Author: Krzysztof Walczak
Tokenization of financial instruments and the development of stablecoins are no longer technological experiments but are becoming elements of financial market infrastructure. It changes the way we perceive ownership, enabling greater liquidity, settlement efficiency, and asset accessibility.
For the Polish FinTech ecosystem, this is an area that should create real, measurable business opportunities, but it also requires conscious navigation through a complex regulatory environment. Whether we utilize it depends on close cooperation between financial institutions, FinTech companies providing infrastructure, and public administration.
In this article, I analyze the latest global trends, examples of implementations, opportunities for Polish FinTech companies, as well as the challenges facing the Polish financial sector, together with proposed solutions.
Global market trends
The global market for tokenization of real-world assets (RWA) is entering a phase of accelerated, institutional adoption, moving from technological experiments to mainstream financial market infrastructure.
Tokenization projects are driven by both financial institutions and individuals or companies holding crypto assets. On one hand, the growing number of individuals and firms holding tokenized assets benefits from features like fractional ownership, increased privacy, independence, and security. On the other hand, market fragmentation, high transaction costs from legacy systems, increased capital requirements, numerous intermediaries, and intensifying competition eroding margins push institutions to seek cost efficiencies, faster transactions, higher liquidity, and new capital attraction.
According to the BCG-Ripple report, the tokenized assets market will grow from $0.6 trillion currently to $18.9 trillion by 2033 (53% CAGR), ranging from $12.5 to $23.4 trillion[1]. The highest potential lies in money market funds, bonds (treasury and corporate), real estate (packaged in financial products), stablecoins (for transaction settlement and collateral), and alternative investments.
These are projections, with many projects in research phases testing usability, know-how, and infrastructure for broader adoption. Currently, tokenisation is mainly being applied to financial instruments with a simple (vanilla) structure and low risk, as well as those used for settlement and collateralisation of operations on financial markets. As a result, the ability to instantly convert an asset into a cash payment within a single transaction will bring tangible commercial benefits to financial institutions involved in collateralised transactions, repos, and liquidity management.
Main categories include money market funds, treasury bonds, and stablecoins used for collateral and settlement to base currency.
Tokenized treasury bonds dominate institutional RWA (real-world assets). By mid-2025, US treasury-based tokenized products exceeded $7.4 billion. On the other side, Tether, the largest stablecoin issuer, holds $135 billion in US treasuries, ranking 17th globally ahead of Germany, Saudi Arabia, and South Korea.[2] Its token value is about $184 billion.[3]
Another example is BlackRock’s USD Institutional Digital Liquidity Fund (“BUIDL”), the first fund on the public Ethereum blockchain, tokenized by Securitize. The fund is backed by short-term US government treasury bills and repo transactions. This mechanism is designed to maintain the stable value of the BUIDL token at 1 USD. The fund is used as collateral in decentralised finance, as a liquidity management tool, and as security for stablecoin solutions and on-chain treasury management. It is therefore a practical example of money market fund tokenisation fully integrated with traditional financial infrastructure, which could develop significantly if it becomes accepted collateral in the wider financial market. According to Securitize data, BUIDL surpassed 1 billion USD in assets under management in March 2025.[4]
Regardless of the above, for the tokenised instruments market to move from the phase of use cases to that of institutional adoption, it is necessary to ensure liquid secondary markets based on the interoperability of individual systems with a public blockchain, on which these instruments are issued and traded. At present, this is difficult, as many tokenised instruments use private blockchains operated by a single bank, with access restricted solely to that bank’s clients.
Creation and acceptance of on-chain solutions like central bank digital currencies (CBDCs), regulated stablecoins, and deposited tokens will drive adoption. Without them, asset transfers occur on-chain, but cash payments remain off-chain, offering limited commercial benefits. As these barriers diminish, digital assets will increasingly be issued using on-chain DvP (delivery versus payment) mechanisms, allowing investors and issuers to truly benefit from the efficiencies of tokenisation.
Institutional coherence as a key element for broad adoption
In order the entire ecosystem to be coherent and enable broad adoption of digital assets, institutions and regulations are essential elements. Consistent and supportive regulations for introducing new tokenization projects are essential for the accelerated development of this capital market services segment. Furthermore, the involvement of administration and regulator already at the project stage, by providing regulatory sandboxes aimed at testing these solutions early and understanding their risks and potential, is a key success factor that enhances the competitiveness of both companies and economies, as well as ecosystems.
It should be noted that there are currently significant differences in the level of regulatory advancement between individual regions of the world, which does not help service providers in creating uniform and cost-effective tokenized services and instruments.
The European Union implemented the MiCA regulatory package at the end of 2024, which creates the basis for unified adoption across the region, introducing requirements for crypto-asset service providers (CASP) and stablecoins. Supervisory authorities (ESMA and national regulators) are currently publishing acts that implement the regulations into national legal orders.
Meanwhile, within Europe itself, the pace is different. Moreover, the very manner of implementing regulations and their restrictiveness creates additional barriers for entities providing these services. Interestingly, the leader is a country outside the EU, namely Switzerland, which has one of the earliest and most comprehensive legal frameworks for tokenized securities and DLT infrastructure. Through cooperation between the government, regulator, central bank, and the Swiss stock exchange, digital assets have been regulated in national law (DLT Act), and infrastructure for trading these instruments has been created on the SIX Digital Exchange (SDX). In this model, digital bonds are treated as “DLT ledger securities,” which benefit from a clear definition in Swiss law, settlement is carried out using wholesale CBDC (wCBDC) on the SDX exchange, enabling real-time settlement (atomic delivery-versus-payment), and the digital record is legally conclusive. Thanks to this, digital bonds were issued on SDX by UBS bank (250 million CHF in 2022), which are dual-listed on SIX Digital Exchange and the traditional SIX Swiss Exchange, or digital bonds issued by the canton of Zurich worth 100 million CHF, which are dual-listed on SDX and SIX Swiss Exchange and can be settled both on SDX and on SIX.[5]
In the US, the GENIUS Act regulations are expected to support the issuance of regulated stablecoins and bring the necessary clarity and certainty essential for broader adoption of digital bonds. At the end of 2025, the FDIC approved a notice of proposed rulemaking that would implement the provisions of the GENIUS Act.
In the Asia-Pacific region, leading jurisdictions (Japan, Singapore, and Hong Kong) are testing funds, bonds, and structured products in tokenized form through regulatory sandboxes and industry consortia. An example is Singapore’s Project Guardian, which expands adoption to tokenized bank liabilities, funds, foreign exchange operations, and interoperability standards.
In the Middle East, tokenization efforts focus on creating an ecosystem for institutional FinTech companies, custody services, tokenized securities, exchanges, wallets, retail platforms, and token issuers. Leading centers are Abu Dhabi and Dubai.
Latin America, led by Brazil, is developing thanks to FinTech platforms and dollar-denominated tokenized assets. In Africa, adoption is gaining popularity in remittances and inflation-resistant instruments, supported by mobile device-based infrastructure and stablecoins.
The need to comply with different legal requirements for the same instruments increases costs and reduces the profitability of such services, also slowing down the speed at which these services/instruments can be deployed in new markets.
Challenges facing the market
The crypto assets market itself must go through individual challenges that will enable its adoption on a broader scale. These are:
- Lack of a single scalable infrastructure on which tokenized financial instruments are exchanged, traded, and settled. Currently, there are no large open platforms available for trading tokenized securities, and those that do function are closed systems available exclusively to one or a small group of financial institutions.
- Interoperability of tokenized assets and platforms. Currently, many pilot projects are emerging that demonstrate potential. However, most of them remain isolated, and mass adoption still depends on solving the infrastructure fragmentation problem. Without cooperation and interoperability between current platforms or closed ecosystems, digital securities and tokenized cash will not be exchangeable. It should be emphasized that the role of major players is important here. The entry of major players who will establish common rules for issuance, distribution, and settlement of tokens should deepen liquidity and create a network effect.
- Implementation costs of projects are still high. As the market matures and large-scale infrastructure emerges, this will change. However, as long as the market is in the early adoption phase, project costs will be high for entities. For example, according to the BCG-Ripple report, a tokenization project can cost $2 million or less. Meanwhile, full integration including custody, trading, compliance, and multiple asset types may require expenditures of $15-20 million for a mid-sized bank to $100 million for a large institution. Such budgets already require strategic decisions and specific resource commitment from organizations.[6]
- Increasing trust and breaking client resistance to using tokenized financial instruments. The crypto assets market is still associated with numerous projects that failed due to supervision, regulation, and poor execution issues. The involvement of large institutional players, who are synonymous with security and regulatory compliance, will be key to increasing trust in such financial services. Clients may often not even know that their transactions are conducted through tokenized assets/DLT, therefore broad education combined with tangible benefits in the form of faster, cheaper settlements and more liquid markets will be crucial for ensuring broad tokenization adoption.
What does this mean for the Polish market?
Tokenization of financial instruments (particularly deposits and securities) and the use of stablecoins should become one of the key directions of transformation for the Polish financial sector over the next 3-7 years. Otherwise, a significant part of payments, and thus revenues, will shift to non-bank and foreign crypto-fintech ecosystems, which may weaken the domestic deposit base, reduce revenues and margins, and hinder macroprudential policy delivery.
At the same time, this requires coordinated actions by bank regulators, commercial banks, payment operators, and FinTech companies. Lack of such coordination means in fact importing solutions and standards from foreign markets and competitors.
These actions can be divided into those to be undertaken by regulators and public administration, as well as those by the market. Of course, cooperation and coordination of actions on both sides is essential so that solutions are efficient and promote the market.
From the regulators and state administration side, the following elements should be noted:
- Administration, regulators, and the central bank should be proactive and draw best practices from their foreign counterparts, enabling the environment to test new solutions in controlled environments/regulatory sandboxes concerning both the instruments themselves and DLT environment interoperability standards necessary for settling tokenized instruments. An example is Digital Securities Sandbox (DSS) – the joint initiative of the Bank of England and FCA regulator, which provides a regulated testing environment enabling the issuance, trading, and settlement of digital securities on DLT technology.
- It is necessary to implement the crypto-assets regulation into the Polish legal order. Although tokenized securities in the EU often fall under MiFID II/CSDR regulations, not MiCA, MiCA implementation should unify and simplify licensing paths for service providers operating alongside securities regulations. Additionally, adopting and “mapping” tokenized instruments and stablecoins to existing banking/payment/investment licenses into the Polish legal order would provide clarity for financial institutions working on these instruments.
- It is necessary to start analyses and work on a national PLN CBDC as a settlement medium for transactions in the Polish tokenization ecosystem, particularly for institutions (banks, payment institutions, FinTech companies), including integration with RTGS/SORBNET2 infrastructure and the KIR system.
At the same time, the market should also start working on infrastructure and product solutions. Such actions could include:
- Traditional / legacy financial institutions/banks will have to modernize systems and payment architecture adapted to “smart money”, otherwise, they will not be able to participate in tokenization ecosystems or offer clients programmable payments. Extremely important is also cooperation with payment institutions and FinTech companies aimed at ensuring interoperability and integration into so-called “multi-rail”. It is necessary to start work on tokenized instruments enabling institutional clients to settle, and in subsequent phases to reach individual clients (digital wallets). Institutions should think about agentic AI, particularly used for transaction settlement, programmable payments, liquidity management, and optimization and active offering/adapting offers to clients.
- Payment institutions should develop “multi-rail” capabilities – the ability to settle not only in traditional transfers and cards, but also in tokenized deposits and selected stablecoins on various platforms and in different standards. It is also necessary to enter the segment of programmable payments, which combined with agentic AI will support real-time decisions.
- Polish FinTech companies should consciously position themselves as partners integrating local systems and regulatory standards with global platforms, banks, and payment institutions, focusing on digital wallet services, KYC/AML for tokenized assets, token issuance platforms including their settlement and reporting, as well as tools based on agentic AI.
Global trends (smart money, agentic payments, stablecoins, tokenized deposits) are already translating into real shifts in volumes, revenues, and deposit base and new sources of risk (fraud, cyber, regulatory risk).
Poland can seize this moment to build its own regulated ecosystem for tokenization of financial instruments and stablecoins with a clear role for KNF and NBP, proactive banks, modern payment operators, and specialized FinTech companies exporting solutions.
Lack of a coordinated strategy means in practice accepting a scenario in which Polish clients and businesses mainly use foreign stablecoins and platforms, and the domestic financial sector is reduced to the role of balance sheet and regulatory “back-office” for foreign ecosystems.
[1] Approaching the Tokenization Tipping Point, Ripple and Boston Consulting Group, 07 April 2024
[2] Stablecoin Giant Tether Now Holds More US Treasuries Than South Korea and UAE, Yahoo Finance, 29 October 2025.
[3] Stablecoin giant is crypto’s fragile foundation, Reuters, 20 February 2026
[4] BlackRock USD Institutional Digital Liquidity Fund (BUIDL), Tokenized By Securitize, Surpasses $1B in AUM, PR Newswire, 13 March 2025
[5] Swiss digital bonds benefit from favorable existing and adapted federal laws, Moody’s Investor Service, 10 August 2023
[6] Approaching the Tokenization Tipping Point, Ripple and Boston Consulting Group, 07 April 2024
