Global Digital Finance releases collateral mobility TMMF report
03 November 2025 Global
Image: ilya_levchenko/stock.adobe.com
Global Digital Finance (GDF), a global digital assets members association, has announced the results of a working group reporting on the legal certainty of collateral eligibility and the mobility of Tokenised Money Market Funds (TMMF) in Luxembourg, Ireland, and the UK.
Ireland and Luxembourg host more than 80 per cent of the Money Market Funds (MMFs) and cross-border funds in Europe and English law governs the Credit Support Annex (CSA).
The report concludes that there is relative legal certainty of TMMFs located in Luxembourg in a digitally native or registered form due to the availability of statutory frameworks to govern such transactions.
Longstanding historical legal interaction between Luxembourg and the UK in respect of financial and investment contractual arrangements, including CSAs, also makes this an attractive place to establish a TMMF where the tokens will be posted as collateral under a CSA governed by English law.
There is not yet express statutory or judicial authority in Ireland specifically addressing tokenised shares or TMMFs.
This means that legal certainty in respect of ownership and treatment of tokenised shares under Irish law requires an analogy to traditional shares and electronic contracts, rather than being directly established.
The report says that it is reasonable to conclude that Irish courts would treat digitally native TMMF shares in a manner consistent with traditional shares.
This alignment reinforces the view that TMMF shares can be accommodated within existing property law principles in Ireland, supporting their recognition and enforceability under Irish legal standards.
Where an MMF is tokenised using a digitally native TMMF and is located in the UK, there is a low degree of legal uncertainty concerning the legal treatment of ownership and a similarly low level of uncertainty concerning the replication of rights for market participants between the traditional MMF and a digitally native TMMF.
It is anticipated that further certainty will be available in the UK if the Property Bill is enacted and common law precedent is developed as to the implications of the 鈥渢hird category鈥� of property.
According to the firm, over 70 firms participated in the working group including S&P, Federated Hermes, R3, J.P. Morgan, Ownera, Finastra, Lloyds Banking Group, Hogan Lovells, LSEG, Archax, Blackrock, State Street, ISDA, EY, Commerzbank, Fireblocks, Northern Trust, Apex Group, Franklin Templeton, and Goldman Sachs.
Amarjit Singh, UK Digital Assets Leader, EY says: 鈥淭he over 30 TradFi and Fintech firms participating in the sandbox have demonstrated that collateral mobility for TMMFs has
arrived.
鈥淭his is an exciting next step in the continued uplift to the future market鈥檚 infrastructure, leveraging digital assets to bring real-world benefit to investors and financial institutions around the globe.鈥�
Armin Peter, GDF executive in residence who is also a former global head of debt syndicate EMEA at UBS and a former GFMA board member, further states: 鈥淎s a co-chair of this working group, I have been impressed with the collaborative and effective working engagement across traditional financial institutions and fintechs as well as legal and professional services contributors and their firms.
鈥淭he combination of research and assessment findings and the practical sandbox execution of production use cases made this working group a very special and successful achievement.鈥�
Ireland and Luxembourg host more than 80 per cent of the Money Market Funds (MMFs) and cross-border funds in Europe and English law governs the Credit Support Annex (CSA).
The report concludes that there is relative legal certainty of TMMFs located in Luxembourg in a digitally native or registered form due to the availability of statutory frameworks to govern such transactions.
Longstanding historical legal interaction between Luxembourg and the UK in respect of financial and investment contractual arrangements, including CSAs, also makes this an attractive place to establish a TMMF where the tokens will be posted as collateral under a CSA governed by English law.
There is not yet express statutory or judicial authority in Ireland specifically addressing tokenised shares or TMMFs.
This means that legal certainty in respect of ownership and treatment of tokenised shares under Irish law requires an analogy to traditional shares and electronic contracts, rather than being directly established.
The report says that it is reasonable to conclude that Irish courts would treat digitally native TMMF shares in a manner consistent with traditional shares.
This alignment reinforces the view that TMMF shares can be accommodated within existing property law principles in Ireland, supporting their recognition and enforceability under Irish legal standards.
Where an MMF is tokenised using a digitally native TMMF and is located in the UK, there is a low degree of legal uncertainty concerning the legal treatment of ownership and a similarly low level of uncertainty concerning the replication of rights for market participants between the traditional MMF and a digitally native TMMF.
It is anticipated that further certainty will be available in the UK if the Property Bill is enacted and common law precedent is developed as to the implications of the 鈥渢hird category鈥� of property.
According to the firm, over 70 firms participated in the working group including S&P, Federated Hermes, R3, J.P. Morgan, Ownera, Finastra, Lloyds Banking Group, Hogan Lovells, LSEG, Archax, Blackrock, State Street, ISDA, EY, Commerzbank, Fireblocks, Northern Trust, Apex Group, Franklin Templeton, and Goldman Sachs.
Amarjit Singh, UK Digital Assets Leader, EY says: 鈥淭he over 30 TradFi and Fintech firms participating in the sandbox have demonstrated that collateral mobility for TMMFs has
arrived.
鈥淭his is an exciting next step in the continued uplift to the future market鈥檚 infrastructure, leveraging digital assets to bring real-world benefit to investors and financial institutions around the globe.鈥�
Armin Peter, GDF executive in residence who is also a former global head of debt syndicate EMEA at UBS and a former GFMA board member, further states: 鈥淎s a co-chair of this working group, I have been impressed with the collaborative and effective working engagement across traditional financial institutions and fintechs as well as legal and professional services contributors and their firms.
鈥淭he combination of research and assessment findings and the practical sandbox execution of production use cases made this working group a very special and successful achievement.鈥�
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