At first glance, tokenisation presents itself as a technology story, but in reality, for banks, fund managers, and financial institutions, it’s a regulation story first.
No matter how compelling the opportunity for faster settlements, better data or improved customer experience, ultimately it comes down to how tokenisation can be implemented from a compliance perspective.
New Zealand’s regulatory framework is still taking shape, but there are clues we can take from overseas, and businesses can prepare themselves now to take advantage of that opportunity when the time is right.
Overseas direction
Globally, regulation is moving quickly.
In April 2026 the Australian Securities and Investments Commission ("ASIC") announced new regulatory guidance relating specifically to digital assets and tokenised custody platforms.
The guidance includes licensing and capital requirements, and transaction and settlement standards, which will come into effect in April 2027.
This has evolved at a respectable pace. In just over a year, Australia has gone from consultation to passing legislation, and is now into an 18-month, clearly defined implementation roadmap with licensing, standards, and enforcement all locked in for 2027.
Elsewhere, the EU’s MiCA framework is introducing clearer rules for digital assets; Singapore is a global leader in structured digital asset regulation and sandbox environments; and the UK is actively integrating tokenisation into its broader financial market reform agenda.
Aside from the specifics of the regulations themselves, the direction of travel is clear. Regulators are overwhelmingly working out how, not if, to enable tokenisation.
Where things stand
In New Zealand, without specific tokenisation regulations in place, tokenised assets fit within general existing financial market regulations. A tokenised fund unit, for example, is still treated as a financial product, regardless of the technology that underpins it.
However, given the unique underlying nature of tokenised assets, there is a question of how exactly current regulations might be applied. This is perhaps the biggest barrier to adoption.
The Financial Markets Authority (“FMA”) has been clear that New Zealand is still in the early stages of exploring tokenisation, and is actively working with the industry to understand how it should be regulated.
Compliance hesitation is one of the common themes in industry submissions to the FMA. There are frequent questions around custody and asset ownership, how disclosure rules apply, and cross-border treatment of tokenised assets.
Ultimately, the players are keen to play the game, they just are not certain of the rules. But that doesn’t mean they can’t prepare for it.
Signals
There are a few clear themes that come through in consultation, commentary and industry feedback to the FMA.
- Technology-neutral regulation will remain
Rather than creating entirely new rules, tokenisation will likely be incorporated into existing frameworks. The focus will be on how current obligations apply, not creating new ones. - Custody and asset security will be critical
Questions around who holds assets, how they are safeguarded, and how investors are protected will sit at the heart of any framework. - Permissioned environments will lead early adoption
Initial use cases are more likely to sit within controlled, institutional environments, rather than fully open, decentralised systems. - Disclosure and transparency will evolve
Tokenisation introduces new forms of data and reporting. Regulators will want to ensure investors still receive clear, comparable information. - Collaboration with industry will continue
The FMA’s approach so far has been consultative, and that’s unlikely to change. Industry input will help shape how regulation develops.
Today’s opportunities
Tokenisation may be proven internationally, but it’s still emerging in New Zealand. It’s enabled here but it’s not yet fully defined, and that creates both hesitation and opportunity.
For example, four of six firms in an FMA fintech sandbox identified a pathway to market for products that may otherwise have been delayed by regulatory uncertainty.
That sends a strong signal that, when regulatory pathways become clearer, adoption follows.
Institutions don’t need to wait for a formal framework to start preparing now.
Pilot programmes or sandbox opportunities can translate into faster product launches, stronger institutional confidence, and a meaningful head start in areas like investor experience, efficiency, and access to new markets.
One place to start is with permissioned products that operate within controlled environments, where only approved participants can gain access and transact.
This creates a built-in safety net, with clear oversight, identity verification, and defined governance around how assets are issued and managed.
For regulators and institutions, it offers a more trusted pathway to adoption, balancing innovation with the safeguards expected in traditional financial systems.
Questions to ask yourself
1. What would be the easiest, or most in-demand test case for a tokenisation pilot?
2. How would an existing product work if it were tokenised?
3. What tokenisation expertise do we have across legal, operations, tech, and product teams? What would we need to launch our first tokenised product?
4. What partnerships might we need?
Tracey has been actively engaged in the digital assets space since 2021, building on over 20 years of experience across Australian superannuation and New Zealand financial services. That combination gives her a grounded perspective on where tokenisation creates genuine value for institutions versus where it adds complexity. Based in Auckland, she is actively involved with the New Zealand digital assets community through FinTechNZ, Blockchain NZ and the broader adviser ecosystem.
