Guides
Tokenization regulation by jurisdiction, 2026
Tokenized securities are legal in all twelve markets below, under the securities law each already has. What changes from one country to the next is the regulator, the exemption a private company raises under, and who it may sell to. The table puts the twelve side by side; each row opens the full guide. Written for the person who has to make the decision, not for a regulator.
12 jurisdictions · 8 procedures · table updated · nothing gated
One table
Tokenization regulation in twelve jurisdictions, side by side.
The route a private company raises under, not every route there is. Each row summarises its guide; the guide carries the sources and the detail.
| Jurisdiction | Legal basis | Regulator | Private-company route | Who it reaches |
|---|---|---|---|---|
| United States | Existing securities law; SEC staff statement, 28 Jan 2026 | SEC, FINRA | Reg D 506(c), with Reg S alongside; Reg CF to $5M; Reg A+ to $75M | Accredited investors under 506(c); retail through Reg CF or Reg A+ |
| European Union | MiFID II and the Prospectus Regulation; MiCA does not cover securities | National authorities, under ESMA guidelines | Prospectus exemptions: under €12M, qualified investors, fewer than 150 per state, €100K tickets; ECSP to €5M | Qualified investors; retail with a prospectus that passports EU-wide |
| United Kingdom | FSMA specified investments; POATRs since 19 Jan 2026 | FCA; Bank of England for the sandbox | Private placement to professional, high-net-worth and sophisticated investors | Retail through authorised Public Offer Platforms; every promotion clears s21 |
| Germany | Electronic Securities Act (eWpG), 2021; shares since 1 Nov 2025 | BaFin | EU exemptions, or the €8M small offer with an information sheet | Qualified investors; retail with BaFin-approved disclosure |
| Switzerland | DLT Act, 2021: ledger-based securities (CO art. 973d) | FINMA | FinSA exemptions: professional clients, under 500 investors, under CHF 8M, CHF 100K tickets | Professional clients; public offers with a FinSA prospectus |
| Liechtenstein | TVTG (Blockchain Act), 2020, plus the EU Prospectus Regulation | FMA | EU exemptions, or the €8M national threshold | An FMA-approved prospectus passports to all 30 EEA states |
| Luxembourg | Blockchain Laws I–IV, 2019–2024 | CSSF | EU Prospectus Regulation with the €8M threshold; securitisation compartments | Professional investors; retail with a prospectus |
| Singapore | SFA and FAA; MAS tokenisation guide, Nov 2025 | MAS | Small offer to S$5M, private placement to 50 persons, or institutional and accredited offers | Accredited and institutional investors |
| Hong Kong | SFO, applied see-through; SFC circular, Nov 2023 | SFC, HKMA | Placement to professional investors under the CWUMPO safe harbours | Professional investors; retail for SFC-authorised products |
| United Arab Emirates | VARA ARVA regime (May 2025), DFSA Investment Tokens, FSRA digital securities, federal CMA | VARA, DFSA, FSRA, CMA | Set by the zone: each route is its own licence | Set by the route; mutual recognition is not passporting |
| British Virgin Islands | FSC token guidance since 2020; SIBA; VASP Act 2022 | FSC | Issuer domicile: private placement to non-BVI investors under their own rules | Whoever the investors’ own rules allow |
| Cayman Islands | Mutual Funds, Private Funds and VASP Amendment Acts, 24 Mar 2026 | CIMA | A tokenized fund registered with CIMA | Fund investors; US$100K minimum in most open-ended funds |
Scroll the table sideways for all five columns.
Table updated . General information, not legal, tax or investment advice. Stobox is not a broker-dealer, investment adviser, custodian or law firm; your counsel picks the route.
Jurisdictions
Tokenization in the United States
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1 min readTokenization in the European Union
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1 min readTokenization in the United Kingdom
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1 min readTokenization in Germany
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1 min readTokenization in Switzerland
Switzerland didn't adapt old law to tokens – it wrote tokens into the law. Since 2021, a Swiss company can issue shares that exist natively on a…
1 min readTokenization in Liechtenstein
Liechtenstein built the legal scaffolding for tokenization before almost anyone – its 2020 Blockchain Act gives a token a statutory civil-law basis…
1 min readTokenization in Luxembourg
Luxembourg legislated tokenization four times before most jurisdictions did it once. Blockchain Laws I–IV (2019–2024) made natively digital…
1 min readTokenization in Singapore
Singapore has done more institutional tokenization groundwork than almost anywhere – Project Guardian put forty-plus global banks through live…
1 min readTokenization in Hong Kong
Hong Kong made an early, deliberate bet on tokenization – and backed it with its own balance sheet, issuing the world's first government tokenized…
1 min readTokenization in the United Arab Emirates
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1 min readTokenization in the British Virgin Islands
The BVI plays a different role from every other guide in this series: it is not an investor market – it is the world's default issuer domicile. Some…
1 min readTokenization in the Cayman Islands
On March 24, 2026 the Cayman Islands did something no major fund domicile had done: it wrote tokenized funds into statute. Digital equity and…
1 min readProcedures
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1 min readThe regulatory changelog
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1 min read
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