UK Finance welcomes the CfI on tokenisation and the future of UK wholesale markets. We commend the FCA and BoE (together the “regulators”) for their ongoing work in respect of building the regulatory framework for cryptoassets and stablecoins. This paper’s dedicated focus on wholesale securities tokenisation is timely and important.

In particular, we welcome the commitment in the vision to equivalent regulatory and prudential treatment of tokenised and non-tokenised assets, and this principle should be applied across the entire regulatory framework. Regulators should, to the greatest extent possible, leverage existing rules to provide clarity — for example, via Dear CEO letters or industry engagement sessions — rather than introducing new rulemaking. Care must be taken not to create an unnecessary and complex new ‘twin track’ of regulation purely because a given security is tokenised.

We acknowledge that HM Treasury (HMT) has included digital securities within the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 via the ‘Specified Investment Cryptoassets (SIC)’ and ‘Relevant Specified Investment Cryptoassets (RSIC)’ definitions. The regulators should now focus on avoiding unintended consequences on traditional firms adopting digital securities.

We look forward to the first DIGIT issuance. We call on the government and the Debt Management Office to assure industry of their ongoing commitment to markets transformation by committing to a series of digital sovereign debt issuances (not yet committed to by the government). As outlined in our Digital Gilt Roadmap, successive issuances across short and longer tenors would help test the full lifecycle of digital sovereign debt, including in connection with on-chain digital money and settlement infrastructure, build confidence among a broader set of market participants, support secondary market and repo use cases, and act as a catalyst for deepening market liquidity, interoperability and collateral management advancements. This would support the development of common market standards and the UK’s wider ambition to modernise capital markets infrastructure.