代币化抵押品：欧盟证券和市场管理局审查区块链资产用于欧盟中央清算

EU financial regulators have launched a public consultation on "tokenized collateral"

The European Securities and Markets Authority (ESMA) is exploring a key issue: whether tokenized assets can still survive stably when they are most needed to play their role. On October 9, 2026, the EU's market regulators officially launched an evidence collection process on "tokenized collateral", inviting clearing houses, banks, custodians and technology providers to respond. The program aims to understand how blockchain-based assets are accessed, transferred and redeemed for cash by a central counterparty (CCP) during periods of default or market stress. Relevant feedback must be submitted before January 15, 2027.

This review focuses on the core practical question of real-world tokenization: whether collateral in the form of digital tokens can be quickly seized, sold and settled when a clearing member defaults, thereby protecting the stability of the financial system. ESMA is not proposing to introduce new asset classes, but rather tests whether current rules that apply to traditional securities also apply to assets issued or recorded on the blockchain.

Specific issues raised by ESMA to the clearing house

作为咨询文件发布的证据征集范围覆盖了抵押品的全生命周期。文件区分了“数字孪生”（即已在传统基础设施中持有的资产的代币化版本）、直接在分布式账本技术上发行的资产，以及混合这两种模式的安排。ESMA希望了解，在必要时，中央对手方是否能够访问、转移并将每种模式转化为流动性；同时，也希望探究当区块链系统与传统的交易后处理轨道交互时，客户保护、资产隔离和结算终局性是否依然稳固。

ESMA中央对手方监管委员会主席克劳斯·勒伯（Klaus Löber）将此次测试定义为底线要求而非放松管制。他表示：“抵押品必须具有高质量、法律可执行性、高流动性，且在操作上易于获取，包括在市场压力条件下及清算成员违约之后。”监管机构希望获得证据，以确认代币化是否会改变现有合格抵押品的风险特征。

为何此刻关注代币化抵押品至关重要

此次咨询正值代币化从试点阶段迈向实际机构级应用的关键时刻。近几个月来，The Clearing House 选择 Quant 为其代币化存款网络提供支持，而英国金融行为监管局（FCA）也针对批发市场的代币化黄金开启了平行的意见征集。抵押品的动员是代币化与中央清算最直接交汇的领域，因为更高效地移动和复用抵押品是该技术最显著的优势之一。

ESMA Chairman Verena Ross said tokenization "has the potential to make Europe's financial markets more efficient, integrated and innovative", while emphasizing that the EU must establish "conditions for cross-border security and large-scale operations of tokenized markets, including legal certainty, interoperability infrastructure and appropriate regulation."

Follow-up progress

Stakeholders can submit feedback through ESMA's consultation page before January 15, 2027. Unless interviewees request confidentiality, all responses will be made public after the deadline. ESMA plans to evaluate these feedback in the first quarter of 2027 and then determine whether existing rules are sufficient or whether enhanced regulatory coordination or regulatory action is needed. It should be noted that this is a review rather than a new regulation: the collection of evidence itself will not change the scope of collateral acceptable to central counterparties.

Frequently Asked Questions (FAQ)

What is tokenized collateral?

Tokenized collateral is a blockchain representation of assets such as bonds, stocks, or money market fund shares that is used to cover transaction losses. It can be a digital twin of assets held in traditional infrastructure or an asset issued directly on a distributed ledger.

Why does ESMA review tokenized collateral?

ESMA wants to know whether clearing houses can access, transfer and exchange tokenized collateral for cash during periods of default or market stress, and whether safeguards such as customer protection, asset isolation and settlement finality remain in effect when the blockchain system interfaces with traditional post-transaction infrastructure.

What is the deadline for ESMA to solicit opinions on tokenized collateral?

Stakeholders must respond by January 15, 2027. ESMA will evaluate the response in the first quarter of 2027 before deciding whether to take further regulatory or supervisory action.

Does this mean that tokenized assets can now be used as collateral?

No. This collection of evidence did not change the scope of eligible collateral. The purpose is to gather information to determine whether existing frameworks can safely and effectively accommodate tokenization arrangements.

What tokenization models are covered by ESMA?

The scope of the review includes tokenized versions of assets held in traditional infrastructure, assets issued directly on distributed ledger technology, and hybrid arrangements, including how they interact with tokenized cash and other settlement assets.