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Key takeaways:
- Traditional and tokenized market structures are likely to operate in parallel for some time. That coexistence could create additional complexity as firms navigate multiple operating models, infrastructure choices and interactions across the evolving market environment.
- As ownership, settlement and asset servicing become more integrated with on-chain infrastructure, firms may need to adapt operating models and responsibilities across the securities lifecycle.
- Firms can make progress without committing to a single future-state model. Building transferable capabilities, making deliberate choices where needed and preserving flexibility can help firms respond as standards, infrastructure and client demand continue to evolve.
Tokenization is moving from early adoption toward broad implementation. However, US capital markets are unlikely to transition neatly from one operating model to another. Traditional infrastructure and multiple tokenized architectures may coexist for an extended period, creating new operational, governance, and strategic challenges for firms across the market ecosystem.
Broker-dealers, custodians, asset managers, transfer agents, issuers, and other market participants should prepare for a range of outcomes without locking into a single tokenization model too early. You'll likely need to build capabilities that are relevant across multiple models and preserve flexibility where standards and operating models remain unsettled.
1. One market, multiple architectures
Today's market structures are fundamentally changing in terms of ownership, settlement, and recordkeeping authority. Rather than converging around a single approach, market participants are developing different models for integrating tokenization into the securities life cycle.
The Depository Trust Company’s (DTC) tokenization pilot illustrates one path. Under the pilot, settlement, finality, and the official ownership record remain anchored in existing DTC infrastructure, while exchanges, broker-dealers, and on-chain wallets can maintain tokenized representations of the same entitlement. This approach preserves much of the established legal and operational structure, and it also introduces additional coordination and reconciliation points between traditional and tokenized records.
Nasdaq’s issuer-led equity token design illustrates a materially different approach. It places the issuer closer to the center of ownership rights and governance, with blockchain records integrated directly into the issuer’s official share registry. Under that model, the token itself can become the authoritative ownership record, potentially reducing the need for parallel records across multiple intermediaries while likely requiring changes to legal, operational, and governance arrangements around control of that record.
These models represent different answers to a fundamental question about market-structure: Does tokenization sit alongside the existing ownership and settlement framework, or become part of the authoritative record itself? Other models may emerge between or around those approaches, including infrastructure to connect different tokenized environments. They’re not mutually exclusive, and different structures may ultimately suit different asset classes, issuers, or types of market activity.
Illustrative market-structure evolution. The graphic depicts one potential path in which tokenized capabilities develop alongside existing infrastructure before elements of the market structure become more streamlined. It is illustrative. Other architectures may develop in parallel, the roles performed by individual market participants may vary by model, and adoption is unlikely to occur uniformly across asset classes.
The implications for market participants will depend on which model or combination of models gains traction. If tokenization remains largely an entitlement layer attached to existing infrastructure, many incumbent roles may remain even as firms modernize how they're performed. If ownership records and asset servicing move further on-chain, some current intermediary functions could be reassigned, combined or compressed.
Broker-dealers may need to support new trading and transfer arrangements, custodians may see greater demand for key management and tokenized asset servicing, and transfer agents may increasingly combine traditional shareholder-servicing responsibilities with tokenized recordkeeping and governance capabilities. Exchanges and infrastructure providers may also need to determine which models they support and how they connect to other networks.
Regulators sit across each of these models. The SEC’s 2026 Staff Statement on Tokenized Securities clarified that tokenized securities remain subject to existing federal securities laws. Firms still need to determine how those requirements translate operationally across custody, customer protection, recordkeeping, and control of the authoritative ownership record. The statutory framework may be familiar, but the operating model is not.
For companies, this makes the current period more than a choice between committing early and waiting for certainty. Some architecture decisions can remain open while standards develop. Other capabilities, including reconciliation across traditional and tokenized records, controls over keys and smart contracts, and operating models for longer trading windows may be relevant across multiple future states. Building those capabilities does not require predicting which architecture may ultimately prevail, but it does require an understanding of the risks of different structures operating simultaneously.
2. The operating risks of parallel market structures
Tokenization introduces risks that have no direct analog in existing capital markets infrastructure, and many companies are only beginning to incorporate them into their risk frameworks, stress scenarios, or supervisory procedures. Many of these risks extend beyond any single entity’s choices and reflect broader changes in market structure that companies should plan for.
Existing risk frameworks and supervisory procedures were generally designed around more established market structures. As tokenized and traditional models begin to interact, firms may need to revisit those frameworks before the market structure itself is fully settled.
3. Not a waiting period but a time to act
The current implementation period matters not because it delays consequences but because it gives firms time to build experience before market structure choices become harder to reverse. Companies that treat this as a waiting period—expecting that regulators, exchanges, or infrastructure providers will resolve the open questions first—may find their competitors setting the agenda.
We suggest acting soon to move from analysis to action. You can arrange near-term steps into three categories:
- What you may want to build regardless of strategic direction,
- Where you likely will need to take a position,
- Where you can preserve optionality instead of making firm commitments.
Market structure is unlikely to be settled all at once, and you don’t need all the answers before acting. By taking early steps to build transferable capabilities, make deliberate choices, and preserve optionality, you can be better positioned for changing standards, infrastructure, and client demand. You don’t need to predict which model will prevail, but you should prepare to operate in the future environment.
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