6.3 Key Jurisdictions Already Moving
- What counts as movement in this section: published proposals, enacted rules not yet in force, and official programs operating or planned, each with a date
- What the United States, the European Union, the United Kingdom, Switzerland, Singapore, Hong Kong, Japan and the United Arab Emirates had in motion on 27 September 2026
- Which cells of the map in Section 6.2 the pending changes would alter, and when a date is set
- The calendar of dates already set between 30 September 2026 and 2029
Section 6.2 mapped what is in force on 27 September 2026 in eight jurisdictions, layer by layer: the United States, the European Union, the United Kingdom, Switzerland, Singapore, Hong Kong, Japan and the United Arab Emirates. This section follows the same eight jurisdictions one by one and records what each has in motion on the same date. "In motion" covers three things: proposals and consultations that a legislature, regulator or government has published but has not yet adopted; laws or rules already enacted or made final but not yet in force; and official programs that a central bank, regulator or government runs alongside the rules already in force.
Where a pending change would alter a cell of the map in Section 6.2, the jurisdiction's part below names that cell and, where its own source gives one, the date the change would take effect. Near its end, the section gives a calendar of the dates already set, running from 30 September 2026 to 2029. A date given below is the date its own source gives, and a step that is only expected is labeled as expected. Section 6 opened with the premise that the law behind a token is part of what the token is worth.
What Counts as Moving
Three kinds of movement. Some jurisdictions have statutes already passed that now await commencement: the United States' stablecoin statute, whose implementing rules are still proposals; the United Kingdom's new cryptoasset regime, whose full commencement on 25 October 2027 Section 6.2 already records; and Japan's 2026 amendment to its securities statute, whose start date is to be set by Cabinet Order. Each of these has a commencement date set or bounded by law. Some jurisdictions, the United Kingdom among them, are also revising pilots and sandboxes they created themselves: the European Union's Pilot Regime for market infrastructures based on distributed ledger technology (DLT), the United Kingdom's Digital Securities Sandbox, and Hong Kong's digital bond issuance, which its 2026 Policy Address plans to regularize. A third kind of movement puts public money and sovereign instruments on ledgers, or prepares to: the Eurosystem, the Swiss National Bank, the Monetary Authority of Singapore, the Hong Kong Monetary Authority and HM Treasury are each doing so, and in Japan the question now sits on a forum's agenda for study.
What is left out. This section does not repeat what Section 6.2 already records as in force, and it does not repeat the programs that Section 1.3 already describes: Singapore's Project Guardian, Global Layer 1 and BLOOM, and Hong Kong's Project Ensemble trials. It adds later dated steps only where a source gives them. Nothing here predicts which of these steps will happen; each is recorded with the status and the date that its own source gives.
The navy box holds items that were still proposals or under consultation. The red box holds laws or rules already enacted or made final, each with the date, or the latest date, on which it takes effect. The green boxes hold what is already in force and the programs operating or scheduled alongside it. Every status in the diagram is as of 27 September 2026. The diagram simplifies one thing: an item can sit in two boxes at once. The GENIUS Act is enacted while its implementing rules are still proposals, and a program can depend on a rule change that is itself still pending, as the UK sandbox's use of stablecoins does.
The United States: Rules for a Statute Already Passed
The stablecoin statute's rules. The GENIUS Act, enacted on 18 July 2025 (Section 6.2), required each primary federal stablecoin regulator, the Treasury and each state regulator to issue implementing rules "not later than 1 year after the date of enactment of this Act"1. On 27 September 2026 the federal implementing rules were still proposals2; three of them are set out here, in this order: the Federal Deposit Insurance Corporation's (FDIC) proposal of 10 April 20263; the Treasury's proposal of 18 August 2026 on issuance, offer and sale, with comments due 19 October 20264; and the Federal Reserve Board's proposal released on 24 September 20265. Because the primary federal payment stablecoin regulators had issued no final implementing regulation by 20 September 2026, the date 120 days before 18 January 2027, the effective-date rule in the Act's Section 20 now points to 18 January 2027, by this section's arithmetic12; the Treasury's proposal of 18 August 2026 says the effective date "is expected to be January 18, 2027"4.
What the proposals say about tokenized assets. The Federal Reserve Board's proposal would let a stablecoin issuer hold certain reserve assets "in tokenized form," on condition that the tokenized asset "confers legal rights that are identical to those of the non-tokenized form of the same asset"5; the proposal's own discussion, elsewhere, uses the looser words "materially the same"5. The FDIC's proposal says that "an IDI's tokenization of its deposit liabilities would not alter the legal status of those liabilities as 'deposits'"3; an IDI is an insured depository institution. On the map in Section 6.2, the United States cash-leg cell, which reads enacted and not yet in effect, has a date already set for change: 18 January 2027.
The securities side. The U.S. Securities and Exchange Commission's (SEC) proposed Regulation Crypto Assets, dated 18 August 2026 with comments due 20 October 2026, would create a new category of covered investment contracts; it "excludes investment contracts that involve crypto assets that are themselves securities (e.g., digital securities)"6, so a tokenized security stays under the offering routes it already uses. The SEC's proposed transfer-agent rules, dated 1 September 2026 with comments due 3 November 2026, "would permit a transfer agent to utilize a blockchain or other distributed ledger technology as its master securityholder file, or a component thereof, but it would not mandate it"7; the proposal would also have registrants report issues serviced "by tokenization model and security type"7. The SEC staff's no-action relief of 11 December 2025 for the pilot run by the Depository Trust & Clearing Corporation's (DTCC) Depository Trust Company (DTC) is described in Section 1.3. DTCC says tokenized trades were processed on 15 July 2026 with more than 30 firms taking part, and that this "sets the stage for the DTCC Tokenization Service to launch in October 2026"8; the launch is expected. The Digital Asset Market Clarity Act's failed cloture vote of 15 September 2026 and the SEC's temporary exemption for tokenized national market system (NMS) stock to 17 September 2031 are set out in Section 6.1.
The European Union: Rewriting Its Own Pilot
The DLT Pilot reform. On 4 December 2025 the European Commission proposed amending the DLT Pilot Regulation as part of a package on capital market integration and supervision9. The proposal would withdraw the asset-specific caps and raise the aggregate one, so that "all asset-specific caps should be withdrawn, whereas the aggregate cap should be raised to EUR 100 billion"9, and it would remove the time limits on permissions, which "should no longer apply"9. It would also provide that, where payments for assets denominated in EU currencies are settled in e-money tokens, those tokens reference EU currencies, and it would let an authorized crypto-asset service provider's trading platform apply for a specific permission to operate a DLT trading venue; separately, it would create a simplified regime for smaller DLT market infrastructures, capped at EUR 10 billion9. On 27 September 2026 the European Parliament's procedure file read "Awaiting committee decision," with the Economic and Monetary Affairs Committee's draft report dated 11 June 202610. Section 6.1 already covers the Council of the EU's progress report of 25 June 2026, whose main open issue was the size of the aggregate cap. The list of authorized DLT market infrastructures that the European Securities and Markets Authority (ESMA) still linked on 27 September 2026 shows six, the latest authorized on 26 November 202511, against three as of 31 May 2025 (Section 4.2). On the map in Section 6.2, the EU venue cell, a EUR 6 billion cap and permissions of up to six years, would change if this proposal is adopted; as proposed, its changes would apply 12 months after the amending regulation enters into force9.
Finality, collateral and the MiCA review. A second Commission proposal of the same date, 4 December 2025, would replace the Settlement Finality Directive with a regulation12. It would let settlement systems set up under the DLT Pilot Regime be designated, "subject to their compliance with the conditions set out in both Regulation (EU) 2022/858 and this Regulation"12, and it would bring cash, financial instruments and credit claims into the Financial Collateral Directive where they are issued or recorded on distributed ledger technology12. Section 6.1 already covers the Settlement Finality Directive's current protection of designated systems. The Commission's consultation on the review of the Markets in Crypto-Assets Regulation (MiCA) opened on 20 May 2026 and had been extended to 30 September 202613. The Commission's report on the review is due "By 30 June 2027" under MiCA's Article 14014, and the Commission says the report "may, if warranted, be accompanied by a new legislative proposal"13.
Central bank money. On 21 September 2026 the European Central Bank (ECB) said the Eurosystem "launched Pontes, a solution that enables wholesale transactions in tokenised assets to be settled in central bank money"15. Thirteen market participants and four DLT operators had completed onboarding at launch, and the Deutsche Bundesbank had also onboarded as a market participant; the participants include public institutions, not banks alone15. The ECB says "enhanced features and longer operating hours will be introduced gradually, with full implementation expected by 2028"15. Pontes is a settlement service; it changes no rule on the map in Section 6.2.
The United Kingdom and Switzerland: Sandboxes and What Follows Them
The cryptoasset regime. The Financial Conduct Authority (FCA) published its final rules on 30 June 202616. Firms can apply for authorization or to vary existing permissions "from 7am on 30 September 2026"16, and the new regime "is expected to come into force on 25 October 2027"16. The FCA says: "Over the coming months, we will continue to publish further policy consultations setting out our proposed rules and guidance"16. Section 6.2 already records the regime's commencement and the issuer rules' in-force date.
The sandbox. The Bank of England's dashboard lists 16 entrants approved at Gate 1 of the Digital Securities Sandbox (DSS). Two have been approved at Gate 2, the approval to begin live activity: HSBC on 13 July 2026 and ClearToken on 18 September 202617. Since 30 June 2026, firms in the sandbox "can now apply to use specific stablecoins as a settlement asset"17; the FCA and the Bank of England say this is "subject to conditions and to Treasury amendments to regulations"18. The authorities' feedback statement of September 2026 says: "We will consider, with the Treasury, whether to extend or further modify the DSS, or make changes to the wider CSDR framework"18, meaning the Central Securities Depositories Regulation (CSDR); it also promises a joint Roadmap "including specific target dates"18. HM Treasury says the first transaction of the Digital Gilt Instrument (DIGIT) "will take place by Q1 2027 on HSBC's digital securities depository (DSD), HSBC Orion"19, and that the government intends to lay legislation to amend the sandbox once parliamentary time allows19. On the map in Section 6.2, the UK cash-leg cell changes on 25 October 2027, when the FCA's stablecoin issuer rules come into force, while the sandbox's end date of 8 January 2029 stands unless legislation changes it.
Funds. The FCA's fund-tokenization policy statement has been in force since 30 April 202620. The FCA says it is open to applications "to modify or waive existing rules to allow the use of stablecoins to settle unit deals as an interim regime for funds before final stablecoin standards are introduced in October 2027"20.
Switzerland. On 13 May 2026, answering a parliamentary question, the Federal Council said the consultation on the stablecoin bill had ended in early February 2026 and its results were being evaluated, and that any changes would be put to Parliament with the dispatch21. SIX said on 5 May 2026 that the Swiss Financial Market Supervisory Authority (FINMA) had approved merging "its digital CSD SIX Digital Exchange AG into SIX SIS AG"22; a CSD is a central securities depository. The Swiss National Bank (SNB) runs Helvetia, a pilot for a wholesale central bank digital currency (CBDC), which the SNB itself calls wCBDC; the pilot "will continue until at least June 2028"23, and the SNB says it "does not, however, constitute a commitment on the SNB's part to introduce wCBDC on a permanent basis"23. Switzerland's stablecoin cell in Section 6.2 would change if a stablecoin bill is enacted, and on 13 May 2026 the Federal Council had not yet sent one to Parliament21.
Singapore and Hong Kong: Public Money First, Statutes Next
Singapore's stablecoin statute and bank capital. The Monetary Authority of Singapore's (MAS) consultation of September 2026 on amending the Payment Services Act, with comments due by 16 October 2026, would give MAS power "to designate a stablecoin as a 'Designated Systemic Stablecoin'"24, a designation that would apply wherever the coin is issued; it would also prohibit issuers of MAS-regulated stablecoins from paying holders interest or any other benefit attributable to holding the stablecoin, and require banks to issue MAS-regulated stablecoins through a separate non-bank entity24. The same paper says banks "may still issue tokenised deposits and MAS will be separately issuing guidance on this in due course"24. In April 2026 MAS proposed letting banks treat some cryptoassets on permissionless blockchains as Group 1 cryptoassets, subject to requirements, with exposures capped at "2% of the bank’s Tier 1 capital"25; the consultation closed on 18 May 2026 and no response had been published by 27 September 2026. Section 6.2 already records Singapore's deferral of the Basel standard "to 1 January 2027 or later." On the map in Section 6.2, Singapore's stablecoin cell would change if the proposed amendments to the Payment Services Act are enacted; MAS has said it will consult on the subsidiary legislation at a later date24.
Tokenized MAS Bills. MAS says it "will trial the issuance of tokenised MAS Bills in 2026, settled using wholesale CBDC through the Singapore dollar Test Network (SGD Testnet)"26. The auction MAS announced on 18 September 2026, for S$1 million, was scheduled for 21 September 2026, to mature on 30 September 2026; MAS's page, last updated on 18 September 2026, shows no auction results26. The trial issues are excluded from MAS's MAS Bills statistics26.
Hong Kong. The HKSAR Government's 2026 Policy Address, delivered on 16 September 2026, plans several steps27. The Policy Address says the Hong Kong Monetary Authority (HKMA) "will conduct tests on the operation of the tokenisation of Exchange Fund Bills by year’s end"27, and that it "is planning to implement central bank digital currency (CBDC) settlement and 24/7 operations under EnsembleTX by around the end of this year"27. It plans to regularize the issuance of digital bonds, and it plans a second-phase legal review, to be launched by the HKMA's expert group on tokenized bonds together with the Financial Services and the Treasury Bureau27; it also plans improvements by the Securities and Futures Commission (SFC) to its framework for tokenized products of gold and other real-world assets on licensed platforms27. These are plans set out in a policy address, not achievements. The Companies Registry, in guidance that prints no date, says: "Bonds, including those in the form of tokenised bonds, fall within the definition of 'debenture' in section 307 of the Companies Ordinance (Cap. 622)"28. Hong Kong's title cell in Section 6.2 ends with a legislative review to follow; on 16 September 2026 the Policy Address still described a second-phase legal review as one to be launched27.
Japan and the United Arab Emirates: New Base Statutes
Japan's crypto-asset transfer. Japan's Act No. 64 of 2026 amends the Financial Instruments and Exchange Act and the Payment Services Act; Japan's Financial Services Agency (FSA) summarized it in an outline of the bill that became the Act29. The Act was promulgated on 23 July 2026, and its main provisions take effect on a date set by Cabinet Order within one year of promulgation, so no later than 22 July 2027; Japan's official law database listed them as not yet in force on 27 September 202630. Act No. 64 moves the rules on crypto-asset trading into the Financial Instruments and Exchange Act, which will treat crypto-assets as a financial instrument distinct from securities; stablecoins stay under the Payment Services Act29. Section 6.2 already records Japan's current stablecoin regime under the Payment Services Act.
Japan's on-chain finance forum. On 25 September 2026 the FSA launched a forum on on-chain finance, together with other ministries and agencies31. Its initiative, run through the forum and two study groups, lists a public-private roadmap; putting the Bank of Japan's (BOJ) current accounts on-chain, as a topic for the forum; a review of the rules for the tokenization of various assets and for stablecoins; and the tokenization of government bonds32. None of these items is yet a rule.
The United Arab Emirates. Federal Decree-Law No. (32) of 2025, in force from 1 January 2026, keeps earlier Cabinet Resolutions in force: they "shall remain in force to the extent that they do not conflict with this Decree-Law and the Relevant Legislation, until repealed, amended, or replaced"33. The provision names Cabinet Resolution No. 111 of 2022, the instrument Section 6.2 calls Cabinet Decision No. 111/2022. The Decree-Law defines the relevant legislation as the Capital Market Law, the legislation governing the UAE's Capital Market Authority and the capital market, and the resolutions issued under them33. The 2022 Cabinet Decision that Section 6.2 describes therefore remains in force to the extent that it does not conflict with the 2025 Decree-Law and the relevant legislation, until it is repealed, amended or replaced33. On 13 April 2026 the Capital Market Authority announced a Virtual Assets Framework that raises the number of regulated activities from three to eight34; its alternative trading system module "extends to conventional multilateral trading facilities for securities and multilateral trading facilities dedicated to tokenized securities"34, and the announcement gives no effective date. Resolution No. (16/Chairman) of 2026, issued on 25 June 2026, lets entities licensed by the Central Bank of the UAE, except insurance companies, practice the activities in the Capital Market Authority's 2026 resolution on virtual asset service providers and the alternative trading system operator35.
The Calendar Already Set
The table below sets out sixteen dated steps already set among the jurisdictions above, drawn from the sources already cited in this section12467813141516181923242730; the T+1 date comes from Section 1.3 and the UK dates of 25 October 2027 and 8 January 2029 from Section 6.2.
| Date | Jurisdiction | Step | Status on 27 September 2026 |
|---|---|---|---|
| 30 September 2026 | United Kingdom | FCA authorization gateway opens for cryptoasset firms | Scheduled; final rules published 30 June 2026 |
| 30 September 2026 | European Union | Commission consultation on the MiCA review closes | Open, after an extension |
| October 2026 | United States | DTCC tokenization service launches | Expected by DTCC after production trades on 15 July 2026 |
| 16 October 2026 | Singapore | Consultation on the stablecoin amendments to the Payment Services Act closes | Proposed; subsidiary legislation to follow |
| 19 October 2026 | United States | Comments due on Treasury's GENIUS issuance, offer and sale rules | Proposed |
| 20 October and 3 November 2026 | United States | Comments due on Regulation Crypto Assets and on the transfer-agent rules | Proposed |
| By around end of 2026 | Hong Kong | Tests of tokenized Exchange Fund Bills; central bank money settlement and 24/7 operation for EnsembleTX | Planned in the 2026 Policy Address |
| 18 January 2027 | United States | GENIUS Act takes effect | Enacted; date fixed by the Act's effective-date rule |
| By end of Q1 2027 | United Kingdom | First digital gilt (DIGIT) transaction on HSBC Orion | Planned |
| By 30 June 2027 | European Union | Commission report on the MiCA review, possibly with a legislative proposal | Statutory deadline |
| By 22 July 2027 | Japan | Crypto-asset provisions of Act No. 64 of 2026 take effect | Enacted; not yet in force; date to be set by Cabinet Order |
| 11 October 2027 | EU, UK, Switzerland | Move to T+1 settlement | Coordinated by the authorities |
| 25 October 2027 | United Kingdom | Cryptoasset regime and FCA stablecoin issuer rules in force | Date set in legislation; issuer rules final; further FCA consultations to come |
| By 2028 | European Union | Pontes fully implemented | Operating since 21 September 2026; full implementation expected by the ECB |
| June 2028 at the earliest | Switzerland | End of the Helvetia wholesale CBDC pilot | Operating; the SNB says an extension is possible |
| 8 January 2029 | United Kingdom | Digital Securities Sandbox regulations cease | Unchanged; extension under consideration |
Reading the calendar. The dates in the table are of different kinds: comment deadlines, dates written into enacted texts, outer limits, and dates that a public authority or a company expects; the Step and Status columns together say which. Most of the dated steps above fall between October 2026 and October 2027. The programs' own end dates run to 2028 and beyond. No row above records a decision already taken to make a pilot permanent.
What the Movement Has in Common
Cash legs first. The United States stablecoin statute takes effect on 18 January 2027 and the United Kingdom's stablecoin issuer rules on 25 October 2027, while the EU's proposed reform of its DLT venue regime, and any change to the UK sandbox, had no adopted date on 27 September 2026. Singapore's and Switzerland's stablecoin changes remain proposals, as Section 6.2 already records for both.
Public money on ledgers. Pontes has been in operation since 21 September 2026. Helvetia is running until at least June 2028. The tokenized MAS Bills trial runs in 2026. EnsembleTX's central bank money settlement is planned for around the end of 2026. DIGIT's first transaction is due by the end of the first quarter of 2027. Putting the Bank of Japan's current accounts on-chain sits on Japan's forum's agenda as a topic for study. None of these is a statute; each is a program, a pilot or a stated plan.
Pilots and their end dates. The EU's proposed reform would remove the time limits on DLT Pilot permissions. The UK authorities say they "will consider" whether to extend or modify the sandbox. The SNB says Helvetia is not a commitment to a permanent wCBDC. Whether each of these pilots becomes permanent had not been decided on 27 September 2026. The map in Section 6.2 is dated 27 September 2026; the calendar above lists dated steps already in motion, some of which would change parts of that map.
Bridge to Section 6.4
Section 6.1 made the case that regulation is part of a tokenized asset's value; Section 6.2 drew the map of the rules in force; this section has dated the movement already under way in eight jurisdictions. Section 6.4 explains why the regulatory question sits at the center of the rest of this paper, and what a second paper covers. Section 5.6 will take up jurisdictional fragmentation itself as a risk to projects. The premise behind all three sections is set out in the Section 6 introduction.
- On 27 September 2026 most of what the eight jurisdictions had in motion was not law in force: proposals and consultations, and rules being written for statutes already passed, alongside official programs running next to the rules in force.
- On 27 September 2026 the United States had an enacted stablecoin statute whose implementing rules were still proposals; by the Act's own effective-date rule it takes effect on 18 January 2027. The SEC's proposed Regulation Crypto Assets would exclude investment contracts involving crypto assets that are themselves securities, while its proposed transfer-agent rules would permit a blockchain as the master securityholder file.
- The European Commission has proposed rewriting the EU's DLT Pilot Regime, raising the aggregate cap from EUR 6 billion to EUR 100 billion and removing the time limits on permissions, but on 27 September 2026 the proposal was still awaiting a committee decision in Parliament; on 21 September 2026 the Eurosystem launched Pontes, which enables wholesale transactions in tokenized assets to be settled in central bank money.
- As of 27 September 2026, two of the UK sandbox's 16 entrants had been approved to begin live activity and the authorities said they will consider whether to extend or further modify it; on 13 May 2026 Switzerland's Federal Council had not yet sent its stablecoin bill to Parliament, and the SNB's wholesale CBDC pilot runs until at least June 2028. MAS had scheduled a tokenized MAS Bill auction for 21 September 2026 under its 2026 trial settled in wholesale CBDC, and Hong Kong's 2026 Policy Address planned tests of tokenized Exchange Fund Bills by the end of 2026 and central bank money settlement for EnsembleTX by around the end of 2026.
- Japan has enacted a law that moves the rules on crypto-asset trading into its Financial Instruments and Exchange Act, which will treat crypto-assets as a financial instrument distinct from securities, by 22 July 2027 at the latest; in the UAE, the 2022 federal Cabinet Decision stays in force where it does not conflict with the 2025 Decree-Law and the relevant legislation, and a federal framework announced on 13 April 2026, with no effective date given, extends to trading facilities for tokenized securities.