A few weeks ago, we wrote that tokenised funds were no longer an experiment. The evidence was already there. Institutional managers were launching them. Major fund jurisdictions were building regulatory frameworks around them. Established financial institutions were providing the infrastructure.
The conversation was moving away from whether tokenisation would become part of mainstream finance towards how quickly that transition might happen.
We may now have part of the answer.
On 14 September 2026, the Financial Conduct Authority and the Bank of England published the industry's response to their joint work on the future of tokenisation in UK wholesale financial markets. 123 responses came from across financial services, infrastructure providers, technology firms, industry bodies, law firms and academia. The message was remarkably consistent.
The market wants to move forward.
Not simply with more proofs of concept. Not with another generation of isolated pilots. But towards production, scale and permanence. That distinction matters. Because tokenisation is beginning to move beyond the question of how individual funds or securities might be represented digitally.
The conversation is now about something considerably bigger. How the infrastructure of financial markets themselves might change.
From experimentation to infrastructure The potential benefits of tokenisation have been discussed for years. Faster settlement. Lower operational costs. Fewer reconciliations. Greater transparency. Programmable transactions. More efficient transfer of assets.
But technology rarely transforms financial markets simply because it works. Infrastructure has to develop around it. Regulation has to accommodate it. Legal certainty has to exist. And institutions have to be prepared to use it at scale.
One of the clearest messages from respondents was the need to move beyond sandboxes and pilots towards full production, scale and permanence. The authorities have responded by committing to publish a joint Tokenisation Roadmap later in 2026, including target dates for their work on wholesale tokenisation. That may prove to be an important moment.
Sandboxes are designed to answer the question:
Can this work?
Roadmaps begin to answer a different one: How do we make it work at scale?
For financial institutions, and for the boards responsible for overseeing them, those are very different questions.
Collateral may be where the real transformation begins Perhaps the most interesting finding in the feedback was where respondents saw the greatest opportunity. It was not necessarily in the initial issuance of tokenised securities. It was in what happens afterwards.
Post-trade activity, and particularly collateral.
Collateral sits quietly underneath enormous parts of the global financial system. Banks, clearing houses, investment firms and other institutions constantly move assets between one another to manage exposures and meet margin requirements. That infrastructure works.
But it can also be fragmented, operationally intensive and dependent upon assets moving between different systems, custodians and counterparties.
Tokenisation creates the possibility of changing that. A tokenised asset can potentially move much more quickly between participants. Ownership can be updated on a shared ledger. Settlement can become increasingly automated. Tokenised money market funds were repeatedly identified as one of the most promising examples.
Instead of liquidating an investment to generate cash collateral, it may increasingly be possible for the investment itself to move digitally and be pledged. That sounds like an operational improvement. At sufficient scale, it is considerably more than that.
It changes how liquidity moves through financial markets.
Then there is the money A tokenised financial system requires more than tokenised securities. It also needs a way to settle transactions. The Bank of England is continuing work on settlement in central bank money for tokenised transactions, while regulated stablecoins can also play a role as settlement assets within the Digital Securities Sandbox, subject to the relevant regulatory framework. That begins to create the components of something much more significant.
A tokenised security. Tokenised collateral. A digital settlement asset. Infrastructure capable of connecting them. And increasingly programmable transactions between each.
The result is sometimes described as composable finance: financial assets, services and processes capable of interacting digitally and, potentially, automatically.
The FCA has already begun exploring what that future might mean. Investor eligibility. Ownership restrictions. Reporting. Transaction conditions.
Elements that today require separate operational processes could increasingly become part of the architecture through which the transaction takes place.
That is a very different financial system from the one most boards govern today. And yet one fundamental principle remains unchanged.
The infrastructure can decentralise. Accountability cannot. One sentence in the FCA and Bank of England's latest feedback deserves particular attention. Regulated activities require an identifiable person to be responsible.
It is a simple statement. Its implications are substantial. A distributed ledger can record ownership. A smart contract can execute instructions. Tokenised collateral can move between counterparties. Settlement can become increasingly automated. But responsibility cannot simply disappear into the technology. Someone remains accountable for the outcome.
Boards cannot outsource their responsibilities to a blockchain. They cannot delegate accountability to a smart contract. And they cannot assume that because a process has become automated, the risks associated with it have disappeared.
Technology changes the nature of the questions boards need to ask.
The boardroom questions are changing A board overseeing a traditional investment structure is accustomed to asking questions about administrators, custodians, valuations, liquidity, conflicts, financial crime, operational resilience and investor protection. Those questions do not disappear in a tokenised structure.
New ones sit alongside them. Who controls the private keys? Who has authority to change the smart contract? What happens if the code performs differently from what was intended? What constitutes legal settlement? Which record takes precedence if a traditional system and distributed ledger disagree? What happens if the underlying blockchain becomes unavailable? How are sanctions, KYC and other financial crime controls applied through digital infrastructure? How does the board oversee the technology providers upon which the structure depends? What happens when assets move between different blockchains or jurisdictions? And perhaps most importantly:
Who is accountable when an automated process produces the wrong outcome? These are not questions that require every director to become a blockchain developer. They are governance questions.
Directors do not need to know how to write the code behind a smart contract any more than they need to know how to build the accounting system used by their administrator. But they do need to understand what the system does. Where its risks sit. Who controls it. And enough to challenge the people telling them that it works. That is what effective oversight has always required.
One of the world's oldest assets may be part of the next stage Perhaps the clearest illustration of how quickly the conversation is developing came on the same day as the feedback statement. The FCA launched a separate call for input on tokenised gold.
Gold - An asset used as a store of value for thousands of years is now being considered as part of the infrastructure of tokenised financial markets. London remains the world's largest centre for spot gold trading, and respondents specifically identified gold as an asset that could benefit from tokenisation. The FCA is now examining whether digital representation of physical gold could improve the way it is traded, transferred, pledged and held. One potential use is particularly interesting.
Collateral.
Tokenised gold could potentially move more easily through digital financial markets and be pledged against financial exposures without requiring the physical asset itself to move through traditional infrastructure. The consultation is also considering some of the difficult regulatory questions that follow. This is precisely why the latest developments matter.
Tokenisation is no longer simply about putting an existing investment fund onto a blockchain. It is beginning to touch the infrastructure through which securities, collateral and money interact.
Traditional and tokenised markets will coexist None of this means traditional financial infrastructure disappears tomorrow. Quite the opposite. The FCA and Bank of England recognise that traditional and tokenised markets are likely to coexist for a considerable period. That creates another challenge.
Interoperability.
New infrastructure has to communicate with old infrastructure. Tokenised assets have to interact with traditional assets. Different distributed ledgers may need to interact with one another. Custodians, trading venues, settlement systems and banks will need to operate across both environments. And financial markets do not stop at national borders. A tokenised security issued in one jurisdiction may be held by an investor in another, administered somewhere else and use infrastructure located somewhere else again. The regulatory framework has to follow. So does governance.
For directors operating across international structures, this may become one of the more complex aspects of tokenisation.
The technology may be global. Director duties and regulatory obligations remain jurisdictional.
Speed does not remove the need for judgement There is an understandable tendency to describe tokenisation primarily in terms of speed. Settlement in seconds rather than days. Instant transfer of ownership. Automated processing. Twenty-four-hour infrastructure. But speed is not automatically the same thing as good governance. Some friction in traditional financial markets exists because systems are old and inefficient. That friction should disappear. Some exists because checks, approvals and controls are deliberately built into a process.
That distinction matters.
The challenge will be ensuring that when financial processes become programmable, appropriate governance does not accidentally get programmed out with the inefficiency. A transaction that takes seconds may still require a decision that deserves considerably longer. A smart contract can execute a rule. It cannot decide whether the rule was sensible.
Technology can provide information. It cannot accept fiduciary responsibility for how that information is used. That remains human.
The role of the director is not becoming less important Technology repeatedly changes the mechanics of financial services. Electronic trading changed markets. Cloud computing changed infrastructure. Digital administration changed fund operations. Artificial intelligence is changing how information is processed. Tokenisation may change how ownership, settlement and collateral operate. Each development creates predictions that technology will reduce the need for human oversight.
In practice, sophisticated technology tends to create a greater need for sophisticated governance. Because the questions become different. The dependencies become less visible. The speed increases. And the consequences of getting something wrong can travel much faster. For directors, the challenge is therefore not to become technologists. It is to remain sufficiently informed to govern technology effectively.
Preparation remains the advantage The conclusion is remarkably similar to the one reached when we first looked at tokenised funds. Preparation matters. Understanding the structure you govern. Understanding the regulatory framework that applies to it. Understanding the technology sufficiently to challenge those responsible for it. Understanding where accountability sits. And having access to reliable information when the board is required to make a decision.
What is changing is the amount of information directors need to absorb. Regulation is evolving. Technology is evolving. Market infrastructure is evolving. And increasingly, all three are evolving simultaneously. The tools supporting directors therefore need to evolve as well.
MyDirector-OS was built around a simple principle.
Technology should make directors better informed, better prepared and better equipped to exercise judgement.
It should not exercise that judgement for them.
BoardLens can analyse board papers, surface risks, identify governance gaps and highlight issues requiring a director's attention. Our regulatory intelligence is jurisdiction-aware, helping directors understand the framework relevant to the appointments they actually hold. The Director's Assistant provides grounded answers from verified regulatory sources when questions arise.
The technology does the work that technology is good at. Finding. Processing. Connecting. Surfacing. The judgement remains with the director.
Because however sophisticated financial infrastructure becomes, the fundamental principle does not change. Someone remains accountable.
A few weeks ago, we wrote that the next wave was already forming. It is becoming increasingly difficult to call it the next wave. It has started.
The infrastructure is changing.
The accountability isn't.