Tokenisation regulatory update — EU, UK, and APAC moves this quarter

Q1 2026 has been heavy on regulatory announcements across the three jurisdictions most relevant to RWA issuance. MiCA is one year in. The UK DSS is expanding. MAS has clarified digital-asset custody requirements. Here's what actually matters.

MiCA · one year in

The first year of MiCA operation has surprised to the upside on one dimension and to the downside on another. Upside: the Asset-Referenced Token (ART) and E-Money Token (EMT) categories have proven workable, with several major stablecoins now operating under clear EU rules. Downside: MiCA explicitly excludes securities and financial instruments, which means RWA issuers either stay out of MiCA's ART/EMT regime or architect under MiFID II and national regimes.

UK Digital Securities Sandbox

FCA has expanded the UK DSS to include a wider range of tokenised instruments, including LP interests and private-credit instruments. Archax has been among the more active participants. For ALKN, the DSS framework is directly relevant to the Archax listing — the sandbox provides an acceptable regulatory envelope for primary trading and post-trade settlement of tokenised securities.

MAS clarifications

MAS has clarified that MPI (Major Payment Institution) licence holders performing digital asset custody under the Payment Services Act must segregate client assets, maintain independent audit, and meet explicit capital requirements. HydraX Digital Assets operates under this regime. The clarification codifies what was already market practice but removes ambiguity for institutional counterparties.

What all of this means for RWAs

Three takeaways. First, the regulatory envelope for properly-structured RWAs is becoming clearer across all three major regimes. Second, the line between "crypto asset" and "digital security" is now institutionally entrenched — there is no going back to the 2021 ambiguity. Third, issuers that chose jurisdictional coverage across EU, UK, and APAC (rather than one of the three) are positioned better under the new equilibrium. ALKN's three-venue, three-regulator design is consistent with that pattern.