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Tokenization does not change an asset’s legal or economic character just because a claim is recorded on a programmable ledger. It can change how ownership is recorded, how transactions settle, and which intermediaries, software and infrastructure the parties rely on. A useful risk framework therefore starts with the holder’s actual legal claim, then traces the asset, settlement method and technical dependencies around it. The case is for adapting familiar financial-risk analysis—not treating tokenization as inherently dangerous.
What tokenization changes—and what it does not
The Bank for International Settlements (BIS) describes tokenization as recording claims on real or financial assets that exist on a traditional ledger onto a programmable platform. Depending on the design, that platform may combine asset records and transfer rules with messaging, reconciliation and asset transfer. Those are potential capabilities, not guaranteed results of putting an asset on a ledger.
For securities, a U.S. Securities and Exchange Commission (SEC) staff statement dated January 28, 2026 defines a tokenized security as a security represented as a crypto asset, with ownership recorded in whole or in part on crypto networks. The SEC distinguishes tokens issued by an issuer or its agent from tokens created by an unaffiliated third party. Those structures can give holders different rights and expose them to different counterparties.
The key distinction is between a token’s technical representation and the legal claim it gives its holder. As SEC Commissioner Hester M. Peirce put it in a July 9, 2025 statement, “Tokenized securities are still securities.” A token’s link to an asset does not, by itself, prove that its holder owns that asset or can redeem it directly.
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Why a tailored framework is warranted
The Financial Stability Board’s (FSB) analysis, summarized by the BIS Financial Stability Institute in August 2025, finds that many tokenization vulnerabilities resemble familiar financial risks. Technology and governance arrangements can amplify them or connect them in new ways. A framework focused only on the token’s quoted price or an institution’s balance sheet can miss risks elsewhere in the chain.
Liquidity and maturity mismatch
A token may appear easier to trade or redeem than the underlying asset or claim. If the token promises rapid redemption but the reference asset is difficult to sell or settle, holders seeking cash at once can create redemption pressure or run risk. The relevant question is whether the redemption promise, asset liquidity and settlement timing actually match.
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Leverage
Programmability and composability—the ability to connect tokens and applications—can make it easier to reuse a token received as collateral. Reuse or rehypothecation can build leverage across several arrangements, so the same underlying value may support multiple exposures. Risk analysis needs to follow collateral use through those connections rather than count only the initial transaction.
Asset-price and quality risk
A token’s market price can diverge from the value or quality of its reference asset. Opaque smart contracts, unregulated oracles that supply external data, valuation difficulty, and legal or market frictions can contribute to that gap. A technical record of a claim does not guarantee that the reference asset is available, correctly valued or redeemable as expected.
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Interconnectedness
Platforms can link institutions and activities, creating paths through which stress spreads. Continuous global operation may affect volatility and make oversight more difficult. A risk review should identify which entities and services share infrastructure or depend on the same counterparties, rather than treating each token or platform as isolated.
Operational fragilities
Smart-contract errors, lost or mismanaged private keys, unclear governance, irreversible transactions and weak accountability or resilience can create operational vulnerabilities. The questions are not only whether code works as intended, but who can respond when it does not, how incidents are contained, and who is answerable for recovery.
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Map the arrangement before rating its risk
There is no single risk profile for “a tokenized asset.” Compare arrangements by tracing the claim from holder to underlying asset and through the systems needed to issue, transfer, value and settle it.
| Dimension | What to establish | Why it matters |
|---|---|---|
| Legal claim | Is the token issuer-issued, issued by an agent, or created by a third party? Does the holder have direct ownership, a security entitlement, a redemption claim or another contractual right? Against whom can that right be enforced? | SEC materials dated July 9, 2025 and January 28, 2026 say tokenized-security structures and rights vary; legal classification depends on facts and rights conveyed. |
| Reference-asset link | Who holds the asset? How is it valued, audited and made available for redemption or settlement? | Weak, delayed or unclear links can leave token price, asset value and redemption outcomes out of alignment. |
| Settlement asset | Does settlement use a stablecoin, tokenized bank deposit or central-bank money? Who issues it, and how does redemption work? | These settlement assets have different risk profiles; the settlement method affects the arrangement’s dependencies and finality. |
| Governance and access | Is the design permissioned or permissionless? Who can make decisions, change rules or respond to an incident, and how are they held accountable? | Decision rights and response capacity shape the system’s operational resilience. |
| Interoperability and dependencies | Which legacy systems, custodians, oracles, protocol developers and bridges are required? Are critical providers concentrated? | Each connection can add reliance on a third party or create a route for disruption to spread. |
| Programmability and composability | Which actions are automated, and which other applications or tokens can use the asset? | Automation may improve efficiency while also increasing code risk, leverage and opaque dependencies. |
| Measurement and prudential treatment | What data history, valuation basis, liquidity and counterparty exposures support the risk assessment? Do applicable prudential rules treat the exposure as equivalent to a traditional asset? | The Basel Framework’s cryptoasset-exposure rules address infrastructure risk and allow supervisory capital add-ons where weaknesses are observed. |
For securities, the SEC’s distinction between issuer or issuer-agent tokenization and third-party tokenization makes the first row especially important. Peirce’s 2025 statement cautions that a third-party token connected to securities held by another entity can expose purchasers to counterparty risk. The holder must understand what the intermediary owes, not infer ownership solely from the token’s reference to securities.
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How to apply the framework in practice
- Write down the enforceable claim. Identify the holder’s rights, the obligated party, the applicable register or intermediary, and the route for asserting or redeeming the claim. Separate what the contract promises from what the token interface suggests.
- Trace assets and settlement end to end. Follow where the reference asset is held and valued, how transfers are recorded, what asset settles payment, and how redemption works. Note where records or obligations must cross from a DLT platform to a traditional system.
- Map service providers and governance. Record the roles of custodians, oracles, developers, bridges and platform operators. Identify who controls upgrades or emergency actions, who can pause or reverse activity if possible, and what happens if a critical provider fails.
- Test the five vulnerability groups against actual use. Assess mismatch, leverage, valuation and quality, interconnectedness, and operational resilience for the arrangement’s specific redemption terms, collateral practices and dependencies. Do not assume a feature is safe merely because it is automated.
- Assess data, prudential treatment and oversight. Establish whether the exposure has a meaningful history, how it is valued and how counterparties are measured. Check the applicable prudential rules and whether supervisory treatment reflects infrastructure weaknesses. Basel rules specifically address infrastructure risk and permit supervisory capital add-ons where weaknesses are observed.
- Reassess when the design or scale changes. New applications, settlement assets, bridges, counterparties or governance arrangements can alter the risk map. A framework should be maintained as those dependencies evolve, not treated as a one-time token review.
What tokenization may improve—and the trade-offs
The BIS describes possible efficiencies from integrating messaging, reconciliation and asset transfer on a programmable platform. In a delivery-versus-payment arrangement, exchanging the asset and payment together can reduce counterparty risk and post-trade reconciliation. In the BIS’s proposed architecture, settlement in central-bank reserves can support finality and the singleness of money. These are design-dependent potential benefits, not universal empirical findings about tokenization projects.
The same integration that may remove some steps can introduce new dependencies. The FSB summary highlights opaque links created by composability, different risk profiles among stablecoins, tokenized bank deposits and central-bank money, and reliance on custodians, oracles, protocol developers and bridges. A sound comparison weighs a particular system’s expected efficiency against the controls, settlement finality and resilience that its design actually provides.
Current scale is not the same as future risk
The FSB summary describes DLT-based financial-asset tokenization as early-stage, with many projects small-scale or experimental. It identifies limited investor demand, weak interoperability between DLT platforms and legacy systems, and regulatory and legal uncertainty as constraints on adoption. It assesses current financial-stability risks as minimal, citing small scale, a focus on permissioned platforms, limited programmability and low interconnectedness.
That assessment is not a guarantee about a larger or more complex future market. The FSB warns that risks could rise with significant scaling, greater complexity and opacity, or insufficient oversight. The argument for a tailored framework is preparedness: map risks before growth or new connections make them harder to see, without presenting a possible future vulnerability as evidence of a current system-wide crisis.
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1Clear out junk files and repair common Windows errors2Fix the driver behind crashes, sound loss and screen glitches3Repair Windows errors before they cause bigger problemsIOSCO’s 2025 report also characterizes the ecosystem as nascent and identifies interoperability and credible settlement assets as constraints on scalability. Its summary says existing IOSCO principles and guidance may remain relevant because they are technology-neutral, while novel or amplified risks call for appropriate controls. This supports adapting established financial principles to the actual legal, infrastructure and operational details of each arrangement—not assuming that tokenization requires abandoning them.
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