Tokenization and industrial scale

European banks issue more than 2 million structured products per quarter. Most tokenization platforms are still celebrating their first hundred. Everyone says tokenization will revolutionize finance — but if you compare it to how banks already issue structured products, one thing becomes clear: tokenization is still far from industrial scale.

Structured products issued
2M+
per quarter in Europe, by traditional banks
Tokenized assets live
~100s
on most platforms, celebrated as milestones
Cost per tokenized asset
10–100×
vs. templated structured note issuance today

What banks already do at scale

Large banks have built fully industrial issuance platforms over decades. Behind every certificate or autocall sits a pipeline that most people never see.

Product structuring & approval
Workflow engines coordinate front office, middle office, back office, and legal sign-off — often within hours.
ISIN generation & product referencing
Each product gets a unique identifier instantly, enabling settlement, reporting, and regulatory compliance.
Pricing engine integration
Traders calibrate pricing models live. Thousands of products can be re-priced simultaneously when markets move.
Distribution to exchanges & liquidity venues
Quotes flow to SIX, Euronext, and OTC desks automatically. Hundreds of thousands of products are live and tradeable simultaneously.
Concrete example

A Swiss private bank wants to issue 500 capital-protected notes on a basket of clean energy equities. Using a major structuring bank's platform, the notes can be structured, approved, ISIN-assigned, priced, and live on SIX within a single business day — without any bespoke engineering.

What tokenization looks like today

Most tokenization projects are built around a single-asset model: one real-world asset, one token, one smart contract deployed for that specific deal. While technically interesting, it is far from operational scale.

Tokenization today
Artisanal model
  • One asset → one smart contract
  • Manual deployment per issuance
  • Lifecycle managed externally or manually
  • Limited trading venue integration
  • No standardized on-chain product schemas
Concrete example

A tokenization platform tokenizes a €10M commercial real estate loan. Engineers write and deploy a bespoke smart contract for that single asset. When the loan is partially repaid, someone updates the contract manually. Coupon payments are tracked off-chain. This is not a pipeline — it is a craft operation.

The economic gap: what things actually cost

The tokenization industry rarely publishes cost-per-issuance data, which makes comparison difficult. But order-of-magnitude estimates from practitioners tell a clear story.

Cost driver Traditional (templated) Tokenization (today)
Smart contract / product engineering ~€0 marginal
Template reused
€20k–€100k+
Bespoke per deal
Legal & structuring opinion ~€2k–5k
Standardized docs
€20k–50k
Novel legal territory
ISIN / product registration Automated
Via NNA integration
Manual or absent
Audit & security review Covered
By platform certification
€10k–30k
Per smart contract
Time to issuance Hours to days Weeks to months
Worked example

A €5M private credit note tokenized today might cost €80k–€150k in engineering, legal, and audit fees before a single investor sees it. The same structured note issued through a major bank's certificate platform costs €5k–€15k all-in, with a time-to-market measured in hours. The economics flip only when platforms achieve template-driven issuance where marginal cost per product approaches zero — as it does in traditional issuance. That point does not yet exist at meaningful scale.

The regulatory wall: what traditional platforms handle automatically

Much of the operational cost in traditional structured product issuance is regulatory compliance — and most of it is automated. Tokenization platforms largely bypass this machinery, which limits who can buy, where products can be sold, and what reporting is required.

ISIN issuance & NNA registration
Traditional: automated via integration with national numbering authorities. Products are globally identifiable from day one.
Gap: mostly manual or absent
PRIIP KID
Traditional: generated automatically from product parameters. Required for any retail distribution in the EU.
Gap: almost entirely missing
MiFID product governance
Traditional: target market, complexity classification, and distribution restrictions built into the issuance workflow.
Partial: handled off-chain
Transaction reporting (EMIR / MiFIR)
Traditional: automated reporting to trade repositories. Real-time for derivatives, T+1 for securities.
Partial: requires external bridge
Prospectus / exemption management
Traditional: exemption thresholds tracked automatically. Prospectus triggered when required.
Gap: typically manual
DLT Pilot Regime (EU, since 2023)
Traditional: not applicable — legacy rails are the default.
Opportunity: sandbox for tokenized securities
The practical consequence

A tokenized product that lacks an ISIN cannot be held in most custodian systems, cannot be reported under MiFIR, and cannot be distributed to retail investors under MiFID. This limits most tokenized assets to a narrow universe of institutional or professional investors — a fundamental distribution constraint that has nothing to do with the quality of the underlying technology. The EU DLT Pilot Regime, live since March 2023, creates a genuine opening — but uptake has been slow and asset caps of €6bn per operator limit its industrial relevance for now.

The missing piece: self-described financial products

One of the most underappreciated promises of tokenization is that smart contracts can make financial products genuinely self-describing. Every term, every payoff rule, every lifecycle event could be encoded in the token itself — not in a PDF term sheet sitting in a document management system.

Payoff structure
Barrier levels, participation rates, capital protection — encoded in the contract, not a PDF
Coupon rules
Conditional coupons, memory effects, autocall triggers — verifiable on-chain by any party
Corporate action logic
Dividend adjustments, merger handling — automated rather than requiring manual intervention
Maturity conditions
Redemption at par, barrier breach scenarios — settled automatically without a back-office team

Here is what a minimal on-chain product schema for an autocall note might look like:

{
  "productType": "AutocallNote",
  "version": "1.2", // schema version for interoperability
  "underlying": {
    "type": "basket",
    "components": ["NESN.SW", "ROG.SW", "NOVN.SW"],
    "oracleAddress": "0xA3f...91c" // on-chain price feed
  },
  "maturity": "2027-06-15",
  "currency": "CHF",
  "autocall": {
    "observationDates": ["2025-06-15", "2026-06-15"],
    "triggerLevel": 1.00, // 100% of initial fixing
    "redemptionPremium": 0.08 // 8% p.a. if called
  },
  "barrier": {
    "type": "european",
    "level": 0.60, // 60% capital protection
    "observationType": "closing"
  },
  "lifecycle": {
    "couponLogic": "memory", // missed coupons accumulate
    "corporateActions": "adjusted",
    "settlementAgent": "contract" // self-settling
  },
  "regulatory": {
    "isin": "CH1234567890",
    "kidHash": "0xb7e...44a", // PRIIP KID content hash
    "targetMarket": "professional"
  }
}
Why this matters in practice

With a standardized schema, a tokenized autocall issued on SDX could be priced by a risk engine on a completely different platform, displayed correctly in a wealth management portal, and settled automatically at maturity — without any bilateral integration work. Today, each of those connections requires bespoke data mapping. The closest existing standards are ISDA's CDM for derivatives and ANNA's work on ISIN harmonization. Neither was designed for on-chain execution. A purpose-built financial product schema standard — governed by a credible industry body — remains an open problem.

The real missing piece: a secondary market that barely exists

Primary issuance infrastructure is only half the equation — and arguably the easier half. The secondary market for tokenized assets is nascent, fragmented, and in most cases functionally illiquid. A tokenized product that cannot be sold is not an asset. It is a locked position with a smart contract attached.

Tokenized assets today
  • A handful of venues (SDX, Boerse Stuttgart Digital) with thin order books
  • Spreads often 2–5%+ or no continuous quote at all
  • Settlement fragmented across chains and custodians
  • Not visible in standard financial data infrastructure
  • Not bookable in most custodian systems without manual workarounds
The liquidity illusion

Many tokenized assets are marketed as more liquid than their traditional equivalents — fractional ownership, 24/7 transferability, programmable settlement. But transferability is not liquidity. A token can be technically transferable on-chain while having zero willing buyers at any given moment. The infrastructure that creates genuine liquidity — continuous quoting, market making, data visibility, custodial integration — is largely absent.

Why the secondary market has not developed

01
Fragmentation across chains and platforms
A tokenized bond on SDX, a real estate token on Polygon, and a fund unit on a permissioned Ethereum chain are not interoperable. Each creates its own liquidity island. Unlike traditional markets where ISINs ensure any product can trade on any venue, tokenized assets are siloed by their issuance platform.
02
No market-making economics
Market makers in traditional structured products earn the bid-ask spread against a hedgeable underlying. For tokenized assets, the hedging infrastructure is absent, regulatory treatment of inventory is unclear, and volumes are too small to justify the operational overhead. Without professional market makers, there is no continuous price.
03
Absence from financial data infrastructure
If a tokenized asset does not have an ISIN, it does not appear in Bloomberg or Refinitiv. If it does not appear there, institutional investors cannot monitor, price, or include it in risk systems. Invisibility to data infrastructure is invisibility to most of the buy side.
04
Small float per asset
Most tokenized assets represent a single deal — a €5M loan, a building, a fund tranche. Even if secondary trading infrastructure existed, the float on any individual token is too small to sustain meaningful market depth. Industrial-scale issuance is a prerequisite for liquid secondary markets, not a consequence of them.
05
Settlement finality and custodial uncertainty
For a secondary trade to settle cleanly, both legs need to clear through infrastructure that institutional counterparties trust. Delivery-versus-payment for tokenized assets remains experimental on most platforms. Without settlement finality certainty, institutions cannot hold tokenized assets on balance sheet at scale.
What this looks like in practice

An investor buys a tokenized real estate token representing a fractional interest in a commercial property in Zurich. The token is technically transferable 24/7. But when the investor needs liquidity six months later, there is no exchange quoting it, no market maker providing a bid, and no mechanism to find a willing buyer other than bilateral negotiation. The investor is in a worse position than if they had bought a traditional real estate fund with quarterly redemption windows — at least those come with a defined exit mechanism.

What would actually unlock secondary liquidity

Near term
Regulated MTFs for tokenized securities
Venues like SDX and Boerse Stuttgart Digital need order book depth. This requires attracting market makers — which requires volume — a classic chicken-and-egg problem that only regulatory mandates or anchor issuers can break.
Near term
Cross-platform interoperability
Atomic swap mechanisms or bridge infrastructure that allows a token issued on one platform to trade on another. Without this, each platform's secondary market remains a liquidity island regardless of total market size.
Medium term
ISIN integration for all tokenized assets
Once tokenized assets carry ISINs and appear in Bloomberg and Refinitiv, institutional monitoring, pricing, and eventually trading become possible. Data visibility is a precondition for buy-side interest, not a consequence of it.
Medium term
Standardized DvP settlement
Delivery-versus-payment finality — ideally via central bank digital currency or a recognized settlement asset — removes the counterparty risk that prevents institutions from holding tokenized positions on balance sheet at scale.

Secondary market liquidity requires scale, and scale requires secondary market liquidity. Tokenization cannot buy its way out of this loop with technology alone — it requires regulatory intervention, institutional anchor commitments, or both.

The demand side: who actually buys tokenized products

Issuance infrastructure and secondary markets are only meaningful if buyers can access and hold what is issued. The demand side has three distinct segments, each with different barriers.

Institutional
Custodians cannot hold most tokenized assets. Prime brokers have no margin framework for them. Risk systems cannot consume non-standard product descriptions.
Unlock: custody solutions (e.g. Clearstream D7, SIX Digital Exchange) and regulatory recognition under the DLT Pilot Regime.
Private banking / UHNW
PMS platforms such as Avaloq and Temenos have added digital asset support, but the connectivity layer between those systems and tokenized asset infrastructure remains thin. Booking workflows, compliance processes, and relationship manager tooling have not kept pace with underlying platform capability.
Unlock: standardized APIs between tokenization platforms and PMS systems, and internal workflow automation within banks — not the PMS vendors themselves.
Retail
No PRIIP KID means no retail distribution in the EU. No ISIN means no booking in retail brokerage accounts. No regulatory clarity on investor protection.
Unlock: MiCA covers crypto-assets but not yet tokenized securities. ISIN issuance for tokenized instruments is the practical first step.
The distribution paradox

Tokenization's most compelling pitch to issuers is democratization — reaching a broader investor base at lower cost. But today's tokenized products are predominantly accessible only to professional or institutional investors, due to the regulatory and infrastructure gaps above. The technology promises to widen distribution; the current reality narrows it.

The counter-argument: is industrial-scale tokenization even the right goal?

There is a serious version of the argument that this entire analysis misses the point.

Two reasonable positions
The premise of this article

Tokenization should be judged against the industrial scale of traditional structured product issuance. Until it can match 2 million products per quarter with automated lifecycle management and liquid secondary markets, it has not delivered on its promise.

The counter-argument

Tokenization is not competing with structured products. It is opening up asset classes — private credit, real estate, infrastructure, fund units — where traditional issuance infrastructure does not exist and where even hundreds of tokenized assets represent genuine market creation, not failure.

The counter-argument has real force. A tokenized private credit facility for an SME, or fractional real estate accessible to a retail investor, does not have a traditional structured product equivalent. The comparison to certificate issuance may be measuring the wrong thing.

At the same time, the counter-argument lets the tokenization industry off a hook it should be held to. If the technology genuinely makes issuance cheaper and easier, it should eventually reach industrial scale in every asset class — not just the ones where traditional infrastructure is absent. The fact that most activity concentrates in a narrow band of assets where there is no incumbent to compete with may reflect a technology that is not yet ready for competitive markets, rather than a deliberate strategic choice.

Both things can be true: tokenization is creating genuine value in underserved asset classes, and it is not yet capable of competing with traditional infrastructure in established ones. The question is whether the former eventually leads to the latter, or whether the two ecosystems remain permanently parallel.

The road ahead

Now
Artisanal, high-cost, institutionally constrained
Bespoke smart contracts. Cost per issuance 10–100× traditional. Regulatory gaps limit distribution to professional investors. No standardized schemas. Secondary markets thin to non-existent. Platforms celebrated for their first hundred assets.
Next
Templated issuance, regulatory integration, nascent liquidity
Reusable product templates reduce marginal cost. ISIN integration and PRIIP KID automation unlock broader distribution. DLT Pilot Regime matures. Schema standards emerge. Regulated MTFs attract anchor market makers. PMS connectivity gaps close. Cost parity with traditional issuance becomes achievable for some product types.
Future
Industrial-scale, self-described, interoperable, liquid
Millions of products issued from standardized templates. Self-describing tokens consumed natively by risk systems, PMS platforms, and secondary markets. Automated lifecycle management. Continuous quoting on regulated venues with professional market makers. DvP settlement via CBDC or recognized settlement assets. The 2 million structured products per quarter becomes the floor, not the ceiling.

The gap between now and the future stage is not primarily a technology gap. The smart contract primitives exist. The gap is in standardization, secondary market infrastructure, regulatory integration, and distribution — all of which require industry coordination rather than individual innovation. That is a slower, harder problem. And it is the one that actually needs solving.

Cost estimates are order-of-magnitude approximations intended to illustrate relative scale, not precise industry benchmarks.