Very different products are sold today under the name tokenised stocks. Two clients who buy an Apple token in two different apps may be holding instruments with completely different legal nature, rights and risks. For a bank that wants to offer this product, understanding that difference is the first step, because it determines the applicable regime, the information it must give the client and the infrastructure it needs.
This article compares the three main forms on the market: tracker certificates, derivatives issued by a broker and native tokenised securities. The general requirements for a bank to distribute this type of product are covered in what a bank needs to offer tokenised stocks.
Tracker certificates
The most widespread form in Europe is the tracker certificate, a debt instrument whose value mirrors that of a share. The best known example is xStocks, issued by Backed Assets (JE) Limited, a Jersey company, under a base prospectus approved by the Liechtenstein financial authority and passported across the European Economic Area.
The client does not own the share. They hold a claim against the issuer, secured by real shares held in custody 1:1 with an independent security agent. They have no voting rights, and corporate actions such as dividends are reflected through adjustments to the token balance rather than as payments. The tokens live on public networks such as Ethereum or Solana and can be transferred between wallets, but their sale is restricted in the United States, the United Kingdom, Canada and Australia.
For a bank, the advantage is that this is a security with an EU-approved prospectus, which it can distribute under MiFID II with its usual controls. The main risk is issuer risk: the client depends on the legal and operational soundness of the structure behind the certificate.
Derivatives issued by a broker
Another form is for the broker itself to issue a derivative contract whose price tracks the share. This is the model Robinhood has used for its European Union clients since June 2025. According to the company, its tokens are offered under MiFID II as derivatives, with the underlying assets held by a US-licensed institution.
The client gets price exposure and dividends, which are credited to their account off-chain, but not shareholder rights. The token lives inside the broker’s ecosystem and cannot be moved to another broker. In July 2025 the Bank of Lithuania, which supervises Robinhood’s European subsidiary, asked for clarification on how these products are structured, a sign that the regulatory treatment of tokenised derivatives is still being refined.
For a bank, this model means issuing its own derivative or distributing a third party’s, with the obligations of a complex product, and taking on or passing to the client a counterparty risk concentrated in the issuer of the contract.
Native tokenised securities
The third form is closest to a traditional share: the token is the share itself, or a record of it, with the same legal rights. There is no intermediate certificate or derivative. What changes is the technology used to record and transfer ownership.
In the United States, DTCC, which settles and holds almost every equity trade in the country, received SEC authorisation in December 2025 to tokenise assets it already holds in custody, carried out live production trades with more than 30 firms in July 2026 and plans its commercial launch in October. In September 2026 the SEC also issued an exemption framework requiring tokenised shares to keep the same dividend and voting rights as traditional ones.
In the European Union, the DLT Pilot Regime (Regulation (EU) 2022/858) allows authorised infrastructures to trade and settle native securities on blockchain. 21X, authorised by BaFin in December 2024, has operated since 2025 a trading and settlement system on Polygon with access restricted to verified wallets. ESMA notes, however, that uptake of the regime remains limited, with three authorised infrastructures and little activity.
For a bank, this is the model with the least added risk for the client, because the asset is the same one they already know. But its availability depends on issuers and market infrastructure offering it, and supply is still small today.
Comparing the three instruments
| Criterion | Tracker certificate | Broker derivative | Native tokenised security |
|---|---|---|---|
| What the client holds | A debt instrument | A contract with the broker | The share |
| Voting rights | No | No | Yes |
| Dividends | Token balance adjustment | Credited to the account | As with the share |
| EU framework | Prospectus and MiFID II | MiFID II, complex product | MiFID II and DLT Pilot Regime |
| Transferable outside the platform | Yes, between wallets | No | Depends on the infrastructure |
| Main risk | Certificate issuer | Issuing broker | Market infrastructure |
| Current availability | Wide | Wide, tied to each broker | Limited, growing |
What it means for a bank
The first consequence concerns client information. If the institution offers a certificate or a derivative, it must explain clearly that the client is not a shareholder, what happens with dividends and against whom they hold their claim. MiFID II product governance requires defining the target market with those differences in mind.
The second concerns infrastructure. The three models coexist today and are likely to do so for years while the supply of native securities matures. An infrastructure tied to a single issuer or instrument type forces the bank to rebuild the product when the market changes. An infrastructure that holds tokens in the bank’s HSMs and connects to several issuers and liquidity venues makes it possible to offer certificates today and add native securities when they become available, without changing the client experience.
The third concerns control. When the token sits in a wallet held by the bank, the institution keeps the client relationship and the position shows up in the client’s overall portfolio. When it sits on a broker’s platform, the relationship and the data stay outside.
At Finhattan we deploy inside each bank an infrastructure that holds assets in its own HSMs and connects to the issuers the institution chooses. It is described in how we work, and the choice between individual and omnibus wallets is covered in this article.
For an institution weighing which instruments to offer, the starting point is contact.