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How the Digital Securities Sandbox Informs Issuer Obligations and Market Design for Digital Fund Shares

23 May 2026 · CurveBlock · Context: Financial Conduct Authority
How the Digital Securities Sandbox Informs Issuer Obligations and Market Design for Digital Fund Shares

The Digital Securities Sandbox was created to let firms trial tokenised and ledger-based representations of securities in a way that interacts with the existing UK regulatory framework. Participants structured offerings to respect core regulatory principles: clear legal title, required disclosures, suitable custody arrangements and robust AML/KYC controls. Those design constraints reflect the reality that digital securities must sit within the same investor-protection perimeter as conventional fund shares.

Operational issues tested in the sandbox include how to demonstrate legal ownership and enforceability, how to segregate client assets, the technical interfaces required for transfers and how to reconcile on‑chain records with off‑chain legal registers. These practical tests highlighted that technology choices—token standards, registries and custodial models—are consequential only insofar as they support the underlying legal and regulatory obligations.

For fund issuers, the sandbox experience points to several enduring obligations: transparent and timely disclosure to investors, demonstrable custody and reconciliation processes, documented settlement and reconciliation procedures, and contingency plans for operational failure. Market design questions—such as whether secondary trading occurs on regulated venues, and how settlement finality is achieved—are important because they affect investor certainty and regulatory oversight.

As the UK moves from testing to a permanent framework, retail investors should expect digital fund shares to be treated through the familiar prism of investor protection, but implemented with new technological patterns. That evolution is relevant to fractional digital share models because it underlines that tokenisation changes technology, not the need for clear legal ownership, custody segregation and disclosure.

Reference source: Financial Conduct Authority

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