Within five days, the two largest capital markets in the world made a move on tokenised finance, and they moved in opposite directions. The Eurosystem switched on a settlement rail that puts central bank money behind tokenised wholesale transactions. The SEC opened tokenised equity trading through a temporary exemption, two days after the Senate declined to give it a statute. Both are described as progress on tokenisation. They’re not the same kind of progress, and for anyone structuring a financing round with a token leg, the difference is the part that matters.
Pontes settles the cash leg. That’s the whole point.
The Eurosystem launched Pontes on 21 September 2026. It links market DLT platforms to TARGET Services so that wholesale tokenised transactions can settle in central bank money (ECB, 21 Sep 2026).
The architecture is worth reading closely, because it tells you what the ECB was willing to concede and what it wasn’t. Participants choose between two paths: settle on the Eurosystem’s own DLT platform using cash tokens, or settle through T2, the real-time gross settlement system. Either way, final settlement of the cash leg is achieved once the corresponding transaction completes in T2. A mechanism called Hash-Link synchronises delivery-versus-payment so that both legs move or neither does (ECB, Pontes).
So the ledger can be new. The finality cannot. The ECB let the securities leg live on distributed infrastructure and kept the cash leg anchored in the system whose legal certainty it already controls. That’s a deliberate design choice, not a technical compromise.
Eligibility runs to banks with T2 access, authorised central securities depositories, operators of DLT settlement systems, payment system operators, central counterparties, and supervised credit institutions, investment firms and market operators. Thirteen institutions and four ledger operators were connected at launch, among them Deutsche Bank, Santander, Société Générale, KfW and the European Investment Bank.
Two qualifications keep this in proportion. Pontes runs on limited operating hours for now and will only reach full capability, with longer hours and enhanced features, by 2028. A longer-term programme, Appia, is being designed alongside it. This is the first stage of a build, not a finished market.
The ECB also began preparatory work to invest part of its own funds, outside monetary policy operations, in tokenised securities settled through Pontes, starting with euro-denominated euro area public sector and European supranational debt (ECB, 21 Sep 2026). No amount has been disclosed. The signal is not the size. It’s that the institution operating the rail intends to be a user of it.
The retail leg is on a slower and more conditional clock
Pontes addresses wholesale settlement between financial institutions. The digital euro addresses the public, and it runs on a separate and considerably longer calendar.
Thirty-six payment service providers were selected from more than fifty applicants to join the pilot, working alongside the ECB and nineteen national central banks over a twelve-month exercise starting in the second half of 2027 (ECB, 14 Jul 2026). In September the Eurosystem opened a call for online and mobile merchants in the euro area to take part in that pilot (ECB, 15 Sep 2026). A possible public issuance is pencilled in for 2029.
That last date carries a condition attached to it that is easy to skip over: it depends on the European legislative framework being completed. The pilot can run on the ECB’s own authority. The issuance cannot. Anyone building a business case on a 2029 digital euro is building on a political outcome, not an engineering schedule.
The Innovation Exemption is a sandbox with a sunset
On 17 September 2026 the SEC issued an order granting temporary relief so that Tokenized Securities Venues can trade tokenised NMS stock using automated market makers and liquidity pools without registering as exchanges under the Securities Exchange Act of 1934. A parallel exemption means firms supplying liquidity to those pools are not captured by the definition of a dealer. The relief expires five years after publication, on 17 September 2031 (SEC, 17 Sep 2026).
The conditions define the thing more accurately than the headline does. Venues face limits on the number of symbols and on trading volume. Tokenised stock must carry rights identical to the underlying NMS stock. Smart contracts must be auditable, public, and deployed on public permissionless ledgers, while the automated market makers themselves are permissioned. Trading must halt when the primary exchange halts. Operations and trading activity must be publicly disclosed. And where an unaffiliated party creates a tokenised version of a company’s stock, the issuer must be notified and given an opportunity to object before it trades (SEC, 17 Sep 2026).
Capped symbols, capped volume, mandatory disclosure, a five-year clock and a request for comment attached to the order. This is a supervised experiment that the Commission has designed so it can watch a market form before deciding whether to write rules for it.
The timing explains the instrument. Two days earlier, on 15 September, the Senate’s cloture vote on the Digital Asset Market Clarity Act failed 49 to 50 on the official record, eleven short of the sixty required, ending market structure legislation for the year (U.S. Senate, 15 Sep 2026). The obstacle was ethics language on officials’ crypto holdings rather than the market structure framework itself, which makes the failure more about the calendar than about the substance. Either way, the SEC was left with administrative tools and used them.
An exemptive order can be narrowed, conditioned or allowed to lapse by a future Commission. A statute cannot, not without Congress. That asymmetry is the entire difference between the two moves made this month.
The unresolved question is collateral. Not trading.
The more consequential development for institutional adoption came earlier and attracted less attention. On 12 August 2026, SEC staff issued a no-action letter allowing Franklin Templeton’s registered funds and ETFs to hold shares of its tokenised government money fund, recorded through the BENJI system, including as collateral for securities lending. The relief waives custody provisions of Rule 17f-2 that were written for paper certificates. The tokenised fund itself is modest, around 726 million dollars, but the fund complex it becomes eligible to sit inside is roughly 872 billion (Banking Exchange, Aug 2026).
That’s the pattern worth tracking. A tokenised money market fund is a registered security: holders are verified, transfer is restricted to approved wallets, and it pays a yield tracking short-term Treasury rates net of fees. A payment stablecoin is not a security and may not pay its holders a yield, but it moves to any address without permission. They’re not competing products. They are answers to different questions, and the institutional question of the moment is which one a fund is permitted to hold against a position, not which one trades faster.
A word on market sizing, because the numbers in circulation are unreliable. Estimates of non-stablecoin tokenised real-world assets in mid-2026 range from roughly 23 to 60 billion dollars depending on whether the count includes only freely tradable on-chain assets or also tokenised funds, centralised wrappers and assets committed but not yet trading. Any single headline figure presented without its methodology should be treated as marketing.
What this changes for a founder
For a founder raising between pre-seed and Series A with a token component in the structure, the honest answer is that neither decision makes the token easier to justify. They change what it can stand on.
In Europe, institutional settlement now has a rail with a public operator behind it and a named longer-term programme. That’s a durable foundation, and it’s also a slow one: limited hours today, full capability in 2028, a retail leg contingent on legislation for 2029. If your token needs to settle against institutional counterparties, the path exists and it has a schedule you can plan against.
In the United States, distribution through a tokenised venue is available now, inside volume caps, until September 2031, under an order rather than a law. A five-year window is a real commercial opportunity. It’s not a foundation for a cap table, which is a ten-year object. Anyone modelling on it should model the reversal alongside the base case.
None of which changes the question I put to founders first, before any of this. Start from the economic model, not from the structure. A token earns its place when it performs an operational function the business actually needs, and a regulatory opening doesn’t create that function where it’s absent. What these two weeks changed is the quality of the ground under a token that already has one, and the ground is now measurably firmer on one side of the Atlantic than the other.
Frequently asked
What is Pontes and what does it change for tokenised securities?
Pontes is the Eurosystem’s settlement solution, launched on 21 September 2026. It links market DLT platforms to TARGET Services so that wholesale transactions in tokenised securities can settle in central bank money. The securities leg can live on a distributed ledger, but final settlement of the cash leg still happens in T2, the system whose legal certainty the ECB already controls.
What does the SEC’s Innovation Exemption allow, and for how long?
Since 17 September 2026, Tokenized Securities Venues can trade tokenised NMS stock through permissioned automated market makers and liquidity pools without registering as exchanges. Conditions apply: caps on symbols and volume, rights identical to the underlying stock, public disclosure, and a right for issuers to object to third-party tokenisation. The relief expires on 17 September 2031 and, being an order rather than a statute, can be narrowed or allowed to lapse by a future Commission.
When could a digital euro be issued?
A twelve-month pilot with 36 payment service providers starts in the second half of 2027. A possible public issuance is pencilled in for 2029, but only if the European legislative framework is completed first. The pilot rests on the ECB’s own authority; the issuance does not.
Does this make a token easier to justify in a pre-seed to Series A round?
No. A token earns its place when it performs an operational function the business actually needs, and a regulatory opening does not create that function. What changed is the ground under a token that already has one: a durable but slow settlement path in Europe, and a five-year distribution window in the United States that should not be treated as a foundation for a cap table.
Related reading: Equity, Tokenomics, or Hybrid: which structure fits your fundraising?
Sources and references
- European Central Bank, Pontes, official service page (architecture, dual settlement model, Hash-Link, eligibility).
- European Central Bank, press release on the launch of Pontes and the investment of own funds in tokenised securities, 21 September 2026.
- Bloomberg, “ECB Launches Key Link Between Blockchain and Euro Payment System”, 21 September 2026.
- Euronews, “ECB launches ‘Pontes’ to settle tokenised assets in central bank money”, 21 September 2026.
- European Central Bank, “ECB selects 36 payment service providers to join digital euro pilot”, 14 July 2026.
- European Central Bank, “Call for online and mobile merchants to participate in digital euro pilot”, 15 September 2026.
- Banque de France, “Eurosystem moving to next phase of digital euro project”.
- European Central Bank, Macroprudential Bulletin, “Tokenised money market funds: new technology, familiar risks?”, 2026.
- U.S. Securities and Exchange Commission, press release 2026-90, “SEC Issues Innovation Exemption to Facilitate the Trading of Tokenized NMS Stock and Request for Comment”, 17 September 2026.
- Reuters, “US securities regulator rolls out five-year exemption for tokenized stock trading”, 17 September 2026.
- The Wall Street Journal, “Tokenized Stocks Get U.S. Regulator’s Green Light to Come Ashore”, September 2026.
- Jones Day, “The SEC’s New Innovation Exemption: Five-Year Relief for Trading on Tokenized Securities Venues”, September 2026.
- U.S. Senate, roll call vote on the motion to invoke cloture on H.R. 3633 (Digital Asset Market Clarity Act), 15 September 2026; see also CNBC coverage.
- Lowenstein Sandler, “Crypto Brief”, JD Supra, 17 September 2026.
- Banking Exchange, coverage of the SEC staff no-action letter to Franklin Templeton, August 2026.
- AYAKO Partners internal analysis.