A principles-based, technology-neutral approach can give financial institutions room to innovate without waiting for a bespoke New Zealand tokenisation rulebook.
In financial innovation, speed is easily mistaken for progress. As other markets move from tokenisation experiments towards implementation, it would be easy to conclude that New Zealand is being left behind.
That conclusion may be wrong. The more important question is not whether New Zealand is first, but whether it creates the conditions for firms to innovate with confidence and a clear understanding of how existing regulatory principles apply.
For our Asia-Pacific Sales Director, Vincent Turcotte, the question is not theoretical. We have been building institutional tokenisation capability globally, including through Apex Tokeny. In 2025, we acquired a majority stake in Tokeny, whose solutions had been used to tokenise more than US$32 billion in assets.
“When I look to New Zealand, I’m seeing a deliberate building of the foundations through consultation and real-world testing, rather than a rush to create technology-specific rules,” Vincent says. “That gives the market room to innovate while maintaining appropriate protections.”
The distinction matters. Tokenisation can change how an asset or financial activity is represented, administered, or transferred, but it does not automatically change the underlying economic activity, legal obligations, or risks attached to it. A durable regulatory approach therefore needs to focus first on what a product or service does, not simply the technology used to deliver it.
As technology changes, a technology-neutral approach gives the framework a better chance of remaining relevant.
That direction is visible in the approach of New Zealand’s Financial Markets Authority (“FMA”). In September 2025, the FMA opened a discussion on tokenisation, asking how the current market and regulatory environment was helping or hindering domestic activity, what benefits and risks tokenisation could create, and what the future environment should look like. The regulator described itself as pro-innovation, engagement-led, and technology-neutral.
The consultation subsequently drew more than 20 submissions from businesses, exchanges, fund managers, banks, law firms, and industry groups. In its March 2026 update, the FMA said submitters had emphasised that regulatory fragmentation and uncertainty were constraining adoption, increasing risk, and increasing the likelihood that New Zealand would fall behind international developments.
Consultation has also been accompanied by practical testing. The FMA has used its FinTech sandbox to test innovative propositions in practice. Six firms entered the pilot and four identified a pathway to market where regulatory uncertainty or other barriers might otherwise have prevented launch. The process gave both the regulator and participating firms practical insight into where existing regulation works, where uncertainty remains, and where change may be required.
Consultation and testing give policymakers evidence about where new safeguards may be needed, while helping firms understand how existing requirements apply to their propositions.
That experience also aligns with what we are seeing globally. Our 2026 tokenisation research found that half of the 100 asset-management executives surveyed had already introduced tokenisation in some form, while only 7% were fully confident in their in-house technology capability. The challenge is increasingly shifting from proving that tokenisation works to building the operating, regulatory, and distribution capabilities required for broader adoption.
Our own work reinforces that point. Apex Digital 3.0 brings together tokenisation with fund administration, custody, transfer agency, digital onboarding, and related digital-finance infrastructure. The practical lesson is that tokenisation is not a standalone technology project. Moving regulated assets on-chain requires the surrounding operating model and controls to work together.
This is already visible in live fund applications. We have described how fund tokenisation is moving from experimentation into operational deployment, with regulated structures using blockchain infrastructure to address settlement delays, operational friction, and distribution constraints without changing the underlying investment strategy or regulatory obligations.
For New Zealand financial institutions, evolving regulation is no reason to put tokenisation strategies on hold. Firms can focus on use cases that address genuine market problems, assess them against existing obligations, establish appropriate governance and operational controls, and engage regulators early where uncertainty remains.
The organisations best positioned as the market develops will be those that use this period to establish viable use cases, build operating capability, and understand how existing legal and regulatory obligations apply, rather than waiting for a bespoke tokenisation rulebook.
That does not remove the need for greater regulatory certainty. The FMA has itself said there is a strong economic and regulatory case for primary legislation reform to establish a purpose-built and enduring legal framework for virtual assets, and that it will continue to advise government on legislative gaps, develop guidance with industry, and use regulatory tools such as exemptions or designations where appropriate.
The challenge is to provide that certainty without locking the market into a highly prescriptive, token-specific framework before the technology and its applications have fully matured. The goal should be clear and enduring expectations around activities, risks, and responsibilities, with sufficient flexibility for the technology and market to evolve.
“The opportunity for New Zealand is to create the conditions for tokenisation to develop with confidence,” Vincent says. “That means providing credible participants with sufficient regulatory certainty to invest, experiment, and scale, supported by appropriate protections.”
Get that balance right, and New Zealand’s measured approach could prove to be an advantage rather than a delay.
