Where to tokenize, and under which rules
The question isn't whether tokenization is legal – it's which framework fits your raise. Twelve 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.
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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 →The Stobox Tokenization Framework
Once you know the jurisdiction, this is the end-to-end process: strategy, asset structuring, securities classification, token economics, the issuing entity, legal documentation, validation, and the STO – phase by phase, authored by Gene Deyev.
Read the framework →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 →Germany wrote tokenized securities into statute – and made them rigorous. The Electronic Securities Act (eWpG) lets bonds and, since November 2025, shares exist as blockchain-based 'crypto securities'. But it is the most procedurally demanding of the twelve markets: BaFin prospectus approval, a licensed register, and one of Europe's strictest KYC/AML regimes all stack. The full compliance path, the €8M exemption, and how a raise actually runs.
Read the guide →Liechtenstein wrote the first purpose-built blockchain law – the TVTG's Token Container Model lets a token hold any right, and EEA membership passports the offer into all 30 European states. The TT-service-provider roles, the MiCA boundary, the €8M prospectus threshold, and how a compliant tokenized raise runs.
Read the guide →MAS regulates a tokenized security as the security it represents – 'same activity, same risk, same regulatory outcome.' The SFA offer exemptions, the accredited-investor opt-in, the VCC for tokenized funds, and what Project Guardian actually produced.
Read the guide →The SFC calls tokenized securities 'traditional securities with a tokenisation wrapper' – same business, same risks, same rules. The professional-investor safe harbours, the 2026 secondary-trading framework, the sovereign tokenized bonds, and how a compliant tokenized raise runs in Hong Kong.
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 | Strongest of the six – 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, the market numbers in the State of RWA 2026 report, and what it all costs in the Cost Index.