Where to tokenize, and under which rules
The question isn't whether tokenization is legal — it's which framework fits your raise. Eight jurisdictions plus the SPV structuring playbook — the actual rules, dated July 10, 2026, from an operator that has structured offerings across 20+ jurisdictions since 2018.
Tokenizing an asset through an SPV
The pattern behind almost every serious deal — asset → SPV → tokens — with the six-step playbook and an honest venue comparison: Delaware, BVI, Cayman, Luxembourg, ADGM, Switzerland, Singapore. Real costs, real timelines, and the mistakes that kill deals.
Read the playbook →How to tokenize real estate
Six steps from a clean property record to an operating tokenized asset — honest costs, the SPV vs native-title routes, and the disclosure that separates issuers from pitch decks.
Read the guide →Choosing a tokenization platform: 12 questions
Fee models, custody, platform-death continuity, document preparation, broker-dealer routing — the questions that sort the market, built from documented failure modes.
Read the checklist →How to tokenize company equity
Cap-table readiness, the three legal patterns (native shares, dedicated class, holdco), exemption stacking — with Stobox's own STBX as the working example.
Read the guide →The tokenization timeline, month by month
The honest schedule: record → structure → offering prep → the ~90-day window → close and issue. Plus the five delays that actually happen.
Read the timeline →What if the platform disappears?
The question demos avoid: what survives a vendor's death — and how non-custodial, attestation-based architecture engineers the answer to "everything."
Read the answer →Security token liquidity: the honest guide
What actually trades, what doesn't, why — and the five levers issuers control. The candor the industry skips, with the data behind it.
Read the guide →Tokenized securities are securities — the SEC said so plainly in January 2026. The exemption menu (Reg D, S, CF, A+), what needs a broker-dealer, Rule 144, and how a compliant tokenized raise actually runs in the US.
Read the guide →Security tokens in the EU are MiFID II financial instruments, not MiCA crypto-assets. The prospectus thresholds and exemptions, the DLT Pilot Regime, the €5M crowdfunding route, and what passporting gives a compliant issuer.
Read the guide →Security tokens are FCA-regulated specified investments. The Digital Securities Sandbox, the new POATRs prospectus regime and Public Offer Platforms (live Jan 2026), the s21 financial-promotion gate, and what the Oct 2027 cryptoasset regime changes.
Read the guide →Four regulators, three routes: VARA's ARVA regime for real-world-asset tokens in Dubai, DFSA's Investment Tokens in the DIFC, FSRA's digital securities in ADGM — and the federal CMA since January 2026. Where each fits, with real precedent.
Read the guide →Switzerland made tokenized shares a first-class legal object: ledger-based securities under the DLT Act, FinSA prospectus exemptions (professional clients, <500 investors, CHF 8M), licensed DLT trading venues, and the CMTA standards that now interoperate with ERC-7943.
Read the guide →The BVI is where token issuers incorporate, not where investors live: a Business Company in 24–48 hours for ~$2,500–3,000, tax-neutral, with pure token issuance outside the VASP Act. What SIBA means for security tokens, the honest FATF grey-list caveat, and why major RWA issuers still use BVI SPVs.
Read the guide →In March 2026 the Cayman Islands became the first major fund domicile with an explicit statutory regime for tokenized funds — digital equity and investment tokens under CIMA, exempt from VASP dual-licensing. The rules, the fees, the entity menu, and why FATF-clean Cayman is the institutional counterpart to the BVI.
Read the guide →Four blockchain laws (2019–2024) made Luxembourg securities natively digital — including unlisted equity via the new control-agent role. Add compartmentalized securitisation vehicles, Europe's first tokenized UCITS, LuxSE's DLT listings, and €8.59T of fund AUM: the EU's institutional tokenization hub, explained.
Read the guide →Not sure the jurisdiction is even the first question? Start with the freeReadiness Score — it checks the legal, asset, and operational groundwork any of these frameworks will demand.
The one-glance comparison
Six markets, side by side — each cell is unpacked in its guide. As of July 10, 2026.
| Jurisdiction | Legal footing | Workhorse route | Regulated venues | Best for |
|---|---|---|---|---|
| 🇺🇸 United States | Settled — SEC: token format doesn't change the law (Jan 2026) | Reg D 506(c) + Reg S; Reg CF/A+ for retail | Live ATSs (tZERO); Nasdaq tokenized trading approved | Raising from the world's deepest accredited-investor pool |
| 🇪🇺 European Union | Settled — MiFID II instruments, not MiCA | Prospectus exemptions (≤€12M, qualified-only, <150/state); ECSP €5M | 4 DLT Pilot infrastructures licensed | One passportable offer across 27 markets |
| 🇬🇧 United Kingdom | Settled — FCA specified investments | POATRs (2026): private placement or Public Offer Platforms | Digital Securities Sandbox — 16 firms live | A rebuilt-for-tokenization offer regime |
| 🇦🇪 UAE | Purpose-built — VARA ARVA regime for RWA tokens | VARA Cat-1 / DIFC investment tokens / ADGM digital securities | Government-backed: DLD tokenized title deeds, live secondary market | RWA-first regulation and Gulf capital |
| 🇨🇭 Switzerland | Best-in-class — the token IS the share (DLT Act) | FinSA exemptions (professional-only, <500, CHF 8M) | Licensed DLT venues: BX Digital, SIX/SDX | Natively digital equity with statutory force |
| 🇻🇬 BVI | Issuer-friendly — FSC token guidance since 2020; grey-list caveat | BVI SPV issues; investors' own laws govern the sale | n/a — issuer domicile, not an investor market | Fast, cheap, tax-neutral issuing vehicles |
| 🇰🇾 Cayman Islands | First-mover — statutory tokenized-funds regime (Mar 2026); FATF-clean | CIMA-registered tokenized fund (digital equity/investment tokens); VASP-exempt | On-chain/hybrid registers in statute; 9 funds registered in the first weeks | Institutional tokenized fund structures |
| 🇱🇺 Luxembourg | Statutory ×4 — Blockchain Laws I–IV; control-agent DLT registers | Securitisation compartments; funds (first tokenized UCITS); <€8M prospectus-free | LuxSE Securities Official List admits DLT bonds since 2023 | EU-passported institutional product |
Rules move fast — the dated log of every change lives in theregulatory changelog, and the market numbers in the State of RWA 2026 report.