RWA Tokenization Regulations by Market

Global regulators in the US, EU, UK, Hong Kong, Singapore, and the UAE are increasingly treating tokenized real-world assets (RWAs) as traditional financial instruments rather than creating new, separate legal categories. The core regulatory challenge lies in ensuring that on-chain token behavior, such as ownership transfers and wallet-level restrictions, aligns perfectly with legal fund registers and custodial records. McKinsey estimates the tokenized asset market could reach 2 trillion USD by 2030, driving central banks and institutions to prioritize the integration of public blockchains with existing financial infrastructure. While the US relies on established frameworks like the Securities Act of 1933 and the Howey test, the EU has implemented the DLT Pilot Regime and MiCA to provide clearer pathways for tokenized financial instruments. The UK and Singapore are leveraging existing regulatory perimeters to allow for institutional experimentation, such as the UK's fund tokenization blueprint and Singapore's Project Guardian. Hong Kong has similarly clarified that tokenized securities fall under the Securities and Futures Ordinance, emphasizing the need for rigorous technology due diligence and smart contract governance. Ultimately, the industry is shifting away from proof-of-concept demos toward live, compliant use cases in fixed income and money-market funds. This regulatory convergence is essential for connecting traditional finance to DeFi and cross-border settlement networks while managing systemic risks like liquidity mismatches and cyber threats.