Tokenisation of Fund Units: A New Chapter in Investment Services
The MFSA’s recent Position Paper (June 2025) marks a significant step toward embracing tokenisation of collective investment scheme (CIS) units — enabling fund shares to be issued as digital tokens on blockchain platforms.
At RMC Wise, we're guiding clients through this shift, helping them unlock the benefits while navigating the evolving regulatory landscape. Key takeaways from the MFSA's paper include:
- Tokenised fund units remain financial instruments under MiFID II (not MiCA)
- Tokenisation is permitted across UCITS, AIFs, PIFs, NAIFs, and NPIFS with robust governance
- Transfer agents and fund administrators will play enhanced roles in DLT-based operations
- Due diligence, AML/KYC, wallet security, and smart contract integrity are critical focus areas
- Investor protection, transparency, and liquidity must remain intact
More recently the MFSA issued a Circular highlighting the importance of the fund administrator in managing the tokenisation process as well as in the operational obligations when dealing with tokenised fund units.
At RMC Wise, we help fund managers assess tokenisation readiness, design compliant structures, and implement governance that aligns with regulatory expectations.
Tokenisation is not just a trend — it’s the future of fund administration. Is your firm ready?
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