenizing a fund change its regulatory status? Who keeps the register of holders in a tokenized fund? How are transfer restrictions enforced on-chain? How does settlement work in a tokenized fund, and what is still missing? Why tokenize a fund at all? How does fund tokenization work in Europe? Fund tokenization has four moving parts. First, a fund is established in a normal European legal form, most often a Luxembourg or Irish alternative investment fund, occasionally a securitisation vehicle. Second, an authorised manager is appointed, along with a depositary and an administrator, exactly as in a conventional structure. Third, the units or shares of that fund are issued as tokens on a ledger, and that ledger record becomes the register of holders. Fourth, eligibility rules are written into the token itself, so a unit cannot move to a holder who fails the fund’s investor tests. Nothing in that sequence is a workaround. The fund documentation still governs the economics. The manager is still accountable under Directive 2011/61/EU (AIFMD) , or under Directive 2009/65/EC (UCITS) where the fund is retail and its assets are eligible. Where units are offered or placed to investors, the firm doing the placing needs investment-services permissions under Directive 2014/65/EU (MiFID II) . The practical consequence is narrow and useful. The holder list is a live object rather than a file reconstructed at each cut-off. Transfers can be validated before they execute instead of corrected afterwards. Subscription and redemption cycles compress, because the register no longer has to be reconciled across several sets of books. That is the whole benefit, and it is enough. $88 trillion Projected value of tokenized real-world assets by 2035. Boston Consulting Group, 2025. BCG, on-chain asset tokenization Does tokenizing a fund change its regulatory status? No. A tokenized fund unit is a financial instrument, and it is regulated as one. The token is a form of record-keeping, not a new asset class. If the unit was a transferable security before tokenization, it remains a transferable security after, and MiFID II applies to its issuance, placement and trading. This is where most European projects go wrong. MiCA, Regulation (EU) 2023/1114 , creates a single regime for crypto-asset service providers and for issuers of asset-referenced and e-money tokens. It expressly excludes crypto-assets that qualify as financial instruments. A MiCA CASP authorisation therefore does not permit a firm to issue or place tokenized fund units. Classification questions are settled against MiFID II and the guidance of the European Securities and Markets Authority , not against MiCA’s categories. The two regimes are not alternatives to choose between. A group that both issues tokenized securities and holds crypto-assets for clients needs permissions under each. In our own group, Black Manta Capital Partners is BaFin -licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process. The first is live. The second is not yet effective and will not be until granted. Who keeps the register of holders in a tokenized fund? A named, accountable party keeps it. On-chain does not mean unowned. The ledger can hold the record, but the legal responsibility for the register’s accuracy sits with the transfer agent or registrar appointed under the fund documentation, and the depositary’s oversight duties are unchanged. What changes is the shape of the work. In a conventional fund, the register is authoritative in the transfer agent’s system, and every other participant holds a copy that drifts between reconciliations. In a tokenized fund, the ledger is the single record all participants read from, so drift is structurally harder. Corporate actions, distributions and holder reporting can be driven from that record directly. Legal recognition of an on-chain register still varies by member state. Some jurisdictions have amended company or securities law to recognise a distributed ledger as the register of a security; others have not, and the on-chain record operates alongside a legally authoritative off-chain one. This is a jurisdiction-selection question at structuring time, not a technology question. It is also the reason fund domicile decisions in tokenization are made early and with counsel. How are transfer restrictions enforced on-chain? Eligibility is checked by the token before the transfer executes. A permissioned token validates the receiving address against a set of on-chain rules — verified identity, jurisdiction, investor category, holding period, holder count — and rejects any transfer that fails. The standard most commonly used for this in Europe is ERC-3643. The effect is that securities-law restrictions survive on a public ledger. A fund unit restricted to professional investors in a defined set of jurisdictions cannot reach a retail wallet, because the transfer never completes. Maintaining the list of eligible addresses, usually called whitelisting, is a continuing obligation: sanctions screening, investor-category re-verification and jurisdiction changes all have to flow into it. This is the part that makes institutional participation possible and it is the part most often skipped. A token that transfers freely is not a compliant securities register in Europe, whatever the offering documents say. Enforcement at the token level is what allows a fund to be transferable and restricted at the same time — the condition every regulated secondary market has always operated under. How does settlement work in a tokenized fund, and what is still missing? The asset leg settles on the ledger in seconds. The cash leg usually does not, and that gap is the honest state of the market. True delivery versus payment inside one transaction requires both legs on the same ledger. Where the cash leg is a bank transfer, settlement is still two processes stitched together, and principal risk remains between them. Two things are closing the gap. The first is tokenized cash: e-money tokens under MiCA and tokenized deposits give the cash leg a ledger representation, which makes atomic settlement achievable rather than theoretical. The second is market-infrastructure reform. Regulation (EU) 2022/858, the DLT Pilot Regime , lets a market infrastructure trade and settle tokenized financial instruments with targeted exemptions from requirements in Regulation (EU) 909/2014 (CSDR) that assume a central securities depository. It carries volume caps and a time limit, because it was built to generate evidence for permanent reform rather than to be the destination. For a fund, the practical position today is this: the register and the transfer mechanics are ready, the cash leg is improving, and the settlement benefit is real but partial. Any firm claiming instant end-to-end settlement of a European fund unit against fiat should be asked which ledger the cash sits on. Why tokenize a fund at all? Because the register is the constraint in private markets. Private funds are slow to subscribe to, slow to transfer, and effectively illiquid between reporting dates — not because the assets are exotic, but because ownership records are maintained manually across several parties. Putting the register on a ledger addresses that specific problem and does not pretend to address others. The honest case is narrow: faster onboarding and redemption cycles, a continuously reconcilable holder list, cheaper administration at scale, and the possibility of a regulated secondary market where transfer restrictions are enforced automatically rather than by review. Liquidity is not created by tokenizing. It appears only if licensed distribution and a venue exist, which is a separate build. Evidence matters more than argument here. COSIMO X is a tokenized evergreen venture fund, live since 2021 and listed on Securitize Markets in December 2021 — four years of operating history through two market cycles. Very few firms can point to a tokenized fund that has been running that long. Read next how the vocabulary of tokenized funds and MiCA is defined , how BaFin-regulated issuance of tokenized securities operates, or where tokenized fund and asset management sits in the group. Related Tokenization glossary: MiCA, MiFID II and digital asset terms defined Thirty definitions, each written to be read on its own. COSIMO Digital regulatory authorisations and their exact status What is licensed, what is registered, and what is in process. MiFID II or MiCA: which licence lets you issue tokenized securities in Europe The classification question, settled. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), EU Official Journal, 2023. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II), EU Official Journal, 2014. Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), EU Official Journal, 2011. Regulation (EU) 2022/858 on a pilot regime for market infrastructures based on distributed ledger technology, EU Official Journal, 2022. Regulation (EU) 909/2014 on central securities depositories (CSDR), EU Official Journal, 2014. Boston Consulting Group, projection of $88 trillion of tokenized real-world assets by 2035, 2025. COSIMO Digital regulatory authorisations, described as of 28 July 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # How to tokenize a fund in Europe: the complete 2026 process URL: https://cosimodigital.com/learn/how-to-tokenize-a-fund ======================================================================== Home / Learn / How to tokenize a fund Tokenized funds and private markets How to tokenize a fund in Europe Tokenizing a fund in Europe takes three to six months and costs €120,000 to €400,000 for a first issuance. The work is not the token. It is the wrapper, the classification, the register owner, the depositary and the cash leg. This is the process, in order, with the timeline and the fees. Last updated: 28 July 2026 By Ciarán Hynes · 16 min read On this page What does it actually mean to tokenize a fund? Which EU legal wrapper do I need — UCITS, AIF, SPV or securitisation vehicle? Is my instrument a MiCA crypto-asset or a MiFID II financial instrument? Who issues, who registers, who custodies and who settles? What does the timeline look like, week by week? What does it cost, and what are the ongoing fees? How do investors subscribe and redeem? What goes wrong, and how do you avoid it? What does it actually mean to tokenize a fund? Tokenizing a fund means issuing its units or shares as transferable records on a distributed ledger, and treating that ledger as the register of holders. Everything else about the fund stays where it was. The legal wrapper is a normal European fund vehicle. The manager is authorised. The depositary holds the assets. The administrator strikes NAV. Tokenization replaces one component — the register and the transfer mechanism — and leaves the other five in place. That is a narrower change than the word suggests, and the narrowness is the point. A fund is not made better by being on a ledger. It is made faster to subscribe to, faster to transfer, cheaper to administer at scale, and continuously reconcilable rather than periodically reconstructed. Those are operational gains in the register, and they are the only gains tokenization delivers directly. Three things are commonly claimed and are not true. Tokenization does not create liquidity: liquidity requires licensed distribution and a venue where transfers can occur, which is a separate build with its own permissions. Tokenization does not reduce regulation: a tokenized fund unit is a financial instrument and carries the same obligations as an untokenized one. And tokenization does not remove intermediaries: the depositary, administrator and transfer agent all remain, because their duties are legal rather than technical. The six components, and which one changes Legal wrapper — the fund vehicle and its domicile. Unchanged. Manager — an authorised AIFM or UCITS management company. Unchanged. Depositary — safekeeping and oversight of the fund’s assets. Unchanged. Administrator — accounting and NAV calculation. Unchanged. Register and transfer agency — this is what tokenization changes. The holder record moves on-chain and transfer eligibility is enforced by the token. Distribution — placement to investors, requiring MiFID II permissions. Unchanged in substance, though a tokenized register makes onboarding and secondary transfer mechanically simpler. If a provider proposes changing more than the fifth item, ask which authorisation covers the change. That question resolves most conversations quickly. What the register change actually buys is worth stating in operational terms rather than in principle. Onboarding a new holder becomes a verification and whitelisting step rather than a paper transfer instruction routed between three parties. A secondary transfer between two eligible holders becomes a validated transaction rather than a bilateral process with a settlement lag and a manual register update. The holder list at any NAV date is read rather than assembled. And each of those improvements compounds with holder count: at twelve holders it is invisible, at three hundred it is the difference between a two-person operations function and a five-person one. Who is commissioning this work in Europe is also instructive. It is predominantly managers of private funds — venture, private credit, real estate — with international holder bases and periodic subscription windows, plus securitisation arrangers issuing note-like instruments repeatedly from a single platform. The common factor is repetition: the economics of tokenization improve markedly on the second and third issuance from the same rails, because the fixed structuring and provider-onboarding costs are already spent. A manager planning one issuance and no successors should expect the cost case to be neutral at best, and should tokenize for the register quality rather than the savings. Which EU legal wrapper do I need — UCITS, AIF, SPV or securitisation vehicle? For a tokenized fund in Europe the answer is almost always an alternative investment fund or a securitisation vehicle. UCITS is available in theory and impractical today, because its eligible-asset rules under Directive 2009/65/EC were not written with ledger-native instruments in mind and its retail distribution obligations add cost that tokenization does not offset. A plain SPV without a fund manager is suitable only for single-asset or note-like structures. The decision turns on four inputs: who the investors are, what the underlying assets are, whether you need a marketing passport, and whether the instrument is better expressed as a fund unit or as a debt security. The table below is the shortlist we work from in practice. European wrapper options for a tokenized fund. Positions summarised from the directives cited; confirm with counsel for your specific facts. Wrapper Typical domicile Investors Best for Manager required Passport Watch out for AIF (Luxembourg RAIF, Irish ICAV/QIAIF) Luxembourg, Ireland Professional and well-informed Venture, private credit, real estate, multi-asset Authorised AIFM under AIFMD Marketing passport to professional investors Depositary is mandatory; no retail distribution UCITS Luxembourg, Ireland Retail and professional Liquid transferable securities only UCITS management company Full retail passport Eligible-asset limits make most tokenized strategies impossible Securitisation vehicle (Luxembourg S.à r.l. / compartment) Luxembourg Professional, sometimes retail via prospectus Single assets, notes, revenue streams, receivables Not a fund manager; requires an arranger Prospectus passport where a prospectus is approved Debt characterisation, tax treatment, and compartment segregation drafting Unregulated SPV Various Professional only, club deals One asset, small holder count None None Little investor protection; often unmarketable to institutions DLT-native issuance under the pilot regime EU member states Professional Instruments intended to trade on a DLT MTF MiFID II firm plus pilot-regime permission Within the regime’s scope Volume caps and the regime’s time limit A short decision path Are the assets liquid transferable securities and do you need retail distribution across the EEA? If yes, consider UCITS. If no, stop considering it. Is this a pooled, actively managed portfolio for professional investors? Then an AIF — a Luxembourg RAIF or an Irish QIAIF — with an authorised AIFM. Is it a single asset, a note, or a defined revenue stream, with the economics expressed as debt? Then a securitisation vehicle, usually with a segregated compartment per issuance. Is the instrument intended to trade on a DLT market infrastructure from day one? Then structure with the pilot regime in view, and accept its volume caps. Domicile follows the wrapper, and it also decides whether an on-chain register can be legally authoritative. Several member states have amended their securities or company law to recognise a distributed ledger as the register; others have not. Where they have not, the on-chain record runs alongside an authoritative off-chain register, which works but adds a reconciliation duty. Ask this question before you pick a domicile, not after. Is my instrument a MiCA crypto-asset or a MiFID II financial instrument? If the token represents a unit or share in a fund, it is a financial instrument and MiFID II applies. MiCA does not. Regulation (EU) 2023/1114 excludes crypto-assets that qualify as financial instruments from its own scope, so a MiCA CASP authorisation does not permit a firm to issue or place tokenized fund units. This is the single most expensive mistake in the category, and it is usually made at the point where a project chooses its service providers. The test is substance, not form. A transferable instrument that carries a claim on a pool of assets, a share of profits, or a right to a return determined by the performance of a portfolio, sits within Annex I Section C of MiFID II. Naming it a utility token, issuing it on a public chain, or describing the holder as a member of a community does not change the analysis. Classification questions are settled against MiFID II and the guidance of ESMA , not against MiCA’s categories. MiCA still matters to a tokenized fund, in two indirect ways. First, the cash leg: e-money tokens under MiCA are the most credible route to a same-ledger payment leg, and their issuers are authorised credit or electronic money institutions. Second, custody of any crypto-assets the fund itself holds is a MiCA service, distinct from the custody of the fund’s units. A fund that invests in digital assets and issues tokenized units therefore touches both regimes at once, through different providers with different permissions. Get this in writing Ask each provider to state, in writing, which authorisation covers the specific service they will perform for you, and in which member state. A firm that answers with a marketing phrase rather than a licence reference is telling you something. Our own group states it plainly: Black Manta Capital Partners is BaFin -licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Who issues, who registers, who custodies and who settles? Four distinct roles, four distinct permissions, and in most European structures four distinct entities. Issuance and placement require a MiFID II investment firm. The register is maintained by a transfer agent or registrar appointed under the fund documentation. Custody of the fund’s assets is the depositary’s duty; custody of any crypto-assets is a separately authorised service. Settlement of the units happens on the ledger, while settlement of the cash leg usually happens in the banking system. The mistake to avoid is assuming a single technology vendor covers all four. Most platforms in this market supply the token standard and the register software, which is the technology layer, and then rely on licensed third parties for issuance, custody and distribution. That is a legitimate model, but it means the regulatory perimeter runs through several firms and the issuer carries the coordination burden. The four roles, the permission each requires, and who typically holds it. Role What it does Permission required Who holds it in practice Issuer / placement agent Structures the offering, admits investors, places the units MiFID II investment firm authorisation for the relevant services A licensed issuance house — in our group, Black Manta Capital Partners, BaFin-licensed under MiFID II Register / transfer agent Maintains the authoritative holder record, processes subscriptions, redemptions and transfers Appointment under fund documentation; national transfer-agency requirements where they apply A transfer agent, or the issuer where permitted, operating the on-chain register Custody Safekeeps fund assets (depositary duty) and any crypto-assets held AIFMD or UCITS depositary authorisation; MiCA authorisation for crypto-asset custody A depositary bank for fund assets; a crypto custodian authorised for that service Settlement Moves units against payment Ledger for the asset leg; payment institution, credit institution or EMT issuer for the cash leg Ledger plus a bank or an e-money token issuer authorised under MiCA Two structural notes. The depositary is not optional for an AIF, and a depositary that has never overseen a tokenized register will price its unfamiliarity into the fee — budget time for its operational due diligence. And the transfer agent role does not disappear when the register is on-chain: someone must remain legally accountable for the accuracy of the record, and that accountability should be named in the documentation rather than implied by the software. What does the timeline look like, week by week? A first tokenized issuance in Europe takes three to six months from decision to first settled subscription, assuming the fund vehicle either exists or is a standard product from a known domicile. Subsequent issuances on the same rails take four to eight weeks. The long pole is never the token. It is the depositary’s operational due diligence, the bank account, and — where a new vehicle is needed — regulator or domicile timetables that are outside your control. Indicative timeline for a first tokenized issuance where the manager is already authorised. Based on live European mandates; the ranges compress on repeat issuances. Weeks Workstream Owner Dependency that slips 1–2 Structuring decision: wrapper, domicile, investor base, classification opinion Issuer, counsel Counsel availability; unclear investor base 2–5 Vehicle established or compartment opened; documentation drafted Counsel, domicile administrator Domicile filing queues 3–7 Provider selection and appointment: issuance firm, transfer agent, depositary, custodian Issuer Depositary operational due diligence on the token layer 5–9 Token configuration: standard, transfer rules, identity and eligibility framework, test transfers Issuance firm, technology provider Late changes to the investor-eligibility matrix 6–10 Bank and payment rails opened; cash-leg design confirmed Issuer, bank Bank onboarding — routinely the longest single item 8–12 AML and onboarding process live; whitelist populated for launch investors Issuance firm Investor documentation returned late 10–14 Dry run: subscription, NAV strike, transfer, redemption, reporting All parties First reconciliation break 12–18 First live subscription settled; register live Issuer, transfer agent — Compressing this is mostly a matter of sequencing rather than speed. Start depositary and bank conversations in week two, not week eight. Freeze the eligibility matrix before token configuration begins. And run the dry run with real documents and a real NAV strike, because the breaks that matter appear in reconciliation, not in test transfers. What does it cost, and what are the ongoing fees? Budget €120,000 to €400,000 for a first European tokenized issuance, and €40,000 to €120,000 a year to run it, excluding the manager’s own costs. The range is wide because three items dominate and each varies by an order of magnitude: legal structuring, the depositary, and whether you are standing up a new vehicle or using an existing compartment. Anyone quoting a single number without knowing your wrapper and domicile is guessing. Indicative cost ranges for a European tokenized fund issuance. Our own observed ranges from live mandates, stated as ranges because they vary by domicile, asset class and provider; not a quotation. Item One-off Annual Notes Legal structuring and classification opinion €40k–€150k €10k–€30k Higher for a new vehicle, a novel asset class, or multi-jurisdiction distribution Vehicle establishment (RAIF, QIAIF or securitisation compartment) €20k–€80k €15k–€40k A compartment in an existing securitisation platform is at the low end Issuance and placement (MiFID II firm) €25k–€100k Often a placement fee on capital raised Structure and distribution scope drive this more than the token does Depositary €5k–€15k onboarding €20k–€60k Basis-point floors are common; unfamiliarity with tokenized registers is priced in Administration and NAV €5k–€15k setup €15k–€45k Frequency of the NAV strike is the main variable Transfer agency and on-chain register €10k–€40k €12k–€35k Some platforms bundle this with token technology Token technology and audit €15k–€60k €8k–€25k Use an established permissioned standard; a bespoke contract adds audit cost with no benefit AML, identity and screening €5k–€20k €8k–€25k Scales with investor count and jurisdictional spread Two economics to keep in view. First, tokenization does not pay for itself on a single small issuance — the fixed costs are front-loaded and the savings are per-transfer and per-reconciliation. The break-even is a function of holder count and transfer frequency, not of fund size. Second, the recurring cost of a tokenized register is lower than a manual one at scale, but only if you stop maintaining a parallel manual process. Firms that run both indefinitely pay for both. Two further budget items are routinely omitted from first plans. The first is the internal cost: someone in the manager’s operations function has to own the whitelist, the reconciliation sign-off and the investor queries that arrive when a transfer fails a rule. Budget a meaningful fraction of one full-time role in the first year, less thereafter. The second is the cost of change: revising the eligibility matrix, adding a jurisdiction, or migrating to a new token standard is a controlled project with legal, technical and communication components, not a configuration edit. Structures that anticipate one change a year and price it are calm about it; structures that treat the configuration as permanent are not. How do investors subscribe and redeem? Subscription in a tokenized fund follows the same sequence as a conventional one, with two steps automated. The investor is onboarded and verified, their wallet address is added to the whitelist, they commit at a NAV struck on the fund’s schedule, they pay the cash leg, and units are minted to their address once payment is confirmed. Redemption reverses it: a redemption instruction, a NAV strike, burning or transferring the units, and payment out. The automation is in eligibility and in the register. Because the token validates the receiving address against on-chain rules before any transfer executes, an ineligible holder cannot be onboarded by mistake and a transfer to an unverified wallet simply fails. And because the register is the ledger, the holder list after each subscription is authoritative immediately rather than after a reconciliation cycle. What is not automated is the cash leg, in most structures today. Where payment is a bank transfer, the fund waits for confirmation before minting, which reintroduces a settlement gap of hours or days. Where the cash leg is a MiCA e-money token or tokenized deposit on the same ledger, subscription can settle atomically — the units and the payment move in one transaction, or neither moves. That is available now for some structures and not for all, and it is the honest dividing line between what tokenization delivers today and what is claimed for it. The subscription cut-off, the NAV strike and the payment confirmation therefore remain the three dates that govern the experience, exactly as in a conventional fund. Where tokenization changes the experience is in what happens either side of those dates: onboarding a holder is faster because verification and whitelisting replace a paper chain, and the post-strike register is authoritative immediately rather than after reconciliation. Managers who expect the fund’s own terms to compress are disappointed; managers who expect the operations around those terms to get lighter are not. Redemption deserves one specific note, because it is where structures diverge most. Units may be burned on redemption, which reduces units in issue and requires the administrator’s books to be updated in step, or transferred back to a treasury address held by the fund, which keeps units in issue constant and treats the treasury holding as unissued. Both are used. The choice affects the reconciliation design and the way units in issue are reported, so it should be settled during structuring rather than discovered at the first redemption window. Practical constraints worth stating to investors up front Redemption terms come from the fund documentation, not from the technology. A quarterly-redemption fund does not become daily because it is tokenized. NAV frequency is unchanged. A ledger cannot value an illiquid portfolio more often than its administrator can. Secondary transfer between eligible holders is possible where the documentation permits it and a venue exists. Absent a venue, transfers are bilateral. The whitelist is a live obligation. An investor whose verification lapses can be blocked from receiving units, which needs to be explained before it happens. What goes wrong, and how do you avoid it? Five failure modes account for nearly every stalled European tokenization project, and none of them is technical. In order of frequency: the wrong classification, an unappointed register owner, a cash leg nobody designed, an eligibility matrix that changes after the token is configured, and a depositary brought in too late. 1. The wrong classification A project selects a MiCA-oriented provider for what is a MiFID II instrument, then discovers at the placement stage that no one in the chain holds the permission to place it. This is recoverable but expensive: it usually means re-papering the offering and appointing a licensed issuance firm mid-process. Avoid it by obtaining a written classification view before selecting any provider. 2. No named owner of the register The software maintains the record and everyone assumes accountability sits somewhere else. When the first break occurs, there is no party contractually responsible for resolving it. Name the transfer agent or registrar in the documentation and define the reconciliation process, including who signs off the holder list at each NAV date. 3. An undesigned cash leg Asset-leg settlement is instant, so the cash leg is assumed to keep up. It does not. Decide early whether payment is fiat through a bank, an e-money token on the same ledger, or a hybrid, and state the resulting settlement timing in the subscription documents. 4. A moving eligibility matrix Investor categories, jurisdictions and holding periods get revised after transfer rules are already encoded. Each revision is a re-configuration and, if the token is live, a controlled migration. Freeze the matrix before configuration and treat changes as a formal change process. 5. A late depositary The depositary’s operational due diligence on a tokenized register is the most under-budgeted item in the plan. It is also the one you cannot compress, because it is their risk decision, not yours. Engage in week two and give them the token documentation, the transfer-rule logic and the reconciliation design in one package. There is a sixth, softer failure: tokenizing without a reason. If a fund has twelve holders, no secondary transfer activity and an annual NAV, the register is not its constraint and tokenization will add cost without removing friction. The honest test is whether holder count, transfer frequency or onboarding volume is the thing slowing the fund down. Where it is, tokenization addresses it directly. Where it is not, it does not. Practitioner resource The Fund Tokenization Playbook The full working version of this guide: the wrapper decision tree, the week-by-week plan as an editable schedule, a provider question list with the licence reference to ask for in each case, and the reconciliation checklist we use at each NAV date. We email it on request. Do not fill this in: Work email address Send me the playbook We email the file once and add you to occasional notes on tokenization and regulation. No noise, and you can unsubscribe at any time. Related What is a tokenized fund? Structure, custody and redemption The category pillar: what the token legally represents and where the risks sit. MiFID II or MiCA: which applies to tokenized securities? The classification question, with five worked instrument examples. Tokenization glossary: MiCA, MiFID II and digital asset terms defined Thirty definitions, each written to be read on its own. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), EU Official Journal, 2011. Directive 2009/65/EC on Undertakings for Collective Investment in Transferable Securities (UCITS), EU Official Journal, 2009. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II), EU Official Journal, 2014. Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), EU Official Journal, 2023. Regulation (EU) 2022/858 on a pilot regime for DLT market infrastructures, EU Official Journal, 2022. Cost and timeline ranges are COSIMO Digital’s own observed ranges from live European mandates as of July 2026, stated as ranges and not as a quotation. COSIMO Digital regulatory authorisations, described as of 28 July 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== Home / Learn / How to tokenize a fund Tokenized funds and private markets How to tokenize a fund in Europe Tokenizing a fund in Europe takes three to six months and costs €120,000 to €400,000 for a first issuance. The work is not the token. It is the wrapper, the classification, the register owner, the depositary and the cash leg. This is the process, in order, with the timeline and the fees. Last updated: 28 July 2026 By Ciarán Hynes · 16 min read On this page What does it actually mean to tokenize a fund? Which EU legal wrapper do I need — UCITS, AIF, SPV or securitisation vehicle? Is my instrument a MiCA crypto-asset or a MiFID II financial instrument? Who issues, who registers, who custodies and who settles? What does the timeline look like, week by week? What does it cost, and what are the ongoing fees? How do investors subscribe and redeem? What goes wrong, and how do you avoid it? What does it actually mean to tokenize a fund? Tokenizing a fund means issuing its units or shares as transferable records on a distributed ledger, and treating that ledger as the register of holders. Everything else about the fund stays where it was. The legal wrapper is a normal European fund vehicle. The manager is authorised. The depositary holds the assets. The administrator strikes NAV. Tokenization replaces one component — the register and the transfer mechanism — and leaves the other five in place. That is a narrower change than the word suggests, and the narrowness is the point. A fund is not made better by being on a ledger. It is made faster to subscribe to, faster to transfer, cheaper to administer at scale, and continuously reconcilable rather than periodically reconstructed. Those are operational gains in the register, and they are the only gains tokenization delivers directly. Three things are commonly claimed and are not true. Tokenization does not create liquidity: liquidity requires licensed distribution and a venue where transfers can occur, which is a separate build with its own permissions. Tokenization does not reduce regulation: a tokenized fund unit is a financial instrument and carries the same obligations as an untokenized one. And tokenization does not remove intermediaries: the depositary, administrator and transfer agent all remain, because their duties are legal rather than technical. The six components, and which one changes Legal wrapper — the fund vehicle and its domicile. Unchanged. Manager — an authorised AIFM or UCITS management company. Unchanged. Depositary — safekeeping and oversight of the fund’s assets. Unchanged. Administrator — accounting and NAV calculation. Unchanged. Register and transfer agency — this is what tokenization changes. The holder record moves on-chain and transfer eligibility is enforced by the token. Distribution — placement to investors, requiring MiFID II permissions. Unchanged in substance, though a tokenized register makes onboarding and secondary transfer mechanically simpler. If a provider proposes changing more than the fifth item, ask which authorisation covers the change. That question resolves most conversations quickly. Which EU legal wrapper do I need — UCITS, AIF, SPV or securitisation vehicle? For a tokenized fund in Europe the answer is almost always an alternative investment fund or a securitisation vehicle. UCITS is available in theory and impractical today, because its eligible-asset rules under Directive 2009/65/EC were not written with ledger-native instruments in mind and its retail distribution obligations add cost that tokenization does not offset. A plain SPV without a fund manager is suitable only for single-asset or note-like structures. The decision turns on four inputs: who the investors are, what the underlying assets are, whether you need a marketing passport, and whether the instrument is better expressed as a fund unit or as a debt security. The table below is the shortlist we work from in practice. European wrapper options for a tokenized fund. Positions summarised from the directives cited; confirm with counsel for your specific facts. Wrapper Typical domicile Investors Best for Manager required Passport Watch out for AIF (Luxembourg RAIF, Irish ICAV/QIAIF) Luxembourg, Ireland Professional and well-informed Venture, private credit, real estate, multi-asset Authorised AIFM under AIFMD Marketing passport to professional investors Depositary is mandatory; no retail distribution UCITS Luxembourg, Ireland Retail and professional Liquid transferable securities only UCITS management company Full retail passport Eligible-asset limits make most tokenized strategies impossible Securitisation vehicle (Luxembourg S.à r.l. / compartment) Luxembourg Professional, sometimes retail via prospectus Single assets, notes, revenue streams, receivables Not a fund manager; requires an arranger Prospectus passport where a prospectus is approved Debt characterisation, tax treatment, and compartment segregation drafting Unregulated SPV Various Professional only, club deals One asset, small holder count None None Little investor protection; often unmarketable to institutions DLT-native issuance under the pilot regime EU member states Professional Instruments intended to trade on a DLT MTF MiFID II firm plus pilot-regime permission Within the regime’s scope Volume caps and the regime’s time limit A short decision path Are the assets liquid transferable securities and do you need retail distribution across the EEA? If yes, consider UCITS. If no, stop considering it. Is this a pooled, actively managed portfolio for professional investors? Then an AIF — a Luxembourg RAIF or an Irish QIAIF — with an authorised AIFM. Is it a single asset, a note, or a defined revenue stream, with the economics expressed as debt? Then a securitisation vehicle, usually with a segregated compartment per issuance. Is the instrument intended to trade on a DLT market infrastructure from day one? Then structure with the pilot regime in view, and accept its volume caps. Domicile follows the wrapper, and it also decides whether an on-chain register can be legally authoritative. Several member states have amended their securities or company law to recognise a distributed ledger as the register; others have not. Where they have not, the on-chain record runs alongside an authoritative off-chain register, which works but adds a reconciliation duty. Ask this question before you pick a domicile, not after. Is my instrument a MiCA crypto-asset or a MiFID II financial instrument? If the token represents a unit or share in a fund, it is a financial instrument and MiFID II applies. MiCA does not. Regulation (EU) 2023/1114 excludes crypto-assets that qualify as financial instruments from its own scope, so a MiCA CASP authorisation does not permit a firm to issue or place tokenized fund units. This is the single most expensive mistake in the category, and it is usually made at the point where a project chooses its service providers. The test is substance, not form. A transferable instrument that carries a claim on a pool of assets, a share of profits, or a right to a return determined by the performance of a portfolio, sits within Annex I Section C of MiFID II. Naming it a utility token, issuing it on a public chain, or describing the holder as a member of a community does not change the analysis. Classification questions are settled against MiFID II and the guidance of ESMA , not against MiCA’s categories. MiCA still matters to a tokenized fund, in two indirect ways. First, the cash leg: e-money tokens under MiCA are the most credible route to a same-ledger payment leg, and their issuers are authorised credit or electronic money institutions. Second, custody of any crypto-assets the fund itself holds is a MiCA service, distinct from the custody of the fund’s units. A fund that invests in digital assets and issues tokenized units therefore touches both regimes at once, through different providers with different permissions. Get this in writing Ask each provider to state, in writing, which authorisation covers the specific service they will perform for you, and in which member state. A firm that answers with a marketing phrase rather than a licence reference is telling you something. Our own group states it plainly: Black Manta Capital Partners is BaFin -licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Who issues, who registers, who custodies and who settles? Four distinct roles, four distinct permissions, and in most European structures four distinct entities. Issuance and placement require a MiFID II investment firm. The register is maintained by a transfer agent or registrar appointed under the fund documentation. Custody of the fund’s assets is the depositary’s duty; custody of any crypto-assets is a separately authorised service. Settlement of the units happens on the ledger, while settlement of the cash leg usually happens in the banking system. The mistake to avoid is assuming a single technology vendor covers all four. Most platforms in this market supply the token standard and the register software, which is the technology layer, and then rely on licensed third parties for issuance, custody and distribution. That is a legitimate model, but it means the regulatory perimeter runs through several firms and the issuer carries the coordination burden. The four roles, the permission each requires, and who typically holds it. Role What it does Permission required Who holds it in practice Issuer / placement agent Structures the offering, admits investors, places the units MiFID II investment firm authorisation for the relevant services A licensed issuance house — in our group, Black Manta Capital Partners, BaFin-licensed under MiFID II Register / transfer agent Maintains the authoritative holder record, processes subscriptions, redemptions and transfers Appointment under fund documentation; national transfer-agency requirements where they apply A transfer agent, or the issuer where permitted, operating the on-chain register Custody Safekeeps fund assets (depositary duty) and any crypto-assets held AIFMD or UCITS depositary authorisation; MiCA authorisation for crypto-asset custody A depositary bank for fund assets; an authorised crypto custodian for digital assets Settlement Moves units against payment Ledger for the asset leg; payment institution, credit institution or EMT issuer for the cash leg Ledger plus a bank or a MiCA-authorised e-money token issuer Two structural notes. The depositary is not optional for an AIF, and a depositary that has never overseen a tokenized register will price its unfamiliarity into the fee — budget time for its operational due diligence. And the transfer agent role does not disappear when the register is on-chain: someone must remain legally accountable for the accuracy of the record, and that accountability should be named in the documentation rather than implied by the software. What does the timeline look like, week by week? A first tokenized issuance in Europe takes three to six months from decision to first settled subscription, assuming the fund vehicle either exists or is a standard product from a known domicile. Subsequent issuances on the same rails take four to eight weeks. The long pole is never the token. It is the depositary’s operational due diligence, the bank account, and — where a new vehicle is needed — regulator or domicile timetables that are outside your control. Indicative timeline for a first tokenized issuance where the manager is already authorised. Based on live European mandates; the ranges compress on repeat issuances. Weeks Workstream Owner Dependency that slips 1–2 Structuring decision: wrapper, domicile, investor base, classification opinion Issuer, counsel Counsel availability; unclear investor base 2–5 Vehicle established or compartment opened; documentation drafted Counsel, domicile administrator Domicile filing queues 3–7 Provider selection and appointment: issuance firm, transfer agent, depositary, custodian Issuer Depositary operational due diligence on the token layer 5–9 Token configuration: standard, transfer rules, identity and eligibility framework, test transfers Issuance firm, technology provider Late changes to the investor-eligibility matrix 6–10 Bank and payment rails opened; cash-leg design confirmed Issuer, bank Bank onboarding — routinely the longest single item 8–12 AML and onboarding process live; whitelist populated for launch investors Issuance firm Investor documentation returned late 10–14 Dry run: subscription, NAV strike, transfer, redemption, reporting All parties First reconciliation break 12–18 First live subscription settled; register live Issuer, transfer agent — Compressing this is mostly a matter of sequencing rather than speed. Start depositary and bank conversations in week two, not week eight. Freeze the eligibility matrix before token configuration begins. And run the dry run with real documents and a real NAV strike, because the breaks that matter appear in reconciliation, not in test transfers. What does it cost, and what are the ongoing fees? Budget €120,000 to €400,000 for a first European tokenized issuance, and €40,000 to €120,000 a year to run it, excluding the manager’s own costs. The range is wide because three items dominate and each varies by an order of magnitude: legal structuring, the depositary, and whether you are standing up a new vehicle or using an existing compartment. Anyone quoting a single number without knowing your wrapper and domicile is guessing. Indicative cost ranges for a European tokenized fund issuance. Our own observed ranges from live mandates, stated as ranges because they vary by domicile, asset class and provider; not a quotation. Item One-off Annual Notes Legal structuring and classification opinion €40k–€150k €10k–€30k Higher for a new vehicle, a novel asset class, or multi-jurisdiction distribution Vehicle establishment (RAIF, QIAIF or securitisation compartment) €20k–€80k €15k–€40k A compartment in an existing securitisation platform is at the low end Issuance and placement (MiFID II firm) €25k–€100k Often a placement fee on capital raised Structure and distribution scope drive this more than the token does Depositary €5k–€15k onboarding €20k–€60k Basis-point floors are common; unfamiliarity with tokenized registers is priced in Administration and NAV €5k–€15k setup €15k–€45k Frequency of the NAV strike is the main variable Transfer agency and on-chain register €10k–€40k €12k–€35k Some platforms bundle this with token technology Token technology and audit €15k–€60k €8k–€25k Use an established permissioned standard; a bespoke contract adds audit cost with no benefit AML, identity and screening €5k–€20k €8k–€25k Scales with investor count and jurisdictional spread Two economics to keep in view. First, tokenization does not pay for itself on a single small issuance — the fixed costs are front-loaded and the savings are per-transfer and per-reconciliation. The break-even is a function of holder count and transfer frequency, not of fund size. Second, the recurring cost of a tokenized register is lower than a manual one at scale, but only if you stop maintaining a parallel manual process. Firms that run both indefinitely pay for both. How do investors subscribe and redeem? Subscription in a tokenized fund follows the same sequence as a conventional one, with two steps automated. The investor is onboarded and verified, their wallet address is added to the whitelist, they commit at a NAV struck on the fund’s schedule, they pay the cash leg, and units are minted to their address once payment is confirmed. Redemption reverses it: a redemption instruction, a NAV strike, burning or transferring the units, and payment out. The automation is in eligibility and in the register. Because the token validates the receiving address against on-chain rules before any transfer executes, an ineligible holder cannot be onboarded by mistake and a transfer to an unverified wallet simply fails. And because the register is the ledger, the holder list after each subscription is authoritative immediately rather than after a reconciliation cycle. What is not automated is the cash leg, in most structures today. Where payment is a bank transfer, the fund waits for confirmation before minting, which reintroduces a settlement gap of hours or days. Where the cash leg is a MiCA e-money token or tokenized deposit on the same ledger, subscription can settle atomically — the units and the payment move in one transaction, or neither moves. That is available now for some structures and not for all, and it is the honest dividing line between what tokenization delivers today and what is claimed for it. Practical constraints worth stating to investors up front Redemption terms come from the fund documentation, not from the technology. A quarterly-redemption fund does not become daily because it is tokenized. NAV frequency is unchanged. A ledger cannot value an illiquid portfolio more often than its administrator can. Secondary transfer between eligible holders is possible where the documentation permits it and a venue exists. Absent a venue, transfers are bilateral. The whitelist is a live obligation. An investor whose verification lapses can be blocked from receiving units, which needs to be explained before it happens. What goes wrong, and how do you avoid it? Five failure modes account for nearly every stalled European tokenization project, and none of them is technical. In order of frequency: the wrong classification, an unappointed register owner, a cash leg nobody designed, an eligibility matrix that changes after the token is configured, and a depositary brought in too late. 1. The wrong classification A project selects a MiCA-oriented provider for what is a MiFID II instrument, then discovers at the placement stage that no one in the chain holds the permission to place it. This is recoverable but expensive: it usually means re-papering the offering and appointing a licensed issuance firm mid-process. Avoid it by obtaining a written classification view before selecting any provider. 2. No named owner of the register The software maintains the record and everyone assumes accountability sits somewhere else. When the first break occurs, there is no party contractually responsible for resolving it. Name the transfer agent or registrar in the documentation and define the reconciliation process, including who signs off the holder list at each NAV date. 3. An undesigned cash leg Asset-leg settlement is instant, so the cash leg is assumed to keep up. It does not. Decide early whether payment is fiat through a bank, an e-money token on the same ledger, or a hybrid, and state the resulting settlement timing in the subscription documents. 4. A moving eligibility matrix Investor categories, jurisdictions and holding periods get revised after transfer rules are already encoded. Each revision is a re-configuration and, if the token is live, a controlled migration. Freeze the matrix before configuration and treat changes as a formal change process. 5. A late depositary The depositary’s operational due diligence on a tokenized register is the most under-budgeted item in the plan. It is also the one you cannot compress, because it is their risk decision, not yours. Engage in week two and give them the token documentation, the transfer-rule logic and the reconciliation design in one package. There is a sixth, softer failure: tokenizing without a reason. If a fund has twelve holders, no secondary transfer activity and an annual NAV, the register is not its constraint and tokenization will add cost without removing friction. The honest test is whether holder count, transfer frequency or onboarding volume is the thing slowing the fund down. Where it is, tokenization addresses it directly. Where it is not, it does not. Practitioner resource The Fund Tokenization Playbook The full working version of this guide: the wrapper decision tree, the week-by-week plan as an editable schedule, a provider question list with the licence reference to ask for in each case, and the reconciliation checklist we use at each NAV date. We email it on request. Do not fill this in: Work email address Send me the playbook We email the file once and add you to occasional notes on tokenization and regulation. No noise, and you can unsubscribe at any time. Related What is a tokenized fund? Structure, custody and redemption The category pillar: what the token legally represents and where the risks sit. MiFID II or MiCA: which applies to tokenized securities? The classification question, with five worked instrument examples. Tokenization glossary: MiCA, MiFID II and digital asset terms defined Thirty definitions, each written to be read on its own. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), EU Official Journal, 2011. Directive 2009/65/EC on Undertakings for Collective Investment in Transferable Securities (UCITS), EU Official Journal, 2009. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II), EU Official Journal, 2014. Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), EU Official Journal, 2023. Regulation (EU) 2022/858 on a pilot regime for DLT market infrastructures, EU Official Journal, 2022. Cost and timeline ranges are COSIMO Digital’s own observed ranges from live European mandates as of July 2026, stated as ranges and not as a quotation. COSIMO Digital regulatory authorisations, described as of 28 July 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # RWA tokenization platforms compared: 15 providers, 2026 URL: https://cosimodigital.com/learn/rwa-tokenization-platforms-compared ======================================================================== Home / Learn / Platforms compared Custody, settlement and operations RWA tokenization platforms compared Fifteen platforms, four functions, and no single firm doing all of them. This compares primary regulator, licence status, asset classes, jurisdictions served and — the column most comparisons omit — what each platform does not do. Our own entries are recorded on the same terms. Last updated: 28 July 2026 By Ciarán Hynes · 12 min read On this page Who are the real tokenization platforms in 2026? What does each one actually do — issuance, custody, transfer agency or venue? Which are regulated, and by whom? Which can serve EU issuers, and which cannot? How do I shortlist for my asset class? What is still missing from every platform on this list? Who are the real tokenization platforms in 2026? Fifteen platforms account for most genuine real-world asset tokenization activity in 2026, and they are not doing the same thing. Grouping them by what they are licensed to do, rather than by marketing category, produces four types: licensed issuers, technology providers, venues and registrars, and custodians. Very few firms are more than one of these, and no firm on this list is all four. The list below covers Securitize, Ondo Finance, Superstate, Tokeny, ADDX, Taurus, Centrifuge, Backed, Archax, InvestaX, Obligate, Nyala, Assetera, Black Manta Capital Partners and COSIMO Digital. Two of those are in our own group, and the table does not weight in their favour: their limitations are recorded in the same column as everyone else’s. One framing point before the detail. The word "platform" flattens a real distinction. A technology provider that supplies a permissioned token standard is doing valuable, well-defined work and holds no licence, because it needs none. A licensed issuer carries regulatory responsibility for the offering. Comparing the two on features misses the only question that matters operationally: when something goes wrong, which authorised entity is accountable? How this table was compiled Entries are compiled from each platform’s public statements, regulator registers and product documentation as of July 2026, and summarised in one line per column. Regulatory status changes; verify current standing on the relevant register before relying on any entry. Where a platform operates through affiliates in several jurisdictions, the primary supervisor of the tokenization business is recorded. Corrections are welcome at info@cosimodigital.com and are reflected at the next quarterly update. What does each one actually do — issuance, custody, transfer agency or venue? Four functions, and each platform occupies one or two of them. Issuance means structuring an offering and placing it with investors, which in the EU requires a MiFID II investment firm. Custody means holding assets under an authorisation that permits it. Transfer agency means maintaining the authoritative register of holders. A venue means operating a market where the instruments trade. Licensed issuers and placement firms Black Manta Capital Partners (BaFin-licensed, MiFID II) and Securitize (through its US broker-dealer and ATS affiliates, with SEC transfer-agent registration) are the clearest examples. They carry regulatory responsibility for the offering itself. ADDX and InvestaX play this role under Singapore MAS licences, and Archax under UK FCA authorisation. Technology providers Tokeny is the reference case: a Luxembourg technology company supplying permissioned token infrastructure to licensed institutions. It does not issue, place, custody or settle, and does not claim to. Centrifuge sits adjacent, providing protocol infrastructure for private credit where the licensed issuer is a separate party on top. Registrars and venues Nyala operates as a crypto-securities registrar under the German Electronic Securities Act, a narrow and specifically authorised role. Assetera operates a MiFID II-authorised secondary market in the EEA. Both are essential and neither is an issuer. Product issuers and custodians Ondo Finance, Superstate and Backed are best understood as product issuers: they create tokenized instruments, principally short-duration government debt exposure or tracker certificates, rather than providing infrastructure to third-party issuers. Taurus is primarily a FINMA-supervised custody and infrastructure provider serving banks, with tokenization capability attached. Reading the four categories together produces a useful discipline. For any structure, write down which named entity performs issuance, which maintains the register, which holds custody, and where the instrument can trade — then check that each of those four names holds an authorisation covering the work, in the jurisdiction where it is performed. Most proposals in this market fill two boxes convincingly and leave two implied. The implied boxes are where the operational risk lives, and they are also where the cost appears later, because the missing role has to be filled by someone at whatever price they ask once the project is committed. The categories also explain why platform comparisons published by platforms tend to mislead. A technology provider compares on features, because features are its product. A licensed issuer compares on permissions, because permissions are its product. A venue compares on liquidity. Each is describing the axis on which it wins, and none is lying. The only comparison that helps an issuer is the one that asks what a provider does not do, which is why that column exists in the table below and why our own rows carry the same treatment as everyone else’s. Which are regulated, and by whom? Nine of the fifteen hold a financial-services authorisation of some kind; the rest are technology providers, protocols or offshore product issuers. Supervision is spread across BaFin, the Central Bank of Ireland, the Austrian regulator, the UK FCA, Singapore's MAS, Swiss FINMA and the US SEC. There is no single EU tokenization licence, and any firm implying otherwise is worth a second look. The distinction that matters most in Europe is between a MiFID II authorisation, which permits issuance and placement of financial instruments, and a MiCA authorisation, which covers crypto-asset services and expressly does not extend to financial instruments. A firm can hold one, both, or neither, and each covers different work. Registration as a Virtual Asset Service Provider under national anti-money-laundering law is a third and narrower thing again: it is an AML supervision status, not permission to provide investment services. This is where our own group's position should be stated precisely rather than favourably. Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for regulated issuance and placement of tokenized securities; that is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Custody and payments are therefore a capability in authorisation, not a capability in operation. RWA tokenization platforms, July 2026. Compiled from public statements and regulator registers; verify current standing before relying on any entry. Platform Primary regulator Licence or status Asset classes Jurisdictions served EU issuer access What it does not do Securitize US SEC (transfer agent; broker-dealer and ATS affiliates) SEC-registered transfer agent; affiliated broker-dealer and ATS Funds, private equity, credit, equities US primarily; selected non-US Indirectly, via non-US arrangements Not an EU-authorised issuer; EU issuance needs an EU-licensed counterparty Ondo Finance US; offshore issuing entities No EU investment-firm licence publicly stated Tokenized US Treasuries and cash equivalents US qualified purchasers; non-US No Does not issue EU fund units or provide EU placement Superstate US SEC (registered investment adviser) US adviser registration; US fund structures Tokenized short-duration government funds US No No EU wrapper or EU distribution permission Tokeny Luxembourg (technology provider) Technology provider; not a licensed financial institution Any asset class, as software EU-wide as a vendor Yes, as technology only Does not issue, place, custody or settle; you appoint licensed parties ADDX Singapore MAS MAS capital markets services licence; recognised market operator Funds, private credit, pre-IPO equity Singapore and accredited investors globally No EU issuance Not an EU-authorised venue; EU investors treated case by case Taurus Switzerland FINMA FINMA-supervised securities firm; bank-grade custody Equities, debt, funds, digital assets Switzerland, EU via clients Partly, as custody and technology to EU institutions Not an EU fund issuer; Swiss perimeter is the primary one Centrifuge Protocol; no single supervisor Protocol and DAO structure; issuers licensed separately Private credit, receivables Global, permissionless components Only where an EU-licensed issuer sits on top No EU authorisation of its own; investor protection depends on the issuer Backed Switzerland Swiss issuer of tracker certificates Tokenized ETFs, equities, bonds as certificates Non-US professional investors Products accessible; not EU fund units Instruments are certificates, not fund units; no EU fund wrapper Archax UK FCA FCA-regulated exchange, broker and custodian Funds, securities, digital assets UK; EU case by case post-Brexit Not as an EU-authorised firm UK perimeter; EU issuance needs an EU-licensed partner InvestaX Singapore MAS MAS capital markets services licence Real estate, funds, private equity Singapore and accredited investors No EU issuance No EU authorisation Obligate Switzerland Swiss regulatory perimeter; on-chain bond issuance Bonds and short-term debt Switzerland, EU issuers case by case Partly, for debt instruments Debt-focused; not a fund wrapper or transfer agent Nyala Germany BaFin Crypto-securities registrar under the German eWpG Debt securities, crypto securities registers Germany primarily Yes, for German-law crypto securities Registrar role only; does not place, custody or manage funds Assetera Austria MiFID II-authorised secondary market operator in the EU Tokenized securities, funds, bonds EEA Yes, as a venue and distribution route A venue, not an issuer or custodian; primary issuance sits elsewhere Black Manta Capital Partners COSIMO GROUP Germany BaFin BaFin-licensed investment firm operating under MiFID II Funds, private equity, real estate, debt EEA via MiFID II passporting Yes, as an EU-licensed issuance and placement firm Not a depositary; not a trading venue; no retail distribution COSIMO Digital (group) US BaFin (issuance); Central Bank of Ireland (VASP registration) MiFID II issuance live; VASP-registered, MiCA CASP authorisation in process and not yet effective Funds, private markets, digital asset treasury EEA; US via affiliate broker-dealer and ATS Yes, for issuance and placement today Custody and payments are not yet authorised; no UCITS capability; no retail channel; not a CSD Which can serve EU issuers, and which cannot? Five of the fifteen can serve an EU issuer directly today: Black Manta Capital Partners, COSIMO Digital through it, Tokeny as a technology supplier, Nyala for German-law crypto securities, and Assetera as an EEA venue. Taurus and Obligate can serve EU clients for specific functions within the Swiss perimeter. The remainder require an EU-licensed counterparty to sit between them and the issuance, or serve EU investors only on a reverse-solicitation or case-by-case basis. That is not a criticism of the others. A US transfer agent with SEC registration is exactly the right provider for a US offering, and a Singapore licence is the right one for Singapore distribution. The error is assuming a licence travels. It does not: MiFID II passporting works within the EEA, MAS authorisation works in Singapore, and neither substitutes for the other. For an EU issuer the practical consequence is a two-part question for any shortlisted provider. First, which EU-authorised entity will be responsible for issuance and placement — named, with its licence reference and supervisor. Second, where does the register legally sit, and is that register recognised under the law of the fund’s domicile. A provider that cannot answer both in one email is not yet a candidate. How do I shortlist for my asset class? Start from the asset and the investor base, not the technology. Four common cases cover most enquiries, and each has a different answer. A European private fund for professional investors You need an EU-licensed issuance firm, an authorised AIFM, a depositary and a register whose legal standing is recognised in the domicile. Shortlist: Black Manta Capital Partners for issuance, Tokeny or an equivalent for the token layer, Assetera if you want an EEA secondary venue, and a depositary from your domicile. Ondo, Superstate and Backed are not relevant to this case. Tokenized short-duration government debt exposure Ondo Finance, Superstate and Backed are the established product issuers here, and none is an EU fund. If you need an EU wrapper for a treasury strategy, you are commissioning a fund issuance, not buying a product, and the first case applies. Private credit or receivables Centrifuge for protocol infrastructure with a licensed issuer on top; Obligate for debt instruments in the Swiss perimeter; an EU issuance firm with a securitisation compartment where the investors are European institutions. Secondary liquidity for an existing tokenized instrument This is a venue question, not an issuance question. Assetera in the EEA, Archax in the UK, ADDX or InvestaX in Singapore. Confirm that your instrument’s transfer restrictions can be enforced on the venue, because a venue that cannot enforce eligibility cannot admit a restricted instrument. Then apply three filters, in order: is there a named EU-authorised entity accountable for issuance; is the register legally recognised in the domicile; and does the provider’s answer to "what do you not do" match ours in the table above. The third filter is the most informative, because a provider who lists their limitations unprompted is describing a real perimeter. One practical sequencing note. Select the issuance firm and confirm the register’s legal standing before selecting the token technology, not after. Projects that begin with a technology decision routinely discover that the licensed parties they then need to appoint have their own requirements about standards, identity frameworks and reporting, and the technology has to be re-configured to satisfy them. Beginning with the permissions and the domicile constrains the technology choice usefully — usually to two or three established permissioned standards — and that constraint is cheaper to accept at the start than to discover in week nine. What is still missing from every platform on this list? No platform on this list offers regulated issuance, qualified custody, settlement and asset management as one authorised, integrated stack in the EU. Every structure in the market today is assembled: an issuer here, a custodian there, a register somewhere else, a venue if you are lucky. The issuer carries the coordination burden and the operational risk that lives in the seams between providers. That gap is not evidence of incompetence. It is a consequence of how the permissions are drawn. MiFID II issuance, depositary duties, MiCA custody and payment services are separate authorisations with separate capital, governance and reporting requirements, and holding several of them at once is slow and expensive. Most firms sensibly specialise. The result is that the market’s standard product is an integration project. Three further gaps are worth naming because no vendor volunteers them. The cash leg is unsolved for most European structures: without tokenized cash on the same ledger, delivery versus payment is aspirational. Secondary liquidity is thin almost everywhere — venues exist, order books largely do not. And legal recognition of an on-chain register still varies by member state, so the same structure has different standing in different domiciles. COSIMO Digital is building toward the integrated case and is not there yet either. Issuance is live and BaFin-licensed. Custody and payments are in authorisation with the Central Bank of Ireland and not yet effective. Settlement and identity infrastructure is built and not operating at scale. Asset management has a four-year live record through COSIMO X, a tokenized evergreen venture fund listed on Securitize Markets in December 2021. Two of six layers are operational, which is more than most and less than the whole. Read the group’s regulatory authorisations and their exact status rather than taking that summary on trust, and if it is useful, read how to tokenize a fund in Europe step by step or the definitions of the terms used in this table . Related How to tokenize a fund in Europe: the complete process Wrapper, classification, providers, timeline and real costs. MiFID II or MiCA: which applies to tokenized securities? Why the licence a platform holds decides what it can do for you. Tokenization glossary: MiCA, MiFID II and digital asset terms defined CASP, VASP, DLT MTF, transfer agent and the rest, defined. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Platform entries compiled from public statements, product documentation and regulator registers as of July 2026. Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA); Directive 2014/65/EU (MiFID II), EU Official Journal. German Act on Electronic Securities (eWpG) for crypto-securities registrar status. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== Home / Learn / Platforms compared Custody, settlement and operations RWA tokenization platforms compared Fifteen platforms, four functions, and no single firm doing all of them. This compares primary regulator, licence status, asset classes, jurisdictions served and — the column most comparisons omit — what each platform does not do. Our own entries are recorded on the same terms. Last updated: 28 July 2026 By Ciarán Hynes · 12 min read On this page Who are the real tokenization platforms in 2026? What does each one actually do — issuance, custody, transfer agency or venue? Which are regulated, and by whom? Which can serve EU issuers, and which cannot? How do I shortlist for my asset class? What is still missing from every platform on this list? Who are the real tokenization platforms in 2026? Fifteen platforms account for most genuine real-world asset tokenization activity in 2026, and they are not doing the same thing. Grouping them by what they are licensed to do, rather than by marketing category, produces four types: licensed issuers, technology providers, venues and registrars, and custodians. Very few firms are more than one of these, and no firm on this list is all four. The list below covers Securitize, Ondo Finance, Superstate, Tokeny, ADDX, Taurus, Centrifuge, Backed, Archax, InvestaX, Obligate, Nyala, Assetera, Black Manta Capital Partners and COSIMO Digital. Two of those are in our own group, and the table does not weight in their favour: their limitations are recorded in the same column as everyone else’s. One framing point before the detail. The word "platform" flattens a real distinction. A technology provider that supplies a permissioned token standard is doing valuable, well-defined work and holds no licence, because it needs none. A licensed issuer carries regulatory responsibility for the offering. Comparing the two on features misses the only question that matters operationally: when something goes wrong, which authorised entity is accountable? How this table was compiled Entries are compiled from each platform’s public statements, regulator registers and product documentation as of July 2026, and summarised in one line per column. Regulatory status changes; verify current standing on the relevant register before relying on any entry. Where a platform operates through affiliates in several jurisdictions, the primary supervisor of the tokenization business is recorded. Corrections are welcome at info@cosimodigital.com and are reflected at the next quarterly update. What does each one actually do — issuance, custody, transfer agency or venue? Four functions, and each platform occupies one or two of them. Issuance means structuring an offering and placing it with investors, which in the EU requires a MiFID II investment firm. Custody means holding assets under an authorisation that permits it. Transfer agency means maintaining the authoritative register of holders. A venue means operating a market where the instruments trade. Licensed issuers and placement firms Black Manta Capital Partners (BaFin-licensed, MiFID II) and Securitize (through its US broker-dealer and ATS affiliates, with SEC transfer-agent registration) are the clearest examples. They carry regulatory responsibility for the offering itself. ADDX and InvestaX play this role under Singapore MAS licences, and Archax under UK FCA authorisation. Technology providers Tokeny is the reference case: a Luxembourg technology company supplying permissioned token infrastructure to licensed institutions. It does not issue, place, custody or settle, and does not claim to. Centrifuge sits adjacent, providing protocol infrastructure for private credit where the licensed issuer is a separate party on top. Registrars and venues Nyala operates as a crypto-securities registrar under the German Electronic Securities Act, a narrow and specifically authorised role. Assetera operates a MiFID II-authorised secondary market in the EEA. Both are essential and neither is an issuer. Product issuers and custodians Ondo Finance, Superstate and Backed are best understood as product issuers: they create tokenized instruments, principally short-duration government debt exposure or tracker certificates, rather than providing infrastructure to third-party issuers. Taurus is primarily a FINMA-supervised custody and infrastructure provider serving banks, with tokenization capability attached. Which are regulated, and by whom? Nine of the fifteen hold a financial-services authorisation of some kind; the rest are technology providers, protocols or offshore product issuers. Supervision is spread across BaFin, the Central Bank of Ireland, the Austrian regulator, the UK FCA, Singapore's MAS, Swiss FINMA and the US SEC. There is no single EU tokenization licence, and any firm implying otherwise is worth a second look. The distinction that matters most in Europe is between a MiFID II authorisation, which permits issuance and placement of financial instruments, and a MiCA authorisation, which covers crypto-asset services and expressly does not extend to financial instruments. A firm can hold one, both, or neither, and each covers different work. Registration as a Virtual Asset Service Provider under national anti-money-laundering law is a third and narrower thing again: it is an AML supervision status, not permission to provide investment services. This is where our own group's position should be stated precisely rather than favourably. Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for regulated issuance and placement of tokenized securities; that is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Custody and payments are therefore a capability in authorisation, not a capability in operation. RWA tokenization platforms, July 2026. Compiled from public statements and regulator registers; verify current standing before relying on any entry. Platform Primary regulator Licence or status Asset classes Jurisdictions served EU issuer access What it does not do Securitize US SEC (transfer agent; broker-dealer and ATS affiliates) SEC-registered transfer agent; affiliated broker-dealer and ATS Funds, private equity, credit, equities US primarily; selected non-US Indirectly, via non-US arrangements Not an EU-authorised issuer; EU issuance needs an EU-licensed counterparty Ondo Finance US; offshore issuing entities No EU investment-firm licence publicly stated Tokenized US Treasuries and cash equivalents US qualified purchasers; non-US No Does not issue EU fund units or provide EU placement Superstate US SEC (registered investment adviser) US adviser registration; US fund structures Tokenized short-duration government funds US No No EU wrapper or EU distribution permission Tokeny Luxembourg (technology provider) Technology provider; not a licensed financial institution Any asset class, as software EU-wide as a vendor Yes, as technology only Does not issue, place, custody or settle; you appoint licensed parties ADDX Singapore MAS MAS capital markets services licence; recognised market operator Funds, private credit, pre-IPO equity Singapore and accredited investors globally No EU issuance Not an EU-authorised venue; EU investors treated case by case Taurus Switzerland FINMA FINMA-supervised securities firm; bank-grade custody Equities, debt, funds, digital assets Switzerland, EU via clients Partly, as custody and technology to EU institutions Not an EU fund issuer; Swiss perimeter is the primary one Centrifuge Protocol; no single supervisor Protocol and DAO structure; issuers licensed separately Private credit, receivables Global, permissionless components Only where an EU-licensed issuer sits on top No EU authorisation of its own; investor protection depends on the issuer Backed Switzerland Swiss issuer of tracker certificates Tokenized ETFs, equities, bonds as certificates Non-US professional investors Products accessible; not EU fund units Instruments are certificates, not fund units; no EU fund wrapper Archax UK FCA FCA-regulated exchange, broker and custodian Funds, securities, digital assets UK; EU case by case post-Brexit Not as an EU-authorised firm UK perimeter; EU issuance needs an EU-licensed partner InvestaX Singapore MAS MAS capital markets services licence Real estate, funds, private equity Singapore and accredited investors No EU issuance No EU authorisation Obligate Switzerland Swiss regulatory perimeter; on-chain bond issuance Bonds and short-term debt Switzerland, EU issuers case by case Partly, for debt instruments Debt-focused; not a fund wrapper or transfer agent Nyala Germany BaFin Crypto-securities registrar under the German eWpG Debt securities, crypto securities registers Germany primarily Yes, for German-law crypto securities Registrar role only; does not place, custody or manage funds Assetera Austria MiFID II-authorised secondary market operator in the EU Tokenized securities, funds, bonds EEA Yes, as a venue and distribution route A venue, not an issuer or custodian; primary issuance sits elsewhere Black Manta Capital Partners COSIMO GROUP Germany BaFin BaFin-licensed investment firm operating under MiFID II Funds, private equity, real estate, debt EEA via MiFID II passporting Yes, as an EU-licensed issuance and placement firm Not a depositary; not a trading venue; no retail distribution COSIMO Digital (group) US BaFin (issuance); Central Bank of Ireland (VASP registration) MiFID II issuance live; VASP-registered, MiCA CASP authorisation in process and not yet effective Funds, private markets, digital asset treasury EEA; US via affiliate broker-dealer and ATS Yes, for issuance and placement today Custody and payments are not yet authorised; no UCITS capability; no retail channel; not a CSD Which can serve EU issuers, and which cannot? Five of the fifteen can serve an EU issuer directly today: Black Manta Capital Partners, COSIMO Digital through it, Tokeny as a technology supplier, Nyala for German-law crypto securities, and Assetera as an EEA venue. Taurus and Obligate can serve EU clients for specific functions within the Swiss perimeter. The remainder require an EU-licensed counterparty to sit between them and the issuance, or serve EU investors only on a reverse-solicitation or case-by-case basis. That is not a criticism of the others. A US transfer agent with SEC registration is exactly the right provider for a US offering, and a Singapore licence is the right one for Singapore distribution. The error is assuming a licence travels. It does not: MiFID II passporting works within the EEA, MAS authorisation works in Singapore, and neither substitutes for the other. For an EU issuer the practical consequence is a two-part question for any shortlisted provider. First, which EU-authorised entity will be responsible for issuance and placement — named, with its licence reference and supervisor. Second, where does the register legally sit, and is that register recognised under the law of the fund’s domicile. A provider that cannot answer both in one email is not yet a candidate. How do I shortlist for my asset class? Start from the asset and the investor base, not the technology. Four common cases cover most enquiries, and each has a different answer. A European private fund for professional investors You need an EU-licensed issuance firm, an authorised AIFM, a depositary and a register whose legal standing is recognised in the domicile. Shortlist: Black Manta Capital Partners for issuance, Tokeny or an equivalent for the token layer, Assetera if you want an EEA secondary venue, and a depositary from your domicile. Ondo, Superstate and Backed are not relevant to this case. Tokenized short-duration government debt exposure Ondo Finance, Superstate and Backed are the established product issuers here, and none is an EU fund. If you need an EU wrapper for a treasury strategy, you are commissioning a fund issuance, not buying a product, and the first case applies. Private credit or receivables Centrifuge for protocol infrastructure with a licensed issuer on top; Obligate for debt instruments in the Swiss perimeter; an EU issuance firm with a securitisation compartment where the investors are European institutions. Secondary liquidity for an existing tokenized instrument This is a venue question, not an issuance question. Assetera in the EEA, Archax in the UK, ADDX or InvestaX in Singapore. Confirm that your instrument’s transfer restrictions can be enforced on the venue, because a venue that cannot enforce eligibility cannot admit a restricted instrument. Then apply three filters, in order: is there a named EU-authorised entity accountable for issuance; is the register legally recognised in the domicile; and does the provider’s answer to "what do you not do" match ours in the table above. The third filter is the most informative, because a provider who lists their limitations unprompted is describing a real perimeter. What is still missing from every platform on this list? No platform on this list offers regulated issuance, qualified custody, settlement and asset management as one authorised, integrated stack in the EU. Every structure in the market today is assembled: an issuer here, a custodian there, a register somewhere else, a venue if you are lucky. The issuer carries the coordination burden and the operational risk that lives in the seams between providers. That gap is not evidence of incompetence. It is a consequence of how the permissions are drawn. MiFID II issuance, depositary duties, MiCA custody and payment services are separate authorisations with separate capital, governance and reporting requirements, and holding several of them at once is slow and expensive. Most firms sensibly specialise. The result is that the market’s standard product is an integration project. Three further gaps are worth naming because no vendor volunteers them. The cash leg is unsolved for most European structures: without tokenized cash on the same ledger, delivery versus payment is aspirational. Secondary liquidity is thin almost everywhere — venues exist, order books largely do not. And legal recognition of an on-chain register still varies by member state, so the same structure has different standing in different domiciles. COSIMO Digital is building toward the integrated case and is not there yet either. Issuance is live and BaFin-licensed. Custody and payments are in authorisation with the Central Bank of Ireland and not yet effective. Settlement and identity infrastructure is built and not operating at scale. Asset management has a four-year live record through COSIMO X, a tokenized evergreen venture fund listed on Securitize Markets in December 2021. Two of six layers are operational, which is more than most and less than the whole. Read the group’s regulatory authorisations and their exact status rather than taking that summary on trust, and if it is useful, read how to tokenize a fund in Europe step by step or the definitions of the terms used in this table . Related How to tokenize a fund in Europe: the complete process Wrapper, classification, providers, timeline and real costs. MiFID II or MiCA: which applies to tokenized securities? Why the licence a platform holds decides what it can do for you. Tokenization glossary: MiCA, MiFID II and digital asset terms defined CASP, VASP, DLT MTF, transfer agent and the rest, defined. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Platform entries compiled from public statements, product documentation and regulator registers as of July 2026. Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA); Directive 2014/65/EU (MiFID II), EU Official Journal. German Act on Electronic Securities (eWpG) for crypto-securities registrar status. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # MiFID II or MiCA — which one applies to your token? URL: https://cosimodigital.com/learn/mifid-ii-or-mica ======================================================================== Home / Learn / MiFID II or MiCA European regulation MiFID II or MiCA — which one applies to your token? MiCA excludes crypto-assets that qualify as financial instruments. Tokenized securities are financial instruments. So the regime is MiFID II, and a MiCA authorisation gives no permission over them. The classification is not a preference; here is how it is actually made, with five worked examples. Last updated: 28 July 2026 By Ciarán Hynes · 10 min read On this page Does MiCA apply to tokenized securities? What makes a token a MiFID II financial instrument? Where exactly is the boundary? Five worked examples Which licence do you actually need? What happens if you get the classification wrong? What is changing in 2026? Does MiCA apply to tokenized securities? No. Tokenized securities are financial instruments, and Regulation (EU) 2023/1114 (MiCA) excludes financial instruments from its own scope. Article 2(4)(a) states it directly: the Regulation does not apply to crypto-assets that qualify as financial instruments within the meaning of Directive 2014/65/EU (MiFID II) . A token that is a security is therefore regulated as a security, and a MiCA authorisation confers no permission over it. This is the opposite of the answer the market repeats. Search results, vendor decks and a good deal of conference commentary treat MiCA as the European regime for tokenization generally, because MiCA is newer and better publicised. The effect is that firms procure the wrong licence, appoint providers who cannot legally perform the service, and discover it at the placement stage, which is the most expensive moment to discover it. The practical rule has two halves. If the token carries a claim on an issuer, a pool of assets, a stream of profits or a return determined by portfolio performance, treat it as a financial instrument and start from MiFID II. If it does not — a payment token, a utility with no claim, an asset-referenced or e-money token — start from MiCA. Where the analysis is close, the classification is a legal opinion and not a preference, and it should be obtained in writing before providers are appointed. Two regimes, no overlap MiCA Article 2(4)(a) excludes crypto-assets qualifying as financial instruments under MiFID II. Regulation (EU) 2023/1114 and Directive 2014/65/EU , EU Official Journal. What makes a token a MiFID II financial instrument? Annex I Section C of MiFID II lists the financial instruments, and the first item — transferable securities — captures most tokenized instruments in practice. A transferable security is a class of securities negotiable on the capital market: shares, bonds and other debt instruments, and securities giving a right to acquire or sell them or giving rise to a cash settlement determined by reference to securities, currencies, rates or indices. Three features do most of the work in the analysis. Negotiability: is the instrument transferable to others, in a class rather than as a bespoke bilateral contract. Claim: does the holder have a right against an issuer or against a pool of assets. Return dependency: is the holder’s outcome determined by the performance of assets, an enterprise or a reference value. An instrument with all three is a transferable security in almost every European analysis. What does not matter: the ledger it sits on, the token standard used, the word in the name, whether the holder is called an investor or a member, and whether the offering documents describe the instrument as a utility. ESMA has published guidance on the conditions and criteria for qualifying crypto-assets as financial instruments precisely because form-over-substance arguments kept being made. Substance governs, and national competent authorities apply it. One further category deserves a note. Units in collective investment undertakings appear in Annex I Section C as their own item. A tokenized fund unit is therefore a financial instrument even where an argument might be made that it is not a transferable security. There is no version of the analysis in which a tokenized fund unit falls under MiCA. Where exactly is the boundary? Five worked examples The boundary is clearer in worked cases than in the abstract. Five instruments, each described the way it is usually pitched, with the classification that actually applies. 1. A token representing units in a venture fund A unit in a collective investment undertaking. MiFID II applies; issuance and placement require an investment firm authorisation, and the fund itself requires an authorised AIFM under AIFMD. MiCA is not engaged by the unit. This is the least ambiguous case on the list and it is still routinely misclassified. 2. A token backed one-to-one by euro deposits, redeemable at par on demand An e-money token under MiCA. It references a single official currency and functions as electronic money, so the issuer must be an authorised credit institution or electronic money institution, with full backing in low-risk liquid reserves and redemption at par at any time. Not a security, and not a MiFID II instrument. 3. A token referencing a basket of currencies and commodities to hold its value stable An asset-referenced token under MiCA, with reserve, governance, disclosure and own-funds obligations, and EU-level supervision if it is deemed significant. The line between this and a fund unit is intent and structure: an ART exists to stabilise value for payment-like use, while a fund unit exists to deliver investment return. 4. A token giving holders a share of revenue from a portfolio of loans A financial instrument. The holder’s return depends on the performance of underlying assets and there is a claim on a pool, so it is a transferable security or a fund unit depending on the wrapper. Describing it as a revenue-share or a protocol incentive does not move it out of MiFID II. 5. A token giving access to a software platform, with no claim and no return Genuinely outside MiFID II, and within MiCA as a crypto-asset. But the test is strict: if the token is marketed on the basis of expected appreciation, if holders are promised any share of proceeds, or if a secondary market is created and supported by the issuer, the analysis can shift. This category is real and much smaller than the market believes. Classification summary for the five examples. Instrument as pitched Actual classification Applicable regime Permission needed to issue and place Tokenized venture fund unit Unit in a collective investment undertaking MiFID II (plus AIFMD for the manager) MiFID II investment firm; authorised AIFM Euro-backed token redeemable at par E-money token MiCA Credit institution or electronic money institution Basket-referenced stable token Asset-referenced token MiCA MiCA ART issuer authorisation Loan-portfolio revenue share Transferable security or fund unit MiFID II MiFID II investment firm Pure platform access token, no claim Crypto-asset MiCA MiCA offeror obligations; CASP for services Which licence do you actually need? For tokenized securities: a MiFID II investment firm authorisation covering the specific services you perform, held by whichever entity performs them. For crypto-asset services: a MiCA CASP authorisation. These are different licences, obtained from different processes, and holding one tells you nothing about the other. Map the services rather than the project. Placing units with investors is a MiFID II service. Receiving and transmitting orders is a MiFID II service. Safekeeping financial instruments is a MiFID II ancillary service, while safekeeping crypto-assets is a MiCA service. Operating a venue is a separate authorisation again. A single tokenized issuance can therefore touch three or four permissions across three or four entities, which is normal and needs to be documented. An anti-money-laundering registration is not a substitute for either. Registration as a Virtual Asset Service Provider under national implementing law is an AML supervision status and does not permit investment services or MiCA services. We state our own position on this in the same terms we would want from a counterparty: Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. The question to put to every provider "Which authorisation, held by which legal entity, supervised by which authority, covers the specific service you will perform for us?" Any answer that names a regime without naming an entity and a supervisor is not an answer. Read the group’s authorisations and their exact status as an example of the form the answer should take. What happens if you get the classification wrong? Treating a security as a crypto-asset means conducting an unauthorised investment service. The consequences run in three directions: supervisory action against the firm and its management, civil exposure to investors whose instruments were placed without the required authorisation, and the practical collapse of the offering — banks, depositaries and venues withdraw once the perimeter is in question. The reverse error is less dangerous and still costly. Treating a genuine crypto-asset as a security means over-engineering: a prospectus or an offering memorandum nobody required, an investment firm engaged for work it did not need to do, and a distribution channel narrowed for no regulatory reason. Firms rarely get sanctioned for this. They simply spend more and reach fewer investors. Remediation of the first error is possible and unpleasant. It generally means suspending the offering, appointing an authorised firm, re-papering the instrument, and in some cases offering rescission to investors who were placed into it. The cost is an order of magnitude above the cost of a written classification opinion obtained at the outset, and the reputational cost with institutional allocators is harder to price and slower to repair. The safeguard is unglamorous: a written classification view from EU counsel, obtained before providers are appointed, refreshed if the instrument’s economics change, and shared with the depositary and the bank. Every experienced allocator asks for it during due diligence. Having it on hand answers the question and signals the discipline behind the rest of the structure. What is changing in 2026? The boundary itself is stable; the practice around it is consolidating. Three developments matter for the classification question this year. ESMA guidance on qualifying crypto-assets as financial instruments is now the reference point national authorities apply, which has narrowed the space for form-over-substance arguments. The MiCA authorisation cohort has become visible, and it is small. And the DLT Pilot Regime continues to generate the evidence base for permanent market-infrastructure reform. About one in six Roughly 210 of approximately 1,200 pre-MiCA firms have secured MiCA authorisation. COSIMO Digital analysis of regulator registers and market data, 2026. The authorisation numbers are the more consequential fact for anyone choosing a counterparty. A market that has gone from roughly 1,200 pre-MiCA firms to roughly 210 authorised ones has not shrunk by accident: authorisation is expensive, slow and demanding of governance, and most firms could not carry it. The firms that did are now the ones institutions can transact with, which is a structural advantage that did not exist before MiCA applied. What is not changing in 2026: MiCA will not begin to cover tokenized securities, and MiFID II will not cede the securities perimeter. Anyone waiting for a single unified tokenization regime in Europe is waiting for something that is not on any legislative agenda. The correct planning assumption is two regimes, a hard boundary between them, and a written opinion telling you which side you are on. Read next how to tokenize a fund in Europe step by step , or what a tokenized fund actually is . Related How to tokenize a fund in Europe: the complete process What follows once the classification question is settled. RWA tokenization platforms compared: which are regulated, and by whom Fifteen platforms, their licences, and what each cannot do. Tokenization glossary: MiCA, MiFID II and digital asset terms defined CASP, ART, EMT, VASP and security token, defined precisely. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), Article 2(4)(a), EU Official Journal, 2023. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II), Annex I Section C, EU Official Journal, 2014. European Securities and Markets Authority, guidance on the conditions and criteria for the qualification of crypto-assets as financial instruments. Regulation (EU) 2022/858 on a pilot regime for DLT market infrastructures, EU Official Journal, 2022. MiCA authorisation counts: COSIMO Digital analysis of regulator registers and market data, 2026 (approximately 210 authorised of approximately 1,200 pre-MiCA firms). COSIMO Digital regulatory authorisations, described as of 28 July 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What is a tokenized fund? Structure, custody and redemption URL: https://cosimodigital.com/learn/tokenized-funds ======================================================================== Home / Learn / Tokenized funds Tokenized funds and private markets What is a tokenized fund? A tokenized fund is a fund whose register of holders sits on a distributed ledger. The wrapper, the manager, the depositary and the investor protections are unchanged. What changes is the ownership record — and that single change is worth understanding precisely, because everything claimed beyond it is usually overstated. Last updated: 28 July 2026 By Ciarán Hynes · 14 min read On this page What is a tokenized fund? How is a tokenized fund different from a crypto ETF? What does the token legally represent? Who maintains the register, and how is it reconciled on-chain? How do subscriptions and redemptions actually work? What are the real risks of a tokenized fund? What does a live tokenized fund look like in practice? What is a tokenized fund? A tokenized fund is a collective investment vehicle whose units or shares are issued and transferred as records on a distributed ledger, with that ledger serving as the register of holders. It is a fund first. The legal wrapper, the authorised manager, the depositary, the administrator and the investor-protection obligations are all present and unchanged. Tokenization replaces the register and the transfer mechanism. Stated the other way round: a tokenized fund is not a crypto product, not a new asset class, and not a lighter regulatory category. A tokenized unit in a European alternative investment fund is a financial instrument under MiFID II , and the fund’s manager is authorised under AIFMD exactly as it would be without a ledger. The instrument’s legal character comes from the wrapper, not from the technology. What the ledger changes is the quality of the ownership record. In a conventional fund, the authoritative register lives in the transfer agent’s system and every other party holds a copy that drifts until the next reconciliation. In a tokenized fund, all parties read from one record, transfers are validated against eligibility rules before they execute, and the holder list is authoritative continuously rather than periodically. The scale of interest is worth stating with its source rather than in the abstract. Boston Consulting Group projects $88 trillion of tokenized real-world assets by 2035 — a projection, not a fact, and useful mainly as an indication of where institutional attention is going. The interesting number for a fund manager is smaller and more concrete: how many holders, how many transfers, how many reconciliation breaks per year. It is also worth being clear about who is doing this. The early tokenized funds were venture and private credit vehicles for professional investors, because those are the strategies where the register is genuinely the bottleneck: illiquid holdings, long horizons, manual transfer processes and holder lists that are reconstructed rather than maintained. Liquid strategies had less to gain, because their registers already move through established infrastructure that works. The pattern since has not changed much. Where a fund has a small number of holders, no transfer activity and an annual valuation, tokenization adds cost and removes nothing. Where it has hundreds of holders across several jurisdictions, periodic subscription windows and a transfer process that takes weeks, the case is immediate and measurable in staff hours rather than in narrative. $88 trillion Projected value of tokenized real-world assets by 2035. Boston Consulting Group, 2025. How is a tokenized fund different from a crypto ETF? A crypto ETF is a conventional exchange-traded fund whose underlying holdings are digital assets. A tokenized fund is a fund whose own units are tokenized, irrespective of what it holds. The first tokenizes nothing; the second may hold no crypto at all. They are answers to different questions: exposure versus infrastructure. Tokenized fund and crypto ETF compared. Tokenized fund Crypto ETF What is tokenized The fund’s own units Nothing — units are conventional What it holds Anything: venture, credit, real estate, securities, digital assets Digital assets or derivatives on them Register On-chain, maintained by an accountable transfer agent or registrar Conventional CSD and intermediary chain Where it trades Bilaterally, or on a venue that can enforce transfer restrictions A regulated exchange, continuously Who can hold it Typically professional investors; eligibility enforced by the token Retail and professional, through a broker Settlement Ledger for the asset leg; cash leg varies Standard exchange settlement cycle Primary benefit Register efficiency, faster onboarding and transfer, cheaper administration at scale Simple, liquid, familiar access to an asset class The confusion between them is understandable and it has a cost. An allocator who wants liquid, daily-priced digital asset exposure should buy an ETF; a tokenized private fund will disappoint on both counts. An allocator who wants private-market exposure with a faster, cleaner ownership record should look at a tokenized fund and should not expect exchange liquidity from it. One structural point that follows. Liquidity in a tokenized fund is not a property of the token. It requires licensed distribution to a pool of eligible holders and a venue where restricted instruments can trade, which is a separate build with its own authorisations. Tokenization makes that build possible; it does not perform it. What does the token legally represent? The token represents a unit or share in the fund, with the rights set out in the fund documentation and nothing more. It is a form of the register entry, not a separate instrument sitting alongside it. Where the domicile’s law recognises a distributed ledger as the register of a security, holding the token is holding legal title. Where it does not, the token evidences an interest recorded in an authoritative off-chain register. That distinction is the most important legal question in the category and it varies by member state. Several EU jurisdictions have amended their securities or company law to give a ledger record legal standing; others have not. Both arrangements work in practice, but they produce different answers to a basic allocator question: if the ledger and the register disagree, which one governs. The documentation must answer it explicitly. Three further points that allocators reliably probe. First, the token confers the rights in the fund documents — distributions, redemption terms, reporting, voting where applicable — and cannot confer more. Second, transfer is permitted only to eligible holders, so the instrument is transferable and restricted at once. Third, loss of a private key is not loss of the investment: the register can be updated by the accountable registrar under a documented procedure, which should exist before it is needed. Corporate actions are the part allocators probe second. Distributions, capital calls where applicable, unit splits, redemptions in kind and changes to the fund’s terms all have to operate against the on-chain register, and each needs a defined mechanic rather than an ad hoc transaction. A well-structured vehicle documents these before launch: who initiates, who authorises, how holders are notified, and how the action is evidenced for audit. The technology handles the execution easily; the governance is what is frequently missing. Inheritance, insolvency and court orders are the harder edge. A private fund unit can be subject to a probate transfer, a creditor claim or a regulator instruction, none of which the holder consents to and none of which a permissionless token can express. This is exactly why the accountable registrar matters: it must be able to move or freeze a holding on proper legal instruction, under a documented procedure that the depositary has reviewed. A structure that has no mechanism for a compelled transfer has not been designed for institutional money, whatever else it does well. The one-line test Ask: "If the ledger and the official register disagree tomorrow, which record determines legal ownership, and under which law?" A structure that cannot answer in one sentence has not resolved the question. The definition of an on-chain register sets out why this varies by jurisdiction. Who maintains the register, and how is it reconciled on-chain? A named transfer agent or registrar maintains it, appointed under the fund documentation and legally accountable for its accuracy. The ledger holds the record; a party owns it. On-chain does not mean unowned, and any structure where accountability for the register is implied by software rather than assigned by contract has a gap in it. Reconciliation changes shape rather than disappearing. In a conventional fund, reconciliation means comparing the transfer agent’s register against the administrator’s books and the depositary’s records, periodically, and resolving breaks after the fact. In a tokenized fund, all parties read the same record, so the reconciliation task becomes narrower: confirming that the on-chain holder list corresponds to the completed subscription, redemption and transfer instructions, and that the whitelist still reflects current investor eligibility. What the reconciliation actually covers at each NAV date Holder list on-chain against subscriptions and redemptions processed in the period. Units in issue on-chain against units in issue in the administrator’s books. Whitelist membership against current verification and sanctions status for each holder. Any failed or reverted transfers, with the reason recorded. Sign-off by the accountable registrar, dated, retained for audit. The depositary’s oversight duties are unchanged and its operational due diligence on the register is the part of a tokenized launch that takes longest. That is appropriate: the depositary is being asked to oversee a register kept in a form it may not have overseen before, and its comfort is a risk decision. Give it the token documentation, the transfer-rule logic and the reconciliation design as one package, early. How do subscriptions and redemptions actually work? Subscription runs in five steps: onboarding and verification, whitelisting of the investor’s address, commitment at a NAV struck on the fund’s published schedule, payment of the cash leg, and minting of units to the address once payment is confirmed. Redemption reverses it — instruction, NAV strike, units burned or transferred back, payment out. Two of those steps are genuinely automated. Eligibility is enforced by the token, so an ineligible address cannot receive units and a transfer to an unverified wallet fails rather than needing to be unwound. And the register updates as part of the transaction, so the holder list is correct immediately after each event. The cash leg is where the honest answer diverges from the marketing. Where payment is a bank transfer, the fund waits for confirmation before minting, and settlement takes hours or days like any other fund. Where the cash leg is a MiCA e-money token or a tokenized deposit on the same ledger, subscription can settle atomically: units and payment move in one transaction or neither moves. Both models are in use; only the second delivers delivery versus payment in the strict sense. What does not change is the fund’s terms. A quarterly-redemption vehicle does not become daily because it is tokenized; a portfolio that can be valued monthly cannot be valued hourly by a ledger. Redemption gates, notice periods, lock-ups and NAV frequency come from the documentation and the liquidity of the underlying assets. Tokenization removes friction from the register, not from the portfolio. A concrete subscription looks like this. An institution completes onboarding and its documentation is verified; its custody address is screened and whitelisted; it commits ahead of the subscription cut-off; the administrator strikes NAV on the scheduled date; payment is made and confirmed; units are minted to the whitelisted address and the register updates in the same transaction. Where the fund uses a fiat cash leg, elapsed time from commitment to units in hand is usually two to five business days, most of it waiting for payment confirmation and the NAV strike. Where the cash leg is on the same ledger, the final two steps collapse into one. The failure cases are worth rehearsing with investors before they occur, because each has an unfamiliar shape. A payment that arrives from an unverified account is held rather than applied. A wallet that changes custodian mid-cycle needs re-whitelisting before it can receive units. A redemption instruction submitted after a cut-off rolls to the next window, exactly as in a conventional fund. And an investor whose periodic verification lapses is blocked from receiving units until it is refreshed — not a defect, but a control that surprises people the first time it fires. What are the real risks of a tokenized fund? The material risks are the fund’s own — strategy, valuation, liquidity, manager quality — as they would be in any private vehicle. Tokenization adds four specific risks on top, and removes none of the originals. Anyone presenting tokenization as risk-reducing has the analysis backwards. 1. Legal recognition of the register If the domicile does not recognise a ledger as the register of the security, the on-chain record is evidential rather than authoritative, and the documentation must say which record governs. Unresolved, this is the risk most likely to matter in a dispute. 2. Smart contract and key management risk The transfer logic is code and can contain defects; access is by private key and keys can be lost or compromised. Mitigation is unremarkable and effective: an established permissioned standard rather than a bespoke contract, an independent audit, institutional custody or qualified key management for holders, and a documented recovery procedure operated by the accountable registrar. 3. Cash-leg and counterparty risk Where the cash leg is a stablecoin or e-money token, the fund takes exposure to that issuer and its reserves. Where it is a bank transfer, a settlement gap remains. Neither is eliminated by tokenization; both should be disclosed with the specific instruments and institutions named. 4. Operational concentration Several structures depend on a single technology provider for the register software. If that provider fails, the question is whether the register can be reconstructed and operated independently. Ask for the answer, in writing, before appointment. One risk that tokenization genuinely reduces is worth naming for balance: the register error. Ownership disputes arising from stale, duplicated or manually maintained holder records are a real source of loss in private funds, and a single continuously reconcilable register addresses that class of problem directly. Sizing these risks is a documentation exercise rather than a modelling one. For each of the four, an allocator should be able to point to the paragraph in the offering documents that discloses it, the party responsible for controlling it, and the evidence that the control has been tested. Legal recognition is answered by a domicile opinion. Contract risk is answered by an audit report and the use of an established standard. Cash-leg exposure is answered by naming the institution or the e-money token issuer and its authorisation. Provider concentration is answered by a written statement of whether the register can be operated independently if the vendor fails. Four questions, four documents. A structure that produces all four on request is materially safer than one that produces reassurance. What does a live tokenized fund look like in practice? It looks like a fund. COSIMO X is a tokenized evergreen venture fund, live since 2021 and listed on Securitize Markets in December 2021. It has a manager, a defined strategy, a NAV process and a holder register maintained on-chain, and it has operated through two market cycles. Four years of live operating history is the part that is hard to replicate: very few firms in this category can point to a tokenized fund that has been running that long. What that record demonstrates is narrow and useful. Tokenized units can be issued, held, transferred and reported on continuously over years without the register becoming the problem. Investor onboarding into a tokenized vehicle works at institutional standard. And an evergreen structure — no fixed term, periodic subscription and redemption windows — is compatible with a tokenized register, which is not obvious in advance. The operating detail behind those four years is unremarkable, which is the point. Subscriptions and redemptions have processed through defined windows. NAV has been struck on schedule by the administrator under the vehicle’s valuation policy. Holders have been onboarded, verified and whitelisted, and the register has been reconciled to the books at each valuation date. Positions have been marked, distributions handled, and reporting delivered. None of that is a technology story; all of it is the evidence an allocator actually asks for, because it demonstrates that the structure has survived contact with ordinary operational reality rather than a pilot. What allocators have asked most often, in our experience, maps closely to the eight questions set out in the tokenized fund due diligence frame : what the token represents in legal substance, which record governs title, who is accountable for the register, how transfer restrictions are enforced, how custody is discharged, who calculates NAV, how the cash leg works, and what the offering document discloses about the tokenized framework specifically. A fund with an operating history answers those from records. A fund without one answers them from design intent. Both answers can be correct; only one of them has been tested. What it does not demonstrate: deep secondary liquidity, which requires venues and order books that largely do not yet exist; or atomic settlement against fiat, which requires the cash leg on the same ledger. We would rather state those limits than let a four-year record imply more than it shows. The rest of the group is where the register meets the other layers. Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Read how to tokenize a fund in Europe step by step , the eight questions in tokenized fund due diligence for allocators , or how tokenized asset management sits in the group . Related How to tokenize a fund in Europe: the complete process Wrapper, classification, providers, week-by-week timeline and real costs. Tokenized fund due diligence: eight questions allocators must ask The allocator frame, with our own answers published in full. MiFID II or MiCA: which applies to tokenized securities? Why a tokenized fund unit is never a MiCA crypto-asset. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), EU Official Journal, 2011. Directive 2009/65/EC (UCITS), EU Official Journal, 2009. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II), EU Official Journal, 2014. Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), EU Official Journal, 2023. Boston Consulting Group, projection of $88 trillion of tokenized real-world assets by 2035, 2025. COSIMO X: tokenized evergreen venture fund, live since 2021, listed on Securitize Markets in December 2021. COSIMO Digital regulatory authorisations, described as of 28 July 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== Home / Learn / Tokenized funds Tokenized funds and private markets What is a tokenized fund? A tokenized fund is a fund whose register of holders sits on a distributed ledger. The wrapper, the manager, the depositary and the investor protections are unchanged. What changes is the ownership record — and that single change is worth understanding precisely, because everything claimed beyond it is usually overstated. Last updated: 28 July 2026 By Ciarán Hynes · 14 min read On this page What is a tokenized fund? How is a tokenized fund different from a crypto ETF? What does the token legally represent? Who maintains the register, and how is it reconciled on-chain? How do subscriptions and redemptions actually work? What are the real risks of a tokenized fund? What does a live tokenized fund look like in practice? What is a tokenized fund? A tokenized fund is a collective investment vehicle whose units or shares are issued and transferred as records on a distributed ledger, with that ledger serving as the register of holders. It is a fund first. The legal wrapper, the authorised manager, the depositary, the administrator and the investor-protection obligations are all present and unchanged. Tokenization replaces the register and the transfer mechanism. Stated the other way round: a tokenized fund is not a crypto product, not a new asset class, and not a lighter regulatory category. A tokenized unit in a European alternative investment fund is a financial instrument under MiFID II , and the fund’s manager is authorised under AIFMD exactly as it would be without a ledger. The instrument’s legal character comes from the wrapper, not from the technology. What the ledger changes is the quality of the ownership record. In a conventional fund, the authoritative register lives in the transfer agent’s system and every other party holds a copy that drifts until the next reconciliation. In a tokenized fund, all parties read from one record, transfers are validated against eligibility rules before they execute, and the holder list is authoritative continuously rather than periodically. The scale of interest is worth stating with its source rather than in the abstract. Boston Consulting Group projects $88 trillion of tokenized real-world assets by 2035 — a projection, not a fact, and useful mainly as an indication of where institutional attention is going. The interesting number for a fund manager is smaller and more concrete: how many holders, how many transfers, how many reconciliation breaks per year. $88 trillion Projected value of tokenized real-world assets by 2035. Boston Consulting Group, 2025. How is a tokenized fund different from a crypto ETF? A crypto ETF is a conventional exchange-traded fund whose underlying holdings are digital assets. A tokenized fund is a fund whose own units are tokenized, irrespective of what it holds. The first tokenizes nothing; the second may hold no crypto at all. They are answers to different questions: exposure versus infrastructure. Tokenized fund and crypto ETF compared. Tokenized fund Crypto ETF What is tokenized The fund’s own units Nothing — units are conventional What it holds Anything: venture, credit, real estate, securities, digital assets Digital assets or derivatives on them Register On-chain, maintained by an accountable transfer agent or registrar Conventional CSD and intermediary chain Where it trades Bilaterally, or on a venue that can enforce transfer restrictions A regulated exchange, continuously Who can hold it Typically professional investors; eligibility enforced by the token Retail and professional, through a broker Settlement Ledger for the asset leg; cash leg varies Standard exchange settlement cycle Primary benefit Register efficiency, faster onboarding and transfer, cheaper administration at scale Simple, liquid, familiar access to an asset class The confusion between them is understandable and it has a cost. An allocator who wants liquid, daily-priced digital asset exposure should buy an ETF; a tokenized private fund will disappoint on both counts. An allocator who wants private-market exposure with a faster, cleaner ownership record should look at a tokenized fund and should not expect exchange liquidity from it. One structural point that follows. Liquidity in a tokenized fund is not a property of the token. It requires licensed distribution to a pool of eligible holders and a venue where restricted instruments can trade, which is a separate build with its own authorisations. Tokenization makes that build possible; it does not perform it. What does the token legally represent? The token represents a unit or share in the fund, with the rights set out in the fund documentation and nothing more. It is a form of the register entry, not a separate instrument sitting alongside it. Where the domicile’s law recognises a distributed ledger as the register of a security, holding the token is holding legal title. Where it does not, the token evidences an interest recorded in an authoritative off-chain register. That distinction is the most important legal question in the category and it varies by member state. Several EU jurisdictions have amended their securities or company law to give a ledger record legal standing; others have not. Both arrangements work in practice, but they produce different answers to a basic allocator question: if the ledger and the register disagree, which one governs. The documentation must answer it explicitly. Three further points that allocators reliably probe. First, the token confers the rights in the fund documents — distributions, redemption terms, reporting, voting where applicable — and cannot confer more. Second, transfer is permitted only to eligible holders, so the instrument is transferable and restricted at once. Third, loss of a private key is not loss of the investment: the register can be updated by the accountable registrar under a documented procedure, which should exist before it is needed. The one-line test Ask: "If the ledger and the official register disagree tomorrow, which record determines legal ownership, and under which law?" A structure that cannot answer in one sentence has not resolved the question. The definition of an on-chain register sets out why this varies by jurisdiction. Who maintains the register, and how is it reconciled on-chain? A named transfer agent or registrar maintains it, appointed under the fund documentation and legally accountable for its accuracy. The ledger holds the record; a party owns it. On-chain does not mean unowned, and any structure where accountability for the register is implied by software rather than assigned by contract has a gap in it. Reconciliation changes shape rather than disappearing. In a conventional fund, reconciliation means comparing the transfer agent’s register against the administrator’s books and the depositary’s records, periodically, and resolving breaks after the fact. In a tokenized fund, all parties read the same record, so the reconciliation task becomes narrower: confirming that the on-chain holder list corresponds to the completed subscription, redemption and transfer instructions, and that the whitelist still reflects current investor eligibility. What the reconciliation actually covers at each NAV date Holder list on-chain against subscriptions and redemptions processed in the period. Units in issue on-chain against units in issue in the administrator’s books. Whitelist membership against current verification and sanctions status for each holder. Any failed or reverted transfers, with the reason recorded. Sign-off by the accountable registrar, dated, retained for audit. The depositary’s oversight duties are unchanged and its operational due diligence on the register is the part of a tokenized launch that takes longest. That is appropriate: the depositary is being asked to oversee a register kept in a form it may not have overseen before, and its comfort is a risk decision. Give it the token documentation, the transfer-rule logic and the reconciliation design as one package, early. How do subscriptions and redemptions actually work? Subscription runs in five steps: onboarding and verification, whitelisting of the investor’s address, commitment at a NAV struck on the fund’s published schedule, payment of the cash leg, and minting of units to the address once payment is confirmed. Redemption reverses it — instruction, NAV strike, units burned or transferred back, payment out. Two of those steps are genuinely automated. Eligibility is enforced by the token, so an ineligible address cannot receive units and a transfer to an unverified wallet fails rather than needing to be unwound. And the register updates as part of the transaction, so the holder list is correct immediately after each event. The cash leg is where the honest answer diverges from the marketing. Where payment is a bank transfer, the fund waits for confirmation before minting, and settlement takes hours or days like any other fund. Where the cash leg is a MiCA e-money token or a tokenized deposit on the same ledger, subscription can settle atomically: units and payment move in one transaction or neither moves. Both models are in use; only the second delivers delivery versus payment in the strict sense. What does not change is the fund’s terms. A quarterly-redemption vehicle does not become daily because it is tokenized; a portfolio that can be valued monthly cannot be valued hourly by a ledger. Redemption gates, notice periods, lock-ups and NAV frequency come from the documentation and the liquidity of the underlying assets. Tokenization removes friction from the register, not from the portfolio. What are the real risks of a tokenized fund? The material risks are the fund’s own — strategy, valuation, liquidity, manager quality — as they would be in any private vehicle. Tokenization adds four specific risks on top, and removes none of the originals. Anyone presenting tokenization as risk-reducing has the analysis backwards. 1. Legal recognition of the register If the domicile does not recognise a ledger as the register of the security, the on-chain record is evidential rather than authoritative, and the documentation must say which record governs. Unresolved, this is the risk most likely to matter in a dispute. 2. Smart contract and key management risk The transfer logic is code and can contain defects; access is by private key and keys can be lost or compromised. Mitigation is unremarkable and effective: an established permissioned standard rather than a bespoke contract, an independent audit, institutional custody or qualified key management for holders, and a documented recovery procedure operated by the accountable registrar. 3. Cash-leg and counterparty risk Where the cash leg is a stablecoin or e-money token, the fund takes exposure to that issuer and its reserves. Where it is a bank transfer, a settlement gap remains. Neither is eliminated by tokenization; both should be disclosed with the specific instruments and institutions named. 4. Operational concentration Several structures depend on a single technology provider for the register software. If that provider fails, the question is whether the register can be reconstructed and operated independently. Ask for the answer, in writing, before appointment. One risk that tokenization genuinely reduces is worth naming for balance: the register error. Ownership disputes arising from stale, duplicated or manually maintained holder records are a real source of loss in private funds, and a single continuously reconcilable register addresses that class of problem directly. What does a live tokenized fund look like in practice? It looks like a fund. COSIMO X is a tokenized evergreen venture fund, live since 2021 and listed on Securitize Markets in December 2021. It has a manager, a defined strategy, a NAV process and a holder register maintained on-chain, and it has operated through two market cycles. Four years of live operating history is the part that is hard to replicate: very few firms in this category can point to a tokenized fund that has been running that long. What that record demonstrates is narrow and useful. Tokenized units can be issued, held, transferred and reported on continuously over years without the register becoming the problem. Investor onboarding into a tokenized vehicle works at institutional standard. And an evergreen structure — no fixed term, periodic subscription and redemption windows — is compatible with a tokenized register, which is not obvious in advance. What it does not demonstrate: deep secondary liquidity, which requires venues and order books that largely do not yet exist; or atomic settlement against fiat, which requires the cash leg on the same ledger. We would rather state those limits than let a four-year record imply more than it shows. The rest of the group is where the register meets the other layers. Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Read how to tokenize a fund in Europe step by step , the eight questions in tokenized fund due diligence for allocators , or how tokenized asset management sits in the group . Related How to tokenize a fund in Europe: the complete process Wrapper, classification, providers, week-by-week timeline and real costs. Tokenized fund due diligence: eight questions allocators must ask The allocator frame, with our own answers published in full. MiFID II or MiCA: which applies to tokenized securities? Why a tokenized fund unit is never a MiCA crypto-asset. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2011/61/EU on Alternative Investment Fund Managers (AIFMD), EU Official Journal, 2011. Directive 2009/65/EC (UCITS), EU Official Journal, 2009. Directive 2014/65/EU on Markets in Financial Instruments (MiFID II), EU Official Journal, 2014. Regulation (EU) 2023/1114 on Markets in Crypto-Assets (MiCA), EU Official Journal, 2023. Boston Consulting Group, projection of $88 trillion of tokenized real-world assets by 2035, 2025. COSIMO X: tokenized evergreen venture fund, live since 2021, listed on Securitize Markets in December 2021. COSIMO Digital regulatory authorisations, described as of 28 July 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Tokenized fund due diligence: 8 questions allocators must ask URL: https://cosimodigital.com/learn/tokenized-fund-due-diligence ======================================================================== Home / Learn / Due diligence Tokenized funds and private markets What allocators should ask before investing in a tokenized fund Eight questions separate a tokenized fund that has been structured properly from one that has been described well. They are the questions institutional allocators already ask under NDA. Below they are answered in general — and then answered for our own structures, in public. Last updated: 28 July 2026 By Ciarán Hynes · 10 min read On this page What does the token represent, in legal substance? Under what regulatory framework is the fund registered? How is the official register maintained, and how is it reconciled to the on-chain record? How are transfer restrictions enforced at the smart contract level? How is custody of the fund’s underlying assets discharged? How is NAV calculated, and who calculates it? How does the cash leg work, and what stablecoins or fiat channels are used? What does the offering memorandum disclose about the tokenized framework specifically? What does the token represent, in legal substance? Ask for the answer in one sentence, and check it against the offering documents. A token in a fund structure should represent a unit or share in that fund, carrying the rights set out in the documentation and no others. If the answer describes the token as representing "exposure to" something, or as a "digital twin" of an interest, press until you have the legal characterisation: unit in a collective investment undertaking, transferable security, or debt instrument. The follow-up matters more than the answer. Where the domicile recognises a distributed ledger as the register of the security, holding the token is holding legal title. Where it does not, the token evidences an interest recorded in an authoritative off-chain register, and the documentation must state which record governs if the two diverge. Both are workable; only one of them is usually disclosed without being asked. Red flags: an instrument described as a utility or access token while carrying economic rights; documentation silent on which record governs title; a structure where the token and the register are maintained by different parties with no reconciliation obligation between them. Any of the three should stop the process until resolved. Under what regulatory framework is the fund registered? You want the named legal entity, its authorisation, its supervisor, and the fund’s own domicile and status. "MiCA-compliant" is not a framework and is usually a signal that the classification work has not been done — a tokenized fund unit is a financial instrument under MiFID II , and MiCA excludes financial instruments from its scope. For a European structure the expected answer names an authorised manager under AIFMD or the UCITS regime, a depositary, and a MiFID II investment firm responsible for issuance and placement. For a non-EU structure it names the equivalent local authorisations and the basis on which the units may be offered to you. Two checks are worth doing yourself. Verify each authorisation on the relevant public register rather than relying on the deck. And distinguish authorisations that are live from those that are pending: a pending authorisation is not effective until granted, and a structure relying on one is relying on something that does not yet exist. How is the official register maintained, and how is it reconciled to the on-chain record? There should be a named party accountable for the register and a written reconciliation process with a defined frequency. If the answer is that the blockchain maintains the register, the question has not been answered: a ledger holds a record, and a legal person is accountable for its accuracy. Ask what the reconciliation covers and how often. A credible answer at each NAV date includes the holder list against processed subscriptions, redemptions and transfers; units in issue on-chain against the administrator’s books; whitelist membership against current verification and sanctions status; failed or reverted transfers with reasons; and a dated sign-off retained for audit. Then ask what happens when a break is found: who investigates, who authorises a correction to the register, and how the correction is evidenced. Funds that have operated a tokenized register for any length of time answer this immediately, because they have done it. Funds that have not tend to describe the process in the conditional tense. How are transfer restrictions enforced at the smart contract level? Enforcement should happen before the transfer executes, not after. A permissioned token validates the receiving address against on-chain identity and eligibility rules — verified identity, jurisdiction, investor category, holding period, holder limits — and rejects any transfer that fails. ERC-3643 is the standard most commonly used for this in European structures. Ask three things. Which standard, and has the implementation been independently audited. Who maintains the whitelist, and how quickly is it updated when an investor’s verification lapses or their jurisdiction changes. And how are changes to the eligibility matrix handled once the token is live, since each change is a re-configuration and potentially a controlled migration. The failure mode to test for is a token that transfers freely with restrictions enforced by review after settlement. That is not enforcement; it is remediation, and it exposes the fund to holders it is not permitted to have. A fund that cannot demonstrate a failed transfer to an ineligible address on request has not proved the control works. How is custody of the fund’s underlying assets discharged? Separate two things: custody of the fund’s assets and custody of the fund’s units. Fund assets are the depositary’s duty under AIFMD or the UCITS regime, and that obligation is unchanged by tokenization. Units are held by investors, in self-custody or with a custodian, and their safekeeping is a different question with different providers. Where the fund holds digital assets, ask which authorised entity performs that custody and under which permission — crypto-asset custody in the EU is a MiCA service and is distinct from the safekeeping of financial instruments under MiFID II. A firm registered only as a Virtual Asset Service Provider under national anti-money-laundering law holds an AML supervision status, not a custody authorisation. Also ask about keys and recovery. What happens if an investor loses access; who can update the register and under what documented procedure; and whether the depositary has reviewed and accepted that procedure. This is routine in mature structures and absent in immature ones. How is NAV calculated, and who calculates it? An independent administrator should calculate NAV on a published schedule, under the valuation policy in the fund documentation, with depositary or equivalent oversight where the structure requires it. Tokenization changes none of this, and a claim of continuous or real-time NAV for a private portfolio should be treated as a warning rather than a feature. Ask for the valuation policy itself, not a summary: how illiquid positions are marked, how often, by whom, and what independent input is used. For venture and private credit strategies the honest answer involves periodic marks and judgement, which is acceptable and disclosable. What is not acceptable is a valuation process that cannot be described. One tokenization-specific check: confirm that the units in issue used in the NAV calculation are taken from the on-chain register at the strike, and that the administrator has a documented method for reading it. Mismatches between units in issue and the ledger are the most common reconciliation break in tokenized funds, and the process should be designed to catch them at the strike rather than after distribution. How does the cash leg work, and what stablecoins or fiat channels are used? Get the specifics: which banks, which payment institutions, and if a stablecoin or e-money token is used, which issuer and under which authorisation. This is where settlement claims are tested. If payment is a bank transfer, the fund waits for confirmation before issuing units and settlement takes hours or days. If the cash leg is an e-money token or tokenized deposit on the same ledger, settlement can be atomic. Where a stablecoin is used, you are taking exposure to its issuer and its reserves, and that exposure should be disclosed and sized. Under MiCA, an e-money token issuer must be an authorised credit or electronic money institution holding full backing in low-risk liquid reserves with redemption at par on demand; a token that does not meet that standard is a different risk proposition and should be named as such. Then ask what happens on a failed payment, on a redemption when the cash channel is unavailable, and on a currency mismatch between the payment channel and the fund’s base currency. Any fund making instant-settlement claims should be able to identify which ledger holds the cash. Most cannot. What does the offering memorandum disclose about the tokenized framework specifically? The memorandum should address tokenization directly rather than treating it as an operational footnote. Expect: what the token represents, which record governs legal title and under which law, transfer restrictions and how they are enforced, key loss and recovery procedure, the technology providers relied on and the consequences of their failure, the cash-leg mechanics, and the risks arising from tokenization in addition to the fund’s own risks. Two omissions are common and both are material. Provider concentration: if one technology provider maintains the register software, the memorandum should say whether the register can be reconstructed and operated independently. And pending authorisations: where a structure relies on a licence in process, that must be identified as pending and not effective until granted, in the document rather than in conversation. Read the risk factors specifically for whether they were written for this structure or lifted from a template. Tokenization-specific risks — legal recognition of the register, smart contract defect, key loss, cash-leg counterparty, provider concentration — should appear with facts attached. Generic blockchain risk language is a sign that the structuring work stopped at the wrapper. Our own answers, in public COSIMO Digital’s answers to all eight questions Allocators ask these eight questions. Rather than answer them only under NDA, we answer them here. Where a capability is not yet authorised, that is stated as such. Answers are current as of 28 July 2026 and are updated when the underlying position changes. 01 What the token represents A token issued by a COSIMO Digital structure represents a unit or share in the fund named in its documentation, carrying the rights set out there and nothing further. It is a form of the register entry, not a parallel instrument. For COSIMO X, the token represents an interest in a tokenized evergreen venture fund live since 2021 and listed on Securitize Markets in December 2021. 02 Regulatory framework Issuance and placement of tokenized securities in our group is performed by Black Manta Capital Partners, which is BaFin-licensed and operates under MiFID II. Fund vehicles are established in recognised European domiciles with an authorised manager, or in the case of COSIMO X under its own documented structure with US distribution through affiliate broker-dealer and ATS arrangements. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. 03 Register maintenance and reconciliation The on-chain record is the operating register, and a named registrar or transfer agent is accountable for its accuracy under the fund documentation. Reconciliation is performed at each NAV date: holder list against processed instructions, units in issue against the administrator’s books, whitelist membership against current verification status, and failed transfers logged with reasons. The sign-off is dated and retained for audit. 04 Transfer restrictions Transfer eligibility is enforced by the token before a transfer executes, using a permissioned standard with on-chain identity and rule checks. Addresses must be whitelisted following identity, sanctions and investor-category verification. A transfer to an ineligible address fails rather than settling and being unwound. The eligibility matrix is version-controlled and changes follow a documented change process. 05 Custody of underlying assets Custody depends on the asset. Fund assets are held under the depositary or custody arrangements named in each vehicle’s documentation. Custody of digital assets held by a vehicle is performed by an authorised crypto custodian. Our own custody capability, Fortuna, is VASP-registered with the Central Bank of Ireland with MiCA CASP authorisation in process; it is not yet authorised to provide MiCA custody services, and we do not present it as though it were. 06 NAV calculation NAV is calculated by the vehicle’s administrator on the schedule set out in its documentation, with depositary or equivalent oversight where the structure requires it. Valuation of illiquid holdings follows the documented valuation policy, which for venture positions means periodic marks rather than continuous pricing. Tokenization does not change the frequency or the methodology. 07 Cash leg Subscriptions and redemptions currently settle with a fiat cash leg through banking channels for most structures, which means a settlement gap between payment confirmation and unit issuance. Where an e-money token or tokenized deposit on the same ledger is available and appropriate, the cash leg can settle atomically with the asset leg. We disclose which model applies per vehicle rather than describing settlement generically as instant. 08 Offering memorandum disclosure Each vehicle’s offering documentation addresses the tokenized framework specifically: what the token represents, which record governs legal title, transfer restrictions and their enforcement, key loss and recovery procedure, the technology providers relied on, the cash-leg mechanics, and the risks arising from tokenization in addition to the fund’s own risks. Where a pending authorisation is referenced, it is identified as pending and not effective until granted. Allocator resource The tokenized fund DDQ template The eight questions above as an editable due-diligence questionnaire, with the follow-up questions, the evidence to request for each answer, and a scoring sheet. Built for investment committees reviewing a tokenized structure for the first time. We email it on request; this page stays open to everyone. Do not fill this in: Work email address Send me the DDQ We email the file once and add you to occasional notes on tokenization and regulation. No noise, and you can unsubscribe at any time. Related What is a tokenized fund? Structure, custody and redemption The category pillar behind these eight questions. How to tokenize a fund in Europe: the complete process The build side of the same questions, with timeline and costs. RWA tokenization platforms compared: which are regulated, and by whom Who holds which licence, and what each platform does not do. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS); Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA) — EU Official Journal. ERC-3643 permissioned token standard documentation. COSIMO Digital regulatory authorisations and structure disclosures, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime URL: https://cosimodigital.com/learn/tokenized-securities-europe ======================================================================== Home / Learn / Tokenized securities in Europe European regulation Tokenized securities in Europe There is no EU tokenization licence. A tokenized security is governed by MiFID II as an instrument, by CSDR for settlement, by the DLT Pilot Regime if it trades on a ledger infrastructure, and by national law for the one thing that actually changes — whether the ledger can be the register. Last updated: 28 July 2026 By Ciarán Hynes · 14 min read On this page How are securities tokenized in Europe? MiCA, MiFID II, CSDR and the DLT Pilot Regime — which applies to what? Where can tokenized securities be issued, traded and settled? What are the custody rules for tokenized securities? How does this differ from Switzerland, the UK and the US? What changes in 2026 and 2027? How are securities tokenized in Europe? A security is tokenized in Europe by issuing it in a form whose ownership record is a distributed ledger, under the same securities law that would apply without the ledger. In practice that means four things: an instrument that is validly created under the law of a member state, an authorised firm to issue and place it, a register whose legal standing is recognised in that jurisdiction, and a transfer mechanism that enforces the instrument’s eligibility restrictions. There is no EU-wide "tokenization licence" and no separate securities regime for tokenized instruments. Directive 2014/65/EU (MiFID II) defines the instruments; Regulation (EU) 2023/1114 (MiCA) expressly excludes crypto-assets that qualify as financial instruments from its scope in Article 2(4); Regulation (EU) 909/2014 (CSDR) governs settlement and central registers; and Regulation (EU) 2022/858 provides a time-limited pilot regime for market infrastructures that trade and settle them on DLT. National law then decides the question EU law leaves open: whether a ledger record can be the legal register of the security. Germany’s Electronic Securities Act created crypto-securities registers for that purpose. France recognised registered securities in a blockchain under its 2017 decree, a route the AMF describes alongside the pilot regime. Luxembourg implemented the pilot regime through its law of 15 March 2023 and amended its definition of financial instruments accordingly, as the CSSF sets out. The instrument is European; the register is national. The EU regulatory stack for a tokenized security Classification MiFID II Annex I C Is the instrument a financial instrument? If yes, MiFID II governs and MiCA is excluded by Article 2(4)(a). Issuance Prospectus Regulation · MiFID II Offer documentation, and a MiFID II investment firm to issue and place. Fund units add AIFMD or UCITS obligations for the manager. Register National securities law Whether a distributed ledger can be the legal register is decided by member-state law, not by EU regulation. This is the variable layer. Trading MiFID II · DLT Pilot Regime An MTF, an OTF, or a DLT MTF or DLT TSS with specific permission under Regulation (EU) 2022/858. Settlement CSDR · DLT Pilot Regime Book-entry and CSD requirements under CSDR, or the targeted exemptions granted to a DLT market infrastructure. Custody MiFID II · MiCA Safekeeping financial instruments is a MiFID II ancillary service. Safekeeping crypto-assets is a MiCA service. Different licences. Read the stack from the top. Everything below classification is conditional on it, and the register layer is where two structures that look identical in a deck can differ materially in law. That is the single most useful thing to take from this page: the question is never "is tokenization allowed in Europe" — it is "which of these six layers is settled for my instrument, in my domicile, and which is not". MiCA, MiFID II, CSDR and the DLT Pilot Regime — which applies to what? MiFID II applies to the instrument. CSDR applies to its settlement and central registration. The DLT Pilot Regime applies to market infrastructures that want to trade or settle it on a ledger with targeted exemptions. MiCA applies to crypto-assets that are not financial instruments, and to crypto-asset services such as custody, exchange and transfer. The four do not overlap on the same object. Which EU instrument governs which part of a tokenized securities structure. Regime What it governs What it does not govern Key reference MiFID II Definition of financial instruments; authorisation of investment firms; trading venues; investor protection Crypto-assets that are not financial instruments Annex I Section C MiCA Asset-referenced tokens, e-money tokens, other crypto-assets, and crypto-asset services including custody Anything qualifying as a financial instrument Article 2(4) CSDR CSD authorisation, book-entry form for securities admitted to trading, settlement discipline The token standard or the technology used Articles 3, 6, 7 DLT Pilot Regime DLT MTF, DLT SS and DLT TSS permissions, with exemptions from specified MiFID II and CSDR requirements The classification of the instrument itself Regulation (EU) 2022/858 National securities law Whether a ledger can be the legal register of the security Instrument classification, which is harmonised Member-state specific The boundary that causes most cost is the first two rows. ESMA published guidelines in December 2024 on the conditions and criteria for qualifying crypto-assets as financial instruments, and those guidelines are the controlling document national authorities apply. A tokenized share, bond or fund unit is a financial instrument; MiCA then applies only to ancillary crypto-asset services around it, not to the instrument. CSDR is the least discussed and most structural. Its requirements assume a central securities depository and book-entry form, which is precisely what a ledger-native issuance is not. That is why the pilot regime exists: it grants specific exemptions from named CSDR and MiFID II articles so a DLT infrastructure can operate. The ESMA register of authorised DLT market infrastructures lists those exemptions per operator, which makes it the most concrete document in this area. Where can tokenized securities be issued, traded and settled? Issued: in any member state whose law supports the instrument and the register, with Germany, Luxembourg, France and Ireland the most used. Traded: on a MiFID II venue, or on one of the small number of DLT market infrastructures authorised under the pilot regime. Settled: through a CSD under CSDR, or within a DLT settlement system or DLT trading and settlement system holding specific permission. The trading and settlement side is genuinely narrow, and the ESMA register is the authoritative list. As recorded there, CSD Prague received permission to operate a DLT settlement system on 11 October 2024, 21X AG received permission for a DLT trading and settlement system on 3 December 2024, and 360X AG received permission for a DLT MTF on 29 April 2025. 21X opened its venue fully on 8 September 2025. Three infrastructures across the whole Union is the market reality behind a great deal of enthusiastic commentary. For an issuer, the practical consequence is that primary issuance is available now and secondary trading is available in a few places. Most tokenized European securities today are issued, held and transferred bilaterally between eligible holders rather than traded on a venue, and any liquidity claim should be tested against which of the authorised infrastructures the instrument is actually admitted to. Settlement of the cash leg remains the constraint. The pilot regime permits settlement in commercial bank money rather than central bank money in defined cases, and e-money tokens under MiCA give a ledger-native cash option. Neither is yet the default. Where the cash leg sits off-ledger, delivery versus payment is a process rather than a property of the transaction, whatever the asset leg can do. What are the custody rules for tokenized securities? Safekeeping a tokenized security is a MiFID II ancillary service, not a MiCA service. That distinction decides which licence a custodian needs and it is regularly stated incorrectly. Where the instrument is a financial instrument, custody sits under MiFID II and, for funds, under the depositary obligations in AIFMD or the UCITS Directive . Where the asset is a crypto-asset that is not a financial instrument, custody is the MiCA service in Article 75. Three obligations matter in either case: segregation of client holdings from the firm’s own, an accurate register of positions per client, and liability for loss. Applied to a ledger, segregation is a question about wallet architecture and key control rather than about account structure, and supervisors ask how the firm evidences that a holding is the client’s and not its own. For fund structures the depositary function is unchanged and is the item that takes longest in practice. The depositary must be able to oversee a register kept in a form it may not have overseen before, and it will want the token documentation, the transfer-rule logic and the reconciliation design before it accepts the appointment. Budget for that review rather than treating it as a formality. Two custody questions worth asking every provider First: which authorisation covers the safekeeping you will perform — a MiFID II ancillary permission for financial instruments, or a MiCA authorisation for crypto-assets. Second: how are client holdings segregated at the key and wallet level, and how is that evidenced to a supervisor. Our own position, stated the same way we would want it from a counterparty: Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. What MiCA actually requires of a custodian sets out the detail. How does this differ from Switzerland, the UK and the US? Switzerland has the clearest register law, the UK has the most active fund tokenization practice, the US has the deepest distribution, and the EU has the only harmonised cross-border framework. Each advantage comes with a corresponding limitation, and the right jurisdiction depends on where the investors are rather than on which regime reads best. Tokenized securities: four jurisdictions compared. European Union Switzerland United Kingdom United States Register law Varies by member state; several recognise ledger registers DLT Act gives ledger-based register securities a clear statutory basis Register recognition developing; fund tokenization progressed through FCA engagement State law and transfer-agent regulation; SEC-registered transfer agents Instrument regime MiFID II, with MiCA for non-instruments FinSA and FinMIA UK MiFID-derived regime Securities Act and Exchange Act; Reg D and Reg S for private offers Venue for tokenized securities MiFID II venues plus three authorised DLT market infrastructures FINMA-licensed venues, including a DLT trading facility category FCA-regulated venues and custodians ATS operated by a registered broker-dealer Cross-border reach Passporting across the EEA Bilateral; no EEA passport Domestic, with third-country access arrangements Large domestic market; offshore structures for non-US Main limitation Register recognition fragmented; settlement reform still in pilot Small domestic market Outside the EEA passport Registration burden; state-level variation The EU’s distinctive asset is the passport. An instrument issued through a MiFID II firm in one member state can be placed across the EEA without re-authorisation, which no other jurisdiction on this list offers. Its distinctive weakness is that the register — the thing tokenization actually changes — is left to national law, so the same structure has different standing in different domiciles. For a manager choosing where to build, the sequence that works is: decide where the investors are, then which regime reaches them, then which domicile gives the register the standing you need. Groups operating across regions run parallel structures deliberately — in our own case, MiFID II issuance in the EEA through a BaFin-licensed firm and US distribution through affiliate broker-dealer and ATS arrangements, because one structure cannot serve both. What changes in 2026 and 2027? Three changes are in motion. ESMA reported on the functioning of the DLT Pilot Regime under Article 14 of the Regulation in 2025 and was mandated to report on the regime’s results by March 2026. The Commission has since proposed a reform of the pilot regime that would widen the entities eligible to operate DLT infrastructures. And the Commission’s market integration package reopens UCITS, AIFMD, MiFID/MiFIR, CSDR and the cross-border fund distribution rules, with tokenization among the subjects in scope. The pilot-regime reform matters most to infrastructure. As reported by practitioners, the proposal would add crypto-asset service providers authorised under MiCA — and organised trading facility operators — to the list of entities that may apply for permission to operate a DLT trading venue or DLT trading and settlement system, on the basis that excluding the firms with the most DLT experience is disproportionate. ESMA’s Article 14 report is explicit that the small number of operational infrastructures limits how much can be concluded from the pilot so far. On the fund side, ESMA is engaging with national authorities on real-life fund tokenization cases and examining whether regulatory barriers exist in the UCITS and AIFMD regimes, as its chair set out in a speech on 12 June 2026. EFAMA has argued that many of the barriers identified in the Savings and Investments Union consultation can be addressed through DLT. Nothing there is settled law yet, and planning on it would be premature. Three authorised DLT market infrastructures CSD Prague (DLT SS, 11 October 2024), 21X AG (DLT TSS, 3 December 2024) and 360X AG (DLT MTF, 29 April 2025). ESMA register of authorised DLT market infrastructures , January 2026. What will not change: MiCA will not begin to cover tokenized securities, and MiFID II will not cede the securities perimeter. Plan on two regimes with a hard boundary, a register question answered by national law, and settlement reform arriving through the pilot regime rather than around it. For the layer below this page, read how the MiFID II and MiCA classification is actually made , what the DLT Pilot Regime permits and who holds a licence , or whether a UCITS or AIF can be tokenized . Related MiFID II or MiCA: which applies to tokenized securities? The classification layer of the stack, with five worked examples. The EU DLT Pilot Regime in 2026: uptake, licences and the upgrade proposal What a DLT MTF, SS or TSS permits, and who holds one. MiCA custody requirements: what authorised custody actually means The custody layer, and how to check who is authorised. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II), Annex I Section C, EU Official Journal, 2014. Regulation (EU) 2023/1114 (MiCA), Article 2(4), EU Official Journal, 2023. Regulation (EU) 909/2014 (CSDR), EU Official Journal, 2014. Regulation (EU) 2022/858 on a pilot regime for DLT market infrastructures, EU Official Journal, 2022. ESMA, guidelines on the conditions and criteria for the qualification of crypto-assets as financial instruments, December 2024. ESMA, register of authorised DLT market infrastructures, January 2026 (CSD Prague, 21X AG, 360X AG, with permission dates and granted exemptions). ESMA, report on the functioning and review of the DLT Pilot Regime under Article 14, June 2025. ESMA, speech by the Chair, "Priorities for European asset management", 12 June 2026. CSSF, DLT Pilot Regime implementation in Luxembourg (Law of 15 March 2023); AMF, pilot regime and the French blockchain decree. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What is the DLT Pilot Regime and who is actually using it? URL: https://cosimodigital.com/learn/dlt-pilot-regime ======================================================================== Home / Learn / DLT Pilot Regime European regulation What is the DLT Pilot Regime and who is actually using it? The exemptions it grants, the volume caps it imposes, and what it was built to prove. Last updated: 28 July 2026 By Ciarán Hynes · 11 min read The DLT Pilot Regime lets market infrastructures trade and settle tokenized financial instruments under temporary exemptions from CSDR and MiFID II, subject to volume caps. It was built to test whether existing rules obstruct DLT market structure. Uptake has been low. The European Commission proposed a significant upgrade in 2026. On this page What is the EU DLT Pilot Regime? Which exemptions does it grant? What volume caps does it impose? What was it built to prove? Who is actually using it today? Why has uptake been so low? What is in the Commission’s 2026 upgrade proposal? What is the EU DLT Pilot Regime? It is Regulation (EU) 2022/858 , in application since 23 March 2023. It allows market infrastructures to trade and settle tokenized financial instruments while being exempted from specified requirements in MiFID II and CSDR that assume a central securities depository and conventional book-entry form. Permissions are granted by national competent authorities for up to six years and are valid only for the life of the regime. It exists because the securities rulebook predates ledgers. CSDR requires book-entry form and central registration; MiFID II separates trading from settlement. A ledger-native infrastructure can perform both in one system, which the standing framework does not contemplate. Rather than rewrite the rulebook first, the EU created a bounded regime granting targeted exemptions and generating evidence. Three permissions exist. A DLT multilateral trading facility, operated by an authorised investment firm or market operator, admitting only DLT financial instruments. A DLT settlement system, operated by an authorised central securities depository. And a DLT trading and settlement system combining both functions in one entity — the regime’s innovation, because no conventional equivalent exists. New entrants are contemplated: a firm without an existing licence may apply for a temporary investment firm, market operator or CSD authorisation alongside its pilot-regime application. That is how the first authorised operators arrived, and it is slow — the first DLT trading and settlement system took around eighteen months of engagement with its national authority, the national central bank, ESMA and the ECB. Which exemptions does it grant? Exemptions are granted per operator, on request, only where a named requirement is incompatible with the DLT use case, and each comes with conditions attached. They are also published: the ESMA register of authorised DLT market infrastructures lists, for each permission, exactly which articles were disapplied. That register is the most precise statement of what the regime does in practice. Exemptions available, and what each unlocks. Requirement disapplied Source What it unlocks Book-entry form and dematerialised form definitions CSDR Articles 2 and 3 A ledger record can constitute the form of the instrument Measures to prevent and address settlement fails CSDR Articles 6 and 7 Settlement discipline designed for a T+ cycle does not apply to instantaneous settlement Requirements for participation, transparency and communication procedures CSDR Articles 33, 34 and 35 Direct access for retail investors in defined circumstances, without an intermediary chain Integrity of the issue and account segregation CSDR Articles 37 and 38 Holdings can be recorded on-ledger rather than in securities accounts Settlement finality and cash settlement CSDR Articles 39 and 40 Settlement in commercial bank money rather than central bank money, in defined cases Link access provisions CSDR Articles 50, 51 and 53 A DLT infrastructure need not maintain conventional CSD links Access to an MTF MiFID II Articles 19(2) and 53(3) A DLT MTF may admit participants on its own terms, including non-intermediated access Two of those matter most commercially. Direct retail access removes an intermediary layer that conventional market structure requires. Settlement in commercial bank money is what makes an on-ledger cash leg feasible at all, since central bank money on a ledger remains largely experimental. The exemption lists granted so far differ materially between operators, which is worth reading rather than assuming. One permission disapplies a short list of settlement-discipline and segregation provisions; another spans CSDR definitions and core articles plus MiFID II access provisions. Permissions are bespoke, not standard. What volume caps does it impose? Caps apply both per instrument and per infrastructure, and national authorities may set lower thresholds still. They are the reason the regime is described as a sandbox rather than a regime: an operator that succeeds runs into a ceiling by design. Volume limits as set out in Article 3 of Regulation (EU) 2022/858. Confirm against the current text; competent authorities may set lower thresholds under Article 3(6). Limit Threshold Shares admitted to a DLT market infrastructure Issuer market capitalisation, or tentative market capitalisation, below €500 million Bonds and other forms of securitised debt Issue size below €1 billion Units in collective investment undertakings Market value of assets under management below €500 million Aggregate market value recorded by one DLT market infrastructure €6 billion at the moment of admission or recording Transition-strategy trigger Where the aggregate value approaches the ceiling, the operator must activate the transition strategy filed with its authority National discretion Competent authorities may set lower thresholds, and any such threshold is recorded on the ESMA register The transition strategy is a condition of permission rather than an afterthought. An operator must set out in advance how it would migrate or wind down its activity if the caps are exceeded or the permission ends, and that plan is assessed as part of the application. For an issuer the practical read is that the caps rarely bind on a first issuance and always bind on a business plan. For an infrastructure operator, they are the central commercial question, and they are what the 2026 reform debate is really about. What was it built to prove? Whether the existing rulebook obstructs DLT market structure, and if so, precisely which provisions. The regime is an evidence-gathering exercise with a legislative purpose: exemptions granted case by case, conditions attached, outcomes reported to ESMA and the Commission, and a decision at the end about which elements should become permanent law. Three specific questions sat behind it. Can trading and settlement be combined safely in one entity, which conventional market structure separates for good reasons? Can retail investors access a market infrastructure directly without the protections an intermediary chain provides? And can settlement in commercial bank money be made safe enough to substitute for central bank money in this context? The regime also had an institutional purpose: to give supervisors direct operational experience rather than theory. National authorities, national central banks, ESMA and the ECB have all been involved in the first authorisations, and that shared learning is part of the output. ESMA’s report on the functioning and review of the regime is candid that the limited number of operational infrastructures and the recency of the first authorisations mean its considerations remain early and high-level. That is an unusual admission from a supervisor and the most reliable summary available: the regime has not failed, and it has not yet been tested at scale. Who is actually using it today? Three infrastructures across the whole Union, as recorded on the ESMA register . Everything else in this area is either an announcement, an application, or a national initiative outside the regime. Authorised DLT market infrastructures. Source: ESMA register of authorised DLT market infrastructures, January 2026. Reviewed monthly; verify before relying on any entry. Operator Infrastructure Type Jurisdiction Competent authority Permission from CSD Prague (Centrální depozitář cenných papírů, a.s.) DLT Register DLT Settlement System Czech Republic Czech National Bank 11 October 2024 21X AG 21X DLT-TSS DLT Trading and Settlement System Germany BaFin 3 December 2024 360X AG 360X DLT MTF DLT Multilateral Trading Facility Germany BaFin 29 April 2025 Operationally, 21X states that it opened its venue fully on 8 September 2025, offering smart-contract based issuance, trading and atomic settlement of tokenized stocks, bonds and funds, with regulated institutions joining as listing sponsors during 2026. That makes it the first EU venue where the trading-and-settlement combination the regime was written for is actually running. Several national authorities publish guidance for prospective applicants without having granted a permission yet, including the CSSF in Luxembourg, the AFM in the Netherlands and the AMF in France. Reading that guidance is the cheapest way to understand what an application involves in a given market. This section is maintained. Where a new permission appears on the ESMA register it is added here with its date, authority and granted exemptions at the next monthly review. If you know of a permission not listed, write to info@cosimodigital.com with the register reference. Why has uptake been so low? Because the regime asks for a full market-infrastructure authorisation in exchange for time-limited exemptions and capped volumes. A firm must satisfy a national competent authority, in practice also ESMA and the ECB, then operate under ceilings, then plan for the permission ending. For most business cases the effort exceeds the benefit. Time limit. Six years, with no guarantee the regime becomes permanent, is a difficult horizon for infrastructure investment. Volume caps. They constrain exactly the instruments an operator would most want to scale. Eligible entities. The regime excluded some of the firms with the deepest DLT experience, notably MiCA-authorised CASPs and OTF operators. Cash leg. Commercial bank money settlement is permitted and still difficult to arrange in practice. Process cost. Eighteen months of multi-authority engagement is a substantial commitment before revenue. There is also a demand-side reason that is rarely stated. Primary issuance of tokenized securities in Europe does not require the pilot regime at all, and secondary demand has been thin, so the marginal value of a venue permission has been low. Operators were not avoiding a burden so much as waiting for a market. The honest read for an issuer today: the regime is more relevant to infrastructure operators than to issuers. It matters when you need a venue and on-ledger settlement, which is a smaller set of cases than the discussion around it suggests. What is in the Commission’s 2026 upgrade proposal? The Commission has proposed reforming the regime to widen who may operate a DLT infrastructure. The change most reported by practitioners is the addition of MiCA-authorised crypto-asset service providers, and operators of organised trading facilities, to the entities eligible to apply for permission to run a DLT trading venue or a DLT trading and settlement system. The reasoning is proportionality. CASPs authorised under MiCA are among the entities with the longest experience of dealing with DLT and digital assets, and the Commission does not regard their exclusion from a technology-focused sandbox as proportionate. OTF operators are subject to an equivalent authorisation regime and to equivalent organisational, conduct and transparency requirements as MTF operators under MiFID II and MiFIR, so their exclusion lacks a clear justification. Newly eligible entities would still have to satisfy the relevant MiFID II, MiFIR and, where applicable, CSDR requirements. The reform sits alongside two other processes. ESMA was mandated to report on the results of the regime by March 2026, following its Article 14 report. And the Commission’s market integration package reopens UCITS, AIFMD, MiFID and MiFIR, EMIR, CSDR and the cross-border fund distribution rules, with tokenisation among the topics in scope. What is not yet decided: whether volume caps are raised, whether the regime’s duration is extended or elements made permanent, and how settlement in central bank money is ultimately handled. Those three determine whether the regime becomes commercially interesting. Anyone presenting the outcome as settled is ahead of the legislative process. Read the dated regulation tracker , the EU regulatory stack , or why the cash leg is the hard part . Related Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime The cluster hub: where the pilot regime sits in the stack. What is atomic settlement, and does DvP work today? What the settlement exemptions are actually for. What is a MiCA CASP authorisation and who needs one? The firms the 2026 proposal would make eligible. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2022/858 on a pilot regime for market infrastructures based on distributed ledger technology, EU Official Journal, 2022; Article 3 volume limits; in application from 23 March 2023. ESMA, register of authorised DLT market infrastructures, January 2026, with per-operator exemption lists and any lower national thresholds under Article 3(6). ESMA, report on the functioning and review of the DLT Pilot Regime under Article 14, June 2025. European Commission proposal to reform the DLT Pilot Regime, 2026, as reported by practitioners: addition of MiCA-authorised CASPs and OTF operators to eligible entities. Regulation (EU) 909/2014 (CSDR) and Directive 2014/65/EU (MiFID II), EU Official Journal. National authority guidance: CSSF (Luxembourg), AFM (Netherlands), AMF (France). 21X AG public statements on the opening of its DLT trading and settlement system, September 2025 and March 2026. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Can a UCITS or AIF be tokenized? ESMA, depositaries and what EU law allows URL: https://cosimodigital.com/learn/ucits-aifmd-tokenization ======================================================================== Home / Learn / UCITS and AIFMD Tokenized funds and private markets Can a UCITS or AIF be tokenized? Yes, and it has been done. Nothing in the UCITS Directive or AIFMD prohibits issuing units in tokenized form — what UCITS restricts is what the fund may hold, which is a different question. This sets out what EU law allows, what ESMA has said, and what the depositary actually does. Last updated: 28 July 2026 By Ciarán Hynes · 12 min read On this page Can a UCITS be tokenized under current EU law? What about an AIF under AIFMD? What has ESMA actually said? What does the depositary do when fund units are tokens? Which member states are furthest ahead? What is likely to change in 2026 and 2027? Can a UCITS be tokenized under current EU law? Yes, in the sense that matters: nothing in Directive 2009/65/EC prohibits issuing UCITS units in tokenized form, and tokenized UCITS share classes exist today in Luxembourg. What is constrained is not the tokenization of the units but the fund’s eligible assets. A UCITS cannot hold crypto-assets as investments, which is a different question and the one most often conflated with this. The distinction is worth stating twice. Tokenizing the units changes the register and the transfer mechanism. Holding digital assets changes the portfolio. A UCITS may do the first and may not do the second. Franklin Templeton obtained approval to deliver a tokenized UCITS fund on blockchain in Luxembourg in October 2024, and Amundi issued its first tokenised fund share in November 2025 — both examples of the first, neither of the second. The real constraints on a tokenized UCITS are operational. The depositary must be able to oversee the register in tokenized form; the transfer-agency function must remain accountable; the prospectus and key information document must describe the tokenized framework and the rights attached; and retail distribution obligations continue in full. Because UCITS is a retail regime, supervisors pay particular attention to whether investors understand what they hold. So the reason most tokenized funds are not UCITS is economic rather than legal. UCITS carries retail obligations and eligible-asset limits suited to liquid strategies, while the strategies with most to gain from a tokenized register — venture, private credit, real estate — cannot be UCITS at all. Where a manager runs a money market or other liquid strategy, tokenizing UCITS share classes is both permitted and, on the evidence of the last two years, being done. What about an AIF under AIFMD? An AIF is the more natural home, and it is where most European tokenized funds sit. Directive 2011/61/EU regulates the manager rather than the fund and imposes no restriction on the form in which units are issued. A Luxembourg RAIF or an Irish QIAIF with an authorised AIFM can issue tokenized units to professional and well-informed investors without any bespoke permission. The manager’s obligations are unchanged and complete: portfolio and risk management, a depositary, valuation, liquidity management, remuneration policy and regulatory reporting. What changes is that the register is a ledger and each transfer is validated against eligibility rules before it executes. The AIFM remains accountable for everything it was accountable for before. Two AIFMD-specific points deserve attention at structuring. The depositary’s duties include verifying ownership of fund assets and overseeing cash flows and the subscription and redemption process, all of which it must discharge against a tokenized register — which is why depositary engagement is the long pole in any launch. And marketing to professional investors uses the AIFMD passport: a token that could technically reach anyone must still only be offered where the passport allows, so distribution controls sit in the eligibility rules rather than in hope. One structural alternative is worth naming. Where the economics are debt-like or the asset is single, a Luxembourg securitisation vehicle with a compartment per issuance is often used instead of a fund, avoiding the appointment of an AIFM and a depositary. That is a legitimate route with a different disclosure and risk profile, not a way around AIFMD, and it should be chosen on the instrument’s substance rather than on which regime looks lighter. What has ESMA actually said? ESMA has said that fund tokenisation is under active supervisory examination, that it is building knowledge with national authorities from real cases, and that it is considering whether regulatory barriers exist in the UCITS and AIFMD regimes. It has not said that fund tokenisation requires new legislation, and it has issued no fund-specific tokenisation rules. That is the accurate position as of July 2026. In a speech published on 12 June 2026, ESMA’s chair set out priorities for European asset management and addressed digital innovation directly: DLT and fund tokenisation are beginning to reshape market practices; ESMA is engaging with member-state competent authorities to build supervisory knowledge, focusing in particular on real-life cases; and part of that conversation concerns whether any regulatory barriers to fund tokenisation exist, including in relation to the UCITS and AIFMD regimes. The same remarks stressed the investor-protection dimension — that investors must understand the rights attached to their holdings and the risks involved — and that efficiencies must be delivered within a framework preserving investor protection, clear accountability, operational resilience and supervisory visibility. Separately, and more consequentially for classification, ESMA published guidelines in December 2024 on the conditions and criteria for qualifying crypto-assets as financial instruments. Those guidelines are the controlling document when a token’s status is in question, and they confirm the architecture: a tokenized fund unit is a financial instrument, MiCA excludes financial instruments by Article 2(4), and MiCA applies only to ancillary crypto-asset services around such an instrument. What to take from ESMA’s position Fund tokenisation in Europe is permitted, supervised case by case, and being examined for friction rather than for prohibition. The supervisory emphasis is on accountability and investor comprehension: who is responsible for the register, and does the investor understand what the token gives them. Structures that answer those two clearly are aligned with where the supervisor is looking. See also EFAMA’s tokenisation work , which has argued that barriers identified in the Commission’s Savings and Investments Union consultation can be addressed through DLT. What does the depositary do when fund units are tokens? Everything it did before. The depositary safekeeps the fund’s assets, verifies ownership of assets it cannot hold in custody, oversees the fund’s cash flows, and monitors the subscription, redemption and valuation processes. Tokenizing the units changes the register of investors, not the depositary’s duties over the portfolio. What is new is oversight of a register kept in tokenized form. In practice the depositary will want to know who is accountable for the register, how it reconciles to the administrator’s books at each NAV date, how transfer eligibility is enforced and under what rules, how failed transfers are recorded, and what happens on key loss or a compelled transfer. It will also want the technology provider’s role documented, including whether the register can be operated independently if that provider fails. Depositary due diligence is therefore the item most likely to determine a launch date, and it is not compressible by pressure — it is the depositary’s own risk decision. Managers who move fastest hand over one complete package early: token documentation, transfer-rule logic, reconciliation design, provider agreements, and the legal opinion on register recognition in the domicile. EFAMA’s buy-side practitioner’s guide to tokenisation is useful here because it sets out the models actually in use: whether the register is maintained by the asset manager itself, by a third-party intermediary such as the depositary or distributor, or by a specialised authorised entity; and whether the investor holds and controls the wallet directly, including the private keys, or holds through an intermediary. Those two choices — register keeper, and direct or intermediated holding — define most of the operational design and most of the depositary conversation. Which member states are furthest ahead? Luxembourg and Germany are furthest ahead, Ireland is moving deliberately and publicly, and France and Italy have workable national routes. The ranking follows two things: whether national law gives a ledger register clear standing, and whether the domicile’s fund industry has actually done it. Luxembourg combines a large fund industry with implementation of the DLT Pilot Regime through its law of 15 March 2023, which also amended its definition of financial instruments, as the CSSF records. It is where tokenized fund shares have actually been issued: Franklin Templeton’s approval to deliver a tokenized UCITS fund on blockchain in October 2024, BNP Paribas Asset Management’s tokenised money market fund shares in May 2025, and Amundi’s first tokenised fund share in November 2025. Germany has the clearest register law through its Act on Electronic Securities, which created crypto-securities registers and a supervised registrar role, and it hosts two of the three authorised DLT market infrastructures. Ireland published a discussion paper on tokenisation through the Central Bank of Ireland in March 2026, which gives managers a stated supervisory view to work with. France recognises securities registered in a blockchain under its 2017 decree, a route the AMF describes alongside the pilot regime. Italy has a national DLT fund route with defined register-keeper options, described in EFAMA’s practitioner guide. For a manager choosing a domicile, the useful test is not which jurisdiction is most enthusiastic but which can answer three questions in writing: can the ledger be the legal register here, which entity may keep it, and has a depositary in this market already overseen a tokenized register. Luxembourg, Germany and Ireland can answer all three today. What is likely to change in 2026 and 2027? Expect clarification rather than a new regime. Three processes are running: ESMA’s supervisory work on real fund tokenisation cases and whether UCITS and AIFMD contain barriers; the Commission’s market integration package, which reopens UCITS, AIFMD, MiFID and MiFIR, EMIR, CSDR and the cross-border fund distribution rules with tokenisation in scope; and the proposed reform of the DLT Pilot Regime. The most likely outcomes are targeted: guidance on how depositary and transfer-agency obligations are discharged against a tokenized register, movement toward more uniform recognition of on-chain registers across member states, and wider eligibility to operate DLT market infrastructures. EFAMA supported most of the measures in the Commission’s package in December 2025 while cautioning against additional ESMA supervisory reviews for large asset managers. What is unlikely: a bespoke tokenized-fund directive, any relaxation of UCITS eligible-asset rules to admit crypto-assets as investments, or the removal of the depositary from tokenized structures. Planning assumptions built on any of those three would be building on sand. The practical consequence for a manager deciding now is that current law already permits what most managers want to do, so the question is operational readiness rather than legal permission. Read how to tokenize a fund in Europe step by step , what a tokenized fund is and what the token represents , or the EU regulatory stack for tokenized securities . Related What is a tokenized fund? Structure, custody and redemption The category pillar: what the token represents and who keeps the register. How to tokenize a fund in Europe: the complete process Wrapper selection, providers, timeline and costs. Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime The regulatory stack a tokenized fund unit sits inside. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2009/65/EC (UCITS) and Directive 2011/61/EU (AIFMD), EU Official Journal. ESMA, guidelines on the conditions and criteria for the qualification of crypto-assets as financial instruments, December 2024. ESMA, speech by the Chair, "Priorities for European asset management: simplification, innovation, resilience and trust", 12 June 2026. EFAMA, "Tokenisation: A Buy-Side Practitioner’s Guide", June 2025; EFAMA tokenisation policy work and response to the European Commission market integration package, December 2025. CSSF, DLT Pilot Regime implementation in Luxembourg (Law of 15 March 2023); AMF, pilot regime and the French blockchain decree; German Act on Electronic Securities (eWpG). Central Bank of Ireland, discussion paper on tokenisation, March 2026. Market examples: Franklin Templeton tokenized UCITS approval, Luxembourg, October 2024; BNP Paribas Asset Management tokenised money market fund shares, May 2025; Amundi first tokenised fund share, November 2025. Regulation (EU) 2023/1114 (MiCA), Article 2(4), EU Official Journal, 2023. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # EU digital asset regulation tracker: MiCA, DLT Pilot and what changed URL: https://cosimodigital.com/learn/eu-digital-asset-regulation-tracker ======================================================================== Home / Learn / Regulation tracker European regulation EU digital asset regulation tracker What is in force, what is in progress, and who actually holds an authorisation — dated per item, with a named source for each, and a month-by-month archive at its own URLs. Updated monthly, including the months when nothing changed. Last updated: 28 July 2026 By Ciarán Hynes · 9 min read On this page What changed this month? What is in force right now? What is coming, and when? Who is authorised, and where? What does this mean for issuers and allocators? What changed this month? Nothing entered into force in July 2026. The two files that will change obligations are both still in progress: the proposed reform of the DLT Pilot Regime, which would widen the entities eligible to operate a DLT market infrastructure, and the Commission’s market integration package, which reopens the UCITS and AIFM Directives, MiFID and MiFIR, EMIR, CSDR and the cross-border fund distribution rules with tokenisation in scope. That is worth stating plainly rather than filling the section. A tracker that reports movement every month is not tracking, it is publishing. The last substantive months were June 2026, when ESMA’s chair addressed fund tokenisation and possible UCITS and AIFMD barriers and the Commission’s pilot-regime reform was reported, and December 2025, when the market integration package landed. Dated record, newest first July 2026 2026-07 archive → 2026-07-28 Status No new EU digital asset legislation entered into force this month Nothing was added to the in-force set in July 2026. Two files remain in progress: the proposed reform of the DLT Pilot Regime, and the Commission’s market integration package. Both are at negotiation stage and neither changes any obligation today. Source: COSIMO Digital monitoring of EU Official Journal and Commission publications. June 2026 2026-06 archive → 2026-06-12 Supervisory ESMA chair addresses fund tokenisation and possible UCITS and AIFMD barriers In a published speech on priorities for European asset management, ESMA’s chair stated that DLT and fund tokenisation are beginning to reshape market practices, that ESMA is engaging with national competent authorities to build supervisory knowledge from real-life cases, and that part of that work concerns whether regulatory barriers to fund tokenisation exist, including in the UCITS and AIFMD regimes. Investor understanding of the rights attached to holdings was emphasised. Source: ESMA, speech by the Chair, 12 June 2026. 2026-06-01 Legislative Commission proposal to widen eligibility under the DLT Pilot Regime reported Practitioner analysis of the Commission’s reform proposal records that MiCA-authorised crypto-asset service providers, and operators of organised trading facilities, would be added to the entities eligible to apply for permission to operate a DLT trading venue or DLT trading and settlement system, subject to the relevant MiFID II, MiFIR and CSDR requirements. Source: European Commission proposal to reform Regulation (EU) 2022/858, 2026, as reported by practitioners. March 2026 2026-03 archive → 2026-03-01 Supervisory Central Bank of Ireland publishes a discussion paper on tokenisation The Central Bank of Ireland published a discussion paper on tokenisation, giving managers and service providers a stated Irish supervisory view to engage with. A discussion paper is not a rule and creates no obligation. Source: Central Bank of Ireland, discussion paper on tokenisation, March 2026. 2026-03-01 Milestone ESMA report on the results of the DLT Pilot Regime due Under the Regulation, ESMA was to report to the Commission on the results of the pilot regime by March 2026, following its earlier report on the regime’s functioning. The report feeds the decision on whether elements of the regime become permanent. Source: Regulation (EU) 2022/858; ESMA Article 14 report, June 2025. January 2026 2026-01 archive → 2026-01-01 Register ESMA register of authorised DLT market infrastructures updated The register records three authorised infrastructures with their permission types, competent authorities, start dates and the specific CSDR and MiFID II exemptions granted to each: CSD Prague, 21X AG and 360X AG. Source: ESMA, register of authorised DLT market infrastructures, January 2026. December 2025 2025-12 archive → 2025-12-04 Legislative Commission market integration package reopens UCITS, AIFMD, MiFID, CSDR and fund distribution rules The Commission released a market integration package addressing cross-border barriers to fund distribution, supervision, market infrastructure, the consolidated tape and tokenisation, reopening the UCITS and AIFM Directives, MiFID and MiFIR, EMIR, CSDR and the Cross-Border Distribution of Funds Regulation. EFAMA supported most measures while cautioning against additional ESMA supervisory reviews for large asset managers. Source: European Commission market integration package, December 2025; EFAMA response, 4 December 2025. 2025-11-01 Market Amundi issues its first tokenised fund share in Luxembourg Following BNP Paribas Asset Management’s tokenised money market fund shares in May 2025, Amundi issued its first tokenised fund share, adding to the set of live European tokenised fund cases supervisors are examining. Source: Industry timeline of tokenised fund issuances, Investment Association; issuer statements. June 2025 2025-06 archive → 2025-06-01 Supervisory ESMA reports on the functioning and review of the DLT Pilot Regime ESMA’s Article 14 report records the authorised infrastructures and states that the limited number of operational DLT market infrastructures and the recency of the first authorisations mean its considerations are early and high-level. Source: ESMA, report on the functioning and review of the DLT Pilot Regime under Article 14, June 2025. 2025-06-01 Industry EFAMA publishes its buy-side practitioner’s guide to tokenisation The guide sets out the register-keeping models in use for tokenised funds, including registers maintained by the asset manager, by a depositary or distributor, or by a specialised authorised entity, and the direct versus intermediated holding models for investors. Source: EFAMA, "Tokenisation: A Buy-Side Practitioner’s Guide", June 2025. Each month above has its own page with the same items and sources, so it can be cited directly: July 2026 , June 2026 , March 2026 , January 2026 , December 2025 , June 2025 . What is in force right now? Six things govern EU digital assets today. MiCA has been fully applicable since 30 December 2024. MiFID II governs anything that is a financial instrument. CSDR governs settlement and central registration. The DLT Pilot Regime has been in application since 23 March 2023. ESMA’s December 2024 guidelines control classification. And national law decides whether a ledger can be the legal register. In force as of 28 July 2026. Instrument In force since What it governs today Regulation (EU) 2023/1114 (MiCA) Fully applicable 30 December 2024 ARTs, EMTs, other crypto-assets and crypto-asset services. Excludes financial instruments by Article 2(4). Directive 2014/65/EU (MiFID II) In force Financial instruments, investment firms, venues, investor protection. The regime for tokenized securities. Regulation (EU) 909/2014 (CSDR) In force CSD authorisation, book-entry form, settlement discipline. Regulation (EU) 2022/858 (DLT Pilot Regime) 23 March 2023 DLT MTF, SS and TSS permissions with targeted exemptions. Three infrastructures authorised. ESMA guidelines on qualifying crypto-assets as financial instruments December 2024 The controlling document for classification questions. National register law (German eWpG, French 2017 decree, Luxembourg law of 15 March 2023 and others) Various Whether and how a distributed ledger can be the legal register of a security. What is not in force, despite frequent claims to the contrary: any EU tokenization licence, any MiCA authorisation covering tokenized securities, and any harmonised EU rule recognising an on-chain register. Those three absences explain most of the structuring work a European issuance actually requires. What is coming, and when? Four items, none of them yet law. The DLT Pilot Regime reform is the closest to a decision. The market integration package is the largest in scope. ESMA’s fund tokenisation work is the most likely to produce practical guidance. And MiCA transitional periods for pre-existing national regimes continue to run down member state by member state. In progress. Dates are indicative and depend on the legislative process, not on our estimate. Item Stage What would change Watch DLT Pilot Regime reform Commission proposal, in negotiation MiCA-authorised CASPs and OTF operators become eligible to operate DLT trading venues and DLT TSSs Whether volume caps are raised and whether elements become permanent Market integration package Proposed, December 2025 Reopens UCITS, AIFMD, MiFID and MiFIR, EMIR, CSDR and cross-border fund distribution, with tokenisation in scope Whether register recognition is addressed at EU level ESMA fund tokenisation work Supervisory engagement, ongoing Possible guidance on depositary and transfer-agency obligations against a tokenized register ESMA statements and national authority discussion papers MiCA transitional run-off Ongoing by member state Firms without CASP authorisation cease in-scope EU services National register updates Our planning assumption, stated so it can be disagreed with: no new EU regime for tokenized securities arrives before 2028, the pilot-regime reform passes in some form, and register recognition remains national for the medium term. Structures built on current law will not need to be rebuilt; structures built on anticipated law may. Who is authorised, and where? Roughly 210 firms hold MiCA authorisation, out of approximately 1,200 that were operating under pre-MiCA national regimes — about one in six. Three DLT market infrastructures hold permissions under the pilot regime. Those two numbers are the most useful summary of the European market’s real capacity. About one in six Roughly 210 of approximately 1,200 pre-MiCA firms have secured MiCA authorisation. COSIMO Digital analysis of regulator registers and market data, 2026. Authorised DLT market infrastructures. Source: ESMA register , January 2026. Operator Type Jurisdiction Authority Permission from CSD Prague DLT Settlement System Czech Republic Czech National Bank 11 October 2024 21X AG DLT Trading and Settlement System Germany BaFin 3 December 2024 360X AG DLT Multilateral Trading Facility Germany BaFin 29 April 2025 Where to check anything on this page yourself: ESMA for EU-level registers and the DLT infrastructure register, and the national competent authority for firm-level authorisations — the Central Bank of Ireland , BaFin , the CSSF and their counterparts. An authorisation exists when it appears on a register. For completeness on our own group, on the same basis we would want from any firm named in a tracker: Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. We hold no DLT market infrastructure permission. What does this mean for issuers and allocators? For issuers: current law is sufficient to issue tokenized securities in Europe today, and waiting for the reforms delays revenue without reducing work. The critical path is classification, domicile and register recognition, a MiFID II firm to issue and place, and a depositary that has done it before. None of those four is affected by anything in the pipeline. For allocators: the diligence questions are unchanged by the pipeline too, and the most useful ones are register accountability, transfer-restriction enforcement, custody authorisation and the cash leg. Where a structure relies on a pending authorisation, treat it as pending — a licence in process is an application under assessment, not a permission. For both: check registers rather than decks, and prefer sources with dates. The reason this tracker exists in this form — per-item dates, named sources, a crawlable month archive — is that most public summaries of EU digital asset regulation are undated, and an undated regulatory summary is worse than none. Read next: the EU regulatory stack for tokenized securities , what the DLT Pilot Regime permits and who holds a licence , or what a MiCA CASP authorisation requires . Related Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime The standing framework behind every item in this tracker. The EU DLT Pilot Regime in 2026: uptake, licences and the upgrade proposal The file with the most movement this year. MiCA CASP licence: capital, timelines and choosing a jurisdiction What the one-in-six authorisation rate actually involves. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources EU Official Journal: Regulation (EU) 2023/1114 (MiCA); Directive 2014/65/EU (MiFID II); Regulation (EU) 909/2014 (CSDR); Regulation (EU) 2022/858 (DLT Pilot Regime). ESMA: register of authorised DLT market infrastructures, January 2026; Article 14 report on the DLT Pilot Regime, June 2025; guidelines on qualifying crypto-assets as financial instruments, December 2024; speech by the Chair, 12 June 2026. European Commission: market integration package, December 2025; proposal to reform the DLT Pilot Regime, 2026 (as reported by practitioners). Central Bank of Ireland: discussion paper on tokenisation, March 2026. EFAMA: tokenisation policy work and buy-side practitioner’s guide. MiCA authorisation counts: COSIMO Digital analysis of regulator registers and market data, 2026. Structured source data for this page: /learn/eu-digital-asset-regulation-tracker/tracker.json. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Securitize vs Ondo vs Superstate: a 2026 comparison URL: https://cosimodigital.com/learn/securitize-vs-ondo-vs-superstate ======================================================================== Home / Learn / Securitize, Ondo, Superstate Custody, settlement and operations Securitize vs Ondo vs Superstate They are not competitors. Securitize is regulated infrastructure, Ondo is a product issuer, Superstate is a fund manager — which is why feature tables of the three mislead. This compares what each actually does, where each is regulated, what can be said about pricing, and the gap all three share. Last updated: 28 July 2026 By Ciarán Hynes · 10 min read On this page What does each company actually do? Which asset classes does each cover? Where is each regulated, and can it serve EU issuers? What do they charge? Which should you choose for which job? What is missing from all three? What does each company actually do? Securitize is regulated infrastructure: an SEC-registered transfer agent with affiliated broker-dealer and alternative trading system capability, providing issuance, register maintenance and distribution for other firms’ products. Ondo Finance is a product issuer: it creates and sells its own tokenized instruments. Superstate is a US fund manager: it operates registered-adviser fund structures that happen to be tokenized. That is the whole comparison in one paragraph, and it explains why feature-by-feature tables of the three tend to mislead. They are not competing for the same mandate. A manager who wants someone to tokenize their fund is talking to Securitize. An allocator who wants tokenized Treasury exposure is buying from Ondo or Superstate. Conflating infrastructure with product is the error the market keeps making. Securitize’s position is the most structurally interesting because it is the register. It acts as transfer agent for BlackRock’s BUIDL and for VanEck’s tokenized Treasury product among others, which means much of the category’s assets sit on a register it maintains. That is a concentration worth naming: a large share of tokenized US Treasury value depends on one firm’s transfer-agency operation. Ondo runs two distinct products with different legal shapes — OUSG, a fund for qualified purchasers, and USDY, a note for non-US persons — and has built the widest chain footprint of the three. Superstate is the smallest and the most conventional: US funds, US adviser registration, Ethereum, and a strategy fund alongside the Treasury fund. Each is well-built for its own market. Which asset classes does each cover? Securitize is the broadest by a wide margin, because it is infrastructure rather than a product line: funds, private equity, private credit, equities and Treasury products, whatever its clients issue. Ondo covers short-duration US government exposure and cash-equivalent instruments. Superstate covers short-duration government securities plus a crypto carry strategy. Asset class coverage. Compiled from public product documentation and company statements as of July 2026. Securitize Ondo Finance Superstate Primary role Transfer agent, broker-dealer and ATS infrastructure Product issuer Fund manager Tokenized Treasuries Yes, as infrastructure for third-party products including BUIDL and VBILL Yes: OUSG (fund), USDY (note) Yes: USTB Private funds and private equity Yes, as issuance and register infrastructure No No Private credit Yes, as infrastructure No No Equities Yes, as infrastructure No No Strategy funds Where a client issues one No Yes: USCC, a crypto carry strategy Own balance-sheet products No Yes Yes The practical read for an issuer: if your asset is not short-duration government debt, Ondo and Superstate are not candidates, because they do not tokenize other people’s assets. Securitize is, and the question then becomes jurisdiction rather than asset class. For an allocator the read inverts. If you want Treasury exposure, Ondo and Superstate issue it and Securitize does not — Securitize is the register underneath several competing products, which is a different relationship and a different risk. Where is each regulated, and can it serve EU issuers? All three are US-regulated and none holds an EU authorisation. Securitize operates through SEC transfer-agent registration with affiliated broker-dealer and ATS entities. Ondo issues from US and offshore entities, with USDY structured for non-US persons and OUSG restricted to qualified purchasers outside the US. Superstate is a US registered investment adviser running US fund structures. Regulatory position and EU access. Compiled from public statements as of July 2026; verify on the relevant register before relying on any entry. Securitize Ondo Finance Superstate Primary regulator US SEC (transfer agent; affiliated broker-dealer and ATS) US, with offshore issuing entities US SEC (registered investment adviser) EU authorisation None identified None identified None identified Can serve an EU issuer directly No — an EU-licensed counterparty is required for EU issuance and placement No — does not tokenize third-party assets No — does not tokenize third-party assets EU investor access to its products Via non-US structures and reverse solicitation, product by product USDY for non-US persons; OUSG for qualified purchasers, reverse solicitation in the EEA US fund structures; no EU wrapper identified What is absent No EU fund passport, no EU depositary relationship, not a CSD No EU wrapper, no EU distribution permission No EU wrapper, no EU distribution permission This is not a deficiency on their part. A US transfer agent with SEC registration is the correct provider for a US offering, and an offshore note for non-US persons is a coherent structure for its intended holders. The error is assuming a licence travels. It does not: US registration does not permit EU issuance or EU distribution, and no amount of chain coverage changes that. For a European manager the consequence is concrete. Using any of the three means pairing them with an EU-authorised entity for issuance and placement, or accepting that the product sits outside an EU wrapper and that EEA investors reach it, if at all, through reverse solicitation. Our own group is one of the EU-licensed counterparties in that pairing — Black Manta Capital Partners is BaFin-licensed and operates under MiFID II — and we would rather state that as the factual answer to "who can issue in the EEA" than dress it as a comparison result. What do they charge? Publicly: not enough to compare. Securitize prices per mandate, and its fees depend on structure, investor count and which entities in the group are engaged. Ondo publishes a management fee for OUSG in its fund documents and states no explicit management fee for USDY, earning on the spread instead. Superstate states a management fee in fund documents available to eligible investors. What can be said about the shape of the economics. Infrastructure is priced as setup plus recurring platform and per-investor fees, so it scales with holder count and activity. Product issuance is priced as a management fee on assets, or as a spread between the underlying yield and what reaches the holder. The two are not comparable on a single number, and any table presenting them side by side as basis points is comparing different things. If you are evaluating cost, three questions produce a usable answer where a public table cannot. For infrastructure: what is the setup fee, the annual platform fee, the per-investor cost, and what is charged for a corporate action or a register migration? For a product: what is the net yield to me after all fees, on the same basis, over the last twelve months? And for both: what does it cost to leave — can the register be exported and operated elsewhere, and on what notice? We would rather record "priced per mandate" and "not publicly stated" than publish estimates. A fee table that looks authoritative and is assembled from inference is worse for a reader than an honest gap, because it gets cited. Which should you choose for which job? Four common jobs, four different answers, and in two of them the answer is none of the three. You are a US manager tokenizing a fund Securitize. SEC transfer-agent registration, affiliated broker-dealer and ATS, and the deepest operating record in this specific job. Ondo and Superstate do not tokenize third-party funds. You want tokenized US Treasury exposure as an allocator Ondo or Superstate, depending on your investor status and preferred structure: USDY as a note for non-US persons, OUSG as a fund for qualified purchasers, USTB as a US fund. Compare on net yield and redemption mechanics rather than on chain count. Our comparison of tokenized treasury products, including EU access sets the field out product by product. You are a European manager tokenizing a European fund None of the three, on their own. You need an EU-authorised issuance and placement firm, an authorised manager, a depositary, and a register recognised in your domicile. Any of the three can be part of a structure; none can be the structure. The European process sets out what is actually required. You are a European institution wanting Treasury exposure inside an EU wrapper Also none of the three, today. No product from any of them is offered under an EU fund passport. That exposure inside an EU wrapper with an EU manager and depositary generally has to be commissioned rather than bought, which is a fund issuance rather than a product purchase. What is missing from all three? An EU wrapper. None of the three offers a product under an EU fund passport, and none can perform EU issuance and placement itself. For the largest pool of professional capital outside the US, all three are reached through non-US structures and reverse solicitation, which is a narrowing route and a supervisory risk for whoever relies on it. Three further gaps, in descending order of how often they are volunteered. Register concentration: a large share of tokenized Treasury value sits on registers maintained by a single transfer agent, and no public disclosure explains what happens to those registers if that firm fails — a question every allocator should ask and few do. Cash-leg dependence: 24/7 mint and redeem against a stablecoin means exposure to that stablecoin’s issuer, which is a counterparty position rather than a settlement feature. And secondary liquidity: the ATS and venue infrastructure exists, order books largely do not, so most holdings are held to redemption rather than traded. For balance, what all three do have that most of the market does not: real operating history, institutional counterparties, and products that have processed subscriptions and redemptions at scale through more than one market condition. That is not a small thing, and it is why they are the three names in this comparison. And our own gap, on the same terms. COSIMO Digital can perform EU issuance and placement today through a BaFin-licensed MiFID II firm, which none of the three can. We cannot offer an authorised custody service today: Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. We are not a transfer agent at Securitize’s scale, we issue no tokenized Treasury product, and we operate no trading venue. Read the fifteen-platform comparison for the wider field, or the EU regulatory stack for why the EU wrapper question keeps recurring. Related RWA tokenization platforms compared: 15 providers by regulator and licence The wider field, on the same editorial terms. Tokenized treasury funds compared: size, yield, chain and EU access The products these firms issue or service, product by product. Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime Why none of the three can perform EU issuance itself. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Company public statements, product documentation and regulatory disclosures for Securitize, Ondo Finance and Superstate, as of July 2026. RWA.xyz tokenized treasuries dashboard, 4 May 2026, for product-level assets under management. Directive 2014/65/EU (MiFID II) and Regulation (EU) 2023/1114 (MiCA), EU Official Journal, for the EU access analysis. EU access and role characterisations are COSIMO Digital’s own assessment from public sources and are not legal advice. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Tokenized treasury funds compared: size, yield, chain and EU access URL: https://cosimodigital.com/data/tokenized-treasuries ======================================================================== Home / Learn / Tokenized treasuries Digital asset treasury Tokenized treasury funds compared Ten products, roughly $15.2 billion in the category, and one column no other comparison carries: whether an EU professional investor can actually access each one. The answer, for every product here, is that none is offered under an EU fund passport. Last updated: 28 July 2026 By Ciarán Hynes · 11 min read On this page Which tokenized treasury products exist today? What are their sizes, yields and chains? Which are accessible to EU professional investors? Who issues, custodies and administers each? How do they compare on fees? How does a tokenized treasury differ from a stablecoin? Which tokenized treasury products exist today? Around seventy-six tokenized US Treasury products were live as of 4 May 2026, holding roughly $15.2 billion across approximately 58,700 holders, according to the RWA.xyz tokenized treasuries dashboard . Ten products account for the overwhelming majority of that, and five account for most of it: USYC, BUIDL, USDY, BENJI and JTRSY. Aggregators count differently and the discrepancies are large enough to matter. Narrower definitions that exclude notes, non-US fund structures or strategy funds produce totals nearer $7 billion for the same period. We use one named source per figure and state it in the table rather than blending them, because a blended number cannot be checked. The products divide into three types, and the distinction matters more than the league table. Registered fund share classes, such as Franklin Templeton’s BENJI within FOBXX and WisdomTree’s WTGXX, are shares in US registered funds that happen to be tokenized. Private-placement funds, such as BUIDL, OUSG, USTB and VBILL, are fund interests offered to qualified investors. Notes, principally Ondo’s USDY, are debt instruments backed by Treasuries and bank deposits rather than fund shares. $15.2bn across 76 products Tokenized US Treasury market, 4 May 2026. RWA.xyz tokenized treasuries dashboard . Other aggregators using narrower definitions report nearer $7bn for the same period. One product worth naming because it is still listed in older comparisons: Mountain Protocol’s USDM, which has been reported as winding down. Where a product on any comparison table has no current issuer disclosure, treat its inclusion as a data-freshness problem rather than as evidence it is live. What are their sizes, yields and chains? Sizes range from roughly $2.9 billion at the top to products too small to be separately listed by aggregators. Reported yields cluster between about 4% and 4.8% for Treasury-only strategies, which is where short-duration government paper has been. Chain coverage splits between Ethereum-anchored products and multichain-first products, principally USDY and BENJI. Tokenized treasury and money market products. AUM as reported by RWA.xyz on 4 May 2026 unless stated; yields as most recently reported by each issuer and subject to daily change. EU access is COSIMO Digital’s own assessment from public product documentation, not a legal opinion. Product Issuer AUM Chains Reported yield Access EU professional access USYC Hashnote US Yield Coin Hashnote (Circle) $2.91bn RWA.xyz Ethereum, others ~4%+ APY as reported Qualified investors, non-US Reverse solicitation only BUIDL BlackRock USD Institutional Digital Liquidity Fund BlackRock $2.58bn RWA.xyz Ethereum and several others ~4–4.5% APY as reported US qualified purchasers; non-US via private placement Reverse solicitation only USDY Ondo USD Yield Ondo Finance $2.14bn RWA.xyz Ethereum, Solana, Sui, Aptos, Mantle, Noble ~4.8% APY as reported Non-US persons; retail-accessible outside the US Not an EU-regulated product BENJI Franklin OnChain US Government Money Fund (FOBXX) Franklin Templeton $2.05bn RWA.xyz Multiple, including Stellar and Ethereum ~4–4.5% APY as reported US retail eligible; share class of a registered fund Separate Luxembourg tokenized UCITS work, not this share class JTRSY Anemoy Janus Henderson Treasury Fund Anemoy / Centrifuge $1.24bn RWA.xyz Ethereum and Centrifuge infrastructure Tracks short-duration Treasury yield Professional and qualified investors, non-US Case by case; not an EU fund passport OUSG Ondo Short-Term US Government Bond Fund Ondo Finance $682m RWA.xyz Ethereum, Solana, others Tracks underlying holdings, mostly BUIDL, USYC, USTB Qualified purchasers outside the US Reverse solicitation only USTB Superstate Short Duration US Government Securities Fund Superstate Not separately listed on aggregators Issuer dashboard Ethereum Tracks short-duration Treasury yield US qualified purchasers No USCC Superstate Crypto Carry Fund Superstate Not separately listed on aggregators Issuer dashboard Ethereum Basis and carry strategy, not a Treasury-only yield US qualified purchasers No VBILL VanEck Treasury Fund VanEck (with Securitize) Reported below the top five Issuer and aggregator dashboards Ethereum, Solana, BNB Chain, Avalanche Tracks short-duration Treasury yield Qualified investors via private placement Reverse solicitation only WTGXX WisdomTree Government Money Market Digital Fund WisdomTree Reported below the top five Issuer disclosures Stellar, Ethereum ~4% area as reported US retail eligible No Three cautions on reading this table. Yields are as most recently reported by each issuer, on different bases — some net, some gross, some seven-day, some monthly — and they change daily, so they are indicative rather than comparable to the basis point. AUM moves quickly in this category: a single institutional allocation can move a product several hundred million in a week. And "chains" records where the token has been deployed, not where liquidity actually sits, which is usually one chain regardless of how many are listed. The yield question that matters for an allocator is not which product reports the highest number but what the number is net of, and what it is exposed to. A Treasury-only fund reporting 4.2% net of fees and a strategy fund reporting more are not comparable instruments. Superstate’s USCC is a carry strategy rather than a Treasury fund, and it is included here only because it is routinely listed alongside them. Which are accessible to EU professional investors? None of these products is offered under an EU fund passport. That is the honest headline, and it is the column no other comparison publishes. EU professional investors reach these products, where they reach them at all, through reverse solicitation, through non-EU structures, or not at all — not through an EU-authorised offering. EU professional investor access, product by product. COSIMO Digital’s assessment from public product documentation as of July 2026. Not a legal opinion; confirm with counsel before relying on it. Product EU professional access Why USYC Reverse solicitation only No EU-passported offering identified; institutional access typically arranged bilaterally. BUIDL Reverse solicitation only Distributed through Securitize; not offered under an EU fund passport. USDY Not an EU-regulated product Structured as a note for non-US persons; no EU wrapper or EU distribution permission. BENJI Separate Luxembourg tokenized UCITS work, not this share class FOBXX is a US registered fund. Franklin Templeton has separately delivered a tokenized UCITS in Luxembourg (approval October 2024). JTRSY Case by case; not an EU fund passport BVI-domiciled fund structure; EU professional access arranged bilaterally. OUSG Reverse solicitation only No EU wrapper; access restricted to qualified purchasers. USTB No US fund with a US adviser; no EU wrapper or distribution permission identified. USCC No Strategy fund rather than a Treasury fund; included because it is frequently listed alongside them. VBILL Reverse solicitation only Distributed through Securitize; no EU fund passport identified. WTGXX No US registered fund; no EU wrapper. The pattern is structural rather than accidental. These are predominantly US products: US registered funds, US private placements to qualified purchasers, or notes issued to non-US persons under Reg S. Each is well-constructed for its own market. None was built to be marketed into the EEA, because doing so requires an EU wrapper and an EU-authorised distributor, which is a different project with different economics. What that means practically for a European institution. Reverse solicitation is a narrow and increasingly scrutinised route, and relying on it as a distribution strategy rather than as an occasional fact is a supervisory risk for the party doing the soliciting. If a European allocator wants tokenized Treasury exposure inside an EU wrapper with an EU-authorised manager and depositary, the honest answer today is that it generally has to be commissioned rather than bought — which is the fund tokenization process , not a product purchase. If you are checking this yourself Three questions resolve EU access for any product on this list. Is there an EU-domiciled wrapper — a UCITS, an AIF, or a securitisation vehicle? Is there an EU-authorised entity marketing it, with a passport for the investor type you are? And does the offering documentation address EEA investors at all? If the answer to all three is no, access is reverse solicitation at best. Who issues, custodies and administers each? Issuance, transfer agency, custody and administration are split across different firms in every product here, and the names repeat. Securitize appears as transfer agent for several of the largest, including BUIDL and VBILL. Fund custody sits with conventional custodians, because the underlying assets are Treasuries and cash rather than crypto. Administration is conventional fund administration. Issuance, custody, administration and fees, as publicly disclosed. Where an issuer does not publish a figure, that is recorded rather than estimated. Product Issuer / transfer agent Custody Administration Fees USYC Hashnote (Circle) Institutional custodians via issuer arrangements Issuer / third-party administrator Not publicly stated in full BUIDL BlackRock Fund custodian; Securitize as transfer agent BlackRock / fund administrator Management fee per fund documents USDY Ondo Finance Bank deposits and T-bill custody per issuer disclosures Issuer No explicit management fee stated BENJI Franklin Templeton Fund custodian Franklin Templeton Fund expense ratio per prospectus JTRSY Anemoy / Centrifuge Fund custodian per documentation Third-party administrator Management fee per fund documents OUSG Ondo Finance Underlying fund custodians; smart-contract based holding Issuer Management fee per fund documents USTB Superstate US qualified custodian US fund administrator Management fee per fund documents USCC Superstate US qualified custodian US fund administrator Management fee per fund documents VBILL VanEck (with Securitize) Fund custodian; Securitize as transfer agent Fund administrator Management fee per fund documents WTGXX WisdomTree Fund custodian WisdomTree Fund expense ratio per prospectus This is the most under-examined part of the category. The token is the least novel component: the assets are custodied the way Treasuries have always been custodied, the NAV is struck by a fund administrator, and the register is maintained by a transfer agent. What is new is the register’s form and the 24/7 mint and redeem mechanics on top of a fund that still values itself on a conventional schedule. Two questions to ask about any product on this list, because they are where the risk actually sits. Who is the transfer agent and what happens to the register if the token infrastructure provider fails? And what is the redemption mechanic when the fund’s own liquidity cycle and the token’s 24/7 promise diverge — during a Treasury market stress, for example, or a US bank holiday. The answers are in the offering documents rather than in the marketing. How do they compare on fees? Honestly: fee comparison in this category is not currently possible from public data, and any table claiming otherwise is filling gaps with assumptions. Registered funds publish an expense ratio in the prospectus. Private-placement funds state a management fee in documents available to eligible investors. Notes such as USDY state no explicit management fee, earning instead on the spread between the underlying yield and what is passed to holders. What can be said structurally. Registered fund share classes are the most transparent, because the expense ratio is published and standardised. Private placements are comparable only once you have the documents, and the headline management fee is not the whole cost — minimums, subscription and redemption mechanics, and any platform fee charged by the distributor all matter. Note structures look cheapest on stated fees and are not necessarily cheapest in net yield, because the spread is where the economics sit. The comparison that actually matters is net yield to the holder, on the same basis, over the same period, after all costs including access. That number is knowable for a specific allocation with the documents in hand, and it is not knowable from a public table. We would rather record "not publicly stated" than publish an estimate that reads like a fact. Two fee-adjacent items to price in. Access cost: reaching several of these products requires onboarding with a distributor, and for a European institution possibly a structure. And operational cost: holding a tokenized fund means custody or key management, whitelisting maintenance, and reconciliation, which is real cost even where the fund charges nothing extra for it. How does a tokenized treasury differ from a stablecoin? A tokenized treasury is a claim on a fund or note that holds Treasuries, and it pays the yield of those holdings to the holder. A stablecoin is a payment instrument designed to hold a stable value, and its issuer generally keeps the reserve yield. The first is an investment; the second is money-like. Conflating them is the most common error in this category. In EU terms the distinction is regulatory as well as economic. A tokenized fund share or note is a financial instrument, so MiFID II applies and MiCA excludes it by Article 2(4). A euro-referenced stablecoin redeemable at par is an e-money token under MiCA, and its issuer must be an authorised credit or electronic money institution holding full backing in low-risk liquid reserves. Different instruments, different regimes, different issuers. The practical consequences follow from that. A tokenized treasury has a NAV, a redemption cycle governed by fund documents, transfer restrictions enforced at the token level, and investor-eligibility requirements. A stablecoin has par redemption on demand, no eligibility gate for holding in most cases, and no yield to the holder. Using a tokenized treasury as a payment instrument imports a settlement and eligibility model it was not designed for. Where the two meet is the cash leg. An e-money token on the same ledger is what makes atomic settlement of a tokenized fund subscription possible, which is why the two categories are complementary rather than competing. Read the definitions of EMT and tokenized treasury , what a tokenized fund is , or how EU law treats tokenized securities . Related What is a tokenized fund? Structure, custody and redemption What the token represents and who keeps the register. Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime Why none of these products carries an EU passport. How to tokenize a fund in Europe: the complete process What commissioning an EU-wrapped equivalent involves. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources RWA.xyz tokenized treasuries dashboard, 4 May 2026: market size, product count, holder count and per-product AUM. DeFiLlama RWA category, May 2026, for cross-checking per-product AUM. Issuer product documentation, prospectuses and transparency reports for each product listed. Regulation (EU) 2023/1114 (MiCA), Article 2(4); Directive 2014/65/EU (MiFID II), EU Official Journal. EU access assessments are COSIMO Digital’s own reading of public product documentation as of July 2026 and are not legal advice. Structured source data for this page: /data/tokenized-treasuries.json. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Tokenized fund vs ETF: what actually differs URL: https://cosimodigital.com/learn/tokenized-fund-vs-etf ======================================================================== Home / Learn / Tokenized fund vs ETF Tokenized funds and private markets What is the difference between a tokenized fund and an ETF? Both are wrappers. They differ in who can hold them, how they trade and how title moves. Last updated: 28 July 2026 By Ciarán Hynes · 6 min read A tokenized fund and an ETF are both wrappers around a pool of assets. They differ in three ways: who is permitted to hold them, where and when they trade, and how title moves. An ETF settles through a central securities depository. A tokenized fund moves title on a register that can enforce investor eligibility at the point of transfer. On this page What is the difference between a tokenized fund and an ETF? Who is allowed to hold each one? How does each one trade? How does title actually move? What is the settlement cycle for each? Which one should an allocator choose, and for what? What is the difference between a tokenized fund and an ETF? The ETF is a distribution innovation. Its shares trade continuously on an exchange, are created and redeemed in blocks by authorised participants, and settle through the conventional securities chain into a central securities depository. It solved access and intraday liquidity for asset classes that were already liquid. The tokenized fund is a record-keeping change. Its register of holders sits on a distributed ledger, and transfer eligibility is enforced by the token before a transfer executes. It addresses the ownership record and the transfer process, which is the binding constraint in private markets rather than in listed ones. So they are not competing versions of the same idea. One optimises how a liquid fund reaches investors; the other optimises how ownership is recorded and moved in a fund that was never going to be exchange-traded. The overlap is narrow: liquid money market strategies, where both wrappers are technically available. Tokenized fund and ETF, side by side. Tokenized fund ETF Eligibility Typically professional or well-informed investors; enforced at the token level Retail and professional, through any broker Minimum Set by fund documents; often substantial One share Trading venue Bilateral, or a venue able to enforce transfer restrictions Regulated exchange Hours Any time the ledger is running Exchange hours Settlement cycle Asset leg in seconds; cash leg varies Standard market cycle via a CSD Title transfer Ledger entry, validated against on-chain eligibility rules Book-entry through the intermediary chain Transfer restrictions Encoded in the token; ineligible transfers fail Handled upstream by distribution rules Redemption route Fund windows per documentation, or transfer to an eligible holder Sale on exchange, or creation and redemption by authorised participants Regulatory regime MiFID II as an instrument; AIFMD or UCITS for the manager UCITS or an equivalent fund regime; MiFID II venue rules Who is allowed to hold each one? An ETF is generally open to anyone with a brokerage account, because its shares are admitted to trading and transferable within the market’s ordinary rules. Eligibility work happens upstream: the fund’s regime, usually UCITS in Europe, determines whether it can be marketed to retail investors, and the broker performs suitability and appropriateness checks. A tokenized fund is typically restricted to professional or well-informed investors, because most tokenized strategies are alternative investment funds under AIFMD rather than UCITS. The restriction is enforced technically as well as contractually: an address must be verified and whitelisted before it can receive units. That enforcement is the substantive difference. In an ETF, an ineligible holding is prevented by process and corrected if it occurs. In a tokenized fund, the transfer simply does not execute. The instrument is transferable and restricted at the same time, which conventional private structures achieve only through manual review. For an investor this creates a continuing obligation rather than a one-off onboarding. If periodic verification lapses, or a holder moves jurisdiction, or a wallet changes custodian, the ability to receive units can be suspended until the whitelist is updated. Read how investor identity is checked before a token transfer . How does each one trade? An ETF trades continuously during exchange hours, with market makers quoting two-way prices and an arbitrage mechanism that keeps the price close to net asset value. That mechanism is the ETF’s defining feature: authorised participants create and redeem shares at NAV, so a persistent premium or discount is arbitraged away. A tokenized fund transfers rather than trades, in most cases. Where the documentation permits it and a counterparty exists, one eligible holder transfers units to another, at a price they agree, at any hour. Where a venue exists that can enforce the instrument’s restrictions, it can be admitted to trading there — a small number of such venues operate in the EU under the DLT Pilot Regime . The honest qualification is that continuous transferability is not continuous liquidity. A ledger can move title at three in the morning; whether anyone is on the other side depends on distribution and market structure, not on the register. Most tokenized private funds today transfer rarely, by design and by market reality. There is also no creation-and-redemption arbitrage in a tokenized private fund. Redemption happens through the fund’s own windows on its own terms, so nothing mechanically anchors a transfer price to NAV between windows. How does title actually move? In an ETF, title moves by book entry through a chain of intermediaries into a central securities depository, under CSDR . The investor typically holds through a broker and a custodian, and the CSD holds the authoritative record at the top of the chain. Each participant maintains its own books, reconciled periodically. In a tokenized fund, title moves as a ledger transaction. The token contract checks the receiving address against the encoded eligibility rules and either executes or rejects. Where national law recognises a distributed ledger as the register of a security, that ledger entry is legal title; where it does not, the token evidences an interest recorded in an authoritative off-chain register. That last distinction is the most important legal question in the category and it varies by member state. The fund documentation must state which record governs if the two diverge, and a structure that cannot answer in one sentence has not resolved it. One consequence is operational rather than legal: because all parties read one record, drift between copies of the register becomes structurally harder. What replaces it is a reconciliation obligation between the chain and the administrator’s books at each valuation date. Read what a transfer agent does for a tokenized fund . What is the settlement cycle for each? An ETF settles on the market’s standard cycle, through the CSD, with clearing and settlement discipline governed by CSDR. The cycle is predictable, well-understood, and slower than a ledger transaction by design, because it carries netting, finality and default management. A tokenized fund settles its asset leg in seconds. Its cash leg usually does not. Where payment is a bank transfer, the fund waits for confirmation before minting or releasing units, so the practical cycle is measured in days and principal risk sits between the legs. Where the cash leg is an e-money token or a tokenized deposit on the same ledger, settlement can be atomic. That is the honest dividing line between what tokenization delivers today and what is claimed for it. Instant transfer of an asset is not instant settlement of a trade. Read what atomic settlement is and whether delivery versus payment works today . Which one should an allocator choose, and for what? Choose the ETF when you want liquid, daily-priced exposure with an exit at a known price on any trading day. Choose a tokenized fund when the exposure is private markets and the value is in a cleaner ownership record, faster onboarding, and transferability where the documentation permits it. In practice the asset class decides before the wrapper does. There is no ETF that gives you venture, private credit or real estate exposure with private-market economics, and there is no tokenized private fund that will behave like an exchange-traded instrument. Expecting either to do the other’s job is the most common source of disappointment in this category. Where both are available — a money market or short-duration government strategy — compare on net yield, eligibility, minimum and redemption terms rather than on which register is more modern. Our comparison of tokenized treasury products, including EU professional access sets that field out product by product. Read next: what a tokenized fund is, and what the token legally represents , and how subscriptions and redemptions work in a tokenized fund . Related What is a tokenized fund? Structure, custody and redemption The cluster hub: what the token represents and who keeps the register. How do subscriptions and redemptions work in a tokenized fund? The NAV strike, the cash leg and the register, step by step. Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime The regulatory stack both wrappers sit inside. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS); Regulation (EU) 909/2014 (CSDR) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # How subscriptions and redemptions work in a tokenized fund URL: https://cosimodigital.com/learn/tokenized-fund-subscriptions-redemptions ======================================================================== Home / Learn / Subscriptions and redemptions Tokenized funds and private markets How do subscriptions and redemptions work in a tokenized fund? Where the NAV strike, the cash leg and the on-chain register meet, and where they still do not. Last updated: 28 July 2026 By Ciarán Hynes · 8 min read A tokenized fund subscription still strikes at NAV. What changes is the register and the cash leg. The token record updates when the transfer agent confirms the subscription, and cash settles in fiat, a stablecoin or a tokenized deposit. The two legs rarely settle atomically today, so a timing gap remains. On this page How do subscriptions work in a tokenized fund? How do redemptions work, and how long do they take? When is NAV struck, and what happens between strike and settlement? How does the cash leg settle — fiat, stablecoin or tokenized deposit? How is the on-chain register updated, and who updates it? Where does this still break today? How do subscriptions work in a tokenized fund? Five steps, in this order. The investor is onboarded and verified. The receiving address is screened and added to the whitelist. The investor commits before the subscription cut-off. The administrator strikes NAV on the scheduled date. Units are minted to the whitelisted address once payment is confirmed. Onboard and verify. Identity, sanctions screening, jurisdiction and investor-category evidence, exactly as in a conventional fund. Whitelist the address. The verified wallet is recorded on-chain as eligible to hold this instrument. No whitelist entry, no units. Commit before the cut-off. Subscription windows come from the fund documents, not from the ledger. NAV strike. The administrator values the portfolio under the valuation policy on the published date. Mint to the address. Units are issued and the register updates in the same transaction. Elapsed time from commitment to units in hand is typically two to five business days where the cash leg is a bank transfer, most of it waiting for payment confirmation and the strike. Where the cash leg sits on the same ledger as the units, the last two steps can collapse into a single transaction. What tokenization removes here is the paper chain: instruction, confirmation and register update across three parties, each holding its own copy. What it does not remove is the fund’s own calendar. How do redemptions work, and how long do they take? Redemption reverses the sequence and takes as long as the fund documents say. Instruction before the cut-off, NAV strike, units burned or transferred back to a fund address, payment out. For an open-ended vehicle with monthly windows, two to six weeks end to end is normal; for a quarterly evergreen structure, longer. Tokenization does not compress those terms. Notice periods, gates, lock-ups, redemption frequency and any holdback pending audit are portfolio and liquidity decisions, not register decisions. A quarterly-redemption fund does not become daily because its units are tokens, and any material claiming otherwise is describing a different fund. One design choice matters operationally. Units may be burned on redemption, reducing units in issue and requiring the administrator’s books to move in step, or transferred to a treasury address held by the fund and treated as unissued. Both are used. The choice affects reconciliation and how units in issue are reported, and it should be settled at structuring rather than discovered at the first redemption. What does improve is certainty. The register reflects the redemption immediately, so the holder list used for the next distribution or valuation is correct without waiting for a reconciliation cycle. When is NAV struck, and what happens between strike and settlement? NAV is struck on the schedule in the fund documents, by the administrator, under the valuation policy, with depositary oversight where the structure requires it. Tokenization changes neither the frequency nor the methodology. A portfolio that can be valued monthly cannot be valued hourly because its register is on a ledger. Between strike and settlement there is a window in which the price is fixed and the transaction is not complete. In a subscription, the investor has committed at a known NAV and payment is in flight; in a redemption, units may already be locked or burned while cash has not yet arrived. That window is where operational risk lives, and it is unchanged in length by the ledger. Two controls matter in the window. First, units in issue used in the NAV calculation should be read from the on-chain register at the strike, under a documented method — mismatches between the ledger and the books at a valuation date are the most common break in tokenized funds. Second, a subscription should not be minted before payment is confirmed unless the documentation expressly permits it and the risk is priced. Claims of real-time NAV for private strategies should be read as marketing. What can genuinely be continuous is the units-in-issue figure, because the register is live. The asset side still depends on inputs that arrive periodically. How does the cash leg settle — fiat, stablecoin or tokenized deposit? Three options, with materially different timing and risk. A conventional bank transfer in fiat, which is the current default. An e-money token under MiCA , issued by an authorised credit or electronic money institution and redeemable at par. Or a tokenized deposit, where a bank represents a deposit claim on a ledger. Cash-leg options for a tokenized fund subscription. Option Timing Who you are exposed to Availability Bank transfer (fiat) Hours to days; settlement gap between legs The banking chain and the counterparty until confirmation Universal E-money token under MiCA Same-ledger; atomic settlement achievable The EMT issuer and its reserves Growing; issuer must be an authorised credit or e-money institution Tokenized deposit Same-ledger where the bank supports it The issuing bank Emerging, bank by bank Unregulated stablecoin Same-ledger The issuer, on undisclosed or partly disclosed terms Common outside regulated structures; rarely acceptable to a depositary Only the same-ledger options make delivery versus payment achievable inside one transaction. Where a token is used, holders take exposure to its issuer and reserves, and that exposure should be named and sized in the documentation rather than treated as cash. Under MiCA an e-money token issuer must hold full backing in low-risk liquid reserves and redeem at par on demand, which is a materially different proposition from an unregulated stablecoin. Ask which ledger the cash sits on. That single question separates a settlement design from a settlement claim. How is the on-chain register updated, and who updates it? A named transfer agent or registrar updates it, appointed under the fund documentation and accountable for the accuracy of the record. Mechanically, subscriptions mint units to a whitelisted address, redemptions burn or return them, and transfers between eligible holders execute only if the token’s rules pass. Every one of those is a ledger transaction with an audit trail. On-chain does not mean unowned. The ledger holds the record and validates transfers; it cannot be accountable for whether the record is correct, cannot respond to a court-ordered transfer, and cannot sign off a holder list at a valuation date. If the documentation names no accountable party, that is a gap. Reconciliation at each NAV date should cover the holder list against processed instructions, units in issue on-chain against the administrator’s books, whitelist membership against current verification and sanctions status, failed or reverted transfers with reasons, and a dated sign-off retained for audit. Then ask what happens when a break is found: who investigates, who authorises a correction to the register, and how the correction is evidenced. Read what a transfer agent does for a tokenized fund . Where does this still break today? In five places, and none of them is the token. First, the cash leg. Most European structures still settle cash off-ledger, so the process is fast on one side and unchanged on the other. Atomic subscription is available in specific structures and is not the market default. Second, whitelist latency. An investor who changes custodian, moves jurisdiction or lets verification lapse cannot receive units until the on-chain state is updated, and the update depends on a human process. Investors experience this as a failed transfer with no explanation unless it has been explained in advance. Third, corporate actions and edge cases. Distributions in kind, unit splits, probate transfers, creditor claims and regulator instructions all require a defined mechanic and an accountable party able to move or freeze a holding. Many structures have the technology and not the governance. Fourth, secondary transfer. Documentation often permits transfer between eligible holders while no venue and no order book exist, so in practice most holders wait for a redemption window. Fifth, depositary comfort: oversight of a tokenized register is still a bespoke exercise in most markets, which lengthens launches and occasionally constrains design. None of that makes tokenization not worth doing. It makes the benefit narrower than advertised: a better register and a lighter transfer process, not end-to-end instant settlement. Read what has to change for atomic settlement to become standard , or the tokenized fund pillar page . Related What is a tokenized fund? Structure, custody and redemption The cluster hub for these mechanics. What is the difference between a tokenized fund and an ETF? Why the settlement cycles differ. What is atomic settlement, and does DvP work today? The cash-leg constraint in detail. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS); Regulation (EU) 909/2014 (CSDR) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What a four-year-old tokenized fund proves URL: https://cosimodigital.com/learn/cosimo-x-tokenized-fund-track-record ======================================================================== Home / Learn / COSIMO X track record Tokenized funds and private markets What does a four-year-old tokenized fund prove? COSIMO X has been live since 2021 and listed on Securitize Markets since December 2021. What that record shows. Last updated: 28 July 2026 By Ciarán Hynes · 6 min read COSIMO X is a tokenized evergreen venture fund that has operated since 2021 and has been listed on Securitize Markets since December 2021. Four years of live record proves the wrapper survives real subscriptions, redemptions, transfer restrictions and audits. It does not prove liquidity. Secondary trading in tokenized venture remains thin. On this page What is COSIMO X? What does a four-year operating record actually prove? What did we learn about subscriptions, redemptions and transfer restrictions? What did not work as expected? What does this mean for an allocator evaluating a tokenized fund today? What is COSIMO X? COSIMO X is a tokenized evergreen venture fund, live since 2021 and listed on Securitize Markets in December 2021. Evergreen means no fixed term: periodic subscription and redemption windows rather than a single drawdown and a wind-down. Tokenized means its interests are issued and transferred as ledger records, with eligibility enforced at the point of transfer. It is also the origin of the wider group’s thesis. Operating a tokenized fund for four years produced the conclusion that the register was never the hard part. The hard parts are licensed issuance, custody, settlement and distribution, which is what the group has since built toward across six connected layers . This page is not a performance page. Investment results belong in the fund’s own reporting to its investors. What is discussed here is operational: what a tokenized wrapper had to survive over four years, and what that does and does not evidence for anyone evaluating a tokenized fund today. What does a four-year operating record actually prove? That the wrapper works under ordinary conditions, which is the only thing operating history can prove and the thing almost nothing in this category has. Subscriptions and redemptions have processed through defined windows. NAV has been struck on schedule by the administrator under the valuation policy. Holders have been onboarded, verified and whitelisted. Transfer restrictions have been enforced. The register has been reconciled to the books at each valuation date. The fund has been audited. None of that is dramatic, which is precisely why it is evidence. The failure modes people fear in tokenized structures are exactly these: a register that drifts from the books, restrictions that cannot be enforced, an audit that cannot be completed, holders who cannot be identified when a distribution is due. Four years of operation tests each of them repeatedly. It also evidences something less obvious. An evergreen structure with recurring windows is compatible with a tokenized register, which is not a given: recurring issuance and redemption against a live holder list is harder than a single closing, and it is where reconciliation design either holds or does not. What the record does not prove is liquidity, performance, or atomic settlement against fiat. Secondary trading in tokenized venture remains thin, and a four-year record of transferability is not a record of an active market. What did we learn about subscriptions, redemptions and transfer restrictions? That the constraint is almost always human, not technical. Subscriptions wait on documentation and payment confirmation, not on the ledger. Redemptions wait on the fund’s windows and its portfolio, not on the register. Transfers wait on eligibility state, which depends on someone maintaining a whitelist. On subscriptions: onboarding is faster than a conventional private fund because verification and whitelisting replace a paper chain, and slower than investors expect because verification itself takes as long as it takes. The gain shows up on the second and third subscription from the same investor, not the first. On redemptions: the mechanics are straightforward and the reporting discipline is what matters. Units in issue on-chain must agree with the administrator’s books at every strike, and the correction procedure has to exist before it is needed rather than be invented during a break. On transfer restrictions: enforcement at the token level works, and it fires more often than expected. Wallet changes, custodian migrations and lapsed verification all produce blocked transfers that are the control working correctly and read to an investor as a broken product. Explaining this at onboarding is worth more than any feature. What did not work as expected? Four things, stated plainly because a track-record page without failures in it is marketing. Secondary liquidity did not appear Listing an instrument makes transfer possible where documentation permits it. It does not create counterparties. Venue infrastructure existed; order books did not. Transfers have been occasional and bilateral rather than continuous, and anyone tokenizing a venture strategy in expectation of a secondary market should plan on the same. The cash leg stayed conventional for longer than we assumed Asset-leg settlement was instant from day one. Cash remained a bank process, so the end-to-end experience for an investor was governed by payment confirmation. Same-ledger cash options have only recently become credible, and they are not yet the default. Investor education was a bigger workload than the technology Wallets, key management, whitelisting and the reasons a transfer can fail all required explanation to institutions whose operations teams had no prior model for them. That workload does not appear in any platform’s implementation plan. Service-provider familiarity was the pacing item Administrators, auditors and depositaries each needed to build comfort with a tokenized register, and their timelines were their own. This is better in 2026 than it was in 2021, and it is still the longest item in a launch plan. What does this mean for an allocator evaluating a tokenized fund today? Ask for operating history and be specific about what you mean. Since when has the register been on-chain, and was the fund tokenized at launch or migrated later? How many subscription and redemption cycles have completed? Has a reconciliation break occurred, and how was it corrected and evidenced? Has the fund been audited since tokenization, and did the auditor take exception to the register? Has a transfer ever been blocked by the eligibility rules, and can that be demonstrated on request? Has any holder lost access, and was the documented recovery procedure actually used? What is the cash-leg arrangement today, and has it changed since launch? A fund with history answers those from records. A fund without one answers from design intent. Both answers can be honest; only one has been tested, and the difference is the entire value of a track record. Read next: the eight questions allocators should ask, with our own answers published in full , the tokenized fund pillar page , or how tokenized asset management sits in the group . Related What is a tokenized fund? Structure, custody and redemption The cluster hub this record sits under. How do subscriptions and redemptions work in a tokenized fund? The mechanics four years of operation exercised. Tokenized fund due diligence: eight questions allocators must ask The frame for testing any claimed record. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS); Regulation (EU) 909/2014 (CSDR) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. COSIMO X: tokenized evergreen venture fund, live since 2021, listed on Securitize Markets in December 2021. Operational observations are COSIMO Digital’s own. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What is a MiCA CASP authorisation and who needs one? URL: https://cosimodigital.com/learn/mica-casp-authorisation ======================================================================== Home / Learn / MiCA CASP authorisation European regulation What is a MiCA CASP authorisation and who needs one? The services in scope, the passport it carries, and why a national VASP registration is not the same thing. Last updated: 28 July 2026 By Ciarán Hynes · 11 min read A MiCA CASP authorisation permits a firm to provide defined crypto-asset services across the EEA under a single licence, passported from one competent authority. It covers custody, exchange, execution, placement, transfer, advice and portfolio management. A national VASP registration is an anti-money-laundering registration only. It carries no passport and no authorisation to provide those services. On this page What is a MiCA CASP authorisation? Which services are in scope? What passport does it carry across the EEA? Why is a national VASP registration not the same thing? What are the capital and governance requirements? How long does authorisation take, and which jurisdiction should you choose? What are the alternatives to applying yourself? What is a MiCA CASP authorisation? It is the authorisation under Regulation (EU) 2023/1114 that permits a firm to provide crypto-asset services in the European Union. It is granted by the competent authority of the member state where the firm has its registered office, and it passports across the EEA, so one authorisation covers all member states for the services it names. MiCA has been fully applicable since 30 December 2024. Before it, crypto-asset businesses operated under a patchwork of national regimes of very different depth — some prudential, most anti-money-laundering only. MiCA replaced that with a single authorisation standard carrying prudential, governance, conduct and client-asset obligations. Two scope points decide whether it is the right licence at all. MiCA excludes crypto-assets that qualify as financial instruments under MiFID II by Article 2(4), so a firm dealing in tokenized securities needs MiFID II permissions instead. And the authorisation attaches to a legal entity and to named services, not to a brand or a group. Substance is part of the test rather than a formality. A registered office in the Union, at least one director resident in the Union, and effective management exercised from within it are expected. Letterbox structures are the specific pattern supervisors have spent two years learning to identify, and the assessment reflects that. Which services are in scope? Ten, and an authorisation covers only those the firm applied and was assessed for. A firm authorised to exchange crypto-assets is not thereby permitted to hold them for clients. This is the distinction most often blurred in marketing material, and it is visible on the register. Crypto-asset services under MiCA. An authorisation names which of these it covers. Service What it involves Typical own-funds class Custody and administration of crypto-assets on behalf of clients Holding client crypto-assets or the means of access, with segregation, a position register and liability for loss Class 2 Operation of a crypto-asset trading platform Running a venue matching buyers and sellers Class 3 Exchange of crypto-assets for funds Dealing against fiat currency Class 2 Exchange of crypto-assets for other crypto-assets Dealing between crypto-assets Class 2 Execution of orders on behalf of clients Acting on client instructions Class 2 Placing of crypto-assets Marketing and placing on behalf of an offeror Class 2 Reception and transmission of orders Passing orders to another party for execution Class 1 Advice on crypto-assets Personal recommendations Class 1 Portfolio management of crypto-assets Discretionary management of client portfolios Class 1 Transfer services on behalf of clients Moving crypto-assets between addresses for clients Class 1 Alongside the service permissions come obligations applying to every CASP: fit-and-proper management, governance and conflicts arrangements, complaints handling, outsourcing oversight, ICT and operational resilience, safekeeping of client funds and assets, and disclosure to clients. Map services rather than projects. A single tokenized issuance can touch a MiFID II permission for placement, a MiCA permission for custody of any crypto-assets held, and a payment or e-money authorisation for the cash leg — three permissions across three entities, which is normal and needs documenting. What passport does it carry across the EEA? A full services passport for the activities named in the authorisation. A CASP authorised in one member state may provide those services to clients in any other, either cross-border or through a branch, after notifying its home authority, which informs the host. There is no second authorisation and no host-state approval. That is the commercial point of MiCA and the reason the effort is concentrated rather than repeated. Before MiCA, serving twenty-seven markets meant assessing twenty-seven national regimes; now it means one authorisation and a notification process, with supervision remaining primarily with the home authority. Two limits are worth stating. The passport covers only the services in the authorisation — adding a service requires an extension, assessed like a new application. And it does not extend to financial instruments: no MiCA passport permits the issuance, placement or trading of tokenized securities, which is MiFID II territory with its own passport. Reverse solicitation is not a substitute for the passport, and it is narrowing. A firm outside the EU serving EU clients on the basis that they approached it first is relying on a limited exemption that supervisors interpret strictly. Read which regime applies to your instrument in the first place . Why is a national VASP registration not the same thing? Because a VASP registration is anti-money-laundering supervision, not permission to provide a service. It records that a firm conducting virtual-asset business is subject to AML obligations under national law implementing FATF standards. It carries no prudential requirement, no client-asset regime, no conduct rules and no passport. VASP registration and MiCA CASP authorisation compared. VASP registration MiCA CASP authorisation Legal basis National AML legislation, derived from FATF standards Regulation (EU) 2023/1114 What it permits Nothing in itself The specific services named in the authorisation Own funds None as such By service class, plus governance and resilience obligations Client-asset protection Not its subject Segregation, position register, liability for loss Conduct obligations AML only Full conduct, disclosure and complaints regime Passport No Yes, across the EEA Supervisor National AML supervisor National competent authority under MiCA Applied to ourselves Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Until that authorisation is granted, Fortuna is not authorised to provide MiCA crypto-asset services, and nothing in our material should be read as saying otherwise. We publish it in those words deliberately. This is the distinction most often softened in this market, and a firm that explains it clearly and then applies a flattering version of it to itself has explained nothing. A pending authorisation is an application under assessment by a supervisor whose decision is not ours to predict. The correct description is "in process, not yet effective" — and the group’s live regulated capability for tokenized securities is issuance and placement through Black Manta Capital Partners, which is BaFin -licensed under MiFID II. What are the capital and governance requirements? Own funds are set by service class: €50,000, €125,000 or €150,000 depending on the services provided, or one quarter of the preceding year’s fixed overheads, whichever is higher. In absolute terms the capital is modest. It is not what makes authorisation hard. Own-funds requirements by class, per Regulation (EU) 2023/1114. Confirm against the current consolidated text before relying on these figures. Class Indicative services Minimum own funds Class 1 Reception and transmission of orders, advice, portfolio management, transfer services €50,000 Class 2 Custody and administration, exchange, execution of orders, placing €125,000 Class 3 Operation of a crypto-asset trading platform €150,000 All classes Alternative floor applying in every case One quarter of the preceding year’s fixed overheads, if higher What the assessment actually turns on is the operation. Fit-and-proper and collective-competence assessment of the management body. Suitability of qualifying shareholders and a clear group structure. Governance, conflicts and complaints arrangements. Client-asset segregation and position registers. ICT and operational resilience aligned with the EU framework. AML systems and controls, including transfer-of-funds information requirements. And a business plan that survives scrutiny with capital evidenced. The pattern in slow and failed applications is consistent: firms that describe an intended operation rather than an existing one. Supervisors are assessing a functioning firm, so the sequence that works is to build the controls, run them, document them as they operate, then apply. How long does authorisation take, and which jurisdiction should you choose? Nine to eighteen months from serious preparation to authorisation is realistic, of which the statutory assessment is the shorter part. The authority checks completeness within a short defined window and then assesses substance within a set period, but the clock stops whenever information is requested, and it is requested. Choose on supervisory fit and the ability to staff real substance, not on perceived speed. Every CASP authorisation passports identically, so the licence is the same wherever granted; what differs is the authority’s expectations, its familiarity with your model, the local talent pool and the cost of maintaining genuine management presence. Six common jurisdictions. Characterisations are COSIMO Digital’s own from public regulator material and market practice as of July 2026, and are not legal advice; timelines are indicative and vary with application quality. Jurisdiction Competent authority Indicative timeline Capital requirement Notable authorisations granted Practical notes Ireland Central Bank of Ireland 12–18 months Class-based, per MiCA Authorisations granted to payments-adjacent and institutional firms Documentation-heavy; strong emphasis on governance, substance and AML; extensive pre-application engagement expected Luxembourg CSSF 12–18 months Class-based, per MiCA Authorisations granted to fund-servicing and institutional firms Fund-industry oriented and precise; suits firms serving asset managers; fund-industry cost levels Germany BaFin 12–18 months Class-based, per MiCA Authorisations granted to trading and custody firms; also DLT Pilot Regime permissions Rigorous and technically deep; experience with crypto securities and DLT infrastructure; parts of the process in German Malta MFSA 9–15 months Class-based, per MiCA Authorisations granted to exchanges migrating from the earlier national VFA regime Long-standing crypto-specific experience predating MiCA; some counterparties apply extra jurisdictional scrutiny Lithuania Bank of Lithuania 9–15 months Class-based, per MiCA Authorisations granted to payments-adjacent and smaller-balance-sheet firms Pragmatic and used to fintech volume; substance expectations have tightened materially since 2024 Netherlands AFM (with DNB for prudential aspects) 12–18 months Class-based, per MiCA Authorisations granted to established trading and brokerage firms Experienced supervisor with a large pre-MiCA registered population; expects mature control frameworks Two selection criteria matter more than any table. Has this authority authorised a firm doing what you intend to do — a supervisor with a comparable precedent asks better questions and decides faster. And can you place real substance there: a resident director, effective management, and control functions physically present. What are the alternatives to applying yourself? Three, each with an honest cost. Rely on an existing authorisation if you hold one that covers the services — credit institutions and certain other authorised firms may provide some crypto-asset services under their existing licence with notification rather than a full CASP application. Restrict scope so no in-scope service is provided. Or partner with an authorised entity. Partnering is common and legitimate, and it should be described plainly rather than sold. The authorised firm performs the regulated service and carries the regulatory responsibility; you perform what is not regulated, under a written agreement allocating activities. The trade is time and cost against control: you reach the market without an application, and the permission stays with the other firm. Outsourcing rules apply to that firm’s reliance on you, and regulators expect the division to be real. Restricting scope is underrated. Many business models touch only one in-scope service, and removing it — by routing custody to an authorised custodian, for instance — can take a firm outside the perimeter entirely while it decides whether to apply. The decision rule: if crypto-asset services are your business, apply, because the licence is the asset. If they are adjacent, partner or restrict, and revisit when volumes justify the build. Read how many firms actually hold an authorisation , which custody permission applies to your instrument , or the EU regulatory stack for tokenized securities . Related Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime The cluster hub: where a CASP authorisation sits in the stack. Who can custody tokenized securities in Europe? Why custody of an instrument is a different permission. How many firms have MiCA authorisation? Roughly one in six of the pre-MiCA population. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 (MiCA): crypto-asset services, authorisation, passporting, own funds by class, EU Official Journal, 2023. Fully applicable from 30 December 2024. Directive 2014/65/EU (MiFID II), Annex I Section C, EU Official Journal, 2014. ESMA and national competent authority registers of authorised crypto-asset service providers. Regulator materials from the Central Bank of Ireland, CSSF, BaFin, MFSA, Bank of Lithuania, AFM and DNB. Jurisdiction characterisations and timelines are COSIMO Digital’s own assessment as of July 2026 and are not legal advice. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Who can custody tokenized securities in Europe? URL: https://cosimodigital.com/learn/custody-tokenized-securities-europe ======================================================================== Home / Learn / Custody of tokenized securities Custody, settlement and operations Who can custody tokenized securities in Europe? Custody of a financial instrument and custody of a crypto-asset are different permissions. Which one applies. Last updated: 28 July 2026 By Ciarán Hynes · 9 min read It depends on what the instrument legally is. A tokenized security is a financial instrument, so custody requires MiFID II permissions and, at settlement, engages CSDR. A crypto-asset that is not a financial instrument requires a MiCA CASP authorisation covering custody. These are different permissions, often held by different firms. Many tokens are misclassified. On this page Who can custody tokenized securities in Europe? What is the difference between custody of a financial instrument and custody of a crypto-asset? Which permission applies to your instrument? What does MiCA require of a crypto-asset custodian? What do MiFID II and CSDR require for financial instruments? How are client assets segregated and protected in insolvency? What should an allocator ask a custodian? Who can custody tokenized securities in Europe? A firm authorised under MiFID II to provide safekeeping and administration of financial instruments for the account of clients, or a credit institution with the equivalent permission. Where the instrument is a fund unit, the depositary appointed under AIFMD or the UCITS Directive carries the safekeeping and oversight duties over the fund’s assets. What is not sufficient: a MiCA authorisation for crypto-asset custody, because MiCA excludes financial instruments from its scope by Article 2(4); and a national VASP registration, which is anti-money-laundering supervision rather than a custody permission. Both have been presented as sufficient in marketing material. The market shape follows from that. Conventional custodians and depositaries hold the assets. A transfer agent or registrar maintains the register of holders. Technology providers supply the ledger infrastructure and the token standard. Three roles, three sets of obligations, in most structures three separate firms. So the first question in any custody conversation is not "can you hold this" but "what is this". Classification comes before permission, and a firm that cannot state the instrument’s legal character should not be selecting a custodian yet. Read how the MiFID II and MiCA boundary is drawn . What is the difference between custody of a financial instrument and custody of a crypto-asset? Different regimes, different obligations, different supervisory expectations, and in most cases different firms. Custody of a financial instrument is a long-established MiFID II ancillary service with decades of supervisory practice behind it. Custody of a crypto-asset is a MiCA service created in 2023 and in application since 30 December 2024. The two custody regimes compared. Financial instrument Crypto-asset (not a financial instrument) Regime MiFID II (ancillary service); AIFMD or UCITS for fund depositaries MiCA (crypto-asset service) Permission needed Investment firm or credit institution authorisation covering safekeeping and administration CASP authorisation covering custody and administration of crypto-assets Settlement rules engaged CSDR , unless exempted under the DLT Pilot Regime None equivalent; MiCA has no settlement-finality regime Client-asset rules MiFID II client-asset rules and national implementations MiCA segregation, position register and liability provisions Passport MiFID II passport MiCA passport Typical provider Custodian bank, depositary, investment firm Authorised crypto custodian The practical consequence for a group holding both is that neither authorisation substitutes for the other, and the perimeter runs between entities rather than around the group. A firm may hold tokenized bonds under a MiFID II permission and the fund’s digital-asset holdings under a MiCA permission, and those are two different licences with two different supervisors. Which permission applies to your instrument? Work from the instrument, not the technology. If the token carries a claim on an issuer, a pool of assets, a share of profits, or a return determined by portfolio performance, it is almost certainly a financial instrument and MiFID II applies. If it does not — a payment token, an asset-referenced token, an e-money token — MiCA applies. Common instruments and the custody permission each requires. Instrument Legal character Custody permission Tokenized fund unit Unit in a collective investment undertaking MiFID II safekeeping; depositary duties under AIFMD or UCITS Tokenized bond or note Transferable security MiFID II safekeeping; CSDR at settlement Tokenized equity Transferable security MiFID II safekeeping; CSDR at settlement E-money token Crypto-asset under MiCA MiCA CASP custody permission Asset-referenced token Crypto-asset under MiCA MiCA CASP custody permission Payment or utility token with no claim Crypto-asset under MiCA MiCA CASP custody permission Where the analysis is close, it is a legal opinion rather than a preference, and it should be obtained in writing before providers are appointed. ESMA published guidelines in December 2024 on the conditions and criteria for qualifying crypto-assets as financial instruments, and those guidelines are what national authorities apply. The expensive direction of error is treating a security as a crypto-asset: the custody arrangement then sits outside the correct regime, and the client-asset protections the instrument requires may not apply at all. What does MiCA require of a crypto-asset custodian? A written agreement with each client, a custody policy, an accurate register of positions per client, segregation of client holdings from the firm’s own assets, and liability to the client for loss of crypto-assets or means of access arising from an incident attributable to the firm. Alongside those sit the general CASP obligations: own funds, fit-and-proper management, governance, complaints handling, outsourcing oversight and ICT resilience. Two requirements carry most operational weight. Segregation must be demonstrable at the level of keys and wallets rather than only in the firm’s books, and supervisors ask how a firm evidences that a specific holding belongs to a client. And the position register must be reconcilable to the ledger at any time, with a documented process and named accountability, because that register is what a liquidator or supervisor would rely on. Our own position, stated in full Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. Until that authorisation is granted, Fortuna is not authorised to provide MiCA crypto-asset custody services, and we do not present it as though it were. The group’s live regulated capability for tokenized securities is issuance and placement through Black Manta Capital Partners, which is BaFin -licensed and operates under MiFID II. Institutions needing authorised crypto-asset custody today should work with a firm that already holds that authorisation. We state it in those exact terms wherever custody is discussed, because a page that explains the VASP-versus-CASP distinction and then applies a softer version of it to its own group has explained nothing. What do MiFID II and CSDR require for financial instruments? MiFID II requires the custodian to hold client financial instruments under a permission covering safekeeping and administration, to keep records and accounts enabling it to distinguish client assets from its own and from other clients’, to conduct regular reconciliations, and not to use client instruments for its own account without express consent. National implementations add detail on registration of client assets and on the use of third parties. CSDR engages at settlement and central registration. Transferable securities admitted to trading must be represented in book-entry form, settlement must occur in a securities settlement system, and settlement discipline applies. Those requirements assume a central securities depository, which is why a ledger-native structure either uses a CSD or operates under the pilot regime’s exemptions. For fund structures, the depositary’s duties are additional and unchanged by tokenization: safekeeping, ownership verification for assets it cannot hold, cash-flow monitoring, and oversight of subscription, redemption and valuation. Its operational due diligence on a tokenized register is the single longest item in most launch plans, and it is a risk decision rather than a formality. Where an instrument sits inside a DLT market infrastructure, read the permission. The ESMA register of authorised DLT market infrastructures records which CSDR articles were disapplied for each operator, including account segregation and settlement finality — which changes the custody analysis materially. How are client assets segregated and protected in insolvency? Segregation is intended to make client holdings identifiable as belonging to specific clients and therefore unavailable to the custodian’s general creditors. Whether that outcome is achieved depends on insolvency law as well as on regulation, and insolvency law is national. Four questions determine the answer in practice. Are client assets held in wallets or accounts distinguishable from the firm’s own? Does the register identify each client’s entitlement at every point in time? Is the arrangement documented as custody rather than as a transfer of title? And has the custodian obtained a legal opinion on the position under its governing law? Omnibus and wallet-per-client structures are the specific design choice. Omnibus pools holdings and relies on the register to allocate entitlements, which is efficient and places weight on register integrity. Wallet-per-client is easier to demonstrate and operationally heavier. Both are used by authorised firms; what matters is that the choice is documented and the client knows which applies. Ask for the insolvency opinion. Institutional allocators do, and it is the document that distinguishes a considered custody arrangement from a technically capable one. What should an allocator ask a custodian? Which legal entity holds the authorisation, on which register, covering which services, from what date? Is the instrument a financial instrument or a crypto-asset, and does your permission match that classification? Are client assets segregated from house assets at the wallet or account level, and how is that evidenced to a supervisor? Is the structure omnibus or client-segregated, and what does the position register record? What is the insolvency analysis under the governing law, and is there an opinion we can read? How are keys generated, stored and recovered, and who can authorise a transfer? What is the liability position for loss of assets or means of access, and how is it limited? Which functions are outsourced, to whom, and under what oversight? How often is the position register reconciled to the ledger, and who signs it off? Two follow-ups separate serious answers from polished ones. Ask for evidence that a control has been tested rather than described — a reconciliation report, an audit finding, a recovery rehearsal. And ask what the custodian will not do: which assets it will not hold, which chains it does not support, which jurisdictions it cannot serve. Read next: what a MiCA CASP authorisation covers , who is accountable for the register , or the eight allocator questions with our own answers . Related Tokenized securities in Europe: MiCA, MiFID II, CSDR and the DLT Pilot Regime The cluster hub: where custody sits in the stack. What is a MiCA CASP authorisation and who needs one? The crypto-asset side of the custody question. Tokenized fund due diligence: eight questions allocators must ask Custody is question five, answered in public. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Regulation (EU) 909/2014 (CSDR); Regulation (EU) 2022/858 (DLT Pilot Regime) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. ESMA, guidelines on the conditions and criteria for the qualification of crypto-assets as financial instruments, December 2024. ESMA, register of authorised DLT market infrastructures, January 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What is atomic settlement, and does DvP work today? URL: https://cosimodigital.com/learn/atomic-settlement-dvp ======================================================================== Home / Learn / Atomic settlement and DvP Custody, settlement and operations What is atomic settlement, and does DvP work today? Delivery versus payment inside one transaction, and the reason the cash leg is the hard part. Last updated: 28 July 2026 By Ciarán Hynes · 7 min read Atomic settlement means the asset leg and the cash leg of a trade move in one indivisible transaction, so neither can complete without the other. The asset leg is straightforward on-chain. The cash leg is the constraint: it requires stablecoins, tokenized deposits or central bank money on the same ledger. Most European settlement today is not atomic. On this page What is atomic settlement? How does delivery versus payment work inside a single transaction? Why is the cash leg the hard part? What are the options for the cash leg — stablecoin, tokenized deposit or central bank money? Does atomic settlement actually work in production today? What has to change for this to become standard? What is atomic settlement? Settlement in which two transfers either both complete or neither does, enforced by the ledger rather than by a post-trade process. In securities terms, the asset moves and the payment moves in the same transaction, so there is no interval in which one party has delivered and the other has not. The benefit is the removal of principal risk between counterparties and the compression of the settlement cycle toward instantaneous. In conventional markets, the same outcome is achieved through infrastructure, netting and default management over a standard cycle, which works well and consumes collateral and time. The distinction that gets blurred commercially: instant transfer of an asset is not atomic settlement. If the cash leg is a bank payment confirmed separately, the transaction is fast on one side and unchanged on the other, and the risk between the legs persists. Atomicity is a property of the pair of transfers, not of either one. How does delivery versus payment work inside a single transaction? Both legs are represented on the same ledger and executed by one atomic operation — a smart contract, or a settlement mechanism that treats the two transfers as inseparable. If either transfer would fail its conditions, the whole transaction reverts and neither leg occurs. Three preconditions have to hold. The asset must be transferable on that ledger and its eligibility rules satisfied. The cash must exist on the same ledger as a claim the seller will accept. And both parties must be able to instruct the transaction, which in practice means custody and key arrangements that support it. The eligibility condition is easy to overlook. A permissioned security will reject a transfer to an unverified address, so an atomic transaction against a whitelisted counterparty succeeds and the same transaction against an unverified one fails cleanly. That is DvP and eligibility enforcement working together, which is the design most European tokenized securities need. Read how eligibility is enforced at the token level . Why is the cash leg the hard part? Because money is issued by institutions whose obligations and infrastructure predate ledgers, and putting a credible claim on money onto a shared ledger requires either a regulated issuer or a central bank. The asset leg needs only a token standard; the cash leg needs a balance sheet and a licence. There is also a hierarchy-of-money problem. A tokenized claim is only as good as its issuer: commercial bank money carries bank credit risk, an e-money token carries issuer and reserve risk, and central bank money carries none of that but is not generally available on third-party ledgers. Central banks have been explicit that the settlement asset matters, which is why wholesale settlement experimentation has focused on it. And there is a regulatory constraint. CSDR assumes settlement in a securities settlement system with cash settlement arrangements to match; the DLT Pilot Regime grants targeted exemptions, including the ability to settle in commercial bank money rather than central bank money in defined cases. Without those exemptions, a ledger-native cash leg has nowhere to sit. What are the options for the cash leg — stablecoin, tokenized deposit or central bank money? Cash-leg options, and what each brings. Option What it is Risk taken Status in Europe E-money token under MiCA A token referencing a single official currency, redeemable at par, issued by an authorised credit or e-money institution Issuer and reserve risk, bounded by MiCA reserve and redemption rules Available and growing; the most credible regulated option today Tokenized deposit A ledger representation of a commercial bank deposit claim Bank credit risk Emerging, bank by bank, often within closed networks Central bank money on-ledger Wholesale settlement in central bank money Effectively none Experimental; explored through Eurosystem and BIS work, not generally available Unregulated stablecoin A token referencing a currency without MiCA authorisation Issuer risk on undisclosed or partly disclosed terms Common outside regulated structures; rarely acceptable to a depositary Conventional bank transfer Fiat payment settled off-ledger Settlement gap and principal risk between legs The default today The Eurosystem has run exploratory work with market participants on settling DLT-based transactions in central bank money, and the ECB has published on that programme; the BIS has done extensive work on tokenisation and the role of the settlement asset, including its unified-ledger analysis. Read those directly rather than second-hand: they are the clearest available statements of why the settlement asset is treated as the central question. For a fund or an issuer choosing today, the practical answer is usually an e-money token where the counterparties will accept one, and a bank transfer where they will not. Does atomic settlement actually work in production today? Yes in a small number of venues, and no as a market default. Under the DLT Pilot Regime, 21X states that it opened the first EU DLT trading and settlement system fully on 8 September 2025, offering smart-contract based issuance, trading and atomic settlement of tokenized stocks, bonds and funds. Within such an infrastructure, atomic DvP is operational. Where it does not work: any structure whose cash leg is a bank transfer, which is most European tokenized issuance; cross-venue transactions where the two legs sit on different ledgers; transactions against fiat outside a pilot-regime infrastructure; and most fund subscriptions and redemptions, where the fund’s own NAV cycle governs timing regardless of settlement technology. It also does not work simply because a stablecoin is involved. Paying for a tokenized security with a stablecoin in a separate transaction is two transfers, not one, and the party who moves first carries the risk. Atomicity requires the transfers to be bound together, which requires infrastructure designed for it. So the honest summary: proven, narrow, and growing slowly. Anyone claiming atomic settlement should be asked which ledger the cash sits on and which venue or contract binds the legs. What has to change for this to become standard? Four things, in order of likely impact. A widely accepted regulated cash leg — either e-money tokens at scale or tokenized deposits with interoperability between banks. Wholesale central bank money available on ledgers used by market infrastructures, which is the subject of ongoing Eurosystem and BIS work rather than a settled matter. Third, permanent market-infrastructure rules rather than exemptions. The pilot regime’s CSDR carve-outs are time-limited and capped; making settlement finality and account segregation work for ledger-native structures in the standing rulebook is what the current reform debate is ultimately about. Fourth, interoperability. Atomic settlement inside one venue is available now; atomic settlement between venues, or between an asset on one ledger and cash on another, requires bridging arrangements whose failure modes are not yet well understood or well regulated. Until those land, treat atomic settlement as a capability of specific infrastructures rather than a property of tokenization. Read which exemptions the pilot regime grants and who holds a permission , where the cash leg sits in a subscription , or the EU regulatory stack . Related What is the DLT Pilot Regime and who is actually using it? The exemptions that permit commercial bank money settlement. How do subscriptions and redemptions work in a tokenized fund? Where the settlement gap actually appears. Who can custody tokenized securities in Europe? Custody arrangements that make atomic instruction possible. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Regulation (EU) 909/2014 (CSDR); Regulation (EU) 2022/858 (DLT Pilot Regime) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. European Central Bank, exploratory work with market participants on settling DLT-based transactions in central bank money, 2024 onwards. Bank for International Settlements, work on tokenisation, the settlement asset and unified ledgers, including the 2023 Annual Economic Report chapter on the future monetary system. 21X AG public statements on the opening of its DLT trading and settlement system, September 2025. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # How is investor identity checked before a token transfer? URL: https://cosimodigital.com/learn/investor-identity-token-transfer ======================================================================== Home / Learn / Identity and token transfer Custody, settlement and operations How is investor identity checked before a token transfer? Whitelisting, permissioned transfer and the standards that enforce eligibility at the token level. Last updated: 28 July 2026 By Ciarán Hynes · 7 min read Eligibility is enforced at the token level, before the transfer executes. Investor identity is verified off-chain, the verified address is added to a whitelist, and the token contract rejects any transfer to an address that is not on it. Standards such as ERC-3643 embed this check in the token itself rather than in a separate agreement. On this page How is investor identity checked before a token transfer? What is whitelisting, and who maintains the list? How is a permissioned transfer enforced at the smart contract level? Which standards do this — ERC-3643, ERC-1400 and others? How does this interact with AML obligations and the travel rule? What happens when an investor becomes ineligible? How is investor identity checked before a token transfer? In three stages, only one of which is on-chain. Verification happens off-chain: identity documents, sanctions screening, jurisdiction and investor-category evidence, performed by the issuer or an appointed agent. Recording happens on-chain: the verified address is added to a whitelist or issued an identity credential. Enforcement happens in the token contract: a transfer to an address failing the rules is rejected before it settles. The order is the point. Because the check runs before execution, an ineligible transfer never becomes a fact that must be unwound. That is the difference between enforcement and remediation, and it is what allows a restricted security to exist on a public ledger without becoming unrestricted. Personal data stays off-chain. What sits on-chain is an eligibility state — this address may hold this instrument — not identity documents or personal details. Any design that publishes more than that has a data-protection problem in addition to a commercial one. What is whitelisting, and who maintains the list? Whitelisting is the recording of addresses that have passed identity, sanctions and eligibility checks, so that they may hold or receive a given instrument. The list is the operational expression of the offering’s investor-eligibility rules, and it is consulted on every transfer. A named party maintains it: the issuer, the transfer agent, or an appointed administrator. It is a continuing obligation rather than an onboarding step, because verification expires, holders move jurisdiction, sanctions lists update and investor categories lapse. Each of those has to flow into the on-chain state, and the latency between the off-chain event and the on-chain update is a control weakness if nobody owns it. Two questions test any arrangement. How quickly is a lapsed verification reflected on-chain, and who authorises an addition? If the answer to the second is the technology provider, accountability sits in the wrong place — it belongs with the party accountable for the register. Read what a transfer agent does for a tokenized fund . Budget for the work. Someone processes additions and removals, answers the queries that arrive when a transfer fails, and evidences to a depositary or auditor that the list reflected current status at each valuation date. How is a permissioned transfer enforced at the smart contract level? The token’s transfer function calls a compliance check before moving any balance. In a typical implementation the contract asks three questions: does the receiving address have a valid on-chain identity; does that identity satisfy the claims required by this instrument; and do the transfer’s parameters satisfy the instrument’s rules. If any check fails, the transaction reverts and no balance moves. Identity registry — maps addresses to on-chain identities holding verified claims issued by trusted parties. Claims — attestations such as verified investor, jurisdiction, professional status or accreditation, issued off-chain and referenced on-chain. Compliance rules — modular conditions applied per instrument: permitted jurisdictions, holder caps, maximum holding per investor, lock-up periods, transfer windows. Agent roles — permissions allowing a named party to freeze, force-transfer or recover balances under a documented procedure, which is what makes probate and court orders operable. For a compliance officer the useful detail is that this is a pre-trade control with an on-chain audit trail. Every rejected transfer is visible, timestamped and attributable, which is a stronger evidence position than a post-trade review process produces. The corresponding obligation is change management. Revising the eligibility matrix means re-configuring compliance rules and, if the instrument is live, potentially a controlled migration. Freeze the matrix before configuration and treat changes as a formal process. Which standards do this — ERC-3643, ERC-1400 and others? ERC-3643 is the standard most used for permissioned securities in Europe. It is an open standard for compliant tokens on EVM-compatible chains, pairing a token contract with an on-chain identity registry and modular compliance rules, so eligibility is validated by the token before any transfer executes. It also defines agent roles for freezing, forced transfer and recovery, which regulated instruments require. ERC-1400 is the earlier and broader security-token family, defining partitioned balances (tranches), transfer restrictions with human-readable failure reasons, and document attachment. It is more of a specification family than a single deployable standard, and implementations vary; parts of it were never finalised in the way ERC-3643 was. Permissioned token standards in practice. Standard What it provides Where it fits ERC-3643 Token plus on-chain identity registry and modular compliance rules; agent roles for freeze, force-transfer and recovery The default choice for EU permissioned securities and tokenized fund units ERC-1400 family Partitioned balances, restricted transfers with failure reasons, document references Earlier security-token designs; still encountered, implementations differ ERC-20 with an external gate Standard token with transfer checks imposed by a wrapper or off-chain process Weaker: enforcement can sit outside the token, so restrictions may not bind Bespoke contracts Custom logic written for one issuance Adds audit cost and reviewer unfamiliarity with no compliance benefit Practical advice: use an established standard. A depositary or auditor may already have reviewed it, the audit cost is lower, and the failure modes are documented. A bespoke contract is a cost with no regulatory upside. How does this interact with AML obligations and the travel rule? Whitelisting is not AML compliance. It is the enforcement layer for investor eligibility; AML obligations sit with the regulated firms in the chain and are performed off-chain — customer due diligence, ongoing monitoring, sanctions screening, suspicious-activity reporting and record-keeping under the applicable national implementation. The travel rule is separate again. In the EU, Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets requires originator and beneficiary information to travel with a transfer between service providers, implementing the FATF standard. It applies to transfers involving crypto-asset service providers rather than to every on-chain movement, and it is a messaging obligation, not a transfer-blocking mechanism in the token. So a well-designed structure has three layers doing different jobs: AML processes at the regulated firms, travel-rule messaging between service providers, and eligibility enforcement in the token. Confusing them produces both over-engineering and gaps — a whitelist does not discharge AML duties, and AML processes do not stop an ineligible transfer. Where the instrument is a financial instrument rather than a crypto-asset, note that the applicable conduct regime is MiFID II and not MiCA , though AML obligations apply either way. Read which regime applies to your instrument . What happens when an investor becomes ineligible? The address stops being able to receive units, and depending on the rules configured it may also be unable to send them. Existing holdings are not confiscated: an investor whose verification lapses generally retains the position and loses the ability to transact until the position is remedied. Three common triggers: verification expiring on a periodic review, a change of tax residence or jurisdiction that takes the holder outside the permitted set, and a sanctions or adverse-media hit. A fourth, more mundane, is a custody migration where the new address was never whitelisted. What the documentation should specify: whether the holding is frozen or merely non-transferable, whether distributions continue to be paid, how the holder is notified, what remediation is required, and whether the instrument may be compulsorily redeemed if eligibility cannot be restored. Those decisions belong in the offering documents rather than in a support conversation. The agent roles in a standard such as ERC-3643 are what make the harder cases operable — probate, insolvency, a court-ordered transfer, or a lost key — under a documented procedure that the depositary has reviewed. A structure with no mechanism for a compelled transfer has not been built for institutional money. Read question four of the allocator frame . Related What does a transfer agent do for a tokenized fund? Who owns the register these checks protect. Who can custody tokenized securities in Europe? Where whitelisted addresses are actually held. What is a tokenized fund? Structure, custody and redemption Why transferable and restricted must coexist. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Directive 2011/61/EU (AIFMD) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets, EU Official Journal, 2023. Financial Action Task Force standards on virtual assets and virtual asset service providers, including the travel rule. ERC-3643 standard documentation; ERC-1400 security-token specification family. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What does a transfer agent do for a tokenized fund? URL: https://cosimodigital.com/learn/transfer-agent-tokenized-fund ======================================================================== Home / Learn / Transfer agent Custody, settlement and operations What does a transfer agent do for a tokenized fund? The register still needs an accountable owner. On-chain does not mean unowned. Last updated: 28 July 2026 By Ciarán Hynes · 7 min read A transfer agent maintains the official register of who owns what, processes subscriptions and redemptions, and is accountable to the fund and its regulator for the accuracy of that record. Tokenizing the units does not remove the role. It changes where the record sits and adds a reconciliation obligation between the chain and the book. On this page What does a transfer agent do for a tokenized fund? Does on-chain issuance remove the need for a transfer agent? Which record is the official register — the chain or the book? How are the two reconciled, and how often? Who is accountable when they diverge? How does this differ between the EU and the US? What does a transfer agent do for a tokenized fund? It keeps the official register of holders and processes the events that change it: subscriptions, redemptions, transfers, distributions and corporate actions. It is accountable, under the fund documentation and to the extent national law provides, for the accuracy of that record. In a tokenized fund it does the same work against a ledger. The role is legal rather than technical, which is why software does not absorb it. A ledger can hold a record and validate a transfer. It cannot be accountable for whether the record is correct, respond to a court-ordered transfer, certify a holder list to an auditor, or decide what happens when an investor loses a key. On-chain does not mean unowned. The register still needs an accountable owner, named in the fund documentation. So the first question about any tokenized fund is who that party is. If the documentation names no accountable owner of the register, that is a gap rather than an elegant design, and it will surface at the first reconciliation break or the first compelled transfer. Does on-chain issuance remove the need for a transfer agent? No. It changes the work and removes some of it, and it does not remove the accountability. What genuinely disappears is a category of manual processing: transfer instructions routed between parties, register updates applied by hand, and periodic reconciliation across several copies of the same list. What remains: certifying the holder list at each valuation date, handling corporate actions, operating the whitelist that eligibility enforcement depends on, managing recovery when access is lost, executing compelled transfers on proper legal instruction, and answering to the depositary, the auditor and the regulator for the record. Some structures perform the role in-house rather than appointing a third party, where national law permits. That is a resourcing decision, not an abolition of the function, and supervisors treat it as such: the obligations attach to whoever performs it. The claim that tokenization removes intermediaries is best read narrowly. It removes reconciliation intermediation between copies of a register. It does not remove the parties whose duties are legal — depositary, administrator, transfer agent — because their duties were never about copying data. Which record is the official register — the chain or the book? It depends on the domicile, and the fund documentation must say. Where national law recognises a distributed ledger as the register of a security, the ledger is the official register and the administrator’s book is an accounting record derived from it. Where it does not, an off-chain register remains legally authoritative and the ledger operates alongside it. Both arrangements work in practice. What does not work is silence: if the two records disagree tomorrow, someone must be able to say in one sentence which one determines legal ownership and under which law. Allocators ask this, and a structure that cannot answer has not resolved its most basic legal question. Germany created crypto-securities registers with a supervised registrar role for exactly this purpose. France recognises securities registered in a blockchain under its 2017 decree. Luxembourg amended its financial-instruments definition alongside implementing the pilot regime. Other member states have not legislated, which is a domicile-selection input rather than a technology problem. Read which member states are furthest ahead . How are the two reconciled, and how often? At every NAV date, and continuously in between where the process supports it. The reconciliation is narrower than conventional fund reconciliation because there is one shared record rather than several copies, but it is not optional and it must be evidenced. Holder list on-chain against subscriptions, redemptions and transfers processed in the period. Units in issue on-chain against units in issue in the administrator’s books at the strike. Whitelist membership against current verification, jurisdiction and sanctions status for each holder. Failed or reverted transfers, with the reason recorded. Any use of agent powers — freeze, forced transfer, recovery — with the instruction and authorisation retained. A dated sign-off by the accountable party, retained for audit. Mismatches between units in issue and the ledger are the most common break in tokenized funds, and they are cheapest to catch at the strike rather than after a distribution has been calculated. The administrator should read units in issue from the register under a documented method rather than from a spreadsheet maintained in parallel. Who is accountable when they diverge? The named transfer agent or registrar, under the fund documentation, with the depositary’s oversight duties sitting above it. Technology providers are accountable for their software under contract; they are not accountable for the register unless the documentation says they are, and it generally should not. The procedure matters as much as the name. Who investigates a break, who authorises a correction to the on-chain record, how the correction is evidenced, whether the depositary is notified, and what is reported to investors if a distribution was affected. Funds that have operated for any length of time answer this immediately, because they have used the procedure. There is also a dependency question that is rarely disclosed. If one provider maintains the register software, can the register be exported and operated independently should that provider fail? Ask before appointment, in writing. Provider concentration is the least-discussed risk in tokenized funds. Read what four years of running this actually involved and question three of the allocator frame . How does this differ between the EU and the US? In the US, transfer agency is a regulated activity in its own right: transfer agents register with the SEC and are subject to specific record-keeping, turnaround, safeguarding and reporting rules. That gives tokenized US structures a ready-made accountable party with an established rulebook, and it is why an SEC-registered transfer agent appears underneath much of the tokenized fund and Treasury market. In the EU, there is no equivalent single transfer-agent authorisation. The function is discharged under the fund’s regime — the AIFM or management company’s obligations, the depositary’s oversight, and national requirements where they exist — and by whichever party the documentation appoints. Germany’s crypto-securities registrar is the closest thing to a dedicated supervised role, and it applies to crypto securities rather than to fund units generally. Transfer agency, EU and US. European Union United States Dedicated regime for the role No single EU authorisation; obligations flow through the fund regime and national law SEC transfer-agent registration with its own rulebook Who is accountable The party appointed in fund documentation, with depositary oversight The registered transfer agent Register recognition Varies by member state State law and transfer-agent regulation Practical effect on tokenized funds Accountability must be constructed in the documentation Accountability is provided by an existing regulated role The practical consequence for a European manager: the accountable owner of the register has to be constructed deliberately rather than inherited from a licensing category. That is more work at structuring and produces the same outcome when done properly. Read the EU regulatory stack . Related What is a tokenized fund? Structure, custody and redemption The cluster hub, including who keeps the register. How is investor identity checked before a token transfer? The whitelist the transfer agent operates. Who can custody tokenized securities in Europe? Custody sits alongside, not instead of, the register. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Directive 2014/65/EU (MiFID II); Regulation (EU) 2023/1114 (MiCA); Directive 2011/61/EU (AIFMD) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. German Act on Electronic Securities (eWpG) crypto-securities registrar role; French decree of 2017 on securities registered in a blockchain; Luxembourg law of 15 March 2023. US Securities and Exchange Commission transfer-agent registration and rules. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What is a digital asset treasury? Policy, custody and reporting URL: https://cosimodigital.com/learn/digital-asset-treasury ======================================================================== Home / Learn / Digital asset treasury Digital asset treasury What is a digital asset treasury? A policy, a custody framework and a reporting line, not a product. Last updated: 28 July 2026 By Ciarán Hynes · 9 min read A digital asset treasury is a governance structure, not a product. It is a written policy setting what may be held and in what size, a custody framework specifying where assets sit and under whose permissions, and a reporting line making someone accountable. Without those three, a company holding digital assets has a position, not a treasury. On this page What is a digital asset treasury? How is a digital asset treasury different from a fund or an ETF? What does the custody framework need to cover? Who is accountable, and what is the reporting line? How is it valued and disclosed? What does a well-governed digital asset treasury look like? What is a digital asset treasury? Three components, none of them exotic. A written policy stating which assets may be held, in what size, for what purpose. A custody framework stating where the assets sit, under whose authorisation, and who can move them. And a reporting line making a named person accountable for both, to a board or an investment committee. The reason to insist on the definition is that the term is applied loosely to any balance sheet holding crypto. A position taken because a treasurer had conviction, custodied wherever it was bought, reported when someone asks, is a position. It may be profitable. It is not a treasury function, and it will not survive an audit, a lender’s diligence or a bad quarter without difficulty. None of the three components is a technology decision. They are the disciplines a conventional treasury already applies to cash, deposits and short-term instruments, applied to assets whose custody model, volatility and settlement behaviour differ. The novelty is in the custody and the valuation inputs, not in the governance. The rest of this page sets out what each component has to cover. The detailed document is treated separately in what belongs in a digital asset treasury policy , and the market’s pricing of all this is in why digital asset treasuries trade below NAV . How is a digital asset treasury different from a fund or an ETF? A fund and an ETF are pooled investment vehicles: third-party capital, a manager with fiduciary duties, a regime governing eligible assets and disclosure, and investors who can subscribe and redeem. A treasury holds the entity’s own capital on its own balance sheet, for its own purposes, with no external investors in the holding itself. Treasury, fund and ETF compared. Digital asset treasury Fund ETF Whose capital The entity’s own Third-party investors’ Third-party investors’ Governing regime Company law, accounting standards, listing rules where applicable AIFMD or UCITS for the manager UCITS or an equivalent fund regime Who is accountable Board and a named executive Authorised manager, with a depositary Authorised manager, with a depositary Subscription and redemption None; capital is deployed and returned by corporate action Fund windows at NAV Creation and redemption at NAV by authorised participants External protections Audit, disclosure, and whatever the policy commits to Depositary, valuation rules, investor-protection obligations Depositary, plus exchange and arbitrage mechanics How the market prices it Equity at a premium or discount to NAV At NAV Close to NAV by arbitrage One consequence is often missed by listed vehicles: because there is no redemption at NAV and no arbitrage mechanism, nothing anchors the equity price to the value of the holdings. That is the structural origin of the discounts observed across the sector. Another is that a treasury’s protections are self-imposed. A fund has a depositary verifying ownership and overseeing cash flows because the law requires one. A treasury has whatever its policy commits to and its board enforces, which is why the policy is the product. What does the custody framework need to cover? Where the assets are, who holds them under which authorisation, how keys are controlled, who may authorise a movement, and what happens if a provider fails. Specific enough to name entities and permissions, not a statement that assets are held securely. Provider and permission. Which authorised entity holds which assets, under which authorisation, in which jurisdiction. In the EU, custody of crypto-assets requires a MiCA authorisation and a national VASP registration is not the same thing. Segregation. Whether holdings are omnibus or segregated, and how the provider evidences that a holding is yours. Key management. How keys are generated, stored and backed up; the recovery procedure; and whether any self-custody is permitted and under what controls. Authorisation of movements. Dual control, transaction limits, whitelisted destination addresses, and time delays on large movements. Provider failure. The insolvency analysis under the provider’s governing law, and the migration path to an alternative. Prohibited activity. Whether lending, staking, rehypothecation or yield activity is permitted, and if so under what limits. On our own capability, stated the way we would want it from a counterparty: the group’s digital asset treasury infrastructure is built and is not operating at scale, and Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. We would not describe either as a live service today. Read which custody permission applies to which instrument . Who is accountable, and what is the reporting line? A named executive owns the treasury; the board or an investment committee approves the policy and receives reporting; internal audit or an equivalent function tests compliance. Diffuse accountability is the most common governance failure in this area, and it is visible immediately to anyone conducting diligence. The reporting line should specify frequency, content and escalation. Monthly or quarterly reporting of holdings, valuations, counterparty exposures against limits, liquidity position, and any breaches. Immediate escalation for a limit breach, a custody incident, a provider failure, or a valuation event that materially changes the position. Deviations from policy should require documented approval at a stated level rather than a conversation. This is what distinguishes a working policy from a filed one: evidence in minutes that limits were monitored, breaches recorded and resolved, and the framework reviewed. For a listed vehicle there is an additional audience. Public-market investors price governance directly, and a board that cannot show who decides what will find that reflected in the equity. Read what mNAV measures and why discounts persist . How is it valued and disclosed? Valuation needs a named pricing source, a methodology, a frequency, and a treatment for illiquid or restricted holdings. For liquid assets with observable prices this is straightforward and should still be written down: which venue or index, at what time, and who reviews it. For thinly traded or locked positions, the policy must state how a price is derived and who approves it. Disclosure has two audiences with different needs. Internally: holdings, valuations, exposures against limits and liquidity, at the agreed cadence. Externally: whatever accounting standards, listing rules and lender covenants require, plus anything the entity has committed to voluntarily. For listed vehicles, holdings, custody arrangements and any encumbrances are the disclosures investors actually use. Encumbrance is the item most often omitted. Assets pledged as collateral, lent, staked with a lock-up, or held in an arrangement that restricts transfer are not equivalent to unencumbered holdings, and a NAV figure that does not distinguish them overstates the position’s quality. Where the treasury holds tokenized instruments rather than native digital assets, note that their valuation frequency is set by the instrument’s own documentation. Our comparison of tokenized treasury products records the relevant terms product by product. What does a well-governed digital asset treasury look like? It can answer six questions from documents, on request, without preparation. What may we hold and how much? Where is it and who holds it? Who can move it and under what controls? What is it worth, on what basis, as of when? What are we exposed to beyond the asset itself? And who approved all of that, and when was it last reviewed? A policy approved by the board, reviewed at least annually, with sizing limits and prohibitions stated. Custody with an authorised provider, documented segregation, dual-control movement authorisation and a tested recovery procedure. Counterparty limits monitored against actual exposure, including exposure to stablecoin and e-money token issuers. A liquidity ladder tested against a stressed scenario rather than a calm one. Valuation on a named methodology, reviewed independently of the person who trades. Reporting at a fixed cadence with a defined escalation path, evidenced in minutes. None of that requires a large team. It requires decisions to be written down and enforced, which is the difference between a treasury and a position — and, for a listed vehicle, a material part of what the market is pricing. Read the policy document section by section or our note on the NAV discount problem . Related What belongs in a digital asset treasury policy? The document that implements this structure. Why do digital asset treasuries trade below NAV? How the market prices treasury governance. Who can custody tokenized securities in Europe? The permission question inside the custody framework. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 (MiCA); Directive 2014/65/EU (MiFID II); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Why do digital asset treasuries trade below NAV? URL: https://cosimodigital.com/learn/mnav-digital-asset-treasury-discount ======================================================================== Home / Learn / mNAV and the discount Digital asset treasury Why do digital asset treasuries trade below NAV? What mNAV measures, and the structural reasons a discount opens and persists. Last updated: 28 July 2026 By Ciarán Hynes · 8 min read mNAV compares a digital asset treasury company's market capitalisation to the net asset value of its holdings. A discount opens when investors can buy the underlying asset directly, more cheaply and with less risk, than through the equity. It persists when the company has no mechanism to close it, such as buybacks or redemption at NAV. On this page What is mNAV? Why do digital asset treasuries trade below NAV? What causes a premium instead? Why does a discount persist rather than closing? What can a treasury actually do about it? What should an investor check before buying at a discount? What is mNAV? The ratio of a vehicle’s traded market capitalisation to the net asset value of what it holds. Above one, the market pays a premium for the wrapper; below one, it applies a discount. It is the standard measure for any listed vehicle whose holdings have observable prices, which is why it transfers cleanly to digital asset treasury companies. It is unusually clean here because the asset side is transparent. A holding of a liquid digital asset can be valued continuously, so a discount is not an artefact of stale marks or opaque valuations. That transparency is what makes the measure uncomfortable for issuers: there is nowhere for the gap to hide. One clarification, since the terms get mixed. NAV is assets less liabilities. mNAV is the market’s valuation of the equity relative to that. A company can grow NAV per share while mNAV falls, and frequently does — accumulating assets is not the same as being valued for them. Compute it carefully. Debt, convertibles, preference instruments and encumbered holdings all belong in the calculation, and a headline NAV that ignores them flatters the vehicle. Encumbered assets — pledged, lent or locked — are not equivalent to unencumbered ones. Why do digital asset treasuries trade below NAV? Because the equity offers the same exposure with additional costs and additional risks, and investors can usually buy the asset directly. The discount is the market pricing everything the wrapper adds that the holder did not ask for. Costs. Corporate overhead, financing costs and management compensation that direct ownership does not carry. Dilution. The possibility of issuance at or below NAV, transferring value away from existing holders. Discretion. Management may sell, hedge, lever or diversify in ways the shareholder did not choose. Custody and counterparty risk. Concentrated in arrangements the shareholder cannot inspect. Leverage. Debt or convertible structures that amplify drawdowns and can force selling. Disclosure gaps. Infrequent or unclear reporting of holdings, custody and encumbrances. Tax and structure. An extra layer between the holder and the asset, with its own consequences. The order matters when diagnosing a specific vehicle. A discount driven by leverage and dilution risk is different from one driven by poor disclosure: the first requires balance-sheet change, the second requires only discipline. Both are fixable; only one is cheap. This expands the argument in our note on the NAV discount problem , which set out why the discount is structural rather than sentimental. What causes a premium instead? A premium exists when the wrapper offers something direct ownership cannot, and it is informative about what the market values. Four causes recur: access, accretion, yield, and index or mandate eligibility. Access premiums arise where investors cannot hold the asset directly — restricted mandates, custody constraints, or jurisdictions where direct holding is impractical. These compress as direct access improves, which is why access-only premiums have historically been the least durable. Accretion premiums arise where management has demonstrated that it can increase NAV per share, typically by issuing equity above NAV and buying more of the asset, or by generating income on the holdings. That is a genuine skill and the market pays for evidence of it, not for the intention. Yield premiums arise where the vehicle produces cash flow the underlying asset does not — staking, lending or structured income — and where the risk of producing it is disclosed and controlled. Mandate eligibility, finally, is worth a premium wherever a large pool of capital can buy the equity and not the asset. Why does a discount persist rather than closing? Because there is no arbitrage mechanism. In an ETF, authorised participants create and redeem at NAV, so any gap is closed mechanically. A closed-ended treasury company offers no such channel: an investor who believes the equity is cheap cannot exchange it for the underlying assets, so the discount can sit there for years. Persistence is therefore structural, not a sentiment problem to be argued away. The only things that close it are a mechanism — buybacks, a redemption right, a tender, a distribution, a wind-down — or a re-rating of the governance that produced the discount in the first place. Two behaviours widen it instead. Issuing equity below NAV to buy more of the asset, which dilutes the holders the purchase was meant to benefit. And announcing that the discount is unjustified without changing anything, which the market reads as confirmation that no mechanism is coming. There is also a reflexivity trap. A wide discount raises the cost of equity, which limits the vehicle’s ability to fund a buyback or to grow accretively, which sustains the discount. Breaking that loop usually requires shrinking rather than growing, which boards resist. What can a treasury actually do about it? Mechanisms, and what each requires. Mechanism Effect on the discount Requires Buybacks funded by asset sales Directly accretive to NAV per share when executed below NAV Liquidity and a willingness to shrink Redemption right at or near NAV Removes the discount structurally A structure permitting it, and liquidity management Tender offer One-off narrowing, with a signal effect Balance-sheet capacity Distribution policy Converts holdings into holder cash flow Sufficient liquidity and a durable policy Clear disclosure of holdings, custody and encumbrances Reduces the risk premium at low cost Reporting discipline Policy limiting discretion, leverage and dilution Reduces the governance premium Board commitment and enforcement Wind-down or conversion Eliminates the wrapper entirely Shareholder approval The cheapest interventions are the disclosure and policy items, and they are the ones most often skipped in favour of narrative. A vehicle that publishes its holdings, its custody arrangements, its encumbrances and a policy constraining dilution has removed several components of its own discount without selling anything. Read what such a policy commits to . The most credible signal remains a used mechanism. A buyback executed below NAV, disclosed with its effect on NAV per share, tells investors more than any statement of intent. What should an investor check before buying at a discount? Is the NAV real? Holdings verified, valuation methodology stated, and encumbered assets identified separately. What sits above the equity? Debt, convertibles and preference instruments, with maturities and covenants. Is there a mechanism, and has it been used? Buyback authority actually exercised, a tender completed, a redemption right that works. What is the dilution risk? Authorised but unissued shares, at-the-market programmes, and any policy limit on issuing below NAV. Where is the custody, and under whose authorisation? Provider, permission, segregation and any lending or staking of the holdings. What discretion does management have? Whether it can change the asset mix, lever up or hedge without shareholder approval. What is the cash burn? Whether overheads are funded from income or from selling the asset. A discount is an opportunity only if it can close. Where there is no mechanism, no policy limiting dilution and no disclosure of encumbrance, the discount is a price, not a bargain — and it can widen. Read what a well-governed digital asset treasury looks like or tokenized treasury products, where NAV mechanics are contractual rather than discretionary . Related What is a digital asset treasury? The cluster hub: the governance the discount prices. What belongs in a digital asset treasury policy? The commitments that reduce the governance premium. The NAV discount problem The original COSIMO note this page expands. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 (MiCA); Directive 2014/65/EU (MiFID II); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. COSIMO Digital, "The NAV Discount Problem", Insights, 2026. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # What belongs in a digital asset treasury policy? URL: https://cosimodigital.com/learn/digital-asset-treasury-policy ======================================================================== Home / Learn / Treasury policy Digital asset treasury What belongs in a digital asset treasury policy? Custody, counterparty limits, liquidity ladders, valuation and disclosure. Last updated: 28 July 2026 By Ciarán Hynes · 9 min read A digital asset treasury policy specifies which assets may be held and in what size, where they are custodied and under whose permissions, counterparty exposure limits, a liquidity ladder matching holdings to expected cash needs, a valuation methodology and frequency, disclosure obligations, and who approves the policy and how often it is reviewed. On this page What belongs in a digital asset treasury policy? How should custody be specified? What counterparty limits are appropriate? How do you build a liquidity ladder? How should assets be valued, and how often? What must be disclosed, and to whom? Who approves the policy, and how often is it reviewed? What belongs in a digital asset treasury policy? Seven sections. Eligible assets and sizing. Custody and permissions. Counterparty limits. Liquidity ladder. Valuation methodology and frequency. Disclosure obligations. Approval and review. Short enough to be read by the board that approves it, specific enough to be tested by an auditor. The seven sections and what each must state. Section What it must state Tested by Eligible assets and sizing Which assets may be held, maximum size in absolute and relative terms, and the purpose of the holding Whether an actual holding is within limits today Custody and permissions Where assets sit, which authorised entity holds them, how keys are controlled, who may authorise a transfer Evidence of the provider’s authorisation on a register Counterparty limits Exposure caps per exchange, broker, lender, and stablecoin or e-money token issuer, and how they are monitored A current exposure report against limits Liquidity ladder Which holdings are available at what notice, matched to expected and stressed cash needs A stressed scenario run against the ladder Valuation Pricing source, methodology, frequency, and treatment of illiquid or restricted holdings A valuation an auditor can reproduce Disclosure What is reported, to whom, how often, and what triggers an ad hoc disclosure Minutes and reports at the stated cadence Approval and review Who approves, who may deviate and on what authority, and the review cadence A dated approval and a review record What does not belong: market views, price targets and strategy narrative. A policy sets limits and processes. A policy that argues a thesis has to be rewritten whenever the thesis changes, which defeats its purpose. How should custody be specified? By naming entities, permissions and controls rather than asserting that assets are held securely. The section should identify which authorised provider holds which assets, under which authorisation and in which jurisdiction, and require evidence of that authorisation on a public register rather than a provider’s description of itself. Segregation model. Omnibus or client-segregated, and how the provider evidences your entitlement. Key management. Generation, storage, backup and recovery; whether self-custody is permitted and under what controls. Movement authorisation. Dual control, per-transaction and daily limits, whitelisted destination addresses, and delays on large movements. Provider failure. The insolvency analysis under the provider’s governing law, and a documented migration path. Prohibited activity. Whether lending, staking, rehypothecation or any yield activity is permitted, and if so under what limits and with which counterparties. In the EU, custody of crypto-assets requires a MiCA authorisation, and a national VASP registration is a different status: an anti-money-laundering registration, not permission to provide custody. The policy should say which is required and require the register entry. Read which custody permission applies to which instrument . Prohibitions are the most useful part of this section in a fast decision. A treasurer who can point to a line saying the treasury does not lend its holdings does not need to convene a committee to decline an offer. What counterparty limits are appropriate? Limits should be per counterparty, per counterparty type, and in aggregate, expressed as a percentage of treasury assets and as an absolute cap, with a stated basis for the cap. The right level depends on the entity’s balance sheet and risk appetite; the discipline is that a number exists and is monitored. The exposures to capture go beyond trading venues. A stablecoin or e-money token position is an exposure to its issuer and reserves. A staking arrangement is an exposure to a protocol and often to a validator operator. A lending position is credit exposure. Assets at a custodian are exposure to that custodian’s solvency and controls, however well segregated. Exposure types and what a limit should address. Exposure What to limit What to monitor Trading venue or broker Balance held on-venue, and time held Daily balances; sweep to custody Custodian Share of total assets with one provider Authorisation status, audit findings, incidents Stablecoin or e-money token issuer Position size per issuer Reserve disclosures, redemption performance, authorisation Lending counterparty Notional and tenor Collateral, mark-to-market, covenant compliance Staking or protocol Amount staked and lock-up Slashing risk, validator performance, unbonding periods Bank Fiat balances above deposit protection Concentration and credit standing Limits should be tested against actual exposure at least monthly, and breaches recorded and escalated rather than tolerated. An unmonitored limit is a statement, not a control. How do you build a liquidity ladder? Map holdings against the time required to convert them into usable cash, then map that against expected and stressed cash needs over defined horizons. The ladder is useful only if the conversion times assume a poor market rather than a calm one. Define horizons. Typically immediate, one week, one month, one quarter, and beyond. Assign holdings to horizons. Based on realistic conversion time including custody withdrawal, settlement and payment. Layer in constraints. Unbonding periods, lock-ups, encumbrance, and venue withdrawal limits. State cash needs per horizon. Operating costs, committed capital, debt service, tax. Stress it. Apply a drawdown and a liquidity contraction simultaneously, since they arrive together. Record the gap. If a horizon is short of cover, the policy should say what action is triggered and by whom. Two honest inputs make the difference. Withdrawal from custody is not instant, and staked or locked assets are not liquid regardless of the asset’s market depth. A ladder that treats a locked position as available at one week is a ladder that will fail when it is needed. Where the treasury holds tokenized instruments, their redemption terms come from the instrument’s documentation and belong in the ladder as stated, not as assumed. See the tokenized treasury products comparison . How should assets be valued, and how often? On a named pricing source, by a stated methodology, at a stated frequency, reviewed by someone other than the person who trades. For liquid assets with observable prices, daily or at each reporting date is normal; for thinly traded, restricted or locked positions, the policy must state how a price is derived and who approves it. The specifics an auditor will ask for: which venue or index, at what time of day, in which currency, and what happens when the primary source is unavailable. A policy that names a fallback source and a tie-break rule avoids an argument at the worst moment. Encumbrance must be visible in the valuation, not only in a footnote. Pledged, lent or locked holdings should be identified separately, because their contribution to net asset value is not equivalent to unencumbered holdings. This is exactly the disclosure the market prices when it values a listed vehicle. Read why digital asset treasuries trade below NAV . Frequency should match decision-making, not appearances. If limits are monitored monthly, valuation must be at least monthly, and a treasury that reports quarterly while trading weekly has a control gap regardless of methodology. What must be disclosed, and to whom? Internally: holdings, valuations, exposures against limits, liquidity position, breaches and incidents, at the agreed cadence, to the board or committee named in the policy. Externally: whatever accounting standards, listing rules, lender covenants and regulatory obligations require, plus anything the entity has voluntarily committed to. For listed vehicles the disclosures investors actually use are holdings, custody arrangements, encumbrances, leverage and any dilution mechanism. Publishing those reduces the risk premium in the discount at very low cost, which is the cheapest governance improvement available. The policy should also define what triggers an ad hoc disclosure: a custody incident, a provider failure, a limit breach of a stated size, a material valuation event, or a change to the policy itself. Deciding this in advance prevents the disclosure question from being litigated during the event. One caution on voluntary disclosure: commit only to what can be sustained. A vehicle that publishes weekly holdings and then stops has created a negative signal where none existed. Who approves the policy, and how often is it reviewed? The board or an investment committee approves it, a named executive owns it, and it is reviewed at least annually and on any material change: a new asset class, a new custodian, a change in a provider’s regulatory status, a loss event, or a change in the entity’s funding position. Deviations require documented approval at a stated level. The policy should name who may authorise a temporary deviation, for how long, and what must be reported afterwards. Silence here is what produces the informal exception that becomes the practice. Evidence of operation matters as much as the document. Minutes recording that limits were monitored, that breaches were recorded and resolved, and that the ladder was tested, are what an auditor, lender or acquirer will ask for. A policy with no operating record reads as an aspiration. Board resource Digital asset treasury policy template The seven sections as an editable board-ready document, with the limit tables, the liquidity ladder worksheet, the valuation and encumbrance schedule, and the escalation matrix. Built for a first policy going to a board or audit committee. We email it on request; this page stays open to everyone. Do not fill this in: Work email address Send me the template We email the file once and add you to occasional notes on tokenization and regulation. No noise, and you can unsubscribe at any time. Read next: what a digital asset treasury is, and what good governance looks like , how the market prices it , or which custody permission your holdings require . Related What is a digital asset treasury? The cluster hub this policy implements. Why do digital asset treasuries trade below NAV? What the market pays for policy discipline. Who can custody tokenized securities in Europe? The permission the custody section must verify. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 (MiCA); Directive 2014/65/EU (MiFID II); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS) — EU Official Journal. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # How many firms have MiCA authorisation? URL: https://cosimodigital.com/data/mica-authorisation-count ======================================================================== Home / Learn / MiCA authorisation count European regulation How many firms have MiCA authorisation? Roughly 210 of approximately 1,200 pre-MiCA firms, about one in six. What happened to the rest. Last updated: 28 July 2026 By Ciarán Hynes · 4 min read Roughly 210 firms hold MiCA CASP authorisation, out of approximately 1,200 that operated under national regimes before MiCA applied. That is about one in six. The remainder either exited, were acquired, moved outside the EU, or continue under expiring national grandfathering. The official position is the ESMA register . Data as of 28 July 2026. COSIMO Digital analysis of regulator registers and market data; reviewed monthly. On this page How many firms have MiCA authorisation? How does that compare to the pre-MiCA population? Which member states have authorised the most? What happened to the firms that did not get authorised? Where can I check the official register? How many firms have MiCA authorisation? Roughly 210, as of 28 July 2026. The figure is an approximation from regulator registers and market data, and it moves as authorisations are granted and as transitional arrangements end. For a specific firm or member state, read the register rather than this page. MiCA authorisation, as of 28 July 2026. Measure Figure Basis Firms holding MiCA CASP authorisation ~210 Regulator registers and market data Firms operating under pre-MiCA national regimes ~1,200 Market data for the period before MiCA applied Authorisation ratio ~1 in 6 Derived MiCA fully applicable since 30 December 2024 Regulation (EU) 2023/1114 How does that compare to the pre-MiCA population? It is a reduction of roughly five-sixths in the population of firms permitted to provide crypto-asset services to EU clients. The pre-MiCA population was supervised under national regimes of very different depth — some prudential, most anti-money-laundering only — so the comparison is between a low bar applied unevenly and a single high bar applied across the Union. The reduction is therefore not evidence of market decline. It is the difference between registration and authorisation. Read what a CASP authorisation actually requires . Which member states have authorised the most? No single official source publishes a consolidated league table by member state, so we do not publish one either. Authorisations are recorded firm by firm on ESMA’s registers and on each national authority’s register, and the count for any member state should be taken from there on the day you need it. Where to verify, by member state. Registers are the authoritative source; counts change weekly. Member state Competent authority Verify at Ireland Central Bank of Ireland centralbank.ie Luxembourg CSSF cssf.lu Germany BaFin bafin.de Malta MFSA mfsa.mt Lithuania Bank of Lithuania lb.lt Netherlands AFM afm.nl All member states ESMA ESMA registers and data What can be said without inventing numbers: authorisations are concentrated in the member states with the largest pre-MiCA registered populations and the most established supervisory capacity, and several small member states that hosted large registered populations before MiCA now host materially fewer authorised firms. What happened to the firms that did not get authorised? Four outcomes. Exit from the EU market, serving non-EU clients only. Narrowing of activity so that no in-scope service is provided. Acquisition by, or becoming an agent or distributor of, an authorised firm. Or continuation under expiring national grandfathering while an application is pending. The common factor is capability rather than intent: authorisation requires governance, client-asset controls, resilience, AML systems and evidenced own funds — an operating firm, not a document. Read the alternatives to applying yourself . Where can I check the official register? ESMA registers and data at EU level, and each national competent authority for firm-level entries. Read three fields: which legal entity holds the authorisation, which services it covers, and from what date. Treat anything not on a register as not authorised. One caution that catches counterparties regularly. A firm appearing on a national anti-money-laundering register of virtual asset service providers holds an AML supervision status, not a MiCA authorisation. Our own position is stated on the same terms: Fortuna’s status and what it permits today . Related What is a MiCA CASP authorisation and who needs one? What the ~210 firms actually hold. Who can custody tokenized securities in Europe? Why an authorisation for custody is a separate question. EU digital asset regulation tracker Dated record of what is in force and who is authorised. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources ESMA registers and data; national competent authority registers of authorised crypto-asset service providers. Regulation (EU) 2023/1114 (MiCA), fully applicable from 30 December 2024, EU Official Journal. Firm counts are COSIMO Digital approximations from regulator registers and market data as of 28 July 2026, not official statistics. COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted. ← All Learn articles ======================================================================== # Tokenization glossary: MiCA, MiFID II and digital asset terms defined URL: https://cosimodigital.com/learn/glossary ======================================================================== Home / Learn / Glossary Reference Tokenization glossary: MiCA, MiFID II and digital asset terms defined Thirty terms that decide what is permitted in European tokenization, defined plainly. Each definition is written to be read on its own, without the others. Where a term names a regime, the regulation is identified so it can be checked against the primary text. Last updated: 28 July 2026 Maintained by Ciarán Hynes All 30 terms Tokenization Real-world asset Security token Tokenized fund Tokenized treasury MiCA CASP ART EMT MiFID II DLT Pilot Regime DLT MTF ESMA CSDR UCITS AIFMD AIFM Transfer agent Registrar Qualified custodian VASP Atomic settlement Delivery versus payment NAV mNAV Digital asset treasury ERC-3643 Permissioned transfer Whitelisting On-chain register Tokenization tokenised assets 01 Representing ownership of an asset as a transferable record on a distributed ledger, so the ledger becomes the register of holders. Tokenization does not change what the asset is: a tokenized bond remains a bond, and the law that applied before applies after. What changes is how title moves and how quickly it settles. Real-world asset RWA 02 An asset that exists off-chain and derives its value there: a bond, a fund unit, a loan, real estate, a commodity or a receivable. Tokenizing it creates an on-chain record of an off-chain claim. The enforceability of that claim comes from contract and applicable law, not from the ledger. Security token 03 A token that qualifies as a transferable security or another financial instrument. In the EU that classification places it under MiFID II rather than MiCA, and its issuance, placement and trading require the corresponding investment-services authorisations. Substance governs: calling a token a utility does not remove it from the securities perimeter. Tokenized fund 04 A collective investment vehicle whose units or shares are issued and transferred as tokens. The fund's legal form, its manager's authorisation and its investor-protection obligations are unchanged. The register moves on-chain, which shortens subscription and redemption cycles and makes the holder list continuously reconcilable. Tokenized treasury 05 A tokenized fund or note whose underlying holdings are short-dated government debt, typically US Treasury bills or EU sovereign paper. It functions as an on-chain cash-equivalent instrument. Yield derives from the underlying securities, and holders hold a claim on the vehicle rather than on the sovereign directly. MiCA Markets in Crypto-Assets Regulation 06 Regulation (EU) 2023/1114 on Markets in Crypto-Assets, in application across the Union since 2024. It creates a single authorisation regime for crypto-asset service providers and for issuers of asset-referenced and e-money tokens. It expressly does not cover crypto-assets that qualify as financial instruments, which remain under MiFID II. CASP Crypto-Asset Service Provider 07 An entity authorised under MiCA to provide services such as custody, exchange, order execution, placement, transfer or advice on crypto-assets. Authorisation in one member state passports across the EEA. Firms holding pre-MiCA national registrations must obtain CASP authorisation to continue providing in-scope services. ART Asset-referenced token 08 MiCA's category for a crypto-asset that references several currencies, assets or a basket of them in order to stabilise its value. Issuers face reserve, governance, disclosure and own-funds requirements, and asset-referenced tokens deemed significant are supervised at EU level by the European Banking Authority. EMT E-money token 09 MiCA's category for a crypto-asset referencing a single official currency, functionally a digital form of electronic money. Issuers must be authorised credit institutions or electronic money institutions, must hold full backing in low-risk liquid reserves, and must redeem at par on demand at any time. MiFID II Markets in Financial Instruments Directive 10 Directive 2014/65/EU, the EU framework governing investment firms, financial instruments, trading venues and investor protection. It is the regime that applies to tokenized securities. Authorisation as a MiFID investment firm carries an EEA passport for the services and instruments the licence covers. DLT Pilot Regime 11 Regulation (EU) 2022/858, a time-limited regime allowing market infrastructures to trade and settle tokenized financial instruments with targeted exemptions from CSDR and MiFID II requirements that assume a central securities depository. It carries volume caps and was designed to generate evidence for permanent reform. DLT MTF DLT multilateral trading facility 12 A multilateral trading facility operating under the DLT Pilot Regime and admitting DLT financial instruments to trading. It may combine trading and settlement functions in one entity, which conventional EU market structure separates. Operators need MiFID II authorisation plus the specific pilot-regime permission. ESMA European Securities and Markets Authority 13 The EU's securities supervisor. It issues technical standards, guidelines, opinions and Q&As that determine how MiCA and MiFID II are applied in practice, maintains EU-level registers, and directly supervises certain entities. Its guidance is where token classification questions are usually settled. CSDR Central Securities Depositories Regulation 14 Regulation (EU) 909/2014 on central securities depositories and settlement. It sets authorisation requirements for CSDs, mandates book-entry form for transferable securities admitted to trading, and imposes settlement discipline. Its assumptions about a central register are the friction tokenized settlement runs into. UCITS Undertakings for Collective Investment in Transferable Securities 15 The EU's retail fund framework, with eligible-asset rules, diversification limits, liquidity requirements and a retail passport. Its eligible-asset constraints are the principal reason most tokenized funds in Europe are structured as alternative investment funds rather than as UCITS. AIFMD Alternative Investment Fund Managers Directive 16 Directive 2011/61/EU, the EU regime for managers of alternative investment funds: private equity, venture, credit, real estate and hedge strategies. It regulates the manager rather than the fund, imposing depositary, valuation, risk-management, remuneration and reporting obligations, and provides a marketing passport to professional investors. AIFM Alternative Investment Fund Manager 17 The authorised entity responsible for portfolio management and risk management of an alternative investment fund under AIFMD. Tokenizing a fund does not remove the need for an AIFM. It changes how the register is kept, not who is accountable for managing the fund. Transfer agent 18 The party maintaining the official record of ownership of a fund or security and processing subscriptions, redemptions, transfers and corporate actions. In a tokenized structure the on-chain register can perform the record-keeping, but legal responsibility for its accuracy still sits with a named, appointed party. Registrar 19 The entity keeping the register of holders of a security and ensuring it reflects legal title. Registrar and transfer-agent roles overlap and are often held together. On-chain registers make the holder list continuously readable; they do not remove the requirement that it be legally authoritative. Qualified custodian 20 A regulated entity permitted to hold client assets, segregate them from its own balance sheet and safeguard them under a specific authorisation. In the EU, custody of crypto-assets is a MiCA service, while custody of financial instruments is a MiFID II ancillary service. The distinction determines which licence is required. VASP Virtual Asset Service Provider 21 The anti-money-laundering designation, drawn from FATF standards and implemented in national law, for firms conducting virtual-asset business. A VASP registration is an AML supervision status, not a prudential or market-conduct authorisation, and does not by itself permit a firm to provide MiCA services. Atomic settlement 22 Settlement in which the transfer of an asset and its payment leg either both complete or neither does, enforced by the ledger rather than by a post-trade process. It removes principal risk between counterparties and compresses the settlement cycle toward instantaneous. Delivery versus payment DvP 23 The settlement convention requiring that securities are delivered only if payment is made, and that payment is made only if securities are delivered. On-chain, it can be enforced inside a single transaction. That requires the cash leg to exist on the same ledger, which is why tokenized cash matters to tokenized securities. NAV Net asset value 24 The value of a fund's assets less its liabilities, expressed per unit. It is the reference price for subscriptions and redemptions and is struck on a defined schedule by, or under the oversight of, the fund's administrator and depositary. Tokenization does not change how NAV is calculated. mNAV Market-to-NAV 25 The ratio of a vehicle's traded market price to its net asset value. Above one, the market pays a premium; below one, a discount. It is the standard measure applied to listed vehicles and to digital asset treasury companies whose holdings have independently observable prices. Digital asset treasury 26 A treasury function that holds, manages and deploys digital assets under defined policy: custody arrangements, counterparty limits, liquidity ladders, valuation and reporting. It is a balance-sheet discipline rather than a product, and its credibility rests on the custody and control framework beneath it. ERC-3643 27 An open token standard for permissioned securities on EVM-compatible chains. Transfers are validated against on-chain identity and compliance rules before they execute, so eligibility is enforced by the token itself rather than by a party reviewing transfers after they have already settled. Permissioned transfer 28 A transfer that executes only if the receiving party satisfies encoded conditions: verified identity, jurisdiction, investor category, holding period or holder limits. It is how securities-law restrictions survive on a public ledger, and it is the mechanism that lets a tokenized security be transferable and restricted at once. Whitelisting 29 Recording the addresses that have passed identity, sanctions and eligibility checks so that they may hold or receive a given token. The whitelist is the operational expression of investor-eligibility rules, and maintaining it is a continuing obligation rather than a one-off onboarding step. On-chain register 30 The ledger record treated as the register of holders of a security or fund. Its value is that ownership is continuously reconcilable rather than reconstructed periodically from several sets of books. Legal recognition of such a register depends on national law, which still varies across member states. Related How does fund tokenization work in Europe? Legal wrapper, manager, register, transfer restrictions and settlement, end to end. Learn: how tokenization actually works in Europe Every explainer, grouped by subject. COSIMO Digital regulatory authorisations and their exact status Licensed, registered, and in process, stated precisely. COSIMO Digital The institutions now entering tokenization need licensed rails they do not have time to build. We operate them. Make an inquiry Explore the platform Sources Regulation (EU) 2023/1114 (MiCA); Directive 2014/65/EU (MiFID II); Directive 2011/61/EU (AIFMD); Directive 2009/65/EC (UCITS); Regulation (EU) 909/2014 (CSDR); Regulation (EU) 2022/858 (DLT Pilot Regime) — EU Official Journal. European Securities and Markets Authority, guidance and Q&As on MiCA and MiFID II classification. Financial Action Task Force standards on virtual assets and virtual asset service providers. This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. 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