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Deloitte Warns T+0 Tokenized Settlement Could Create an Oversight Blind Spot

Pilot programs under no‑action relief will determine whether tokenization scales safely.

Overview

  • Deloitte’s 2026 outlook highlights same‑day settlement and tokenized securities as pivotal experiments that could reduce visibility if reporting and audit trails do not keep pace.
  • Accelerated timelines compress the window to correct errors, source cash, locate securities, and handle margin calls, raising operational and intraday liquidity pressures even as counterparty exposure may fall.
  • The SEC is enabling limited trials through no‑action letters and staff guidance, and the CFTC is assessing tokenized collateral and dollar‑linked stablecoins for instant settlement use cases.
  • A transition with parallel tokenized and conventional versions of the same assets is likely, complicating pricing, liquidity concentration, and order routing across venues.
  • Deloitte urges firms to strengthen surveillance, documentation, auditability, and cybersecurity, framing 2026 as a make‑or‑break test for integrating tokenization into market infrastructure.