Public Discussion Paper | September 2026 revision — draft

Settle-as-you-goTM

Completing tokenised securities settlement: a proposed route to simultaneous exchange within existing legal frameworks.

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.

SAYGTM objective: both sides of an eligible transaction complete together, or neither completes, using an agreed settlement instrument within applicable existing legal frameworks. The eight requirements below describe the intended standard, not a claim of verified deployment.

Source: SEC Nasdaq approval order, 18 March 2026, particularly pages 2–3 and 7.

Key links

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.

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.

InitiativeEstablished positionRelevance to SAYG
Nasdaq / DTCSEC-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.
FnalityOperational 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 / OndoMay 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 AgoráPrototype 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.
SAYG must demonstrate a practical advantage for its intended participants. A competing service can meet a customer's needs without satisfying every SAYG design objective.

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.

SAYG’s proposed opportunity is to use token-processing capabilities to complete the settlement arrangement. Compatibility with Nasdaq/DTC infrastructure and permission to operate within it must be established separately.

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.

Read the SEC approval order.

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.

Real-time atomic settlement
Both legs complete simultaneously, or neither completes.
Pre-trade certainty
Failed settlement must be structurally impossible.
Legislative independence
The mechanism must work within existing law.
Universal applicability
It must be available to all opted-in participants across jurisdictions.
Distributed implementation
No single central processor or single point of systemic failure.
Transparent fee structure
Costs visible and immutably recorded at the moment incurred.
Par value stability
The settlement instrument must maintain a consistent face value.
Unconditional redeemability
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.

A simultaneous token exchange must also produce the intended legal discharge of the payment obligation. Technical completion and legal finality both matter.

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.

The non-cash settlement gap is less visible today, but it is likely to become more important as tokenised infrastructure expands across asset classes.

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.

These links are not required reading, but they may help readers understand why the settlement question is moving from a technical back-office issue to a front-line market infrastructure issue.