{
  "title": "RWA Regulatory Map",
  "version": "1.0.0",
  "generatedAt": "2026-08-17",
  "path": "/research/data/rwa-regulatory-map.json",
  "sourcesAccessed": "2026-08-17",
  "method": "Two planes of one dataset. Plane A maps six tokenized asset classes against seven cross-cutting legal layers as they stand in the United States. Plane B maps seven jurisdictions against five layers. Every cell carries a status, a named primary source where one exists, and the channel by which it was observed. A full asset-by-jurisdiction-by-layer cube would be 294 cells; filling that many at this evidence standard was not possible in one session, and a half-filled cube is a worse artifact than a filled smaller one, so the grid is 77 cells and says so.",
  "channelStatement": "No primary-source document was retrieved in original form. Every regulator and statute domain attempted (sec.gov among them) was refused by this environment's network egress proxy, so the research channel was web search alone. Cells therefore carry no quotation marks around source text: each names the primary instrument it points to, names the search result that surfaced it, and states the wording as the author's restatement, not the source's words. Nothing in this file is marked document-verified. Where a claim could not be observed at all this session, the cell says unverified and carries the queries that failed and the thing that would settle it.",
  "independence": "This is a personal research artifact. It maps structure, not conduct. It grades no entity, predicts no entity's failure, and is not legal advice. It is informational only, is not an assurance opinion, and is not affiliated with or endorsed by any employer.",
  "statusLegend": {
    "enacted": "A statute or final rule in force addresses this directly.",
    "staff-position": "A regulator's staff has taken a published no-action, interpretive, or guidance position. Not law, and withdrawable.",
    "proposed": "Formally proposed and not adopted.",
    "consulted": "Out for consultation or comment, no instrument yet.",
    "pilot": "A time-boxed sandbox or pilot with named participants.",
    "analogy": "No instrument addresses the tokenized form. Pre-tokenization law is applied by analogy, and the analogy is where the risk sits.",
    "absent": "Nothing addresses it, by analogy or otherwise.",
    "unverified": "Could not be observed this session. Trail recorded."
  },
  "channelLegend": {
    "search-observed": "Surfaced in one search result this session, with a URL.",
    "search-corroborated": "Surfaced consistently across two or more independent search results this session.",
    "derived": "Computed from other cells in this file, not from an outside source.",
    "unverified": "Not observed this session."
  },
  "layers": [
    {
      "key": "offering",
      "label": "Offering and exemption",
      "question": "Under what authority is the thing sold, and to whom."
    },
    {
      "key": "holderGates",
      "label": "Holder gates and enforcement",
      "question": "Who may hold it, and does the transfer restriction actually enforce the gate."
    },
    {
      "key": "custody",
      "label": "Custody",
      "question": "Who holds the underlying, under which custody rule."
    },
    {
      "key": "register",
      "label": "Transfer agency and register of record",
      "question": "Which record is the register, the chain or the book."
    },
    {
      "key": "valuation",
      "label": "Valuation",
      "question": "Who determines value under what rule, and what a live on-chain price legally is."
    },
    {
      "key": "reporting",
      "label": "Reporting",
      "question": "What gets filed, with whom, how often."
    },
    {
      "key": "assurance",
      "label": "Assurance",
      "question": "Who examines what, under which standard, and what is left unexamined."
    }
  ],
  "jurisdictionLayers": [
    {
      "key": "framework",
      "label": "Purpose-built framework",
      "question": "Is there a law written for tokenized real-world assets, or is existing law applied by analogy."
    },
    {
      "key": "offering",
      "label": "Offering regime",
      "question": "What governs the sale of a tokenized instrument."
    },
    {
      "key": "register",
      "label": "Register of record",
      "question": "Does the law recognize a distributed ledger as the register itself."
    },
    {
      "key": "venue",
      "label": "Trading and market infrastructure",
      "question": "Where a tokenized instrument may legally trade and settle."
    },
    {
      "key": "assurance",
      "label": "Assurance requirement",
      "question": "Is any examination or attestation required of the tokenized layer specifically."
    }
  ],
  "assetClasses": [
    {
      "key": "treasuries",
      "label": "Tokenized treasuries and money market funds",
      "examples": "BUIDL, BENJI/FOBXX, OUSG, USDY",
      "cells": {
        "offering": {
          "status": "enacted",
          "finding": "Three live paths, none of them tokenization-specific. A registered money market fund under Investment Company Act Rule 2a-7 (Franklin OnChain U.S. Government Money Fund). A Section 3(c)(7) private fund sold to qualified purchasers under Securities Act Rule 506(c) (BUIDL, OUSG). Regulation S debt sold only outside the United States (USDY). The token changes the distribution, not the exemption.",
          "source": "Investment Company Act Rule 2a-7; Securities Act Rule 506(c); Regulation S",
          "sourceDate": "pre-existing",
          "url": "https://blockonomi.com/inside-ondo-finance-how-ousg-and-usdy-tokenize-us-treasuries-through-distinct-legal-frameworks",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "holderGates": {
          "status": "analogy",
          "finding": "The gate comes from the exemption: qualified purchaser status, verified accredited status, or non-US person status. The enforcement comes from an allowlist in the token contract plus the transfer agent's own controls. No rule requires the contract to match the exemption, so the gate and its enforcement are separate systems that happen to be pointed at each other.",
          "source": "Rule 506(c) verification requirement; Regulation S offshore transaction requirement",
          "sourceDate": "pre-existing",
          "url": "https://coinpaprika.com/education/ondo-usdy-vs-ousg-two-tokenized-treasury-yields-explained/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "custody": {
          "status": "staff-position",
          "finding": "Two different answers for two structures. BUIDL's underlying cash and securities sit with BNY Mellon as custodian and administrator. For the Franklin fund, an affiliated transfer agent holds the private keys, which the SEC staff addressed directly in the 12 August 2026 no-action letter rather than by pointing at an existing custody rule.",
          "source": "SEC Division of Investment Management no-action letter, Franklin Templeton, 12 August 2026; Investment Company Act Section 17(f)",
          "sourceDate": "2026-08-12",
          "url": "https://www.sec.gov/rules-regulations/no-action-interpretive-exemptive-letters/division-investment-management-staff-no-action-interpretive-letters/franklin-templeton-081226",
          "accessed": "2026-08-17",
          "channel": "search-corroborated",
          "note": "Post-cutoff claim. Corroborated across at least six independent outlets and a sec.gov URL slug carrying the date."
        },
        "register": {
          "status": "staff-position",
          "finding": "The Franklin fund is the one registered fund observed using a public blockchain as its official system of record, and even there the affiliated transfer agent retains the private keys and the shareholder register. In the private-fund structures the transfer agent's book remains the register and the token mirrors it.",
          "source": "Exchange Act transfer agent rules 17Ad-1 through 17Ad-23; Franklin Templeton no-action letter, 12 August 2026",
          "sourceDate": "2026-08-12",
          "url": "https://www.theblock.co/news/defi/2026-08-12-sec-clears-franklin-templeton-funds-use-onchain-benji-system-cash-management-411654",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "valuation": {
          "status": "enacted",
          "finding": "For the registered money market fund, Rule 2a-7 governs portfolio quality, maturity and liquidity and produces the stable share price. For the private funds the administrator strikes net asset value. Neither rule says anything about the price a blockchain oracle publishes for the same token.",
          "source": "Investment Company Act Rule 2a-7",
          "sourceDate": "pre-existing",
          "url": "https://coinpaprika.com/education/franklin-templeton-tokenized-fund-fobxx-and-benji-explained/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "reporting": {
          "status": "enacted",
          "finding": "The registered fund reports annually on Form N-CEN under Section 30(a) of the Investment Company Act, plus the rest of the registered-fund reporting stack. The 3(c)(7) funds file a Form D and nothing further that is public.",
          "source": "Investment Company Act Section 30(a); Form N-CEN, 17 CFR 249.330",
          "sourceDate": "pre-existing",
          "url": "https://www.ecfr.gov/current/title-17/chapter-II/part-249/subpart-D/section-249.330",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "analogy",
          "finding": "The registered fund gets an annual financial statement audit by an accountant registered with and inspected by the PCAOB. The private fund's audit is a contractual undertaking that the Advisers Act custody rule's annual-audit provision makes attractive, not a tokenization requirement. In both cases the audit opinion covers the fund's financial statements, not the correspondence between tokens outstanding and shares on the register.",
          "source": "Advisers Act custody rule annual audit provision; PCAOB registration and inspection requirement",
          "sourceDate": "pre-existing",
          "url": "https://www.sec.gov/rules-regulations/staff-guidance/division-investment-management-frequently-asked-questions/staff-responses-questions-about-custody-rule",
          "accessed": "2026-08-17",
          "channel": "search-observed",
          "note": "The identity of BUIDL's independent accountant was searched for and not observed. See unverified list."
        }
      }
    },
    {
      "key": "private-credit",
      "label": "Tokenized private credit",
      "examples": "ACRED (Apollo Diversified Credit Securitize Fund)",
      "cells": {
        "offering": {
          "status": "enacted",
          "finding": "ACRED is a feeder that tokenizes access to Apollo Diversified Credit Fund, which is registered under the Investment Company Act as a diversified closed-end management investment company operating as an interval fund with quarterly repurchases at net asset value. Qualifying investors subscribe through Securitize Markets, a registered broker-dealer. The registered fund is the regulated object; the token is a distribution wrapper around a feeder.",
          "source": "Investment Company Act registration as a closed-end management investment company; Rule 23c-3 interval fund repurchase structure",
          "sourceDate": "pre-existing",
          "url": "https://www.prnewswire.com/news-releases/apollo-and-securitize-announce-partnership-and-launch-tokenized-access-to-credit-fund-on-aptos-avalanche-ethereum-ink-polygon-and-solana-networks-302364212.html",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "holderGates": {
          "status": "analogy",
          "finding": "Access is limited to qualifying investors and runs exclusively through Securitize Markets, which is also the transfer agent and fund administrator. The same entity therefore sets the gate, keeps the register, and administers the fund. Nothing in the interval fund rules contemplates that concentration, because nothing in them contemplates a token.",
          "source": "Exchange Act broker-dealer registration; Exchange Act transfer agent registration",
          "sourceDate": "pre-existing",
          "url": "https://www.marketsmedia.com/apollo-tokenizes-credit-fund-with-securitize/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "custody": {
          "status": "unverified",
          "finding": "The custodian of the master fund's portfolio assets was not observed this session.",
          "trail": [
            "Apollo ACRED tokenized private credit fund Securitize structure 1940 Act closed-end interval fund",
            "Apollo Diversified Credit Fund custodian administrator"
          ],
          "settles": "The master fund's registration statement or its Form N-CEN, which names the custodian in a fixed field.",
          "channel": "unverified"
        },
        "register": {
          "status": "enacted",
          "finding": "Securitize is an SEC-registered transfer agent, which means it filed Form TA-1 and is subject to the transfer agent rules; its markets affiliate is a FINRA member broker-dealer operating a registered alternative trading system. The register of record is the transfer agent's book. The chain records movements of a token that represents an interest recorded there.",
          "source": "Exchange Act Section 17A; Form TA-1; Regulation ATS",
          "sourceDate": "pre-existing",
          "url": "https://investorsupport.securitize.io/hc/en-us/articles/4407778650775-Is-Securitize-Markets-registered-with-FINRA-and-the-SEC",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "valuation": {
          "status": "enacted",
          "finding": "Rule 2a-5 governs. It places fair value determination on the fund's board, which may designate a valuation designee it continues to oversee. The rule was adopted in Release IC-34128 on 3 December 2020 and became effective 8 March 2021. An interval fund holding direct lending and structured credit strikes net asset value on the fund's own cycle and repurchases quarterly at that value. A continuously published on-chain price for the token is not a Rule 2a-5 determination and no rule says what it is.",
          "source": "Investment Company Act Rule 2a-5, Release IC-34128",
          "sourceDate": "2020-12-03",
          "url": "https://www.dechert.com/knowledge/onpoint/2020/12/sec-adopts-fund-fair-valuation-rule.html",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "reporting": {
          "status": "enacted",
          "finding": "The master fund files the registered closed-end fund stack, including portfolio holdings reports; an NPORT-P filing for Apollo Diversified Credit Fund was surfaced on the SEC's archive during this research. The token layer files nothing of its own.",
          "source": "Investment Company Act Section 30(a); Form N-PORT; Form N-CEN",
          "sourceDate": "pre-existing",
          "url": "https://www.sec.gov/Archives/edgar/data/0001676197/000104916926001344/d124608d8k.htm",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "absent",
          "finding": "The master fund's financial statements get an annual audit. Nothing observed assures the layer that practitioners actually care about here: that tokens outstanding equal feeder interests on the register, that the allowlist matches the investor set the exemption requires, and that the price a lending protocol reads matches the valuation the board determined. No standard, no engagement, no report.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://www.ici.org/system/files/2026-04/26-ppr-valuation-governance-for-private-credit-assets.pdf",
          "accessed": "2026-08-17",
          "channel": "search-observed",
          "note": "Absence asserted from failure to observe any such requirement across the searches in this file, not from a document that states no requirement exists."
        }
      }
    },
    {
      "key": "commodities",
      "label": "Tokenized commodities",
      "examples": "PAXG, XAUT",
      "cells": {
        "offering": {
          "status": "analogy",
          "finding": "Neither of the two largest gold tokens is offered as a security or under a commodities offering regime, because no federal offering regime addresses a spot commodity token. PAXG is issued under a New York trust charter; XAUT is issued by TG Commodities Limited under El Salvador's digital asset regime. The offering question is answered by an entity licence, not by an offering rule.",
          "source": "NYDFS limited purpose trust charter; El Salvador CNAD digital asset registration",
          "sourceDate": "pre-existing",
          "url": "https://beincrypto.com/learn/tokenized-gold/",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "holderGates": {
          "status": "absent",
          "finding": "Identity checks happen at the issuer boundary, on mint and on redemption. On-chain transfer between wallets in between is not gated by any observed rule.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://www.paxos.com/terms-and-conditions/pax-gold-terms-conditions",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "custody": {
          "status": "analogy",
          "finding": "PAXG's gold is London Bullion Market Association good-delivery bars in allocated storage at Brink's London, with each token tied to a serial-numbered bar. XAUT's gold is LBMA bars in a vault in Switzerland. Both arrangements are trust and bailment law plus a vault contract. Neither is a securities custody rule and neither is a qualified custodian requirement.",
          "source": "custody by contract under trust law; LBMA good delivery standard",
          "sourceDate": "pre-existing",
          "url": "https://www.coindesk.com/markets/2025/04/28/tethers-770m-xaut-backed-by-77-tons-of-gold-in-swiss-vault-says-company",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "register": {
          "status": "absent",
          "finding": "There is no register of record concept in law for a spot commodity token. The issuer publishes an allocation lookup tying tokens to bar serial numbers, and that lookup is a service, not a statutory register. If the lookup and the chain disagree, no rule says which one governs.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://learn.backpack.exchange/articles/paxg-gold-token-guide",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "valuation": {
          "status": "absent",
          "finding": "Spot gold, marked by the market. No valuation rule applies to the token because no regime claims it.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://beincrypto.com/learn/tokenized-gold/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "reporting": {
          "status": "absent",
          "finding": "No periodic filing regime. The issuers publish transparency pages on their own cadence and in their own format.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://tether.io/news/tether-gold-accounts-for-more-than-half-the-entire-gold-backed-stablecoin-market-as-xaut-surpasses-4-billion-in-value/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "analogy",
          "finding": "Attestation, not audit. BDO Italia provides quarterly attestations covering Tether's reserves including the gold backing XAUT. An attestation is a point-in-time report against criteria the issuer sets, which is a different product from an opinion on financial statements, and the difference is the whole subject of the companion scorecard.",
          "source": "issuer-commissioned attestation engagement; no regulatory requirement identified",
          "sourceDate": "2025",
          "url": "https://tether.io/news/tether-reports-xaut-grows-amid-shifting-monetary-landscape-releases-its-first-attestation-for-q1-2025-more-than-7-7-tons-of-physical-gold-backing-the-token-in-circulation/",
          "accessed": "2026-08-17",
          "channel": "search-corroborated",
          "note": "Per-issuer attestation detail, including standard and practitioner, lives in the Stablecoin Attestation Scorecard rather than being restated here."
        }
      }
    },
    {
      "key": "equities",
      "label": "Tokenized equities",
      "examples": "DTC tokenization pilot; xStocks",
      "cells": {
        "offering": {
          "status": "staff-position",
          "finding": "Two shapes, and they are not variations on each other. Onshore, the DTC pilot tokenizes security entitlements in securities that are already registered, under a Division of Trading and Markets no-action letter dated 11 December 2025, with staff declining to recommend enforcement for three years from launch. Offshore, xStocks are issued by Backed Assets (JE) Limited, a Jersey vehicle, as contractual instruments carrying economic and governance rights against the issuer, and are not registered US securities.",
          "source": "SEC Division of Trading and Markets no-action letter to DTC, 11 December 2025; Jersey company and trust law",
          "sourceDate": "2025-12-11",
          "url": "https://www.dechert.com/knowledge/onpoint/2025/12/sec-greenlights-dtc-s-tokenization-pilot-program.html",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "holderGates": {
          "status": "staff-position",
          "finding": "In the pilot, tokens move only among registered wallets and open permissionless circulation is not part of the design. The gate is an operating condition of the relief, which means it can be changed by the same staff that granted it.",
          "source": "SEC Division of Trading and Markets no-action letter to DTC, 11 December 2025",
          "sourceDate": "2025-12-11",
          "url": "https://www.morganlewis.com/pubs/2026/01/new-sec-guidance-provides-regulatory-pathway-for-dtc-securities-tokenization-services",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "custody": {
          "status": "enacted",
          "finding": "Unchanged. The depository holds the position and the intermediated holding chain runs as it always has, with investor protections resting on Article 8 of the Uniform Commercial Code. The token sits beside that chain rather than replacing any link in it.",
          "source": "UCC Article 8; Exchange Act Section 17A clearing agency framework",
          "sourceDate": "pre-existing",
          "url": "https://www.morganlewis.com/pubs/2026/01/new-sec-guidance-provides-regulatory-pathway-for-dtc-securities-tokenization-services",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "register": {
          "status": "staff-position",
          "finding": "The sharpest cell in the file. In the pilot the tokens are explicitly not the securities and not security entitlements; they are an alternative method of instructing the depository to record and transfer entitlements on its own official books. Ownership stays registered in the name of the depository's nominee. The token is an instruction, not a title.",
          "source": "SEC Division of Trading and Markets no-action letter to DTC, 11 December 2025",
          "sourceDate": "2025-12-11",
          "url": "https://www.sidley.com/en/insights/newsupdates/2025/12/the-depository-trust-company-gets-sec-ok-to-tokenize-securities-and-skip-key-regulations",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "valuation": {
          "status": "absent",
          "finding": "The underlying trades on an exchange and is priced there. Nothing governs what the token trades at, and nothing requires the two to converge.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://altstreet.investments/blog/tokenized-equities-valuation-marks-guide",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "reporting": {
          "status": "enacted",
          "finding": "The issuer's Exchange Act reporting is untouched, and that is the point: the issuer of the equity generally has no relationship with, and no disclosure obligation arising from, the token.",
          "source": "Exchange Act Sections 13 and 15(d)",
          "sourceDate": "pre-existing",
          "url": "https://www.sec.gov/newsroom/speeches-statements/peirce-statement-tokenized-securities-070925",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "absent",
          "finding": "Nothing observed requires an examination of the correspondence between tokens outstanding and entitlements recorded. In the pilot the depository retains administrative control including the ability to mint, burn, or forcibly transfer tokens in limited circumstances, which is a control, not an assurance report, and no one outside the depository opines on whether it operated.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://www.morganlewis.com/pubs/2026/01/new-sec-guidance-provides-regulatory-pathway-for-dtc-securities-tokenization-services",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        }
      }
    },
    {
      "key": "real-estate",
      "label": "Tokenized real estate",
      "examples": "Reg A+ property programs; series-LLC token platforms",
      "cells": {
        "offering": {
          "status": "analogy",
          "finding": "Regulation D, Regulation S, or Regulation A+, applied to interests in an entity that owns the property. A concrete qualified offering surfaced this session is Landa App 2 LLC, Form 1-A file number 024-11648, qualified 2 December 2021, offering series interests each holding a residential rental property. Platform structures differ: one places each property in a Delaware or Wyoming series LLC and treats the token as a membership interest, another uses a Wyoming LLC that takes the deed after the raise closes.",
          "source": "Regulation A, Form 1-A file no. 024-11648, qualified 2 December 2021; Regulation D; Regulation S",
          "sourceDate": "2021-12-02",
          "url": "https://www.sec.gov/Archives/edgar/data/1875877/000121390022055174/ea165477-1apos_landaapp2.htm",
          "accessed": "2026-08-17",
          "channel": "search-observed",
          "note": "Whether that specific offering uses a blockchain was not observed; it is cited as a filed real-estate series offering, not as a tokenized one."
        },
        "holderGates": {
          "status": "unverified",
          "finding": "Whether transfer restrictions in these token contracts actually enforce the exemption's holder conditions was not observed for any named program this session.",
          "trail": [
            "RealT Lofty tokenized rental property LLC membership interests SEC no registration series LLC deed held by LLC",
            "tokenized real estate Regulation A+ offering county recorder deed title token does not convey ownership"
          ],
          "settles": "The offering circular's transfer restriction section read against the deployed token contract's transfer function.",
          "channel": "unverified"
        },
        "custody": {
          "status": "absent",
          "finding": "There is no custodian. The entity holds the deed and the holder holds a token. No custody rule attaches to either side, because the interest is not held through an intermediary.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://www.innreg.com/blog/tokenized-real-estate",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "register": {
          "status": "absent",
          "finding": "Two registers, and the one that governs the land is the county's. The deed sits in county land records under state property law and a blockchain transfer does not update those records by itself. No state recording statute was observed that gives a ledger entry recording effect. What the token can move cleanly is the entity interest, not the real property.",
          "source": "state recording statutes; no instrument identified that recognizes ledger entries",
          "sourceDate": "n/a",
          "url": "https://moritzlaw.osu.edu/sites/default/files/2026-04/Online%20Vol%2087-Odinet%20&%20Tosato-Final.pdf",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "valuation": {
          "status": "absent",
          "finding": "No valuation rule reaches these structures. Value is whatever the sponsor's appraisal process produces, on the sponsor's cadence.",
          "source": "no instrument identified",
          "sourceDate": "n/a",
          "url": "https://blog.tokenizer.estate/real-estate-tokenization-in-us-2026",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "reporting": {
          "status": "enacted",
          "finding": "Regulation A Tier 2 issuers file annual and semiannual reports. Regulation D issuers file a Form D and stop. The reporting a token holder gets is a function of which exemption the sponsor picked, which the token holder generally did not pick.",
          "source": "Regulation A Tier 2 ongoing reporting; Regulation D Form D",
          "sourceDate": "pre-existing",
          "url": "https://dilendorf.com/blockchain-crypto/regulation-a-tokenized-offerings.html",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "analogy",
          "finding": "Regulation A Tier 2 brings audited financial statements of the issuing entity. Regulation D and the unregistered structures bring none. In no case was any examination observed of whether token supply matches the entity's membership register, which is the one thing a holder cannot check from the deed.",
          "source": "Regulation A Tier 2 audited financial statement requirement",
          "sourceDate": "pre-existing",
          "url": "https://dilendorf.com/blockchain-crypto/regulation-a-tokenized-offerings.html",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        }
      }
    },
    {
      "key": "funds",
      "label": "Tokenized fund vehicles under the 1940 Act",
      "examples": "the wrapper itself, across the products above",
      "cells": {
        "offering": {
          "status": "absent",
          "finding": "There is no tokenized fund registration path. The wrapper decides everything, and the token decides nothing. The Commission's declared position is that tokenized securities are still securities and market participants must adhere to the federal securities laws when transacting in them.",
          "source": "Commissioner Hester M. Peirce, statement on the tokenization of securities, 9 July 2025",
          "sourceDate": "2025-07-09",
          "url": "https://www.sec.gov/newsroom/speeches-statements/peirce-statement-tokenized-securities-070925",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "holderGates": {
          "status": "analogy",
          "finding": "The transfer agent and the token contract together. Which one wins when they disagree is not addressed by any rule observed, and the transfer agent rules predate the question by decades.",
          "source": "Exchange Act transfer agent rules",
          "sourceDate": "pre-existing",
          "url": "https://www.sec.gov/about/divisions-offices/division-trading-markets/transfer-agents",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "custody": {
          "status": "staff-position",
          "finding": "Section 17(f) and Rule 17f-2 govern, and Rule 17f-2 was written for paper. The Franklin relief runs to three paragraphs of that rule, subparagraphs (b), (e) and (f), which presuppose physical certificates: vault placement, physical segregation, notation on certificates, and physical examination. The rest of the rule stands.",
          "source": "Investment Company Act Section 17(f) and Rule 17f-2, 17 CFR 270.17f-2; Franklin Templeton no-action letter, 12 August 2026",
          "sourceDate": "2026-08-12",
          "url": "https://www.law.cornell.edu/cfr/text/17/270.17f-2",
          "accessed": "2026-08-17",
          "channel": "search-corroborated",
          "note": "Post-cutoff claim as to the relief. The identification of subparagraphs (b), (e) and (f) was observed in one result and not independently corroborated; treated as such in the article."
        },
        "register": {
          "status": "enacted",
          "finding": "The transfer agent rules 17Ad-1 through 17Ad-23 govern, and the master securityholder file is the official list of individual securityholder accounts. A transfer agent may keep that file on a distributed ledger. Nothing makes the ledger the file.",
          "source": "Exchange Act Section 17A; Rules 17Ad-1 through 17Ad-23; Concept Release on Transfer Agent Regulations, Release 34-76743, 31 December 2015",
          "sourceDate": "2015-12-31",
          "url": "https://www.sec.gov/files/rules/concept/2015/34-76743.pdf",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "valuation": {
          "status": "enacted",
          "finding": "Rule 2a-5 for registered funds, adopted 3 December 2020 in Release IC-34128, effective 8 March 2021, with fair value determination on the board or an overseen valuation designee. It is the single most load-bearing rule in this map for anything holding illiquid assets, and it says nothing about a token.",
          "source": "Investment Company Act Rule 2a-5, Release IC-34128",
          "sourceDate": "2020-12-03",
          "url": "https://www.sec.gov/newsroom/press-releases/2020-302",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "reporting": {
          "status": "enacted",
          "finding": "Section 30(a) of the Investment Company Act and Form N-CEN, unchanged by the presence of a token.",
          "source": "Investment Company Act Section 30(a); Form N-CEN",
          "sourceDate": "pre-existing",
          "url": "https://www.sec.gov/files/formn-cen.pdf",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "staff-position",
          "finding": "The most useful single fact in the map. Rule 17f-2 requires an independent accountant to verify the fund's assets at least three times each fiscal year, at least twice unannounced. The Franklin relief drops the paragraphs that assume a vault and a certificate and keeps the accountant: the conditions include independent accountant verification at least three times each fiscal year with two unannounced, plus separate wallets per fund, daily reconciliation, and board oversight. The examination survived the disappearance of the thing it was written to examine.",
          "source": "Rule 17f-2, 17 CFR 270.17f-2; Franklin Templeton no-action letter conditions, 12 August 2026",
          "sourceDate": "2026-08-12",
          "url": "https://www.cryptotimes.io/2026/08/13/franklin-templeton-gets-sec-relief-for-blockchain-fund-custody/",
          "accessed": "2026-08-17",
          "channel": "search-corroborated",
          "note": "Post-cutoff claim. The three-times-per-year verification with two unannounced appears both in the text of Rule 17f-2 as described in an independent search and in the reported conditions of the letter."
        }
      }
    }
  ],
  "jurisdictions": [
    {
      "key": "us",
      "label": "United States",
      "cells": {
        "framework": {
          "status": "analogy",
          "finding": "No purpose-built framework for tokenized real-world assets. Securities, fund, custody, transfer agency and commodities law applied by analogy, supplemented by staff positions that are not law. An innovation exemption for on-chain securities has been described in speeches and sketched in outline, and has not been adopted.",
          "source": "SEC Chairman and Commissioner statements on an innovation exemption; no adopted rule",
          "sourceDate": "2025",
          "url": "https://www.theblock.co/post/395159/lawmakers-weigh-tokenization-push-sec-preps-innovation-exemption-plan",
          "accessed": "2026-08-17",
          "channel": "search-corroborated",
          "note": "Sources this session disagree on when the exemption was first floated. It is recorded here as proposed-in-outline and not adopted, which is the part every source agrees on."
        },
        "offering": {
          "status": "enacted",
          "finding": "The Securities Act and the Investment Company Act, unmodified. Tokenized securities are still securities and the token does not change the exemption analysis.",
          "source": "Securities Act of 1933; Investment Company Act of 1940; Peirce statement, 9 July 2025",
          "sourceDate": "2025-07-09",
          "url": "https://www.sec.gov/newsroom/speeches-statements/peirce-statement-tokenized-securities-070925",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "register": {
          "status": "analogy",
          "finding": "No statute makes a ledger the register. The transfer agent's master securityholder file is the official list, a transfer agent may maintain it using a ledger, and in the depository pilot the token is expressly not the security. Separately, thirty-three states had enacted the 2022 UCC amendments by the end of 2025, creating controllable electronic records with control-based perfection and take-free protection, which is a property-law regime for the token, not a register-of-record regime for the asset.",
          "source": "Exchange Act Rules 17Ad-1 through 17Ad-23; UCC Article 12 as enacted by states",
          "sourceDate": "2025-12-31",
          "url": "https://www.orrick.com/en/Insights/2025/12/New-York-Enacts-2022-UCC-Amendments-A-New-Era-for-Digital-Asset-Transactions",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "venue": {
          "status": "pilot",
          "finding": "Registered alternative trading systems for security tokens, plus a depository tokenization pilot cleared by staff no-action on 11 December 2025 covering security entitlements in Treasury securities, large-cap equities and selected index ETFs, with pilot and public launch phased across 2026.",
          "source": "Regulation ATS; SEC Division of Trading and Markets no-action letter to DTC, 11 December 2025",
          "sourceDate": "2025-12-11",
          "url": "https://www.cadwalader.com/fin-news/index.php?eid=1003&nid=142",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "assurance": {
          "status": "staff-position",
          "finding": "The only observed assurance requirement aimed at a tokenized structure anywhere in this map: the independent accountant verification carried into the Franklin no-action conditions. It is a condition of relief for one fund complex, not a rule of general application.",
          "source": "Franklin Templeton no-action letter conditions, 12 August 2026",
          "sourceDate": "2026-08-12",
          "url": "https://www.crowdfundinsider.com/2026/08/296611-sec-clears-path-for-franklin-templeton-funds-to-use-onchain-money-market-vehicle-for-cash-management/",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        }
      }
    },
    {
      "key": "eu",
      "label": "European Union",
      "cells": {
        "framework": {
          "status": "enacted",
          "finding": "MiCA, Regulation (EU) 2023/1114, is in force and expressly does not apply to crypto-assets that qualify as financial instruments under MiFID II. Tokenized securities therefore fall outside MiCA and into MiFID II, the Prospectus Regulation, CSDR and the market abuse regime. The EU has a comprehensive crypto framework and a tokenized-securities gap in the same instrument, on purpose.",
          "source": "Regulation (EU) 2023/1114 (MiCA) Article 2(4); Directive 2014/65/EU (MiFID II)",
          "sourceDate": "2023",
          "url": "https://cosimodigital.com/learn/tokenized-securities-europe",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "offering": {
          "status": "enacted",
          "finding": "MiFID II and the Prospectus Regulation for tokenized financial instruments; MiCA Title III for asset-referenced tokens. Gold-backed tokens land in the asset-referenced category, which carries white paper approval, own funds, segregated reserves and redemption obligations. One search result this session reported zero approved applicants in that category for gold tokens across two years; it is a single secondary source and is treated as such.",
          "source": "MiCA Titles III; Prospectus Regulation (EU) 2017/1129",
          "sourceDate": "2023",
          "url": "https://crypto.news/tokenized-gold-is-a-4-4b-market-with-no-eu-rulebook/",
          "accessed": "2026-08-17",
          "channel": "search-observed",
          "note": "The zero-authorisation claim is single-sourced. See unverified list."
        },
        "register": {
          "status": "enacted",
          "finding": "The DLT Pilot Regime amended the MiFID II definition of financial instruments to cover instruments issued by means of distributed ledger technology, which closes the argument that a tokenized security escapes MiFID II by being on a chain. It does not make the ledger the register; it makes the ledger a permissible medium inside the pilot's perimeter.",
          "source": "Regulation (EU) 2022/858 (DLT Pilot Regime), amending MiFID II",
          "sourceDate": "2022-05-30",
          "url": "https://eur-lex.europa.eu/eli/reg/2022/858/oj/eng",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "venue": {
          "status": "pilot",
          "finding": "The DLT Pilot Regime entered into application on 23 June 2022 and has been used almost not at all. ESMA reported three authorised infrastructures with minimal live trading, having earlier declined to publish an interim report because none had been authorised at all, and has proposed making the regime permanent and more attractive.",
          "source": "Regulation (EU) 2022/858; ESMA report ESMA75-117376770-460, published 25 June 2025",
          "sourceDate": "2025-06-25",
          "url": "https://www.esma.europa.eu/sites/default/files/2025-06/ESMA75-117376770-460_Report_on_the_functioning_and_review_of_the_DLTR_-_Art.14.pdf",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "assurance": {
          "status": "unverified",
          "finding": "No assurance requirement specific to the tokenized layer was observed for EU tokenized securities.",
          "trail": [
            "MiCA Article 2 exclusion financial instruments MiFID II tokenized securities not in scope",
            "EU DLT Pilot Regime 2022/858 ESMA report number of authorised DLT market infrastructures low uptake review"
          ],
          "settles": "The DLT Pilot Regime's operating conditions read alongside CSDR reconciliation requirements for the same instruments.",
          "channel": "unverified"
        }
      }
    },
    {
      "key": "uk",
      "label": "United Kingdom",
      "cells": {
        "framework": {
          "status": "analogy",
          "finding": "No purpose-built framework. The declared route is that tokenization works inside existing law. The fund tokenisation Blueprint published on 24 November 2023 by the industry Technology Working Group sets out a baseline model using distributed ledger for the unitholder register, explicitly compatible with existing law and requiring no new legislation.",
          "source": "Technology Working Group Blueprint for implementation of fund tokenisation, 24 November 2023",
          "sourceDate": "2023-11-24",
          "url": "https://www.reedsmith.com/en/perspectives/2024/02/uk-fund-tokenisation-summary-technology-working-blueprint-implementation",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "offering": {
          "status": "enacted",
          "finding": "Existing UK regulated activity and prospectus rules, unmodified for tokenized form.",
          "source": "existing FCA rules for authorised funds",
          "sourceDate": "pre-existing",
          "url": "https://www.pwc.co.uk/industries/financial-services/understanding-regulatory-developments/fca-opens-door-to-tokenised-funds.html",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "register": {
          "status": "consulted",
          "finding": "The baseline model puts the unitholder register on a ledger within the existing framework, and the FCA published a consultation on progressing fund tokenisation, CP25/28, on 14 October 2025. A consultation is not a rule, and this cell should be reread when the policy statement lands.",
          "source": "FCA CP25/28, 14 October 2025",
          "sourceDate": "2025-10-14",
          "url": "https://cms.law/en/gbr/legal-updates/fca-consults-on-progressing-fund-tokenisation-cp25-282",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "venue": {
          "status": "pilot",
          "finding": "The Digital Securities Sandbox opened on 30 September 2024 under a joint Bank of England and FCA policy statement, PS24/12, running to December 2028 with an application window expected to close around March 2027. Firms admitted were not observed this session.",
          "source": "FCA and Bank of England PS24/12, Digital Securities Sandbox",
          "sourceDate": "2024-09-30",
          "url": "https://www.fca.org.uk/publications/policy-statements/ps24-12-digital-securities-sandbox-joint-policy-statement-final-guidance",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "assurance": {
          "status": "unverified",
          "finding": "No assurance requirement specific to a tokenized unitholder register was observed.",
          "trail": [
            "UK Technology Working Group fund tokenisation blueprint baseline model FCA 2023 2024 no legislative change required",
            "UK Digital Securities Sandbox FCA Bank of England go live 2024 2025 firms admitted"
          ],
          "settles": "CP25/28's proposed rules and the depositary oversight obligations they interact with.",
          "channel": "unverified"
        }
      }
    },
    {
      "key": "sg",
      "label": "Singapore",
      "cells": {
        "framework": {
          "status": "enacted",
          "finding": "No purpose-built framework, and MAS says so directly. Tokenised capital markets products are regulated under the Securities and Futures Act 2001 and the Financial Advisers Act 2001 in the same manner as their non-tokenised counterparts, on a same activity, same risk, same regulatory outcome basis. The clarity here is not a new regime, it is an explicit refusal to create one.",
          "source": "MAS Guide on the Tokenisation of Capital Markets Products, revised November 2025",
          "sourceDate": "2025-11",
          "url": "https://www.mas.gov.sg/-/media/mas/sectors/guidance/guide-on-the-tokenisation-of-capital-markets-products.pdf",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "offering": {
          "status": "enacted",
          "finding": "Offers of tokenised capital markets products may trigger SFA prospectus requirements unless an exemption applies, and intermediaries dealing or advising may need a capital markets services or financial adviser licence.",
          "source": "Securities and Futures Act 2001; Financial Advisers Act 2001",
          "sourceDate": "pre-existing",
          "url": "https://www.twobirds.com/en/insights/2025/singapore/monetary-authority-of-singapore-issues-revised-guide-on-tokenisation-of-capital-markets-products",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "register": {
          "status": "unverified",
          "finding": "Whether Singapore law recognises a ledger entry as the register of record for a capital markets product was not observed this session.",
          "trail": [
            "Singapore MAS tokenised capital markets products Securities and Futures Act existing law applies no new regime guidance",
            "MAS Project Guardian Global Layer One tokenised funds framework 2025 industry pilots report"
          ],
          "settles": "The register provisions of the Companies Act and the SFA read against the MAS Guide's treatment of the ledger.",
          "channel": "unverified"
        },
        "venue": {
          "status": "pilot",
          "finding": "Project Guardian is an initiative rather than law: MAS working with financial institutions on tokenisation pilots across asset management, fixed income and foreign exchange, with a Fixed Income Framework published in November 2025 and the Global Layer One infrastructure work alongside it. Pilots are evidence of intent, not of legal permission.",
          "source": "MAS Project Guardian; Guardian Fixed Income Framework, November 2025",
          "sourceDate": "2025-11",
          "url": "https://www.mas.gov.sg/-/media/mas-media-library/development/fintech/guardian/guardian-fixed-income-framework-v1_1.pdf",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "assurance": {
          "status": "unverified",
          "finding": "No assurance requirement specific to the tokenized layer was observed.",
          "trail": [
            "Singapore MAS tokenised capital markets products Securities and Futures Act existing law applies no new regime guidance"
          ],
          "settles": "The MAS Guide's sections on technology risk and record keeping, read in full.",
          "channel": "unverified"
        }
      }
    },
    {
      "key": "hk",
      "label": "Hong Kong",
      "cells": {
        "framework": {
          "status": "enacted",
          "finding": "No purpose-built framework. Two SFC circulars dated 2 November 2023 cover tokenisation of SFC-authorised investment products and the conduct of intermediaries in tokenised securities activities, on a same business, same risks, same rules basis.",
          "source": "SFC circulars on tokenised securities-related activities and tokenisation of SFC-authorised products, 2 November 2023",
          "sourceDate": "2023-11-02",
          "url": "https://apps.sfc.hk/edistributionWeb/api/circular/list-content?refNo=23EC52&lang=EN",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "offering": {
          "status": "enacted",
          "finding": "The prospectus regime and the offers of investments regime apply to public offers of tokenised securities; an offer that is neither authorised nor prospectus-compliant can reach professional investors only, or must fit another exemption.",
          "source": "SFC intermediaries circular, 2 November 2023; Hong Kong prospectus regime",
          "sourceDate": "2023-11-02",
          "url": "https://www.kingandwood.com/hk/en/insights/latest-thinking/tokenised-securities-hk-sfc-issues-important-guidance-for-intermediaries.html",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "register": {
          "status": "unverified",
          "finding": "Whether Hong Kong law recognises a ledger as the register of record was not observed this session.",
          "trail": [
            "Hong Kong SFC circular tokenised securities-related activities November 2023 requirements intermediaries"
          ],
          "settles": "The full text of the two 2023 circulars on ownership recordkeeping, plus the Companies Ordinance register provisions.",
          "channel": "unverified"
        },
        "venue": {
          "status": "unverified",
          "finding": "Which venues may list or trade tokenised securities, and under what conditions, was not observed at the level of a named instrument.",
          "trail": [
            "Hong Kong SFC circular tokenised securities-related activities November 2023 requirements intermediaries"
          ],
          "settles": "The SFC's licensing conditions for virtual asset trading platforms read against the tokenised securities circulars.",
          "channel": "unverified"
        },
        "assurance": {
          "status": "unverified",
          "finding": "No assurance requirement specific to the tokenized layer was observed.",
          "trail": [
            "Hong Kong SFC circular tokenised securities-related activities November 2023 requirements intermediaries"
          ],
          "settles": "The intermediaries circular's due diligence expectations, read in full.",
          "channel": "unverified"
        }
      }
    },
    {
      "key": "ch",
      "label": "Switzerland",
      "cells": {
        "framework": {
          "status": "enacted",
          "finding": "The one purpose-built law in this map. The DLT Act's amendments to the Code of Obligations entered into force on 1 February 2021, creating register uncertificated securities at Articles 973d to 973i. Switzerland did not apply old law by analogy; it wrote the category.",
          "source": "Swiss DLT Act; Code of Obligations Articles 973d to 973i, in force 1 February 2021",
          "sourceDate": "2021-02-01",
          "url": "https://www.pwc.ch/en/insights/regulation/partial-entry-swiss-dlt-act.html",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "offering": {
          "status": "enacted",
          "finding": "Swiss financial market law applies to the instrument; the DLT Act supplies the private-law form the instrument takes rather than a separate offering regime.",
          "source": "Swiss Code of Obligations Articles 973d to 973i",
          "sourceDate": "2021-02-01",
          "url": "https://pestalozzilaw.com/en/insights/news/legal-insights/ledger-based-securities-introduction-dlt-shares-switzerland/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "register": {
          "status": "enacted",
          "finding": "The answer the rest of the map does not have. A register uncertificated security exists on entry in an electronic register meeting statutory requirements for functional safety, integrity and transparency, and can be transferred and asserted only via that register. The ledger is not a mirror of the register. It is the register.",
          "source": "Swiss Code of Obligations Article 973d",
          "sourceDate": "2021-02-01",
          "url": "https://stach.ch/en/new-dlt-act-and-the-digitization-of-shares/",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "venue": {
          "status": "enacted",
          "finding": "The DLT legislative package also created a licence category for DLT trading facilities alongside the private-law changes.",
          "source": "Swiss DLT legislative package, financial market infrastructure amendments",
          "sourceDate": "2021",
          "url": "https://www.globalcompliancenews.com/2021/01/23/switzerland-swiss-legislative-package-on-dlt-07012021/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "unverified",
          "finding": "Whether the statutory register requirements carry an audit or examination obligation, and who performs it, was not observed this session. This is the single most valuable unverified cell in the file, because Switzerland is the only place where the ledger is the legal record and therefore the only place where examining the ledger is examining the register.",
          "trail": [
            "Swiss DLT Act ledger-based securities Article 973d Code of Obligations register of uncertificated securities in force 2021"
          ],
          "settles": "Article 973d's functional safety and integrity requirements read in the statute, plus any FINMA or audit-firm guidance on how compliance with them is tested.",
          "channel": "unverified"
        }
      }
    },
    {
      "key": "ae",
      "label": "United Arab Emirates",
      "cells": {
        "framework": {
          "status": "enacted",
          "finding": "Multi-regulator and, unusually, explicit about real-world assets. VARA's Virtual Asset Issuance Rulebook, in force 19 June 2025, defines an asset-referenced virtual asset broadly enough to cover tokenised real estate, commodities and revenue participations, including direct-ownership, fractionalised and wrapped forms, and requires a licence to place one in Dubai as a business.",
          "source": "VARA Virtual Asset Issuance Rulebook, in force 19 June 2025",
          "sourceDate": "2025-06-19",
          "url": "https://www.kayrouzandassociates.com/insights/vara-arva-issuance-requirements-dubai-2026",
          "accessed": "2026-08-17",
          "channel": "search-corroborated"
        },
        "offering": {
          "status": "enacted",
          "finding": "Category 1 issuance licensing under the VARA rulebook for asset-referenced virtual assets, alongside the separate regimes of the financial free zones.",
          "source": "VARA Virtual Asset Issuance Rulebook",
          "sourceDate": "2025-06-19",
          "url": "https://www.forbes.com/sites/irinaheaver/2025/12/29/uae-crypto-regulations-2025-recap-vara-rwa-tokens-and-2026-outlook/",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "register": {
          "status": "unverified",
          "finding": "Whether any UAE authority treats a ledger entry as the register of record, including for the Dubai land register, was not observed at the level of a named instrument.",
          "trail": [
            "UAE ADGM DFSA VARA tokenised real world assets regulatory framework 2025 rulebook"
          ],
          "settles": "The Dubai Land Department's tokenisation arrangements and the VARA rulebook's recordkeeping provisions, read directly.",
          "channel": "unverified"
        },
        "venue": {
          "status": "pilot",
          "finding": "The DIFC Tokenisation Sandbox launched in 2025 under an Innovation Testing Licence supervised by the DFSA, for piloting tokenised equities, sukuk and fund units before full launch.",
          "source": "DFSA Innovation Testing Licence; DIFC Tokenisation Sandbox, 2025",
          "sourceDate": "2025",
          "url": "https://practiceguides.chambers.com/practice-guides/blockchain-crypto-assets-2026/uae/trends-and-developments",
          "accessed": "2026-08-17",
          "channel": "search-observed"
        },
        "assurance": {
          "status": "unverified",
          "finding": "No assurance requirement specific to the tokenized layer was observed.",
          "trail": [
            "UAE ADGM DFSA VARA tokenised real world assets regulatory framework 2025 rulebook"
          ],
          "settles": "The VARA rulebook's reserve and reporting provisions for asset-referenced virtual assets, read directly.",
          "channel": "unverified"
        }
      }
    }
  ],
  "cellCount": 77,
  "statusCounts": {
    "enacted": 28,
    "analogy": 12,
    "staff-position": 8,
    "unverified": 12,
    "absent": 11,
    "pilot": 5,
    "consulted": 1
  },
  "unverifiedCount": 12,
  "unverifiedCells": [
    "private-credit/custody",
    "real-estate/holderGates",
    "eu/assurance",
    "uk/assurance",
    "sg/register",
    "sg/assurance",
    "hk/register",
    "hk/venue",
    "hk/assurance",
    "ch/assurance",
    "ae/register",
    "ae/assurance"
  ]
}