---
title: "How to tokenize real-world assets on Solana: cases, EU and Spanish rules, and process"
url: "https://www.unknowngravity.com/en/articulos/tokenize-real-world-assets-solana"
site: Unknown Gravity
published: "2026-10-16T15:25:45+00:00"
modified: "2026-10-16T15:25:47+00:00"
language: en
description: "How to tokenize real-world assets on Solana: which regime applies, Token-2022 controls, cases such as BUIDL and SWEEP, and what Spain's Law 6/2023 requires."
section: "Home > Blog > How to tokenize real-world assets on Solana: cases, EU and Spanish rules, and process"
---

# How to tokenize real-world assets on Solana: cases, EU and Spanish rules, and process

**Yes, you can tokenize real-world assets on Solana: the Token-2022 program supports investor allowlists, freezing, pausing and forced transfers.** But the network does not set the legal regime; the asset does. If the token is a transferable security under Spanish law, you need an ERIR, an issue document and a prospectus or an exemption.

This guide follows the order in which a project gets decided: what right the token gives and which rules apply, how it is built on Solana, which institutions already do it (with their announcements), what changes when the issuer is Spanish, and what the process looks like. If you are looking for the service, see our [Solana development](/en/blockchain/desarrollo-blockchain-solana) page; if you need the network basics first, start with [what Solana is](/en/glosario/solana).

## Which real-world assets can be tokenized and which regime applies

A real-world asset, or [RWA](/en/glosario/real-world-assets-rwa), can be real estate, debt, a fund, shares or a commodity. For the rules, what matters is less the asset than the right the token gives. MiCA starts from technology neutrality (recital 9), and Spain's Law 6/2023 allows transferable securities to be represented on distributed ledger systems without naming any network (art. 6.1). No network is compliant on its own: what is regulated is the asset and whoever offers it.

| What the token represents | Examples | Regime | What it requires |
| --- | --- | --- | --- |
| A financial instrument: a share, bond, commercial paper or fund unit | Shares or debt of the company that owns a building; a money market fund | MiFID II: still a financial instrument when issued on a distributed ledger (art. 4(1)(15), as worded by Regulation 2022/858). MiCA does not apply (art. 2(4)(a)). In Spain, Law 6/2023 | Issue document and ERIR (arts. 7 and 8.4 of Law 6/2023), a prospectus or an exemption, and authorized firms for investment services |
| A crypto-asset aiming at a stable value by referencing one official currency | A tokenized euro or dollar | MiCA: e-money token, or EMT (art. 3(1)(7)) | The issuer must be a credit institution or an electronic money institution (art. 48(1)) |
| A crypto-asset aiming at a stable value by referencing other values or rights | A token tied to a basket of assets or to a commodity, designed to hold a stable value | MiCA: asset-referenced token, or ART (art. 3(1)(6)) | An authorized issuer or a credit institution (art. 16(1)) |
| Any other crypto-asset that is not a financial instrument | A transferable non-financial right | MiCA, Title II | A legal person, and a white paper drawn up, notified and published (art. 4(1)) |
| A unique, non-fungible asset | A specific artwork represented by a single token | Outside MiCA (art. 2(3)) | Careful: fractions of a unique asset are not considered unique (recital 11) |

The main responsibility for classifying the token lies with whoever offers it or seeks its admission to trading, and the authority may challenge that classification before or after the offer (MiCA recital 14). For the line between crypto-asset and financial instrument, MiCA tasked ESMA with guidelines (art. 2(5)). If you are unsure which regime applies, read [MiCA vs MiFID II: which regulation applies to your token](/en/articulos/mica-vs-mifid-ii) first. The institutional cases below represent fund units, debt or exposure to equities.

## How the token is built on Solana: Token-2022

On Solana a token is not a new contract: you create a "mint" account of a token program that is already deployed. There are two main token programs: the original one and Token Extensions, known as Token-2022. The [official tokenization documentation](https://solana.com/docs/tokenization) says tokenized assets on Solana are built on Token-2022 and its extensions, which add optional features to the token or to each holder's account.

The ones used most for a regulated asset:

- **Default Account State.** New accounts start frozen and cannot be used until the freeze authority thaws them. It is the pattern for onboarding an investor after KYC.
- **Transfer Hook.** Runs a custom program on every transfer. The documentation lists allowlists and blocklists of recipients as a use.
- **Permanent Delegate.** An authority that can transfer or burn from any account of the token, and holders cannot revoke it.
- **Pausable.** Stops transfers, mints and burns for the whole token.
- **Scaled UI Amount and Interest-Bearing.** Change the amount displayed (a split, a dividend, an interest rate) without creating new tokens.
- **Token Metadata.** Stores metadata on the mint itself.

One design rule to settle early: most extensions cannot be added after the account is created, and some are incompatible with each other. Controls are decided before issuance. Each extension, and how it maps to the Ethereum standard, is covered in [Token-2022 for regulated tokens](/en/articulos/solana-token-extensions-regulated-assets).

## Investor allowlists: three documented approaches

- **Frozen-by-default accounts and manual onboarding.** With Default Account State, whoever holds the freeze authority thaws each account once the investor passes KYC. The [official NAV guide for money market funds](https://solana.com/docs/tokenization/nav-strikes) uses this state and calls it "critical for regulatory compliance."
- **Token ACL (sRFC 37).** The mint delegates its freeze authority to a Token ACL configuration, and investors can thaw their own accounts if a "gate program" approves: through an allowlist, a blocklist or custom logic. If a wallet is on both lists, the blocklist wins. As of October 16, 2026, the Token ACL program and its reference gate are already on mainnet, according to the [official repository](https://github.com/solana-foundation/token-acl) and our own query to the network, although one section of the [Token ACL documentation](https://solana.com/docs/tokenization/token-acl) still says they are only on devnet. They are upgradeable programs: consider who controls their upgrade authority.
- **Transfer hook.** Checks every transfer, not just onboarding. It is more flexible, but each transfer needs extra accounts and, according to the Token ACL documentation itself, many DeFi protocols do not accept these tokens.

Token ACL and a hook can be combined: the first controls who can hold the token, the second how it moves.

## Custody, issuer authorities and oracles

**Authorities.** A Token-2022 mint can carry several powerful keys: mint, freeze, pause and permanent delegate. The [solana.com guide to ERC-3643](https://solana.com/developers/evm-to-svm/erc3643) places the compliance admin in a PDA (an address controlled by a program) or in a multisig that owns the mint. Whoever controls those keys controls other people's balances: for the issuer it is a compliance function, and for the investor a counterparty risk that must be disclosed in the issuance documents. If you also deploy your own program, such as a hook, it stays upgradeable for as long as its upgrade authority exists.

**Investor custody.** For securities, safekeeping and administering financial instruments for clients is an ancillary investment service (art. 126.a of Law 6/2023) that requires authorization (art. 129.1). It is also the activity the ERIR must be authorized for (art. 8.4). In Galaxy's commercial paper, Coinbase provided private-key custody and wallet services for the token, according to J.P. Morgan's release.

**Oracles and off-chain data.** A real-world asset needs data from outside the chain: prices, net asset value or payments. There are two documented patterns. In the official NAV guide, net asset value is stored in the token's metadata and updated by the fund administrator, with no oracle. If you need market data, Chainlink documents its [Data Feeds on Solana](https://docs.chain.link/data-feeds/solana), which your program can read on the network itself. Either way, the data source and who can change it should be in the documentation.

## Institutional cases on Solana, with their announcements

Cases checked against the issuer's or arranger's own source, as of October 16, 2026:

| Date | Asset | What was done on Solana | Source |
| --- | --- | --- | --- |
| Mar 25, 2025 | BUIDL, BlackRock's USD liquidity fund, tokenized by Securitize | A new share class on Solana, for qualified investors. Securitize, LLC is an SEC-registered transfer agent | [Securitize (PR Newswire)](https://www.prnewswire.com/news-releases/blackrock-and-securitize-debut-new-buidl-share-class-on-solana-network-302410160.html) |
| May 22, 2025 | xStocks (Backed): tokenized US stocks and ETFs | Announced for Kraken and Solana apps. Backed does not sell them to "U.S. Persons" | [Backed](https://backed.fi/news-updates/backed-announces-xstocks-coming-soon-to-kraken-and-solana) |
| Dec 11, 2025 | US commercial paper of Galaxy Digital Holdings LP | J.P. Morgan arranged the issuance, created the token and facilitated delivery-versus-payment; Galaxy also acted as structurer. Bought by Coinbase and Franklin Templeton; issuance and redemption paid in USDC | [J.P. Morgan](https://www.jpmorgan.com/about-us/corporate-news/2025/jpmorgan-commercial-paper-issuance-solana-blockchain) |
| Jan 21, 2026 | Ondo Global Markets | More than 200 tokenized US stocks and ETFs available on Solana | [Solana Foundation](https://solana.com/news/ondo-global-markets-tokenized-stocks-etfs-solana) |
| May 5, 2026 | SWEEP, a liquidity fund by State Street Investment Management and Galaxy | Launched on Solana, for "Qualified Purchasers" only, with subscriptions in PYUSD | [State Street](https://investors.statestreet.com/investor-news-events/press-releases/news-details/2026/State-Street-Investment-Management-and-Galaxy-Digital-Bring-Cash-Management-Onchain/default.aspx) |
| SAI dated Aug 1, 2026 | Franklin OnChain U.S. Government Money Fund (FOBXX, BENJI) | Solana available for certain accounts upon request | [Franklin Templeton (SAI)](https://www.franklintempleton.com/forms-literature/download-preview/9001-SAI) |

These cases show that the technical pattern works: funds, debt and equities, with stablecoin settlement and delivery-versus-payment. They do not replace the analysis of the rules that apply to your issuance. A longer list of banks and asset managers is in [banks and asset managers using Solana](/en/articulos/banks-asset-managers-using-solana).

## How much tokenized value is on Solana

According to [rwa.xyz](https://app.rwa.xyz/networks/solana), as of October 16, 2026 Solana holds USD 4.39 billion in "distributed" real-world assets, excluding stablecoins, with 907,329 holders. Stablecoins are counted separately: USD 15.02 billion. rwa.xyz calls "distributed" the tokens that can leave the issuing platform and move between wallets; "represented" assets, which cannot, total USD 125.86 million.

## If the issuer is Spanish: ERIR, issue document, prospectus and MiFID II

If the token is a transferable security, Law 6/2023 sets the path regardless of the network:

- **Form of representation.** The issuer chooses book entries, certificates or distributed ledgers, and the choice applies to the whole issue (art. 6.1).
- **Issue document.** Drawn up by the issuer, it identifies the entity responsible for the register (art. 7.1).
- **ERIR.** The issuer appoints one or more entities responsible for registering and recording the securities in the system. It can be the issuer itself, but always an entity authorized to safekeep and administer financial instruments (art. 8.4, which refers to art. 126.a). These entities identify the holders and record corporate events, entries and encumbrances. Solana is the system; the [ERIR](/en/glosario/erir-entidad-de-registro-e-identificacion-registral) is accountable for the register.
- **Prospectus or exemption.** A public offer of securities requires a prospectus (art. 35.1 of Law 6/2023 and Regulation 2017/1129). There are exemptions by audience: qualified investors only, fewer than 150 persons per Member State other than qualified investors, or at least EUR 100,000 per unit or per investor (art. 1(4) of the Regulation). By size, since June 5, 2026 the Regulation exempts offers below EUR 12 million over twelve months (art. 3(2)(b)), unless the Member State opts for a EUR 5 million threshold (art. 3(2a)), but art. 35.2.b of Law 6/2023 still says EUR 8 million, and the CNMV says the law is still pending amendment. Check with your counsel and the CNMV before setting the offer size.
- **Placement with advertising.** If a prospectus-exempt issue targets the general public with advertising, a firm authorized to provide investment services must be involved (art. 36.1).
- **MiFID II services.** Placing the security or bringing investors together are investment services (art. 125.1 of Law 6/2023), and providing them on a professional basis requires authorization (art. 129.1). Running the platform on Solana does not change that.

We cover this in more depth in [Law 6/2023 (LMVSI) and securities tokenization](/en/articulos/lmvsi-ley-6-2023-tokenizacion).

## Secondary market: the DLT Pilot Regime

If you want the token to trade on a trading venue, Law 6/2023 requires admitted securities to be in book-entry form or on distributed ledgers within the framework of Regulation (EU) 2022/858 (art. 6.2). That regulation is the [DLT Pilot Regime](/en/glosario/regimen-piloto-dlt): it has applied since March 23, 2023 and creates three types of infrastructure, the DLT MTF, the DLT SS and the DLT TSS, which combines trading and settlement.

It sets limits per instrument at the time of admission (art. 3(1)): shares of issuers with a market capitalization below EUR 500 million, bonds and other debt with an issue size below EUR 1 billion, and UCITS units with assets below EUR 500 million. On top of that, the aggregate market value of all instruments admitted or recorded on one infrastructure cannot exceed EUR 6 billion (art. 3(2)). [ESMA's list of authorized infrastructures](https://www.esma.europa.eu/sites/default/files/2026-01/Authorised_DLT_Market_Infrastructures.pdf) includes Securitize Europe DLT TSS, with the CNMV as competent authority and a specific permission dated November 26, 2025. The Commission proposed reforming the regime on December 4, 2025 (COM(2025) 943); as of October 16, 2026, the [European Parliament procedure file](https://oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0383(COD)) reads "Awaiting committee decision." It is a proposal, not law.

Before choosing a network, ask the infrastructure which networks it supports. Without a regulated secondary market, transfers between investors go through the token's controls and through the ERIR's register, which identifies the holders (art. 8.4).

## Step by step: a tokenization project on Solana

1. **Classify the token.** With your legal counsel: financial instrument, EMT, ART or another crypto-asset. Everything else depends on it.
2. **Choose the structure and documents.** Vehicle, issue document, appointed ERIR, and a prospectus or an exemption. If there will be a secondary market, the Pilot Regime infrastructure.
3. **Design the token.** Pick the Token-2022 extensions before creating the mint: frozen-by-default accounts, permanent delegate, pause, metadata and, if needed, a hook or Token ACL.
4. **Assign the keys.** Who holds each authority (mint, freeze, pause, permanent delegate), in which multisig or PDA, and how it is explained to investors.
5. **Connect KYC.** Onboard investors (thaw their account or add them to the list) only after verification.
6. **Reconcile with the ERIR.** On-chain balances and the ERIR's register must match, including corporate events and encumbrances.
7. **Audit.** Every custom program, with verified builds to show that the deployed binary matches the published code, and a clear policy on its upgrade authority.
8. **Issue and settle.** Delivery-versus-payment in a single transaction, with a stablecoin as the payment leg. solana.com publishes reference guides for delivery-versus-payment and fund NAV, with a warning not to use them in production without audits and legal review.
9. **Run the security's life cycle.** Payments, corporate events (with Scaled UI Amount where it fits), investor onboarding and offboarding, and orders from authorities.

**How we approach it.** At Unknown Gravity we design and build the token, the programs and the integrations (KYC, ERIR, custody and payments), and we work with the ERIR and the legal counsel you appoint. We are a Spanish tokenization technology company: we are not an ERIR, an investment firm, an investment adviser or a law firm.

## Frequently asked questions

### Can tokenized securities be issued on Solana under Spain's Law 6/2023?

The law does not prevent it: it allows transferable securities to be represented on distributed ledgers without naming any network (art. 6.1). What it requires is an issue document and an ERIR authorized to safekeep and administer financial instruments (arts. 7 and 8.4). The network does not replace the ERIR.

### Do I need a prospectus to tokenize a real-world asset?

If the token is a security and you offer it to the public, yes, unless an exemption applies: qualified investors only, fewer than 150 persons per Member State, EUR 100,000 per unit or per investor, or a small offer size. The size threshold in the Prospectus Regulation has been EUR 12 million since June 5, 2026, but Law 6/2023 still says EUR 8 million: check with the CNMV.

### Does MiCA apply to a real-world asset token?

It depends on what the token represents. If it is a financial instrument, no (MiCA art. 2(4)(a)). If it aims at a stable value by referencing one official currency, it is an EMT; if it references other assets, an ART. A unique, non-fungible asset falls outside MiCA, but its fractions do not.

### Which real-world assets are already tokenized on Solana?

Among the cases with an announcement: BlackRock's BUIDL fund (March 2025), Galaxy commercial paper arranged by J.P. Morgan (December 2025), Ondo Global Markets (January 2026), the SWEEP fund by State Street and Galaxy (May 2026), and Franklin Templeton's FOBXX money market fund, with Solana for certain accounts. According to rwa.xyz, as of October 16, 2026 there are USD 4.39 billion in distributed real-world assets on Solana.

### Can a tokenized security on Solana trade on a secondary market?

On a trading venue, only within the DLT Pilot Regime (art. 6.2 of Law 6/2023), on an authorized infrastructure and within its limits. Ask the infrastructure which networks it supports before you issue.

## Sources

- [Law 6/2023 on Securities Markets and Investment Services (BOE, consolidated text, in Spanish)](https://www.boe.es/buscar/act.php?id=BOE-A-2023-7053)
- [Regulation (EU) 2023/1114, MiCA (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32023R1114)
- [Regulation (EU) 2022/858, DLT Pilot Regime (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:32022R0858)
- [Regulation (EU) 2017/1129, Prospectus Regulation, consolidated as of June 5, 2026 (EUR-Lex)](https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX:02017R1129-20260605)
- [CNMV: prospectus-exempt offers (in Spanish)](https://www.cnmv.es/portal/sistemas-multilaterales-negociacion/ofertas-exentos-folleto)
- [ESMA: authorized DLT market infrastructures](https://www.esma.europa.eu/sites/default/files/2026-01/Authorised_DLT_Market_Infrastructures.pdf)
- [European Parliament: procedure 2025/0383(COD)](https://oeil.secure.europarl.europa.eu/oeil/en/procedure-file?reference=2025/0383(COD))
- [Solana: Asset Issuance & Tokenization](https://solana.com/docs/tokenization)
- [Solana: Permissioned Tokens with Token ACL (sRFC 37)](https://solana.com/docs/tokenization/token-acl)
- [Solana Foundation: Token ACL repository (GitHub)](https://github.com/solana-foundation/token-acl)
- [Solana: NAV Strikes for Money Market Funds](https://solana.com/docs/tokenization/nav-strikes)
- [Solana: Token Extensions](https://solana.com/docs/tokens/extensions)
- [Securitize: BUIDL share class on Solana (Mar 25, 2025)](https://www.prnewswire.com/news-releases/blackrock-and-securitize-debut-new-buidl-share-class-on-solana-network-302410160.html)
- [J.P. Morgan: US commercial paper issuance on Solana for Galaxy (Dec 11, 2025)](https://www.jpmorgan.com/about-us/corporate-news/2025/jpmorgan-commercial-paper-issuance-solana-blockchain)
- [State Street Investment Management and Galaxy: SWEEP (May 5, 2026)](https://investors.statestreet.com/investor-news-events/press-releases/news-details/2026/State-Street-Investment-Management-and-Galaxy-Digital-Bring-Cash-Management-Onchain/default.aspx)
- [Solana Foundation: Ondo Global Markets on Solana (Jan 21, 2026)](https://solana.com/news/ondo-global-markets-tokenized-stocks-etfs-solana)
- [Backed: xStocks coming to Kraken and Solana (May 22, 2025)](https://backed.fi/news-updates/backed-announces-xstocks-coming-soon-to-kraken-and-solana)
- [Franklin Templeton: Statement of Additional Information (Aug 1, 2026)](https://www.franklintempleton.com/forms-literature/download-preview/9001-SAI)
- [rwa.xyz: Solana](https://app.rwa.xyz/networks/solana)

*Framework verified as of October 16, 2026.* Considering tokenizing an asset on Solana and want to review the structure and the token's controls? [Talk to us](/en/meeting).