Discussion paper: Tokenisation in financial markets

March 2026 update

We have published a summary of key themes raised in submissions, and our comments in response to some points raised.

Among other points, submitters emphasised that regulatory fragmentation and uncertainty are constraining adoption, increasing risk, and increasing the likelihood that New Zealand will fall behind international developments in tokenisation and virtual asset markets.

Our market engagement and this consultation point to a strong economic and regulatory case for primary legislation reform, consistent with our signal to Government that primary legislation is necessary to establish a purpose-built and enduring legal framework for virtual assets.

We will continue to:

• advise Government on how existing legislation affects tokenised products and services, and where changes could improve certainty or address clear gaps
• work closely with industry, and intend to collaboratively develop guidance to support businesses and their advisers to consider how financial markets law may apply to tokenised products and services
• use our regulatory tools, such as exemptions or designations, where appropriate, to support innovation and reduce regulatory uncertainty
• monitor domestic and international developments to help keep New Zealand aligned with emerging global practice.

Download the Tokenisation in financial markets submissions report [551KB]

December 2025 update

Our extended consultation period for the Tokenisation in financial markets discussion paper closed on Friday 14 November 2025.

We received over 20 submissions from a wide range of market participants and other interested parties, including businesses, exchanges, fund managers, banks, law firms and industry groups. We are busy now reviewing and summarising the helpful and insightful comments and observations.

We aim to publish thematic insights in the first calendar quarter of 2026 and indicate the direction of travel for our focus in this area.

September 2025

We are seeking to open a dialogue about the current use and future potential of tokenisation in New Zealand’s financial markets. 

Tokens are a subset of virtual assets, which are intangible assets that are created, traded and stored often on a programmable, distributed or centralised ledger. Tokenisation typically refers to issuing a token using distributed ledger technology to separately represent ownership of real-world assets. However, digital tokens themselves may be the sole asset, i.e. there is no link to a real-world asset. 

Internationally, tokenisation is increasingly being used in financial markets in offerings of financial products and instruments to retail and wholesale investors.

To help us consider what the FMA could do to support innovation, improve regulatory certainty, and enhance consumer protection, we are seeking views on three main areas relating to financial markets: 

• How is the current market and regulatory environment helping or hindering domestic tokenisation activity in financial markets? 
• What benefits or risks do you see for tokenisation for New Zealand financial markets? 
• What should or could the future market and regulatory environment look like? 

The paper provides an overview of the current environment relating to tokenisation, and discussion topics and questions about areas we are interested in. Have your say by 31 October 2025. 

Download the Tokenisation in financial markets discussion paper [PDF 507KB]