How it works today
The record sits with CDP.
CDP alone maintains the record, so every party settles through CDP.
Prying Power & Control
Tokenised shares in Singapore: Faster settlement, new risks, what changes
Tokenisation promises to make share settlement more efficient. Today, trading a share on the Singapore Exchange (SGX) settles two business days later. The shares and the cash move together, and the cash is finalised by the Monetary Authority of Singapore (MAS), but only from 9 a.m. to 7 p.m. on weekdays. How much tokenisation improves this depends on what is tokenised and who runs the ledger.
A token is a twin, which has to be reconciled with an underlying ledger, or a native, which is the only ledger. For shares, CDP is SGX’s depository and a transfer is made by an entry in CDP’s register. Unless CDP tokenises that register, every other party still deals with CDP and not with a shared ledger. The same holds for the cash, which stays with MAS unless MAS tokenises it.
Instant settlement is the prize, and it has a price. Swapping the shares and the cash in one step needs both in place at each trade, and a shared ledger takes more coordination to maintain. In return, cash and shares sit idle for less time. Singapore has run several tokenisation efforts. SGX’s 2020 bond pilot recorded proof of ownership on an SGX operated ledger, and MAS is trialling the issuance of tokenised MAS Bills in 2026. This piece sets out what tokenising shares would speed up, what it would put at risk and what stays the same.
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T+2settlement cycle
Business days from trade to settlement on SGX’s main market, the baseline for every path
SGX-ST Rule 9.2.1 4 Nov 2026
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2runs a day
Settlement runs at CDP, at 10.00 a.m. and 1.30 p.m. on the value date
CDP disclosure 30 Jun 2023
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10hours, weekday only
Singapore dollar cash settles in MEPS+, the central bank’s payment system, from 9 a.m. to 7 p.m.
MEPS+ disclosure 9 May 2016
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1.5morders
Fund orders processed in 2025, says Marketnode, a tokenised fund platform 37.3% held by SGX Group
Digital assets: Twin vs native
A twin reconciles with another ledger, a native is the only one.
Shown for shares The diagrams below show the share leg of a trade at CDP. The cash leg follows the same test.
Twin
Reconciles with another ledger.
Holders maintain the share token, but it settles through the broker’s link to CDP.
Native
The only ledger.
Every party maintains the share token directly.
How it works today
The record sits with CDP.
For a share held at CDP, the Singapore Exchange’s central depository, a transfer is made by CDP making an entry in its Depository Register. CDP novates trades between clearing members and settles their cash through settlement banks, so the other parties settle against CDP.
- Only CDP writes the record. The diagram shows that write path.
- What reading access brokers and banks have to the register is not publicly described.
Where it is seen
- SGX and CDPSingapore, every listed share
Twin
Reconciles with another ledger.
The US market infrastructure group DTCC calls it a digital record that represents an asset whose official record is kept somewhere else, and not a second ownership claim. The Guardian fixed income group, a Singapore industry group, describes securities issued and held in the traditional way, then represented by tokens. For a share at CDP, the official ledger stays CDP’s register, so the share token’s ledger and CDP’s register have to be reconciled.
- A broker issues the share token, and the investor and the broker both maintain the shared ledger it lives on. A bank, a custodian or a depository can issue a twin too.
- CDP does not see the share token. The shares behind it stay in the broker’s sub-account, where the Securities and Futures Act deems the agent a bare trustee for its sub-account holders.
- A transfer of the shares themselves is made by an entry in CDP’s register, so the share token settles through the broker’s link to CDP. That follows from the Securities and Futures Act. CDP recognising a share token is not described anywhere.
- When a depository issues the twin, as DTC (the US central securities depository, part of DTCC) does, it sits on the token network itself and keeps the official books and records.
The Bermuda Monetary Authority says twins introduce intermediary and credit risk and need ongoing reconciliation between the token and the asset.
Who uses the terms
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DTCCUS post-trade infrastructure group, glossary defines both - MAS GuardianIndustry group run by Singapore’s regulator, fixed income framework defines both
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Bermuda Monetary AuthorityBermuda’s financial regulator, uses both terms for operations and not as legal definitions
Where it is seen
- DTC tokenization serviceUnited States, live
The definitions are DTCC’s and the Guardian group’s. Who has to change under each is reasoning, and no published rule states it.
Native
The only ledger.
The US market infrastructure group DTCC calls it an asset whose main record is the token itself, with no other system of record behind it, so there is no other ledger to reconcile with. The Guardian fixed income group, a Singapore industry group, describes securities issued and held natively as tokens. If CDP’s own record became a share token, every broker, clearing member and settlement bank would connect to it.
- In the direct design, every party maintains the share token itself. Whether the others connect directly or through an operator is a design choice.
- Each holder has a wallet, its own account on the token network, controlled by a key pair. Wallet and account mean the same thing here, and each platform uses its own word. In the Ubin prototype each trader held accounts and key pairs on the ledgers, at Euroclear participants hold the notes in wallets on the platform, and at DTC tokens move between wallets that participants have registered, while DTC keeps the official books.
- It is not described for CDP.
The Bermuda Monetary Authority says natives reduce intermediary risk but rely entirely on the integrity of the underlying system and its governance.
Who uses the terms
- DTCCUS post-trade infrastructure group, glossary defines both
- MAS GuardianIndustry group run by Singapore’s regulator, fixed income framework defines both
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EuroclearEuropean settlement group, calls its notes Digital Native Notes - Bermuda Monetary AuthorityBermuda’s financial regulator, uses both terms for operations and not as legal definitions
Where it is seen
- Euroclear D-FMIEurope, live, bonds
- SGX digital bondsSingapore, 2020 pilot and 2022 channel
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Swiss lawLedger-based securities -
German lawElectronic securities
The definitions are DTCC’s and the Guardian group’s. Who has to change under each is reasoning, and no published rule states it.
How tokenisation changes the flow
Shares and cash can settle in one step, but only if both legs are tokenised.
1Initiation2Clearing3Settlement
Today
The share token is a twin, reconciled with a ledger kept elsewhere
The share token is a native, the only ledger
ABuy into a CDP account
Expand to read the labels.
What to know
Buy into a CDP account
The exchange matches the order on the trade date, and CDP posts the cash and the shares together two business days later.
When it happens
- Trade date
- T order matched, trade novated
- Settlement
- T+2 two business days later, in the 10:00 and 13:30 runs
- Cash
- SGD finalised in MEPS+
Key facts
- CDP novates the trade between two clearing members, so it faces each side.
- Money settles on a net basis and securities on a gross basis, conditionally and simultaneously, so neither leg is final without the other.
- Singapore dollars are settled and finalised in MEPS+, the central bank’s payment system, through eight settlement banks. CDP collects and distributes the funds among those banks, so the net cash owed to sellers goes out the same way. The payments stack covers how MEPS+ fits with the other rails.
- For a share held at CDP, the Act says a transfer is made by an entry in CDP’s register, and CDP holds the securities as a bare trustee for depositors.
Not in the public record How and when the investor funds the broker is set by the broker’s own terms. The public CDP rules start at the clearing member.
What is not publicly stated (1)
- How and when the investor funds the broker is set by the broker’s own terms. The public CDP rules start at the clearing member. CDP, Making CDP Transparent for Market Participants, December 2023
BA broker issues a share token for its CDP holdingIllustration
Expand to read the labels.
Twin, an illustration
A broker issues a share token for its CDP holding
One firm tokenises a holding it already keeps at CDP, so the share token is a twin of a share the firm holds. The trade clears and settles at CDP as today, and no other broker, clearing member or bank has to change.
What changes What the investor holdsA claim on the issuing firm
What does not The exchangeCDP and its registerSettlement banksMEPS+T+2
Key facts
- A depository agent is already deemed a bare trustee for its sub-account holders, so a broker’s customer already holds a claim on the broker and not a name on CDP’s register.
- DTCC defines a digital twin as a record on a ledger that represents an asset held on another system of record, and says it is not a duplicate ownership claim.
- MAS says tokenised and non-tokenised products follow the principle of same activity, same risk, same regulatory outcome, and asks issuers to say whether the share token confers legal or beneficial title.
- ASX’s working group warns that wrapper products may separate investors from direct legal ownership.
- That the trade is unchanged for everyone else follows from the share token sitting on top of CDP’s record. That is reasoning, and SGX has not published it.
Not in the public record Whether a broker in Singapore could issue such a token for an SGX-listed share, and on what terms. None has been announced.
What is not publicly stated (1)
- Whether a broker in Singapore could issue such a token for an SGX-listed share, and on what terms. None has been announced. MAS, Guide on the Tokenisation of Capital Markets Products, 14 Nov 2025
Sources (4)
Securities and Futures Act, section 81SI, read 4 Nov 2026DTCC, Tokenization Hub and glossary, read 4 Nov 2026MAS, Guide on the Tokenisation of Capital Markets Products, 14 Nov 2025, read 4 Nov 2026ASX Tokenisation Working Group, cash equities workshop summary, 14 Oct 2026, read 4 Nov 2026CDTC mints securities tokens against securities it holds (US, live)
Expand to read the labels.
Twin, live in the United States
DTC mints securities tokens against securities it holds (US, live)
DTC is itself the US central securities depository, and the securities token is still a twin. What decides it is where the official record sits, and at DTC that stays in its book-entry books. Holders can convert the securities token back, which is a conversion and not a trade.
Where it exists
- Launched
- 28 Oct 2026 live, 20 participants signed
- Networks
- 1 or 2 Canton, and DTCC’s private Besu network, which DTCC’s pages show as live and as due in 2027
Key facts
- Each securities token is 1:1 backed by securities held at DTC, and DTCC says its official books and records remain with DTC.
- Conversion orders run from 2 a.m. to 6 p.m. ET on business days, targeting 15 minutes or less, and securities tokens move peer to peer around the clock between registered wallets.
- Every wallet has to be registered. Only DTC participants may register wallets, DTC screens each one for sanctions, and the tokens can only be transferred to registered wallets. A participant can register a wallet for a customer and even give the customer the keys, but DTC recognises only the participant as the holder, so a holder outside the participants does not hold directly.
- The service is voluntary and runs under an SEC no-action letter for a three year period, for Russell 1000 stocks, index ETFs and Treasuries.
- DTCC’s roadmap from 2027 lists a consolidated stock record across book-entry and on-chain positions, and on-chain netting and digital cash.
Not in the public record How the securities token and the DTC record are reconciled in detail. DTCC’s pages do not say. DTCC’s own pages also give two counts for the securities at launch, 34 and 25.
What is not publicly stated (1)
- How the securities token and the DTC record are reconciled in detail. DTCC’s pages do not say. DTCC’s own pages also give two counts for the securities at launch, 34 and 25. DTCC Tokenization Service, scope at launch and what’s next
DCDP tokenises its own register, with cash tokensIllustration
Expand to read the labels.
Native, an illustration
CDP tokenises its own register, with cash tokens
CDP is the record that every broker, clearing member and settlement bank settles against. If CDP tokenised its own register, the share token would be the share and its register entry, a native, and every one of their flows would change. This is an illustration for listed shares.
Who would have to change Every brokerEvery clearing memberEvery settlement bankMEPS+ cash settlement
Where it exists
- Listed shares on SGX
- T+2 no tokenised settlement found
- Singapore bonds
- 2020, 2022 digital issuance on a ledger
- Europe, Pontes
- Sep 2026 cash leg only, in central bank money
Key facts
- For a share held at CDP, the Act says a transfer must be made by an entry in CDP’s Depository Register. In this design the ledger entry is that register.
- CDP novates trades between clearing members and settles cash through eight settlement banks, so a change at CDP reaches each of them.
- SGX has done this for bonds. Its 2020 digital bond platform recorded proof of ownership on an SGX operated ledger, and CDP took digital debt issuance in 2022. It has not announced the same for listed shares.
- The cash token can come from a bank or from the central bank. The Guardian fixed income paper lists wholesale CBDC tokens, tokenised bank liabilities and regulated stablecoins as settlement assets, MAS’s tokenised bill trial settles in wholesale CBDC, and BLOOM works on tokenised deposits and stablecoins. With a tokenised deposit the bank keeps the money and owes it as a cash token. With wholesale CBDC the bank swaps part of its central bank balance for the cash tokens. By the same test as the shares, a tokenised deposit is a twin of the bank’s books, and wholesale CBDC or a regulated stablecoin is a native.
- In Europe, the Eurosystem’s Pontes lets market participants settle with cash tokens on the Eurosystem platform or in T2, the Eurosystem’s large-payment system. That cash is central bank money, and the cash tokens represent balances in T2, where final settlement of the cash leg happens once the matching T2 transaction completes, so they are twins of those balances.
- The swap in one step is what the BIS calls atomic settlement. The Guardian fixed income group says that across different networks, settlement finality has to be assessed case by case.
Not in the public record Whether the Act would let a share token be the register entry for a listed share, who would run the ledger, and what it would mean for finality and for the cash leg.
What is not publicly stated (1)
- Whether the Act would let a share token be the register entry for a listed share, who would run the ledger, and what it would mean for finality and for the cash leg. Securities and Futures Act, section 81SM
Sources (7)
Securities and Futures Act, section 81SM, read 4 Nov 2026CDP, Making CDP Transparent for Market Participants, December 2023, read 2 Nov 2026SGX, Digital Asset Issuance Platform diagram, 2020, read 4 Nov 2026SGX, CDP makes available Marketnode’s direct-to-depository service, 1 Jun 2022, read 4 Nov 2026ECB, Pontes, read 4 Nov 2026BIS Annual Economic Report 2025, chapter III, read 4 Nov 2026Guardian Fixed Income Framework, version 1.1, November 2025, read 4 Nov 2026ECDP tokenises its own register, cash stays in MEPS+Illustration
Expand to read the labels.
Native, an illustration
CDP tokenises its own register, cash stays in MEPS+
The share record at CDP becomes a token, and the cash does not. Singapore dollars still settle through the settlement banks and MEPS+, so the banks and the central bank do not change.
What changes The register at CDPEvery brokerEvery clearing member
What does not Settlement banksMEPS+The cash leg
Key facts
- For a share held at CDP, the Act says a transfer must be made by an entry in CDP’s Depository Register. In this design the share token is that register.
- Singapore dollars are settled and finalised in MEPS+ through eight settlement banks, and that stays as it is.
- Others keep the cash on the traditional side. At Euroclear, securities and cash move to the traditional platform for secondary trading, and Pontes lets market participants settle with cash tokens on the Eurosystem platform or in T2.
- The cash and the shares have to stay tied, so neither is final without the other. The BIS calls a swap in one step atomic settlement.
Not in the public record How CDP would link a share ledger to MEPS+ so the two legs stay delivery versus payment is not publicly stated.
What is not publicly stated (1)
- How CDP would link a share ledger to MEPS+ so the two legs stay delivery versus payment is not publicly stated. CDP, Making CDP Transparent for Market Participants, December 2023
FSGX digital bond platform (Singapore, 2020 pilot)
Expand to read the labels.
Native, Singapore, a 2020 pilot
SGX digital bond platform (Singapore, 2020 pilot)
SGX ran a digital bond on a ledger it operated, so the proof of ownership was recorded there. It was a pilot for primary issuance, a bond sale and not a trade on the exchange.
Where it exists
- Pilot
- Sep 2020 the Olam bond, on an SGX platform
- CDP channel
- Jun 2022 for debt issuers, first deal by OCBC
Key facts
- SGX’s platform replicated a S$400 million bond issue and a S$100 million tap for Olam International, with HSBC and Temasek.
- SGX’s diagram shows an atomic transfer of assets and proceeds, and proof of ownership recorded on an SGX operated ledger.
- SGX says the pilot cut primary issuance settlement from 5 days to 2 days and automated registrar functionality.
- In 2022, CDP made Marketnode’s platform available to debt issuers, connecting them into CDP, with OCBC’s US$100 million Euro Commercial Paper as the first deal.
Not in the public record What triggers the atomic transfer, and how investors fund the cash side before it. Whether the ledger entry is the legal register for the bonds, and whether the same would be allowed for listed shares.
What is not publicly stated (1)
- What triggers the atomic transfer, and how investors fund the cash side before it. Whether the ledger entry is the legal register for the bonds, and whether the same would be allowed for listed shares. SGX, Digital Asset Issuance Platform diagram, 2020
GUbin, a swap across two ledgers (Singapore, 2018 prototype)
Expand to read the labels.
Two ledgers, Singapore, a 2018 prototype
Ubin, a swap across two ledgers (Singapore, 2018 prototype)
MAS and SGX tested a swap between a cash ledger and a securities ledger for government securities, with a hash lock tying the two legs together.
Where it exists
- Prototype
- 2018 concluded 11 Nov 2018, not a live service
Key facts
- The project tested tokenised Singapore Government Securities against digital SGD on separate ledgers, on prototypes built on Quorum, Hyperledger Fabric, Ethereum, Anquan and Chain. The cash was central bank-issued cash-depository receipts, receipts for Singapore dollars held at MAS, so a twin of that cash.
- A secret and its hash tie the legs together. The seller locks securities and the buyer locks cash, each with a timeout, and revealing the secret to claim the cash lets the buyer claim the securities.
- The recognised market operator keeps a central role, overseeing both ledgers and able to act as arbitrator.
- MAS and SGX said the prototypes showed simultaneous exchange and final settlement on different blockchain platforms.
Not in the public record How each side learns that the other’s lock is confirmed. Both have access to the ledgers, and no alert is described. How clearing would work, and whether the securities ledger would be the legal register, is also not publicly stated.
What is not publicly stated (1)
- How each side learns that the other’s lock is confirmed. Both have access to the ledgers, and no alert is described. How clearing would work, and whether the securities ledger would be the legal register, is also not publicly stated. MAS and SGX, Project Ubin, Delivery versus Payment on Distributed Ledger Technologies, 2018
HEuroclear D-FMI (Europe, live)
Expand to read the labels.
Native, live in Europe
Euroclear D-FMI (Europe, live)
Euroclear runs a ledger component for issuance. The notes are issued on it, held in wallets there, and moved to the traditional platform for secondary trading.
Where it exists
- Instruments
- Notes digital Euro Medium Term Notes
- Settlement
- DvP in euro or US dollars
Key facts
- Euroclear issues Digital Native Notes on D-FMI, and participants hold them in securities wallets on the ledger.
- The distribution settles delivery versus payment in euro or US dollars, then the securities and cash move to the traditional platform for secondary trading.
- Euroclear says D-FMI is integrated with Euroclear Bank, which gives it compliance with the CSD Regulation, and that issuance, distribution and secondary activity all settle on the same day.
- On 7 November 2024, a EUR 100 million note by Caisse des Dépôts was issued on D-FMI and settled through Banque de France’s DL3S platform for digital currency. The Banque de France said that its DLT solution for settling the cash leg of this issuance stresses the importance of tokenised Central Bank Money. It was part of the ECB’s trials, so both legs were on ledgers.
Not in the public record Which record is the legal register once the notes move to the traditional platform, and whether they stay tokens there. Whether a participant’s securities wallet is self-hosted or has to be approved first. Euroclear’s page does not say.
What is not publicly stated (1)
- Which record is the legal register once the notes move to the traditional platform, and whether they stay tokens there. Whether a participant’s securities wallet is self-hosted or has to be approved first. Euroclear’s page does not say. Euroclear, D-FMI
The benefits and costs of tokenisation
Tokenisation could speed up settlement, but it adds new risks and new coordination.
Who changes, and when
Risk and money
Records and holdings
Reach
Who has to change
A twin touches the parties that agree to use its ledger, and the holders. A change at CDP touches everyone who settles there.
Touched if CDP changes
- Every broker
- Every clearing member
- Every settlement bank
- Every other participant
- Cash settlement in MEPS+
A twin
- − Analysis The parties that agree to use the ledger build and run it, and share the cost.
- − Analysis Each of those parties has to stay connected to CDP, where the share is held, to reconcile the shared ledger with CDP’s record.
- = Analysis Parties that are not on the ledger, and CDP, carry on as today.
- = DTCC describes its service as keeping liquidity in traditional markets while expanding it through the tokenized service, with holders able to convert between the two forms.
A native
- + Analysis Every clearing member would work from the same ledger, so there is one record and no reconciling between separate databases.
- − Every clearing member would have to connect, each with its own permissions, because CDP novates trades between clearing members.
- − Analysis Brokers, depository agents and every other party that deals with CDP would need to connect. Anyone going through CDP could stay as they are, but would rely on CDP to carry out its instructions and read the ledger.
- − Every settlement bank and the payment leg would be touched, because CDP settles cash through eight settlement banks and MEPS+, the interbank payment system run by MAS.
- → Analysis CDP becomes counterparty only if the relevant conditions for novation are met, and a novation cannot be revoked or modified. A ledger could keep that order. A member writes the trade, it stays pending, and CDP confirms it once the conditions are met. How CDP would do this is not stated.
Not publicly stated Whether CDP or SGX plans any change.
Timing
When the trade settles, and at what hours
Tokenised shares are meant to shorten the lag between trade and settlement, and the cash, the trade’s other leg, has to speed up in parallel. A twin leaves CDP’s settlement as it is, with both legs at T+2 in its 10.00 a.m. and 1.30 p.m. runs, though its parties could transfer the share token among themselves sooner. A native could settle both legs together on the trade date, if the cash is tokenised too.
A twin
- + Analysis Parties on the ledger could transfer the share token among themselves on their own rules, without waiting for CDP’s runs, while the share stays at CDP.
- = A twin leaves CDP’s settlement as it is. Settlement stays at CDP, where the cash is final upon CDP debiting or crediting the cash ledger account, and Singapore dollars are settled and finalised in MEPS+, the interbank payment system run by MAS.
- = So the trade still settles at T+2, in an intraday run at 10.00 a.m. and a final run at 1.30 p.m. on the value date.
A native
- + Analysis Tokenised shares can cut the lag between trade and settlement. With cash on the same ledger, both legs could swap in one step at the trade, so settlement could be near instant.
- + The ECB plans immediate settlement finality as early as 2027 on Pontes.
- + The ECB plans longer Pontes hours by mid-2027 and round the clock availability in 2028, beyond fixed daily runs.
- + Europe moves to T+1 on 11 October 2027, and the ECB says T2S, the Eurosystem’s securities settlement platform, already settles substantial volumes at T+1 and even T+0.
- → Analysis Faster shares are not enough, because the cash has to move too. Cash in MEPS+ settles instantly and irrevocably if the paying bank has enough funds in its account, but only on weekdays from 9.00 a.m. to 7.00 p.m., excluding public holidays. A cash token on the ledger would remove that limit.
Not publicly stated A date for any tokenised settlement of an SGX-listed share, whether it would run outside CDP’s 10.00 a.m. and 1.30 p.m. runs, and whether a transfer inside a twin’s group has any effect at CDP.
Both legs
Why neither leg settles alone
A trade has two legs, the shares and the cash. Simultaneous settlement means neither leg is final without the other, which is delivery versus payment. Today CDP enforces settlement in each run, and a ledger could settle both legs automatically in one transfer, under rules the group agreed, visible to everyone on it. The cash leg settles in MEPS+, the interbank payment system run by MAS.
A twin
- = CDP settles securities and money conditionally and simultaneously in each run on its own ledger, and a twin’s share token still depends on the share CDP holds.
- = CDP still enforces settlement. Once all payments are received by CDP, it will conduct securities and cash settlement simultaneously.
- = Analysis The parties on the ledger can see the share token move, but the share still settles only when CDP acts.
A native
- + A ledger could settle both legs in one step. The BIS defines atomic settlement as a synchronous exchange in which each asset transfers only when the others do, and says it can mitigate principal risk.
- + Pontes runs delivery versus payment and other all-or-none transactions through the Hash-Link protocol.
- + Analysis The ledger settles automatically under rules the group agreed, so no single party has to trigger each leg. Each participant can do only what the group has pre-approved, and everyone on it sees the same state.
- = Analysis The guarantee stays the same, and only the mechanism differs.
- → Analysis Cash in MEPS+, the MAS interbank payment system, would need a link to the ledger to settle simultaneously, or the cash would have to be a token on the ledger.
- → Analysis Only parties on the ledger would see that state. Anyone going through CDP would still rely on CDP to show it.
- → Pontes shows both routes. It lets market participants settle with cash tokens on the Eurosystem platform or in T2, the Eurosystem’s large-payment system, so the cash can stay in the existing system with only the securities on the ledger.
Not publicly stated How a share ledger at CDP would settle simultaneously with cash settled in MEPS+, and who would run and govern it.
Liquidity
What it takes to settle
Today CDP settles in batches. The cash is netted, so each net payer’s bank sends only the difference to CDP before the run, and the shares are reserved for it. Instant settlement handles each trade as it happens, so cash and shares must be in place at that moment, but they sit idle for less time.
A twin
- + Analysis Parties on the shared ledger could move and reuse the share token among themselves under their own arrangements, even with cash on traditional rails, so shares sit idle for less time. A cash token of their own would let them swap both legs at once and free their cash sooner too.
- = Today CDP settles money on a net basis and securities on a gross basis, so a twin leaves cash and share needs as they are.
A native
- + Analysis Cash and shares sit idle for less time. Today shares are ear-marked and reserved for that settlement run, so settling at the trade releases them and the cash sooner and cuts the cost of tying them up.
- + A ledger could still net. The Guardian fixed income paper says DLT does not necessitate a gross settlement model and could support deferred or real-time atomic net settlement, that is, holding trades and netting them in batches, or netting continuously as they arrive.
- − Analysis Instant settlement needs both legs tokenised, the shares and the cash, and both in place at the moment of each trade. Today they only have to be ready when the batch runs.
- − Losing netting would be costly. DTCC says multilateral netting cuts equities payment obligations by 98 percent on average.
- → Analysis Someone has to supply the cash and shares in time, through intraday credit, repo or prefunding.
- → In MEPS+, banks move funds from their MAS current accounts to their payment accounts before the day starts, and MAS offers an interest-free intraday liquidity facility against eligible collateral.
Not publicly stated How much more liquidity a tokenised settlement of SGX shares would need.
Counterparty risk
If the other side fails
Today CDP stands between buyer and seller, backed by margin and a Clearing Fund. The risk that the other side fails shrinks with the gap between trade and settlement.
A twin
- − The Bermuda Monetary Authority says twins introduce intermediary and credit risk and need ongoing reconciliation between the token and the asset.
- − Analysis If the shared ledger strays from CDP’s record, share token holders depend on the parties on the ledger to realign it. How those parties share that liability is not stated.
- − Analysis If the group settles against a cash token of its own, that adds a new settlement asset and a new party to trust, depending on who issues it.
- = CDP becomes the buyer to each seller and the seller to each buyer in every trade, so each side depends on CDP and not on the other. A twin leaves that in place.
- = Analysis CDP’s own failure risk stays. Every trade runs through CDP, so its failure, however unlikely, would reach all of them, and a twin does not change that.
- = CDP requires variation and maintenance margin for all outstanding trades, and its Clearing Fund, a pool of contributions from CDP and Clearing Members, is sized to cover the default of the Clearing Member that is responsible for CDP’s largest credit exposure, its affiliates, and the two financially weakest Clearing Members.
A native
- + Cutting the gap cuts the risk. The BIS says the gap between trade and settlement, which can take up to two business days, exposes parties to replacement cost risk.
- + The Guardian fixed income paper says DLT-based settlement can mitigate replacement cost risk by cutting the delay between trade and settlement.
- + The Bermuda Monetary Authority says natives reduce intermediary risk.
- + MAS is trialling tokenised MAS Bills in 2026, settled using wholesale CBDC on the SGD Testnet, so the cash token is central bank money, for institutional investors only. It is a trial, not a listed share.
- − Analysis A cash token adds a new settlement asset and a new party to trust, depending on who issues it.
- = Analysis If CDP stays the counterparty to every trade, its own failure risk stays too, however unlikely.
- = Analysis If CDP keeps its own register on a ledger, the share token carries the same rights and only the format of the record changes, so CDP would likely still novate trades and apply margin and the Clearing Fund.
- = Analysis A shorter gap leaves less exposure to cover, but anything left unsettled would still need margin and a Clearing Fund.
- → The cash asset has to be chosen. The Guardian fixed income paper lists wholesale CBDC tokens, tokenised bank liabilities and regulated stablecoins as settlement assets that will coexist, and MAS’s BLOOM initiative works on settlement in tokenised deposits and regulated stablecoins. The rules for stablecoins are in Singapore digital asset regulation.
Not publicly stated Whether CDP would confirm that it still novates trades if its register ran on a ledger, and how the parties on a twin ledger share liability if it strays from CDP’s record.
Register
Who holds the shares, and what protects the holder
At CDP an investor holds directly, named on CDP’s register, or through a broker custody account, where the broker is named and the investor claims through it. A twin leaves both as they are. A native could make the share token the register entry, and whose name sits on it, and which protections follow, is not publicly stated.
A twin
- − Analysis The protections of a direct account stay with the account at CDP and do not follow the share token, so a share token holder relies on the parties on the ledger.
- − The Bermuda Monetary Authority says twins need ongoing reconciliation between the token and the asset.
- − Analysis Changing the shared ledger’s rules needs the parties on it to coordinate, which is harder than one operator updating its own system.
- = A transfer of book-entry securities must be made by the Depository making an appropriate entry in its Depository Register. So a share held at CDP changes hands only when CDP updates its register, whatever the Companies Act or the issuer’s constitution says.
- = A direct account holder is named on the register, and the Act deems the persons named as depositors to be its members for the amount entered against their names. CDP calls a direct account individually segregated.
- = At DTC, tokens can only move to wallets that a participant has registered with DTC.
- = A custody client is not named. The agent is, and the Act deems it a bare trustee for its sub-account holders, meaning it holds the shares for them and does not own them. A broker must keep a separate book entry for each customer, and since 15 July 2026 a depository agent may pool clients in an omnibus sub-account.
A native
- + Analysis A holder who keeps the share token in their own wallet could stand where a direct account holder does today, named on the record and not through a broker.
- + Swiss law defines a ledger-based security as a right registered in a ledger under an agreement between the parties, and exercised and transferred only through that ledger. The holder, not the issuer, controls the right, and the ledger must be protected against unauthorised changes. The issuer sets up the ledger, so it is not open to anyone to register. Germany and the EU have similar regimes.
- + For funds, the Guardian Funds Framework describes three register forms. In the first, changes made on the ledger are not immediately authoritative in law, and in the other two the fund token is the source of truth.
- − Every party’s security policy would have to cover private keys, where today each holds its own secrets, such as API signing keys. The Guardian custody paper says safekeeping of private cryptographic keys needs special attention.
- − Analysis Changing the ledger’s rules needs the parties on it to coordinate, which is harder than one operator updating its own system.
- = Analysis Flaws in the ledger’s code are a risk in any software, with or without a ledger.
- = Analysis Keeping client assets apart from the intermediary’s own, and reconciling the records, would still be needed.
- → Analysis A share token could be the register only if the law and the issuer’s constitution say so.
- → The Guardian custody paper asks whether tokenised instruments can be held by traditional depositories or need new custody models.
- → Analysis Whether custody through a broker, with pooled omnibus holdings, would carry over to share tokens is not stated.
Not publicly stated Whether a share token could be the register for a share listed on SGX, which holder it would name, whether a token of a CDP-held share could sit in a wallet outside CDP, and whether tokenised settlement changes legal title.
More detail
What MAS asks
- MAS asks issuers of tokenised products to disclose whether the token confers legal or beneficial title, and which record is definitive of legal ownership. The guide is general reference and does not override any law. Singapore digital asset regulation sets out which rules apply to tokenised securities.
Funds in Singapore
- The Guardian paper on tokenised funds says there is no express guidance on whether a blockchain instruction can be an instrument of transfer for shares of a variable capital company.
- It also says the Electronic Transactions Act gives a blockchain register some certainty of legal effect.
- These are industry papers about funds, not law and not about listed shares.
Who is tokenising: Securities and cash
Cash and securities are tokenising on separate tracks, and no live service settles a listed share.
Existing rails The record at the depository
Twin A token of a share held elsewhere
None confirmed. DTCC lists digital cash on its roadmap for 2027 and beyond.
None confirmed.
Native The token is the share
None confirmed. Pontes links market DLT platforms and TARGET Services.
A leg is not stated
The source for each names one leg and not the other.
Where the law makes the ledger the register
A statute decides what a ledger entry is, for the securities leg only.
Expand to read every tile.
Australia, a peer exchange
ASX working group
ASX is Australia’s main stock exchange. Its tokenisation working group met on cash equities on 14 October 2026.
Why it exists
The working group brings industry participants together to discuss where tokenisation could apply to the steps after a share trade, and whether it should.
What it found
Participants did not identify an immediate priority for tokenisation across the cash equities post trade lifecycle.
Where it sits
- Securities
- Existing rails
- Cash
- Existing rails
What it represents Cash equities
Who it reaches Industry workshop
The register Not decided
When
- Study
- 14 Oct 2026 working group met on cash equities
Key facts
- Atomic settlement may suit selected transactions, but broad adoption could replace settlement risk with funding and liquidity risk.
- Wrapper products may separate investors from direct legal ownership.
- Before any model could scale, the group would need to settle the authoritative record, token issuer, legal holder, permissions, reversals and corporate-action treatment.
Not in the public record Any ASX plan for a live tokenised service.
Singapore
MAS BLOOM
BLOOM is a public and private initiative on settlement in digital money, such as tokenised deposits and regulated stablecoins. MAS, Singapore’s central bank, launched it on 16 October 2025, and Bank Negara Malaysia and the Bank of Thailand joined as policymaker members on 23 October 2026.
Why it exists
Banks and countries are building different forms of digital money. BLOOM develops common approaches for how they can be accepted, exchanged and settled across institutions, networks and jurisdictions.
Where it stands
No outcome is published yet. Participation has since grown, and the industry side now includes Airwallex, Mastercard, Maybank, Monee, Nium, Ripple, ShopeePay, Visa and the World Bank Group.
Where it sits
- Securities
- None
- Cash
- Twin and native
What it represents Tokenised depositsRegulated stablecoins
Who it reaches MASBank Negara MalaysiaBank of ThailandBanks, payment networks and technology providers
MASBank Negara MalaysiaBank of ThailandBanks, payment networks and technology providers The register Not covered
When
- Programme
- 16 Oct 2025 launched
Key facts
- It covers tokenised deposits and regulated stablecoins, and its participants include banks, payment networks and technology providers.
- It works on three areas: acceptance and settlement across jurisdictions, interoperability across digital money arrangements, and programmable controls.
- A tokenised deposit is a twin of the bank’s books, and a regulated stablecoin is a native, because the stablecoin is the record of the claim on its issuer. That is reasoning, not a published fact.
- BLOOM is about the cash side and does not cover the register of any asset.
Europe
ECB Pontes
Pontes is a European Central Bank service that links the ledgers where tokenised assets trade to the Eurosystem’s payment and settlement services, known as TARGET. That lets deals settle in central bank money, which is a claim on the central bank itself and not on a commercial bank. The Eurosystem launched Pontes on 21 September 2026.
Why it exists
Tokenised assets trade on market ledgers, while large cash payments settle in central bank money. Pontes lets wholesale transactions in tokenised assets settle in central bank money.
Where it stands
Pontes is live, and the ECB plans longer Pontes hours by mid-2027 and round the clock availability in 2028.
Where it sits
- Securities
- Set by each platform
- Cash
- Twin
What it represents Cash in central bank money
Who it reaches Onboarded banks and platforms
The register Not covered
When
- Live
- 21 Sep 2026 launched
Key facts
- Pontes links market DLT platforms and TARGET Services. Eligible platform operators include central securities depositories and operators of a DLT settlement system under the pilot regime.
- T2 is the Eurosystem’s real-time gross settlement system, where banks and central banks hold accounts and settle euro payments one by one in central bank money.
- Participants can settle the cash leg with cash tokens on the Eurosystem platform or in T2, and final settlement happens once the matching T2 transaction completes.
- The cash tokens stand for balances held in T2 accounts, and the money is final only in T2, so they are twins of those balances. That is reasoning, not a published fact.
- The ECB plans round the clock availability in 2028.
- Pontes settles the cash, and the register of each asset sits with the platform that issues it. That is reasoning, not a published fact.
Singapore
MAS wholesale CBDC trial
A wholesale central bank digital currency, or wholesale CBDC, is the central bank’s own money issued as a cash token for banks to settle with. On 13 November 2025 MAS announced the successful completion of a live trial settling interbank overnight lending in wholesale CBDC on its Singapore dollar test network, with DBS, OCBC and UOB.
Why it exists
The test network, the SGD Testnet, is a shared ledger that lets financial institutions test the settlement of tokenised assets using wholesale CBDC. The network offers a common settlement asset, programmable payments and atomic settlement of cash and securities.
What it found
The trial was completed successfully, and MAS will build on this CBDC settlement pilot with tokenised MAS Bills.
Where it sits
- Securities
- None
- Cash
- Native
What it represents Singapore dollar wholesale CBDC
Who it reaches 
DBS
OCBC
UOB
DBSOCBCUOB The register Not covered
When
- Trial
- 13 Nov 2025 trial completed
Key facts
- The trial featured the first live issuance of Singapore dollar wholesale CBDC, with transactions recorded in the banks’ official books.
- Wholesale CBDC is the central bank’s own money as the cash token, so the cash is a native. That is reasoning, not a published fact.
- The trial settled overnight lending between banks, which has no securities leg.
Not in the public record Whether Singapore dollar wholesale CBDC will settle a listed share. MAS names tokenised MAS Bills as the next trial.
United States
DTC tokenization service
DTC is the US central securities depository, the institution that holds US securities and settles trades in them, and it is part of DTCC. DTC launched the service on 28 October 2026 after an SEC no-action letter in December 2025 covering Russell 1000 stocks, index ETFs and Treasuries.
Why it exists
The service aims to keep liquidity in traditional markets while expanding it through the tokenized service, with holders able to convert between the two forms.
Where it stands
20 DTC participants have signed, and more networks, more eligible securities, digital cash and a consolidated stock record are on the roadmap for 2027 and beyond.
Where it sits
- Securities
- Twin
- Cash
- Existing rails
What it represents Securities held at DTC
Who it reaches Participants only, 20 signed
The register Official books stay at DTC
When
- Live
- 28 Oct 2026 launched
Key facts
- Tokens 1:1 backed by securities held at DTC are converted in and out through screens and an API, and moved between registered wallets around the clock.
- 20 DTC participants have signed, and the launch release says it is currently integrated with the Canton Network and DTCC’s private Besu network. The scope sheet lists Besu as anticipated in 2027, so DTCC’s pages differ on whether it is live.
- Only DTC participants may register wallets, DTC screens each one for sanctions, and the tokens can only be transferred to registered wallets. A participant can give a customer the keys, but DTC recognises only the participant as the holder.
- DTCC puts the assets available to tokenize at about US$30 trillion, out of the more than $114 trillion in assets under custody DTC holds.
- DTCC says its official books and records remain with DTC, and that its securities tokens retain the ownership rights, investor protections and economic entitlements of their traditional counterparts. Those are DTCC’s own claims.
- The cash stays on today’s rails. Treasury distributions are paid in fiat to participants’ traditional accounts, and digital cash is on the roadmap for 2027 and beyond.
Not in the public record How the securities token and the DTC record are reconciled.
Europe
Euroclear D-FMI
Euroclear is a European settlement group, and D-FMI is its regulated platform that issues bonds on a ledger. Euroclear launched its first D-FMI service on 24 October 2023. Participants hold the notes in securities wallets on the ledger, and the notes can move to the traditional platform for secondary trading.
Why it exists
The aim is to bring bond issuance onto a ledger inside a regulated depository, and D-FMI is fully integrated with Euroclear Bank, which gives it compliance with the CSD Regulation.
Where it stands
Issuance, distribution and secondary activity all settle on the same day.
Where it sits
- Securities
- Native
- Cash
- Existing rails
What it represents Digital native notes
Who it reaches Issuers and participants who opt in
The register Not stated
When
- Live
- 24 Oct 2023 first service launched
Key facts
- Digital Native Notes under Euro Medium Term Note programmes, with delivery versus payment in euro or US dollars.
- Issuance, distribution and secondary activity all settle on the same day.
- For secondary trading, securities and cash move to the traditional platform.
Not in the public record Which record is the legal register once the notes move to the traditional platform, whether they stay tokens there, and whether a participant’s securities wallet is self-hosted or has to be approved first.
Europe
Digitally native note
Caisse des Dépôts, a French public financial institution, issued a EUR 100 million note on 7 November 2024 on Euroclear’s D-FMI platform, settled through Banque de France’s DL3S platform for digital currency. Banque de France is France’s central bank.
Why it exists
What it found
The operation allowed Banque de France to enrich its connectivity solutions by setting-up a new interoperability link between the 2 DLT.
Where it sits
- Securities
- Native
- Cash
- Native
What it represents A digitally native noteTokenised central bank money
Who it reaches Caisse des DépôtsBanque de FranceEuroclear
Caisse des DépôtsBanque de FranceEuroclear The register Not stated
When
- Pilot
- 7 Nov 2024 note issued
Key facts
- The Banque de France used its own DLT solution for the cash leg, which stresses the importance of tokenised Central Bank Money.
- The link between the two platforms was co-designed by the Banque de France and Euroclear, on top of HTLC and SWIFT protocols.
- Euroclear’s Digital Native Notes are natives and tokenised central bank money is a native, so both legs sit on ledgers. That is reasoning, not a published fact.
Not in the public record Whether this became a standing service. It was a single issue.
Singapore, Guardian
Digital JPY bond repo
A repo is a short-term loan against a security, repaid with interest. On 15 November 2023 UBS, SBI and DBS announced, as part of MAS’s Project Guardian, that they had launched the world’s first live repo with a natively-issued digital bond on a public blockchain.
Why it exists
It tested whether a whole transaction could run on a public blockchain. The deal automatically and instantly settled a repo, digital bond purchase and redemption using regulated digital payment tokens, across regulated entities located in three different jurisdictions.
What it found
Where it sits
- Securities
- Native
- Cash
- Native
What it represents A digital bondTokenised yen
Who it reaches UBSSBIDBS
UBSSBIDBS The register Not stated
When
- Pilot
- 15 Nov 2023 repo announced
Key facts
- The deal borrowed tokenized Japanese yen against a yen-denominated natively-issued digital bond, and used the borrowed yen tokens to buy the same bond.
- The redemption and the payment of principal and interest were executed on-chain as well.
- Shinsei Trust & Banking was the issuer of JPY stablecoin.
- A regulated stablecoin is the record of its own claims, so the cash is a native, and so is the bond. That is reasoning, not a published fact.
Not in the public record Singapore dollar settlement. The transaction was in yen.
Singapore
MAS and SGX, Project Ubin
Project Ubin was a MAS programme to put Singapore dollars and securities on ledgers. This phase tested delivery versus payment, where the shares and the cash move only together, across separate ledgers. MAS and SGX announced on 11 November 2018 that the prototypes had worked.
Why it exists
What it found
The prototypes demonstrated the functional capabilities of three different blockchain pairs to establish an interledger DvP settlement system, and highlighted the need for an arbitrator for dispute resolution. Five areas were left for later work: rulebook integration, compression of the settlement cycle, arbitration design, enhanced security and privacy, and liquidity and market structure.
Where it sits
- Securities
- Not stated
- Cash
- Twin
What it represents Government securities and digital SGD
Who it reaches Prototype participants
The register Not stated
When
- Prototype
- 11 Nov 2018 prototypes announced
Key facts
- The prototypes exchanged tokenised Singapore Government Securities against digital SGD on separate ledgers, trade by trade.
- At the time, the current market practice on settlement cycles was T+3, and the design showed how settlement could compress to T+1 or even round-the-clock.
- The cash was central bank-issued cash-depository receipts, receipts for Singapore dollars held at MAS, so a twin of that cash.
- A hash lock tied the legs together, and the market operator kept a central role, able to act as arbitrator.
Not in the public record Whether the tokenised securities are twins or natives, and whether the securities ledger would be the legal register.
Singapore
MAS tokenised MAS Bill trial
MAS Bills are short-term bills that MAS issues. MAS is trialling the issuance of tokenised MAS Bills in 2026, settled using wholesale CBDC through the Singapore dollar test network.
Why it exists
The trial builds on MAS’s wholesale CBDC trial, after which MAS planned in a future trial to issue tokenised MAS Bills to Primary Dealers which will be settled using CBDC.
Where it stands
The trial is under way, and the page lists issues from 23 September 2026. No results are published yet.
Where it sits
- Securities
- Not stated
- Cash
- Native
What it represents Tokenised MAS Bills
Who it reaches Institutional investorsPrimary dealers, a fifth of each issue
The register Not stated
When
- Trial
- From 23 Sep 2026 first issue
Key facts
- Only institutional investors, as defined in section 4A of the Securities and Futures Act, may apply, and a primary dealer must apply for at least a fifth of each issue.
- The first three issues are on 23 September, 9 October and 6 November 2026, of S$1 million, S$10 million and S$100 million.
Not in the public record Whether the bill token is the legal bill or a representation of a bill held elsewhere, which ledger holds it, and so whether it is a twin or a native.
Switzerland
SNB Project Helvetia
Project Helvetia is the Swiss National Bank’s pilot on settling tokenised assets in central bank money. The SNB has provided wholesale CBDC on the SIX Digital Exchange trading and settlement platform since the end of 2023.
Why it exists
What it found
The SNB evaluated the project and decided to extend it for a further year, to at least mid-2027, and added a second route that settles tokenised assets with traditional central bank money.
Where it sits
- Securities
- Not stated
- Cash
- Native
What it represents Wholesale CBDC
Who it reaches 
SIX Digital ExchangeBXBX Digital
SIX Digital ExchangeBXBX Digital The register Not stated
When
- Pilot
- 2023 to 2027 wholesale CBDC from the end of 2023, pilot extended to mid-2027
Key facts
- The SNB extended the pilot until at least mid-2027, without committing to wholesale CBDC permanently.
- It also gave BX Digital a production connection to the Swiss Interbank Clearing system, to settle tokenised assets with traditional central bank money.
Not in the public record Which tokenised assets settle, and whether they are twins or natives.
Singapore
SGX and CDP, bonds
SGX is Singapore’s exchange and CDP is its central depository. SGX has run bond issuance on a ledger it operates, and CDP has taken digital debt issuance since June 2022. Both are for debt and neither is for listed shares.
Why it exists
The 2022 channel is meant as a blueprint for a digital bond infrastructure utility within a regulated securities depository. On its 2020 platform, an atomic transfer of assets and proceeds is triggered, and proof of ownership is recorded on an SGX operated ledger.
What it found
SGX says the pilot cut primary issuance settlement from 5 days to 2 days and automated registrar functionality.
Where it sits
- Securities
- Native
- Cash
- Not stated
What it represents Bonds
Who it reaches Debt issuers who opt in
The register Proof of ownership on SGX’s ledger
When
- Pilot
- 2020, 2022 Olam pilot, then the CDP channel
Key facts
- In 2020, SGX’s platform replicated a S$400 million bond issue and a S$100 million tap for Olam International.
- In 2022, CDP made Marketnode’s platform available to debt issuers, connecting them into CDP, with OCBC’s US$100 million Euro Commercial Paper as the first deal.
Not in the public record Whether the ledger entry is the legal register for those bonds, what triggers the atomic transfer, and how investors fund the cash side before it.
Singapore
Marketnode
Marketnode is a digital asset infrastructure company, a venture of SGX and Temasek in which SGX Group holds 37.3 percent. SGX and Temasek announced it on 22 January 2021. Its Fundnode service covers order routing, settlement orchestration and record-keeping for funds.
Why it exists
Marketnode uses smart contracts, ledger and tokenisation technologies for traditional capital markets products.
Where it sits
- Securities
- Not stated
- Cash
- Not stated
What it represents Fund orders
Who it reaches Fund network members
The register Not stated
When
- Venture
- 22 Jan 2021 announced
Key facts
- Marketnode processed 1,495,514 fund orders in 2025, by its own count, and that covers funds, not shares on the exchange.
Not in the public record Whether Fundnode’s records are tokens, and whether they are the legal register of the funds it handles.
Singapore
MAS Project Guardian
Project Guardian is a MAS-led sandbox where policymakers and the financial industry run trials of asset tokenisation and write frameworks. MAS launched it on 31 May 2022, and SGX Group and Euroclear are in its industry group.
Why it exists
Where it sits
- Securities
- Several
- Cash
- Several
What it represents Funds, bonds and FX
Who it reaches Trial participants
The register Forms described, for funds
When
- Programme
- 31 May 2022 launched
Key facts
- Tokenised funds, bonds, stablecoins and bank liabilities are tried across asset and wealth management, fixed income and foreign exchange.
- The fixed income framework added a settlement guide and custody lessons for DLT-based debt securities in November 2025.
- The Funds Framework describes three register forms, from a mirror of the authoritative register to a register held on the ledger.
- These are industry papers and not rules.
Not in the public record A share listed on SGX, which the Guardian papers leave out.
Switzerland, law
Ledger-based securities
Switzerland’s Code of Obligations lets a right exist as a ledger-based security, a right that exists and moves only through a securities ledger. The ledger entry is the record.
Why it exists
The rules came with the Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology, in force since 1 February 2021.
What it represents Rights recorded in a securities ledger
Who it reaches Any issuer that opts in
The register The ledger, by statute
When
- Law
- 1 Feb 2021 in force
Key facts
- A ledger-based security is a right registered in a securities ledger that may be exercised and transferred only via that ledger (Article 973d).
- The ledger must give creditors the power of disposal, protect its integrity, record the content of the rights, and let creditors check entries (Article 973d).
- The obligor must perform only to the creditor shown in the ledger, and an acquirer in good faith is protected (Article 973e).
- The English text is a Fedlex translation, which carries no legal force.
Germany, law
Electronic securities act
German law lets an issuer create a security by an entry in an electronic register instead of a paper certificate, and lets that register run on a ledger.
Why it exists
Before the Act, a security needed a certificate. The Act lets an issuer issue a security by making an entry in an electronic securities register instead of issuing a certificate.
What it represents Electronic securities
Who it reaches Issuers that opt in
The register A register on a tamper-proof system
When
- Law
- 10 Jun 2021 in force
Key facts
- The electronic security has the same legal effect as one issued on paper (section 2).
- A crypto securities register must run on a forgery-proof recording system that logs data in time order and protects it against unauthorised deletion or later change (section 16).
- The Act is in German, so these descriptions are paraphrases.
Europe, law
EU DLT Pilot Regime
EU law lets a settlement system record and settle instruments on a ledger, as a capped pilot. It is the clearest case of shares on a ledger as the primary record, and it is bounded.
Why it exists
The Regulation sets up a pilot regime for market infrastructures based on distributed ledger technology, so trading and settling on a ledger can be tested within limits.
What it represents Shares, bonds and fund units
Who it reaches Capped pilot venues
The register Recorded on the ledger, within caps
When
- Law
- 23 Mar 2023 applies from
Key facts
- A DLT financial instrument is one issued, recorded, transferred and stored using distributed ledger technology.
- A DLT settlement system settles those instruments against payment or delivery, and allows their initial recording or safekeeping.
- Shares are eligible only if the issuer’s market capitalisation is under EUR 500 million, and bonds under EUR 1 billion of issue size.
- The total on one infrastructure may not exceed EUR 6 billion when a new instrument is added, and at EUR 9 billion the operator must start its transition strategy.
Questions still open
The statute and MAS guidance frame the questions, and neither answers them for a listed share.
Why does it matter whether a share token is a twin or a native?
A twin has to be reconciled with CDP’s record, so CDP stays the record and the trade settles as today. A native is the only ledger, so it replaces CDP’s record and everyone who deals with CDP has to connect to it.
- A twin DTC’s securities tokens are 1:1 backed by securities held at DTC, whose official books and records remain with DTC, and the Bermuda Monetary Authority says twins need ongoing reconciliation between the token and the asset.
- A native CDP novates trades between clearing members and settles cash through eight settlement banks, so a record at CDP that moved onto a ledger would reach each of them.
- Reasoning Who has to change follows from where the record sits. A twin reconciles with a ledger kept elsewhere, so that ledger stays the record. A native is the only ledger, so it becomes the record. No published rule for Singapore states this.
Does the cash have to be tokenised too?
No. Tokenising the share and tokenising the cash are separate choices, and each leg can sit on today’s rails, as a twin or as a native. Settling both legs in one step needs both tokenised, on one ledger or linked.
- Share only At DTC the shares are tokenised and the cash is not. Treasury distributions are paid in fiat to participants’ traditional accounts, and digital cash is on its roadmap for 2027 and beyond.
- Cash only MAS completed a live trial settling interbank overnight lending in wholesale CBDC, and Pontes lets market participants settle with cash tokens on the Eurosystem platform or in T2, the Eurosystem’s large-payment system. Neither involves a tokenised share.
- Both The BIS defines atomic settlement as an exchange in which each asset transfers only when the others do. In 2024 a EUR 100 million note was issued on Euroclear’s D-FMI platform, settled through Banque de France’s DL3S platform for digital currency, so both legs were on ledgers.
- Not publicly stated How a share ledger at CDP would settle simultaneously with cash settled in MEPS+.
Would tokenised settlement need more cash and shares on hand?
Settling each trade instantly gives up today’s netting and needs the cash and shares in place at the trade. They then sit idle for less time, because they are no longer reserved for a batch run.
- Today CDP settles money on a net basis and securities on a gross basis, in an intraday run at 10.00 a.m. and a final run at 1.30 p.m..
- Instant settlement It needs both legs tokenised and in place at each trade. DTCC says multilateral netting cuts equities payment obligations by 98 percent on average, which instant settlement would lose unless the design nets.
- A design can still net The Guardian fixed income paper says DLT does not necessitate a gross settlement model and could support deferred or real-time atomic net settlement.
- Not publicly stated How much more liquidity a tokenised settlement of SGX shares would need.
Does tokenised settlement change who legally owns the share?
Not publicly stated for SGX. What exists is a statute that names CDP’s register for deposited shares, guidance that asks issuers to say which record counts, and a US letter on DTC’s twin.
- What the Act says For a share held at CDP, a transfer is made by an entry in CDP’s Depository Register.
- What MAS asks Issuers of tokenised products are asked to disclose which record is definitive of legal ownership, and the guide does not override any law.
- United States For DTC, the SEC staff letter says DTC recognises only the participant as the entitlement holder, and its rights and duties for a tokenised entitlement are equivalent to those for a book-entry one.
- Not publicly stated Whether tokenised settlement changes legal title for a share listed on SGX.
Details
The Guardian fixed income paper calls it a key open question where settlement finality and beneficial ownership will be recorded.
The BIS says legal and regulatory uncertainty remains a challenge for tokenised bonds.
Could a share token be the register for an SGX-listed share?
Not publicly stated for Singapore. Switzerland and Germany already let a ledger be the legal register, and industry papers describe it for funds, but the Act points to CDP’s register for deposited shares.
- Abroad Swiss law makes a ledger-based security a right that is exercised and transferred only through its ledger, and German law lets an issuer issue a security by an entry in an electronic securities register.
- Funds The Guardian Funds Framework describes a register held on the ledger itself as one of three forms. It is an industry paper about funds.
- United States DTC describes its securities tokens as representations of assets held at DTC, so the original stays on its books.
- Not publicly stated Whether Singapore law would let a share token be the register for a share on the exchange.
Details
For shares of a variable capital company, the Guardian paper on tokenised funds says there is no express guidance on whether a blockchain instruction can be an instrument of transfer.
Has SGX or CDP tokenised listed shares?
Not announced. SGX and CDP have done digital debt issuance on a ledger, and that work is for bonds.
- Bonds SGX’s 2020 pilot recorded proof of ownership on an SGX operated ledger, and in 2022 CDP made Marketnode’s platform available to debt issuers.
- SGX report The latest annual report describes crypto perpetual futures and a 37.3 percent stake in MarketNode.
- Not publicly stated Any SGX or CDP plan to settle a listed share on a tokenised path.
