Executive summary
Tokenisation is entering mainstream securities markets. Tokenisation alone does not deliver simultaneous settlement of the security and its payment.
On 18 March 2026, the SEC approved Nasdaq rule changes enabling eligible securities to trade in tokenised form under the DTC tokenisation pilot. The order expressly states that these trades would continue to settle on T+1. This is a concrete example of the distinction between changing the form in which a security is held and changing when a transaction settles.
The proposed elegance of SAYG lies in applying token-processing capabilities to the settlement arrangement itself, so that the security and the agreed settlement instrument transfer together. The tokenisation infrastructure being introduced into regulated markets offers a potential implementation route. Whether SAYG can use a particular platform depends on technical integration, the instruments that platform supports, and its legal and operating rules.
Nasdaq’s approval establishes a regulatory precedent for a specified tokenised-securities trading arrangement. It does not approve SAYG, certify a general-purpose technology, or establish that SAYG can be deployed through the DTC pilot without further work or approvals.
Other approaches already provide or demonstrate real-time settlement in defined settings. SAYG’s commercial case therefore depends on what its proposed mechanism adds: the suitability of its settlement instrument, access, liquidity requirements, cost and practical implementation.
Source: SEC Nasdaq approval order, 18 March 2026, particularly pages 2–3 and 7.
1. Why settlement matters — and why the gap is costly
A securities transaction has two legs: the transfer of the security and the transfer of payment. Modern trading systems can agree the trade in milliseconds, but the cash payment often completes only on T+1 or T+2.
- Counterparty risk accumulates during the settlement window.
- Capital is locked against settlement exposure.
- Failed settlements create penalties, buy-in costs, interest charges and remediation costs.
- End-of-day batch reconciliation remains resource-intensive.
- Continuous trading with deferred settlement still requires arrangements for funding and managing exposures outside conventional settlement hours.
2. The settlement landscape — September 2026
Real-time settlement is an active field with operational systems and substantial institutional pilots. These examples distinguish demonstrated capabilities from wider ambitions; they are not an exhaustive market or patent search.
| Initiative | Established position | Relevance to SAYG |
|---|---|---|
| Nasdaq / DTC | SEC-approved trading rule changes for eligible tokenised securities under the DTC pilot. The approval retains T+1 settlement. | Tokenisation infrastructure is a potential enabler; this approval does not itself deliver simultaneous securities-and-payment settlement. |
| Fnality | Operational sterling payment system backed by funds held at the central bank. A separate HQLAX pilot demonstrated atomic settlement across platforms. | A credible settlement-asset alternative. Currency coverage, participation and jurisdiction-specific arrangements matter when comparing implementation. |
| Kinexys / Chainlink / Ondo | May 2025 test of cross-chain delivery-versus-payment involving tokenised US Treasury exposure and dollar deposits at JPMorgan. | Shows that bank deposits can support coordinated settlement across networks. The cited transaction was a test, not evidence of universal availability. |
| BIS Project Agorá | Prototype combining tokenised bank deposits and central-bank reserves. BIS reports controlled real-value cross-border payment testing in July 2026. | Significant progress on the payment side. It remains a prototype and is not, by itself, a complete securities-settlement service. |
Sources: SEC order; Fnality sterling system; Fnality pilot; Kinexys test; BIS Agorá.
3. What the Nasdaq approval establishes
The SEC’s March 2026 order permits a defined tokenised-securities trading arrangement under Nasdaq’s rules and the DTC pilot. Eligible tokenised and traditional shares can share the same order book when the required equivalence conditions are met. Nasdaq communicates participants’ tokenisation preferences to DTC for post-trade processing.
The order retains T+1 settlement. It therefore supports an important distinction: accepting tokenised securities within regulated markets is not the same as enabling real-time exchange of both the security and payment.
Operating within existing law remains a SAYG objective. Existing law can still require licences, regulatory consent, participant agreements and enforceable arrangements for custody, redemption and settlement finality.
4. SAYG’s intended design requirements
These are design objectives to be tested against the detailed mechanism and implementation, including operational failures, liquidity stress and applicable law.
Both legs complete simultaneously, or neither completes.
Failed settlement must be structurally impossible.
The mechanism must work within existing law.
It must be available to all opted-in participants across jurisdictions.
No single central processor or single point of systemic failure.
Costs visible and immutably recorded at the moment incurred.
The settlement instrument must maintain a consistent face value.
Exit to cash at par must always be open.
5. The settlement instrument — the central design question
There are already credible ways to represent and transfer money within tokenised systems. The question for SAYG is which instrument its intended participants can accept as payment, on what legal terms, and with what liquidity and redemption arrangements.
Central-bank-backed systems, tokenised commercial-bank deposits and regulated stablecoins must be compared on their actual capabilities and conditions. This overview does not establish that all alternatives fail the SAYG requirements.
The proposed SAYG approach explores contractual acceptance of a settlement instrument backed by assets convertible to cash, divisible to the required denominations, and usable within existing legal frameworks. Its detailed specification must establish how issuance, backing, transfer and redemption work, including under stress.
Real-time gross settlement can also require funds or assets to be available before each trade. Any claim of reduced capital or liquidity needs must therefore be demonstrated against the netting and funding arrangements it would replace.
6. Non-cash asset settlement — an emerging dimension
Tokenisation is extending beyond equities and bonds into commodities, carbon credits, emissions units, real property interests, quota rights and digital assets.
Not all settlement obligations are naturally discharged in cash. Some participants may prefer settlement in kind or in an instrument linked directly to the underlying asset.
Non-cash settlement introduces additional requirements: stable value relative to the underlying asset, redeemability in that asset, and reliable availability of the backing asset.
Background reading
The paper is intended to stand on its own, but the following background reading may help readers who want a wider context before considering the Settle-as-you-goTM argument. Together, these links point to three useful themes: the mainstream market shift toward tokenised trading, the policy concerns being raised around tokenised finance, and a practical crypto-market issue — slippage — that helps explain why settlement design matters.
Settle-as-you-goTM — closing note
Tokenisation provides a potential route to implementing SAYG. The next test is whether its specific settlement mechanism offers a demonstrable legal, operational and commercial advantage over available alternatives. Platform compatibility and regulatory requirements remain to be established.