Gold and precious metals tokenization

FOR TOKENIZED GOLD ISSUERSRESERVE, CUSTODY AND AUDITSCLASSIFICATION IN THE US AND THE EU

Precious metals tokenization means issuing tokens that represent a fixed amount of gold, silver or another metal held in a vault, with custody and audits of the holdings. In the EU, if the token is not a financial instrument, falls under no other MiCA exclusion and purports to maintain a stable value by referencing the metal, it is an asset-referenced token. Unknown Gravity builds the technology for the issuance.

Gold tokenization means issuing tokens that represent a set amount of physical metal held in a vault, with a fixed ratio between each token and a weight of metal, such as one troy ounce or one gram, and with custody and audit arrangements that show the metal exists. This page is for those who want to be the issuer: a refiner, a mining company, a metals dealer, a financial institution or a fintech that wants to launch its own tokenized gold in the United States, the European Union or Latin America.

If you are looking at it from the investor's side (which gold tokens exist, how they are backed and what risks they carry), see our article on gold-backed cryptocurrencies. Here we cover how the issuance is structured, how the token is classified and which part we build. Unknown Gravity builds the technology: we do not hold metal or audit reserves, and we are not a credit institution, broker-dealer, investment adviser, investment firm, crypto-asset service provider (CASP) or law firm.

01 / How a tokenized gold issuance is structured

A tokenized gold issuance has five parts: who issues, where the metal is, how much metal each token represents, how the reserve is proven and how the token is issued and redeemed. Each part is a decision the issuer makes with its advisors; the technology makes it verifiable.

Part	What has to be decided	What the platform builds
Issuer or vehicle	Whether the company itself issues or a company set up only for the issuance, which separates the metal from the rest of the business, and what obligation it takes on toward holders	The token contract and its admin roles, which we recommend be held by the issuer or the regulated firm it appoints
Physical custody	The custodian and the vault, and whether the metal is allocated (identified bars, for example by serial number) or unallocated (a general claim to an amount of metal)	The bar or holdings register, connected to the custodian's reports
Token-to-metal ratio	How much metal, and of what fineness, each token represents, what fees apply and the minimum amount for a physical redemption	Issuance rules that tie each new token to registered metal
Proof of reserves	Who audits or certifies the holdings, how often and what is published	Reconciliation between tokens in circulation and certified metal, and the public page with that data
Issuance and redemption	How the token is bought and how it is exchanged for metal or cash, with which timelines and for whom	Investor onboarding with KYC/AML, minting when payment or metal is received and burning on redemption

The holder's right is set by the contract and the terms of the issuance, not by the blockchain: the holder may own allocated metal or have a claim against the issuer or the custodian. If the token is an asset-referenced token under MiCA, the law adds a permanent right of redemption: at the holder's request, the issuer pays the market value of the referenced assets or delivers them (Regulation (EU) 2023/1114, Art. 39(1) and 39(2)).

02 / How it is classified in the European Union: MiFID II or MiCA

In the EU, the first question is whether the token is a financial instrument; if it is not and it purports to maintain a stable value by referencing the metal, it is an asset-referenced token under MiCA. The two regimes do not apply at the same time: MiCA does not apply to crypto-assets that qualify as financial instruments (Regulation (EU) 2023/1114, Art. 2(4)(a)).

When it is a financial instrument (MiFID II)

If it is a security negotiable on the capital market that gives rise to a cash settlement determined by reference to commodities, it is a transferable security (Directive 2014/65/EU, Art. 4(1)(44)(c)).
If it is a bond or another form of the issuer's securitized debt, it is one too (Art. 4(1)(44)(b)).
If it is a unit in a fund that invests in metal, it is a unit in a collective investment undertaking (Annex I, Section C, point 3).
If it is a derivative on the metal, such as a future, an option or a swap, it may be a financial instrument depending on how it settles and where it trades (Annex I, Section C, points 5 to 7).

Securities law then applies. In Spain, transferable securities may be represented on distributed ledger systems, with an issuance document and an ERIR (Law 6/2023, Arts. 6(1), 7 and 8(4)), and an offer to the public requires an approved prospectus unless an exemption applies (Art. 35(1)).

When it is an asset-referenced token (MiCA)

If it is not a financial instrument and falls under no other exclusion in Art. 2(4), the token is a crypto-asset: a digital representation of a value or of a right that is able to be transferred and stored electronically using distributed ledger technology (Art. 3(1)(5)). If it also purports to maintain a stable value by referencing the metal, it is an asset-referenced token (Art. 3(1)(6)). For the issuer, that means:

Authorization. To offer it to the public or seek its admission to trading in the Union, the issuer must be a legal person established in the EU and authorized by its competent authority, or a credit institution (Art. 16(1), which refers to Arts. 21 and 17). That authorization is not needed if the average value of the tokens in circulation does not exceed EUR 5 million over 12 months and the issuer is not linked to a network of other exempt issuers, or if the offer is addressed only to qualified investors and only they can hold the tokens, but the issuer must still draw up a white paper and notify it (Art. 16(2)).
Reserve. The issuer keeps a reserve of assets at all times, legally and operationally segregated from its own estate (Art. 36(1) to 36(3)).
Custody. Reserve assets that are neither crypto-assets nor financial instruments, such as physical metal, must be held in custody by a credit institution, which must be a legal person other than the issuer, no later than five business days after the token is issued (Art. 37(3)(b) and 37(4)). For these assets, the credit institution verifies that the issuer owns them and keeps a record of them (Art. 37(6)(d)).
Audit and disclosure. An independent audit of the reserve every six months, with publication of the result (Art. 36(9) and 36(10)), and publication, at least monthly, of the number of tokens in circulation and the value and composition of the reserve (Art. 30(1)).
No interest. Neither the issuer nor crypto-asset service providers may grant interest on the token, and any remuneration tied to the length of time it is held counts as interest (Art. 40).

The issuer's legal counsel confirms the category, not the technology. For a first pass, try our MiCA or MiFID II classifier.

03 / How it is classified in the United States and in Latin America

In the US, a gold token that is not a security may be a commodity under the Commodity Exchange Act; it is a security if it is one of the instruments the law defines as securities, and if it is offered with the promise of a return that depends on the issuer's management, it becomes subject to an investment contract, which is a security. That is how the SEC's 2026 interpretation, published together with the CFTC, lays it out (Release 33-11412, in effect since March 23, 2026):

Commodity. The SEC states that any crypto asset that is not a security, other than a payment stablecoin issued by a permitted issuer, could meet the definition of commodity under the Commodity Exchange Act (Release 33-11412, footnote 48). That definition covers, besides a list of agricultural products, "all other goods and articles" (7 U.S.C. 1a(9)).
A security by its form. A digital security is an instrument listed in the legal definition of security, represented as a crypto asset (Section III.E). That definition includes, among others, bonds, participations in profit-sharing agreements and fractional undivided interests in mineral rights (Securities Act Section 2(a)(1), 15 U.S.C. 77b(a)(1)). A token on a mine's future production may fall here.
Subject to an investment contract. A crypto asset that is not a security becomes subject to an investment contract when the issuer offers it with promises of essential managerial efforts from which buyers expect profits (Section IV.A; the Howey test, SEC v. W.J. Howey Co., 328 U.S. 293). A gold token that promises a return generated by the issuer's management, for example by lending out the metal, may end up there.
Not a payment stablecoin. Under the GENIUS Act, the issuer of a payment stablecoin must be obligated, among other requirements, to convert, redeem or repurchase it for a fixed amount of monetary value, that is, a national currency or a deposit denominated in one (Sections 2(17) and 2(22)), and the law excludes from the definitions of security and commodity only payment stablecoins issued by a permitted issuer (Section 17). A token whose value tracks gold has no such reference to a fixed amount of currency. Those exclusions take effect no later than January 18, 2027 (Section 20).
Retail sales with financing. If the token is offered on a leveraged or margined basis, or financed, to someone who is neither an eligible contract participant nor an eligible commercial entity, 7 U.S.C. 6(a), 6(b) and 6b apply to it as if it were a futures contract, subject to exceptions such as a sale that results in actual delivery within 28 days (7 U.S.C. 2(c)(2)(D)).

The issuer's US counsel decides the classification and the offering route. If the token is a security, the rules for any tokenized security apply, as summarized in our guide to asset tokenization in the United States.

Latin America

Each country classifies the token under its securities law and, where it has one, its virtual asset rules. We work with the issuer's local legal counsel; see our country-by-country map of asset tokenization in Latin America.

04 / What we build for the issuer and what stays with others

We build the technology for the issuance: the token, the investor platform, the issuer dashboard and the integrations with the custodian and the auditor.

Token smart contract. ERC-20, or ERC-3643 if only identified investors may hold it, with minting and burning tied to the holdings register, pause, and admin roles, which we recommend be held by the issuer or the regulated firm it appoints.
Investor platform. Onboarding with KYC/AML, purchase, redemption requests for metal or cash, and access to the reserve data.
Issuer dashboard. Issuances, redemptions, periodic reconciliation of tokens and metal, and preparation of the disclosures the applicable regime requires.
Integrations. With the custodian's and the auditor's reports, payment providers and key custody, connected in each project to the providers the issuer chooses. If your issuance needs a full platform of its own, see tokenization platform development.
Code audit. The smart contracts go through an audit before mainnet.

Function	Who takes it on
Buying, storing and insuring the metal	The issuer and its custodian; if the token is an asset-referenced token, a credit institution holds the reserve (MiCA, Art. 37(3)(b))
Auditing or certifying the holdings	An independent auditor
Classifying the token and drafting the documents	The issuer's legal counsel
Applying for authorization, if needed	The issuer
Providing services on the token for clients, such as custody or placement	In the EU, an authorized CASP or another eligible firm (MiCA, Arts. 3(1)(16) and 59(1)) or, if the token is a financial instrument, a firm authorized to provide investment services (MiFID II, Art. 5(1)); in the US, whatever follows from the token's classification
Building the token, the platform and the integrations	Unknown Gravity

05 / How we do it, phase by phase

1. Structure with your advisors

We start from the token classification your counsel makes, the custodian and auditor you choose and the token-to-metal ratio, and turn them into issuance, transfer and redemption rules.

2. Technical design

Network, token standard, admin roles, reserve data sources and the specification of each integration.

3. Development and integrations

Token contract, investor platform, issuer dashboard and the connection to the custodian's and auditor's reports, tested on testnet with your team.

4. Audit and launch

Smart contract audit and mainnet deployment. The date of the first issuance also depends on the authorization or documents the applicable regime requires and on custody being up and running.

5. Operation

Maintenance and further development of the platform, including the page where the issuer periodically publishes the reserve data.

How we work

Unknown Gravity is a Spanish tokenization technology and blockchain infrastructure company. We build the token, the platform and the integrations, and we work alongside the issuer's legal counsel (its US counsel in the United States, local counsel in Latin America), its custodian, its auditor and the regulated firms involved. We do not hold metal or audit reserves.

Official sources

This page is informative only and does not constitute legal, tax or investment advice.

Framework verified as of October 13, 2026. If you are preparing a tokenized gold issuance, we review the structure, the custodian and the technology with you and your counsel before any code is written. Talk to us.

FAQ

Frequently asked questions

Is a gold token an asset-referenced token under MiCA?

It depends on what it represents. If it is a financial instrument, for example a bond of the issuer or a security that settles in cash by reference to the gold price, MiCA does not apply (Regulation (EU) 2023/1114, Art. 2(4)(a)) and MiFID II does (Directive 2014/65/EU, Art. 4(1)(44)). If it is not, falls under no other exclusion and purports to maintain a stable value by referencing the metal, it meets the definition of an asset-referenced token (MiCA, Art. 3(1)(6)): issuer authorization unless an Art. 16(2) exemption applies, a reserve of assets and a right of redemption. The issuer's legal counsel makes the call.

Who holds the gold, and how is it shown to exist?

The issuer chooses the custodian. If the token is an asset-referenced token, reserve assets that are neither crypto-assets nor financial instruments must be held by a credit institution (MiCA, Art. 37(3)(b)), with an independent audit every six months (Art. 36(9)) and publication, at least monthly, of the tokens in circulation and the composition of the reserve (Art. 30(1)). The platform reconciles tokens with metal and publishes that data; an independent third party performs the audit.

In the US, is a gold token a security or a commodity?

Under the SEC's 2026 interpretation, a crypto asset that is not a security could be a commodity under the Commodity Exchange Act (Release 33-11412, footnote 48; 7 U.S.C. 1a(9)). It is a security if it is one of the instruments in the legal definition, such as a bond or a participation in profits (15 U.S.C. 77b(a)(1)); if it is offered with promises of managerial efforts from which buyers expect profits, it becomes subject to an investment contract, which is a security (Release 33-11412, Section IV.A). If it is also sold to retail customers with financing or leverage, 7 U.S.C. 6(a), 6(b) and 6b apply as if it were a futures contract, subject to exceptions such as actual delivery within 28 days (7 U.S.C. 2(c)(2)(D)). The issuer's US counsel decides.