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The UK’s home for tokenised equity. Independent news, insight and resources for founders raising capital, investors deploying it, and the firms supporting both — as the regulation, infrastructure and opportunity converge.

Bob Wigley Warns the UK Risks Losing Control of Tokenisation Rules to the US Unless It Moves Faster

Writer: Shawn Jhanji
Shawn Jhanji
4 days ago
4 min read
Whoever ends up writing the rulebook for tokenised markets will decide who gets easy access to them first, and a growing chorus of City figures is warning that the UK's window to write that rulebook itself is closing fast. In a City AM op-ed published on 8 September 2026, City grandee Bob Wigley argued that the UK has entered what he calls a new phase of capital markets tokenisation, and now faces a genuine fork in the road: shape the rules, or spend the next decade adapting to rules written somewhere else. The immediate competitive pressure is coming from the United States, where executive orders, an avowedly inclusive posture from regulators and the enactment of the GENIUS Act have combined to give US institutions a head start on legal and operational clarity. The UK is not standing still. Wigley points to a run of recent moves: fresh guidance on tokenised funds and tokenised collateral, the Chancellor's plan for a Digital Gilt Issuance in 2027, and the Bank of England's new secondary objective to support innovation in digital money. Taken together with July's formation of a UK tokenisation taskforce involving BlackRock, Goldman Sachs, JPMorgan and Morgan Stanley, the ingredients for a serious wholesale market strategy are on the table. Wigley's argument is that the UK's real advantage lies in the depth, global reach and specialisation of its existing capital markets, backed by a strong legal and regulatory framework, and that focusing on wholesale fixed income markets with the right architecture, governance and coordination is where the UK can genuinely lead rather than follow. That is a wholesale markets argument, and a reasonable one. But it undersells what is actually at stake for the audience this publication exists to serve. The frameworks being negotiated now for gilts, tokenised funds and institutional collateral will not stay contained to wholesale markets. They will become the template, procedurally and often literally, for how smaller companies eventually issue and trade tokenised equity, how PISCES trading windows get built, and how a SEIS-eligible seed round interacts with a digital share register. If the UK lets the US, or Singapore, or Hong Kong write that template first, the version that eventually filters down to early-stage UK companies will have been designed around someone else's market structure and someone else's investor base, not around the specific problem this country has: a persistent, well-documented gap between how much capital early-stage founders need and how efficiently that capital currently reaches them, particularly outside London. That is the case for urgency that deserves more attention than it currently gets in the wholesale-market framing. The UK's competitive edge was never really going to be won or lost on the depth of its gilt market alone, impressive as that is. It will be won or lost on whether the infrastructure being designed today, ledger standards, custody and nominee models, settlement rules, ends up compatible with the realities of early-stage UK fundraising: SEIS and EIS relief, PISCES-style periodic trading windows, and a Companies House register that has to remain the legal source of truth regardless of what ledger sits on top of it. None of that is being actively worked against in current policy, but none of it is being actively designed for either. It is, at best, an assumed later addition. Coordination is the practical test of whether that changes. HM Treasury, the Bank of England, the FCA and the operators of the PISCES private securities market are all working on adjacent pieces of the same puzzle, largely in parallel rather than in an integrated way. A formal channel connecting the wholesale tokenisation taskforce's work to the FCA's digital securities sandbox and to the practical questions SEIS and PISCES specialists are already raising about custody and holding-period compliance would cost very little and would materially reduce the risk of early-stage market infrastructure being bolted on as an afterthought once the wholesale rules are settled. Wigley is right that, in his words, the UK can still "lead the next phase of financial innovation." Whether founders and early investors actually benefit from that leadership, rather than simply inheriting whatever wholesale market plumbing gets built first, is the open question this publication will keep returning to.

Whoever ends up writing the rulebook for tokenised markets will decide who gets easy access to them first, and a growing chorus of City figures is warning that the UK's window to write that rulebook itself is closing fast.


In a City AM published on 8 September 2026, City grandee Bob Wigley argued that the UK has entered what he calls a new phase of capital markets tokenisation, and now faces a genuine fork in the road: shape the rules, or spend the next decade adapting to rules written somewhere else. The immediate competitive pressure is coming from the United States, where executive orders, an avowedly inclusive posture from regulators and the enactment of the GENIUS Act have combined to give US institutions a head start on legal and operational clarity.


The UK is not standing still and Wigley points to a run of recent moves: fresh guidance on tokenised funds and tokenised collateral, the Chancellor's plan for a Digital Gilt Issuance in 2027, and the Bank of England's new secondary objective to support innovation in digital money.


Taken together with July's formation of a UK tokenisation taskforce involving BlackRock, Goldman Sachs, JPMorgan and Morgan Stanley, the ingredients for a serious wholesale market strategy are on the table. Wigley's argument is that the UK's real advantage lies in the depth, global reach and specialisation of its existing capital markets, backed by a strong legal and regulatory framework, and that focusing on wholesale fixed income markets with the right architecture, governance and coordination is where the UK can genuinely lead rather than follow.


That is a wholesale markets argument, and a reasonable one. But it undersells what is actually at stake for the wider landscape. The frameworks being negotiated now for gilts, tokenised funds and institutional collateral will not stay contained to wholesale markets. They will become the template, procedurally and often literally, for how smaller companies eventually issue and trade tokenised equity, how PISCES trading windows get built, and how a SEIS-eligible seed round interacts with a digital share register.


If the UK lets the US, or Singapore, or Hong Kong write that template first, the version that eventually filters down to early-stage UK companies will have been designed around someone else's market structure and someone else's investor base, not around the specific problem this country has: a persistent, well-documented gap between how much capital early-stage founders need and how efficiently that capital currently reaches them, particularly outside London.


That is the case for urgency that deserves more attention than it currently gets in the wholesale-market framing. The UK's competitive edge was never really going to be won or lost on the depth of its gilt market alone, impressive as that is. It will be won or lost on whether the infrastructure being designed today, ledger standards, custody and nominee models, settlement rules, ends up compatible with the realities of early-stage UK fundraising: SEIS and EIS relief, PISCES-style periodic trading windows, and a Companies House register that has to remain the legal source of truth regardless of what ledger sits on top of it. None of that is being actively worked against in current policy, but none of it is being actively designed for either. It is, at best, an assumed later addition.


Coordination is the practical test of whether that changes. HM Treasury, the Bank of England, the FCA and the operators of the PISCES private securities market are all working on adjacent pieces of the same puzzle, largely in parallel rather than in an integrated way. A formal channel connecting the wholesale tokenisation taskforce's work to the FCA's digital securities sandbox and to the practical questions SEIS and PISCES specialists are already raising about custody and holding-period compliance would cost very little and would materially reduce the risk of early-stage market infrastructure being bolted on as an afterthought once the wholesale rules are settled.


Wigley is right that, in his words, the UK can still "lead the next phase of financial innovation." Whether founders and early investors actually benefit from that leadership, rather than simply inheriting whatever wholesale market plumbing gets built first, is the open question this publication will keep returning to.


Key Takeaways

  • Bob Wigley argues the UK must move quickly to shape global tokenisation rules or risk following frameworks set by the US, which has moved ahead via the GENIUS Act and an inclusive regulatory posture.

  • UK progress so far includes guidance on tokenised funds and collateral, a planned 2027 Digital Gilt Issuance, a new Bank of England secondary objective on digital money innovation, and a July 2026 tokenisation taskforce with BlackRock, Goldman Sachs, JPMorgan and Morgan Stanley.

  • The current UK framing is largely a wholesale markets argument, but the same infrastructure decisions will shape how tokenised equity, SEIS relief and PISCES trading eventually work for early-stage companies.

  • Closer coordination between HM Treasury, the Bank of England, the FCA and PISCES operators would reduce the risk that early-stage market infrastructure is designed as an afterthought.


This piece reflects editorial analysis and is general information, not investment or regulatory advice.


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