In our last episode we compared the global race across Asia, Europe, and the US to see who might lead the charge in real estate tokenization.
The spotlight was on speed, ambition, and capital. But here is the catch: even the fastest runners cannot win if they are playing by different rulebooks. This week we are zooming in on those rulebooks—the regulatory frameworks that quietly decide how accessible, liquid, and trustworthy tokenized assets really are. From Dubai’s bold Virtual Assets Regulatory Authority to Europe’s MiCA framework, and from Singapore’s clear pathways to the SEC’s hesitations, these differences do not just matter for lawyers.
They matter for you as an investor, because they determine where your money can actually move safely and profitably.
🏙️ Stay on top of the future of investments
(Real Estate Tokenization News, 14th of September 2025)
Nasdaq pushes for tokenized securities trading on its main exchange
Nasdaq has officially filed a proposal with the U.S. Securities and Exchange Commission to allow tokenized securities to trade on its primary market. If approved, this would mark the first time a major U.S. exchange integrates tokenized assets at scale—a breakthrough that could unlock institutional liquidity. Read more →
Galaxy Digital tokenizes its common stock
Galaxy Digital has become the first U.S.-registered company to offer shareholders the option of converting their stock into blockchain-based tokens. Through a partnership with Superstate, investors can now hold and transfer their equity fully on-chain—a proof of concept for how real estate tokens could one day work at scale. Read more →
BlackRock files for a digital liquidity fund with tokenized real estate exposure.
In a recent SEC filing, BlackRock disclosed plans for a new Digital Liquidity Fund that will invest in tokenized private credit and real estate assets. The move signals that the world’s largest asset manager is preparing to bring tokenization into mainstream institutional portfolios.
Read more → (SEC filing, Sept 10, 2025)
Dubai’s Virtual Assets Regulatory Authority (VARA):
Dubai is the boldest player in tokenized real estate.
Its Virtual Assets Regulatory Authority (VARA) has created one of the world’s first dedicated frameworks for digital assets, including real estate tokens. This makes Dubai attractive for developers and investors because rules are already in place for issuance, compliance, and even secondary trading.
Unlike many Western markets, Dubai is signaling, “You can build here now.”
First city with a dedicated crypto and token regulator (VARA)
Clear process for licensing platforms that handle tokenized assets
Tax-friendly environment encourages cross-border capital inflows
Secondary market trading permitted under regulation
💡Relevant & Remarkable Facts
(Did you know…?)
Over $25B in real-world assets have already been tokenized. But most of these tokens see almost no trading activity, behaving more like illiquid property than digital securities. Source
Fewer than 15% of real estate firms have fully launched tokenization programs. Nearly half are still experimenting, waiting for clearer rules, lower costs, and better infrastructure. Source
Deloitte forecasts real estate tokenization will soar from under $0.3T today to $4T by 2035. That’s a 13-fold jump that could reshape global property investment. Source
Europe’s MiCA Regulation: Harmonizing Token Rules Across 27 Countries
Europe is trying to build trust through bureaucracy.
The Markets in Crypto-Assets Regulation (MiCA) is the EU’s comprehensive law covering digital assets, including tokenized securities. It is slower to roll out than Dubai’s VARA, but it offers something equally valuable: harmonization across 27 countries.
For investors, this means more paperwork but also long-term certainty.
Applies across the EU with a single regulatory framework
Covers security tokens and stablecoins explicitly
Strong consumer protection and compliance requirements
Slower adoption but stable long-term rules for institutional investors
Singapore is the clarity champion.
The Monetary Authority of Singapore (MAS) treats most real estate tokens as securities, requiring licensing for issuance and trading. This strict but clear approach has turned Singapore into a hub for institutional deals and tokenized funds.
Investors know exactly what category they are dealing with and what rules apply.
MAS defines tokens as securities when tied to income or ownership
Licenses required for asset managers and trading platforms
Regulatory sandbox allows controlled innovation
Popular base for fund tokenization and cross-border issuance
Hong Kong’s Securities and Futures Commission
Hong Kong is the legal pioneer in Asia.
Its Securities and Futures Commission (SFC) explicitly requires that tokenized securities can only be offered to professional investors and that platforms need special licenses. This makes the market more exclusive, but it also sets a clear path for serious players.
The SFC’s rules helped launch Asia’s first tokenized real estate fund.
Security tokens treated like traditional securities under SFC law
Type 1 and Type 7 licenses required for platforms
Restricts offers to professional investors only
Case study: Asia’s first tokenized fund launched here
Japan’s FSA and GATES Model: A $200 Billion Push for National Tokenization
Japan is going all in on national tokenization.
The Financial Services Agency (FSA) has supported the launch of GATES Inc., aiming to tokenize up to $200B worth of Tokyo properties. Unlike other regions, Japan is moving toward integrating tokenization into mainstream capital markets, not just niche deals.
This makes it one of the boldest government-backed moves globally.
Government support via FSA ensures regulatory clarity
GATES Inc. project targeting $200B in Tokyo real estate
Emphasis on large-scale tokenization of prime assets
National push, not just private initiatives
The United States and the SEC: A Hesitant Giant Falling Behind
The United States is the hesitant giant.
The Securities and Exchange Commission (SEC) treats most real estate tokens as securities but has not created a clear, dedicated framework for tokenization. This leaves investors and platforms in legal limbo, relying on exemptions or costly compliance routes.
As a result, the US risks losing ground to faster-moving regions like Dubai and Asia.
SEC applies existing securities laws to tokenized assets
No dedicated framework for real estate tokenization
Heavy focus on investor protection and enforcement
Uncertainty has slowed innovation and deal flow
Indonesia’s Financial Services Authority: A Sandbox for Tokenized Property
Indonesia is positioning itself as a rising hub for digital assets in Southeast Asia.
The Financial Services Authority (Otoritas Jasa Keuangan, OJK) recently introduced Regulation No. 27 of 2024, which covers digital financial assets, including crypto and potential tokenized real estate. While the rules are still new, the framework gives investors and platforms a clearer pathway, moving beyond the older commodity-style oversight.
With Bali Invest and others pushing forward, Indonesia may quickly emerge as a key regional market for tokenized property.
OJK licenses required for trading platforms, custodians, and exchanges
Regulatory sandbox launched, with GORO as the first property tokenization pilot
Strong focus on governance, transparency, and consumer protection
Transition underway from commodity rules (Bappebti) to full OJK oversight
The race is on
That’s a wrap!
Talk soon.
Kevin
Do you have any questions about real estate tokenization?
We’ve helped global investors navigate the emerging world of tokenized real estate with projects like Segara Seaside and Lovina Retreat & Wellness Center. But before diving into details, we first make sure it’s the right fit for you.
That’s why we invite you to schedule a 15-minute Qualification & Insights Call with our team.
On this call, we’ll:
Review your current setup and investment goals
Assess if Bali real estate and tokenization align with your needs
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