Figure Heloc

The UAE regulates tokenised securities and tokenised funds, but which regulator applies depends on location: the FSRA in ADGM and the DFSA in DIFC treat such tokens as securities or fund units under their normal rules, VARA in Dubai licenses tokens that reference real-world assets but not securities, and the CMA covers the rest of the country. Buy only through a firm licensed by the right regulator, and check the product's investor restrictions. Individuals pay no income tax on gains.

Regulators

Capital Market Authority (CMA, formerly SCA, federal), ADGM Financial Services Regulatory Authority (FSRA), Dubai Financial Services Authority (DFSA, DIFC), Virtual Assets Regulatory Authority (VARA, Dubai), Central Bank of the UAE (CBUAE)Read moreShow less

Licensing

In force: the regulator depends on where the activity is carried on. ADGM: issuers and intermediaries in digital securities need FSRA authorisation under its digital securities guidance, and a tokenised fund is generally regulated as a fund first. DIFC: DFSA rules for the underlying Investment, including fund-marketing restrictions, continue to apply. Dubai mainland: VARA's Virtual Asset Issuance Rulebook (in force 2025) with Annex 2 on Asset-Referenced Virtual Assets (ARVA) requires a VARA licence and per-token approval for tokens referencing real-world assets, but instruments that are securities fall to the securities regulator. Onshore federal: CMA. Whether a retail investor may buy a given tokenised fund depends on the product's own offering rules and the licensed intermediary.Read moreShow less

Payments

Not a payment instrument; only licensed dirham payment tokens may be used for general payments onshore (CBUAE Payment Token Services Regulation).

Tax

No personal income or capital gains tax; transfers and conversions of virtual assets are VAT-exempt (Cabinet Decision 100/2024). Corporate tax applies to business profits. No tax rule specific to tokenised securities was identified.Read moreShow less

In the EU a tokenised fund or bond is treated as a financial instrument, not as a crypto-asset: MiCA does not apply, and the normal investment-services, fund and prospectus rules do. Blockchain trading and settlement infrastructure can operate under the DLT Pilot Regime. Whether an ordinary investor can buy a given product depends on how it is offered: many tokenised Treasury products are open only to professional or qualified investors. Tax follows national rules for the underlying investment.

Regulators

ESMA, National competent authorities (e.g. AMF, BaFin, AFM, CONSOB, CSSF), European Commission

Licensing

In force: offering, distributing, trading and holding tokenised financial instruments requires the usual MiFID II authorisation (investment firm, trading venue), the fund rules that apply to the underlying fund (e.g. UCITS or money-market fund rules) and a prospectus or an exemption for public offers. Since 23 Mar 2023 the DLT Pilot Regime (Regulation (EU) 2022/858) lets authorised operators run DLT multilateral trading facilities and DLT settlement systems for such instruments; it runs for at least three years and can be extended by the Commission. Retail access depends on the product: many tokenised Treasury products are sold only to professional or qualified investors — for example, the issuer of Ondo USDY restricts EEA buyers to MiFID II professional clients or Prospectus Regulation qualified investors.Read moreShow less

Payments

Not a payment instrument; payment tokens are a separate MiCA category (e-money tokens).

Tax

Set by each Member State under the rules for the underlying security or fund; no EU-level tax rule specific to tokenised securities was identified.

In the United States a tokenised fund or tokenised Treasury product is simply a security, and SEC staff confirmed in January 2026 that putting it on a blockchain does not change that. It must be registered or sold under an exemption, which is why most such products are available only to accredited or qualified investors, and some (such as Ondo USDY) are not sold to US persons at all. Synthetic tokens that only track a security may be security-based swaps and are largely closed to retail investors. Returns are taxed like those of the underlying investment.

Regulators

Securities and Exchange Commission (SEC), Financial Industry Regulatory Authority (FINRA), Commodity Futures Trading Commission (CFTC), Internal Revenue Service (IRS)Read moreShow less

Licensing

In force: an offer or sale must be registered with the SEC or rely on an exemption; intermediaries, exchanges and transfer agents need the usual SEC/FINRA registrations. SEC staff distinguish issuer-sponsored tokens from third-party tokens (custodial or synthetic); a synthetic token may be a security-based swap, which cannot be offered to investors who are not eligible contract participants unless registered and traded on a national securities exchange. No new exemption or safe harbour for tokenised securities was created. In practice many tokenised Treasury and money-market products are private offerings limited to eligible (accredited or qualified) investors, and some are closed to US persons altogether: for example, the issuer of Ondo USDY prohibits US persons under Regulation S.Read moreShow less

Payments

Not a payment instrument; tokenised fund shares are investments, not money. Payment stablecoins are a separate category under the GENIUS Act.

Tax

Taxed as the underlying security: fund distributions and interest are income, and gains on sale or redemption are capital gains. No tax rule specific to the token format was identified.Read moreShow less

In the UK a token that works like a share, bond or fund unit is a security token and is regulated like the traditional investment: the firm offering it needs FCA authorisation, and normal investor-protection rules apply. The Bank of England and the FCA run a Digital Securities Sandbox (until 2029) for firms issuing and settling such securities on blockchain. Many tokenised Treasury products are sold in the UK only to professional or qualified investors. Returns are taxed like the underlying investment.

Regulators

Financial Conduct Authority (FCA), Bank of England, HM Treasury, HM Revenue & Customs (HMRC)

Licensing

In force: dealing in, arranging, managing or offering security tokens requires FCA authorisation for the relevant regulated activity, and public offers follow the prospectus and financial promotion rules. Since 8 January 2024 the Digital Securities Sandbox, run jointly by the Bank of England and the FCA under the FSMA 2023 (Digital Securities Sandbox) Regulations 2023, lets approved firms issue, trade and settle digital securities — including equities, bonds, money-market instruments and fund units — on DLT under a modified legal regime; it is due to run until 8 Jan 2029 and may be extended by HM Treasury through legislation. Retail access depends on the product: for example, the issuer of Ondo USDY restricts UK buyers to professional clients or qualified investors.Read moreShow less

Payments

Not a payment instrument; tokenised fund units are investments.

Tax

Taxed like the underlying security or fund (income on distributions, Capital Gains Tax on disposals); no tax rule specific to the token format was identified.Read moreShow less

Bahrain has a legal framework for tokens that are securities: the Central Bank of Bahrain treats them as 'Digital Tokens' with offering and whitepaper rules, and only CBB-licensed firms may provide services around them. There is no specific approval for foreign tokenised Treasury or money-market funds for ordinary investors, so availability depends on the licensed firm and the product. Individuals pay no income tax on gains.

Regulators

Central Bank of Bahrain (CBB)

Licensing

In force: the CRA Module contains a chapter on Digital Token offerings, with a whitepaper requirement and a CBB whitepaper template; potential issuers are encouraged to discuss offerings with the CBB first. Crypto-asset services, including exchanges, require a CBB licence in one of four categories. No CBB rule specifically authorising foreign tokenised money-market or Treasury funds for Bahraini retail investors was identified in this review.Read moreShow less

Payments

Not a payment instrument; stablecoins are covered by the separate 2025 Stablecoin Issuance and Offering Module.

Tax

No personal income or capital gains tax (law-firm summary); no tax rule specific to tokenised securities identified.

Indonesia has no final rules yet for tokenised securities or tokenised funds. The financial regulator OJK is reported to be drafting a regulation on tokenising real-world assets, following projects tested in its sandbox. Until those rules exist, there is no approved local way to buy foreign tokenised Treasury funds; regulated crypto trading is limited to eligible assets on OJK-licensed platforms, and crypto cannot be used for payments.

Regulators

Financial Services Authority (OJK), Bank Indonesia, Ministry of Finance / Directorate General of Taxes

Licensing

Pending: no final OJK rule for tokenised securities or tokenised funds was identified. Some firms are testing real-world-asset tokenisation in OJK's regulatory sandbox (reported). No OJK approval of foreign tokenised Treasury or money-market funds for Indonesian investors was identified; retail crypto trading must go through OJK-licensed traders and only in assets meeting OJK criteria.Read moreShow less

Payments

banned — the rupiah is the only legal means of payment; Bank Indonesia prohibits crypto payments.

Tax

No tax rule specific to tokenised securities identified. Crypto assets traded as digital financial assets fall under PMK 50/2025 (from 1 Aug 2025: final income tax of 0.21% on transactions through domestic platforms, 1% through foreign platforms).Read moreShow less

Kazakhstan has a legal category for tokenised securities and tokenised real assets: since May 2026 they are 'digital financial assets', supervised by the financial market regulator ARDFM and issued through registered platforms, while the AIFC financial centre has its own regime. A July 2026 decree plans to recognise AIFC-issued tokenised securities across the country. Use a licensed or registered platform; rules for foreign tokenised funds are not yet clear.

Regulators

Agency for Regulation and Development of the Financial Market (ARDFM), National Bank of Kazakhstan (NBK), Astana Financial Services Authority (AFSA, AIFC)Read moreShow less

Licensing

In force: outside the AIFC, ARDFM regulates the turnover of DFAs (except stablecoins), and registered DFA-platform operators issue DFAs in tokenised form and account for rights in transactions. Inside the AIFC, AFSA regulates firms under its own capital-market and digital-asset frameworks (amended from 1 Jan 2026), and has licensed at least one platform for tokenised real-world assets in its FinTech Lab. A presidential decree of 7 Jul 2026 plans recognition in the rest of Kazakhstan of digital assets and tokenised securities issued under the AIFC. Whether foreign tokenised funds may be offered to Kazakh retail investors was not confirmed.Read moreShow less

Payments

Not a payment instrument; the July 2026 decree provides for AIFC-licensed stablecoin issuers to support cross-border trade settlements.

Tax

The 7 Jul 2026 decree introduces tax incentives for moving digital assets from foreign to regulated Kazakh platforms (implementing rules not verified); no tax rule specific to tokenised securities identified.Read moreShow less

Malaysia treats tokenised shares, bonds and fund units as ordinary capital market products regulated by the Securities Commission, separately from crypto tokens and digital currencies. The SC consulted in 2025 on extra rules for tokenised products; final rules were not confirmed. Foreign tokenised Treasury products are often open only to sophisticated investors.

Regulators

Securities Commission Malaysia (SC), Bank Negara Malaysia (BNM), Inland Revenue Board (LHDN)

Licensing

Partly in force: dealing in, offering or managing tokenised shares, bonds or fund units needs the same SC licences and approvals as the conventional product. On 6 May 2025 the SC consulted (Public Consultation Paper No. 1/2025, until 16 Jun 2025) on a framework with extra disclosure, governance, record-keeping and technology-risk obligations for tokenised capital market products; as of this review the SC's published material still describes it as a proposed framework, and no final rules were found. Foreign tokenised Treasury products are often limited to sophisticated investors: for example, the issuer of Ondo USDY accepts Malaysian buyers only if they are sophisticated investors.Read moreShow less

Payments

Not a payment instrument; in 2026 BNM is piloting ringgit stablecoins and tokenised deposits for wholesale payments and settlement of tokenised assets in a controlled environment.Read moreShow less

Tax

Treated under the general rules of the Income Tax Act 1967 for the underlying product; no tax rule specific to tokenised securities identified.

Pakistan has a new virtual-asset law and regulator (PVARA), and officials talk openly about tokenising government debt and real-world assets, but there are no published rules yet for tokenised securities or tokenised funds, and it is unclear whether PVARA or the securities regulator SECP would supervise them. No licensed local offering exists, so the status is uncertain.

Regulators

Securities and Exchange Commission of Pakistan (SECP), Pakistan Virtual Assets Regulatory Authority (PVARA), State Bank of Pakistan (SBP)

Licensing

Being implemented: PVARA opened licensing under the Virtual Assets Act 2026, and existing operators had to apply for a no-objection certificate by 5 Sep 2026 or stop. No licensed offering of tokenised securities or tokenised funds to Pakistani investors was identified. In August 2026 the PVARA chairman said Pakistan is exploring digitally native sovereign notes on regulated blockchain infrastructure and wider tokenisation of real-world assets.Read moreShow less

Payments

restricted — not legal tender; banks may serve PVARA-licensed providers but may not invest in, trade or hold virtual assets themselves.

Qatar allows tokenised securities, but only inside the Qatar Financial Centre, whose 2024 Digital Assets Framework covers tokens representing shares, bonds, sukuk and other assets. Cryptocurrencies and stablecoins remain excluded, and there is no identified local channel for ordinary residents to buy foreign tokenised funds. Tax treatment specific to such tokens was not found.

Regulators

Qatar Financial Centre Regulatory Authority (QFCRA), Qatar Central Bank (QCB)

Licensing

In force inside the Qatar Financial Centre only: the Digital Assets Framework (enacted 1 Sep 2024) provides for the validation, registration and custody of tokens that represent assets such as securities. The QFCRA's December 2019 restrictions on virtual-asset services still apply to Excluded Tokens. No local route for residents to buy foreign tokenised Treasury or money-market funds was identified.Read moreShow less

Payments

Not a payment instrument; tokens that act as a substitute for currency are excluded from the framework.

In Russia, tokenised financial claims exist as domestic 'digital financial assets' issued on platforms registered with the Bank of Russia, and from September 2026 digital rights may also be issued in public networks. Ordinary (non-qualified) investors may buy only some of them, within limits set by the Bank of Russia. Foreign tokenised Treasury and money-market funds are not part of this system and some of them bar Russian buyers in their own eligibility rules.

Regulators

Bank of Russia, Federal Tax Service, Rosfinmonitoring

Licensing

In force: DFAs may be issued only by operators (Russian legal entities) included in the Bank of Russia register. Bank of Russia Instruction No. 5635-U restricts which DFAs non-qualified investors may buy, with a RUB 600,000 limit for certain categories (law-firm summary). The crypto-circulation law adopted by the State Duma on 21 Jul 2026 (in force 1 Sep 2026) also lets digital rights be issued in public networks, not only on registered operators' platforms. Foreign tokenised Treasury products usually exclude Russia themselves: for example, Russia is on the prohibited list for Ondo USDY.Read moreShow less

Payments

banned domestically for digital currencies; no domestic payment use of tokenised securities identified.

Tax

No tax rule specific to tokenised securities or DFAs was verified in this review; the 2026 crypto law requires cryptocurrency holdings recorded abroad to be reported to the tax authorities.Read moreShow less

Saudi Arabia has no confirmed legal framework for tokenised securities or tokenised funds. No local platform is licensed to offer them, and regulators have warned that virtual currencies are unregulated. Lawyers expect a token that works like a security to fall under the Capital Market Authority, but there are no published rules or approved offerings yet. Treat the status as unclear until the CMA publishes rules.

Regulators

Capital Market Authority (CMA), Saudi Central Bank (SAMA)

Licensing

None identified for this class: no CMA authorisation of a tokenised fund or security-token offering to Saudi investors was found, and no platform is licensed to offer crypto trading. The CMA's FinTech Lab (experimental permits) allows new business models to be tested under a simplified regime, and the first local tokenisation project is in real estate under joint REGA and CMA supervision (law-firm guide). Claims on commercial websites about a CMA tokenisation framework with licensed issuers could not be confirmed from official or reputable sources.Read moreShow less

Payments

restricted — not legal tender; no licensed payment use.

Turkey regulates crypto platforms through the Capital Markets Board (SPK) but has no specific rules for tokenised securities or tokenised funds. Lawyer commentary suggests a token that works like an investment would be treated as a capital market instrument needing SPK approval, but the SPK has not said so for tokens and no such approved offering was found, and foreign tokenised Treasury funds are not approved for sale in Turkey. Crypto cannot be used for payments.

Regulators

Capital Markets Board (SPK), Central Bank of the Republic of Türkiye (CBRT), Financial Crimes Investigation Board (MASAK)

Licensing

Partly in force: crypto-asset service providers need an SPK licence (communiqués of 13 Mar 2025), and SPK states that appearing on its provisional list of operating providers does not mean a firm is authorised. Under the general Law 6362 regime, a public offering of a capital market instrument needs an SPK-approved prospectus; whether and how this applies to tokens is so far described only in lawyer commentary, and no SPK-approved tokenised security offering was identified. No SPK approval for offering foreign tokenised money-market or Treasury funds to Turkish investors was found.Read moreShow less

Payments

banned — CBRT regulation (2021) prohibits using crypto-assets for payments.

Tax

No specific rule for tokenised securities identified. A March 2026 bill with a 10% withholding tax on crypto gains was proposed; its crypto provisions were reported withdrawn from the bill in parliament on 26 Mar 2026 (crypto media reports).Read moreShow less

Uzbekistan is only starting to allow tokenised securities: according to press reports of a late-2025 decree, local companies may issue tokenised shares and bonds within a supervised test regime from 2026. Residents may deal in crypto-assets only through domestically licensed providers, so foreign tokenised Treasury or money-market funds are not lawfully accessible through foreign platforms. Rules may change as the sandbox develops.

Regulators

National Agency for Perspective Projects (NAPP), Central Bank of Uzbekistan (CBU)

Licensing

Restricted: tokenised securities are being tested only in a controlled sandbox regime (reported), with licensed domestic exchanges preparing trading platforms; no permanent rules were identified. Since 1 Jan 2023 residents may transact in crypto-assets only through domestic NAPP-licensed providers, so buying foreign tokenised Treasury or money-market tokens on foreign platforms is not a lawful channel.Read moreShow less

Payments

banned for crypto generally; fiat-backed stablecoin payments only inside a NAPP/CBU sandbox from 2026 (reported).

Tax

Crypto-asset transactions by individuals and legal entities are exempt from tax (Elliptic guide, law as at Sep 2023); no rule specific to tokenised securities identified.Read moreShow less