Dutch regulators say national law blocks native securities tokenisation

The AFM and DNB publish a joint exploratory study on securities tokenisation in the Netherlands, concluding that current Dutch law offers no basis for fully native tokens and forcing firms into hybrid dual-registration arrangements. This segment covers what the regulators found, what they are asking government to do, and why Dutch market infrastructure choices may migrate elsewhere.

• AFM and DNB find Dutch law gives no basis for securities issued, held and transferred exclusively as tokens; native tokenisation is not currently possible.
• Hybrid dual registration alongside DLT limits efficiency gains and creates uncertainty over the legal significance of the token record.
• The regulators call for a government-led follow-up aligned with European initiatives, using specific use cases to decide whether to clarify or amend rules.

Executive summary

The Dutch Authority for the Financial Markets (AFM) and De Nederlandsche Bank (DNB) have published a joint exploratory study concluding that the Dutch legal framework provides no basis for securities that are issued, held and transferred exclusively as tokens. The…

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