03 Oct 2026

The Gold Stays in the Vault. The Rights Move: Why Tokenised Commodities Need an Asset Passport

The UK Financial Conduct Authority is exploring whether tokenised gold can improve how bullion is traded, transferred, pledged and held, with wholesale collateral identified as a particularly important use case. The consultation exposes a deeper infrastructure problem: the token is not the gold. A serious institutional record must connect the physical bullion, vault and custodian, legal ownership, digital representation, redemption rights, encumbrances, transfers and collateral state....

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Topics tokenised commodities Primary gold collateral custody asset identity redemption market infrastructure

A gold bar can remain in the same vault for years.

Nothing physical needs to move.

Yet the economic rights around it can move many times.

That is why tokenised gold is a useful test for real-world asset infrastructure.

On 14 September 2026, the UK Financial Conduct Authority opened a Call for Input on whether tokenising gold could improve the way it is:

traded;
transferred;
pledged; and
held.

The FCA specifically identified wholesale collateral as a potentially important use case.

FCA: Tokenised gold – opportunities and risk for UK wholesale markets

The consultation is important because the regulator does not describe tokenisation as making physical gold disappear into a blockchain.

It describes tokens that represent ownership of physical gold.

That distinction is the whole story.

The gold stays physical. The transferable representation changes.

A tokenised commodity therefore has at least two layers from the beginning:

Physical asset
    ->
Digital representation

For institutional use, that is still too simple.

The actual structure can look more like:

Physical bullion
    ->
Vault / custodian
    ->
Ownership record
    ->
Tokenisation terms
    ->
Digital token
    ->
Holder
    ->
Transfer / pledge
    ->
Redemption

Every arrow can contain a separate legal, operational or evidential relationship.

The token is not the bullion

A digital token can identify an entitlement connected to gold.

It is not itself the physical metal.

That sounds obvious.

It becomes important when a system needs to answer questions such as:

Which exact gold backs this token?

Where is the gold held?

Who owns it?

What does the token holder legally own?

Can the token be redeemed?

Can it be pledged?

Has the same underlying gold already been encumbered?

A blockchain balance cannot answer all of those questions by itself.

“Backed by gold” is not a complete asset description

Two products can both say:

Gold-backed token

and still create materially different rights.

One structure might give the holder a direct ownership interest.

Another might create a contractual claim against an issuer.

Another might represent a pooled interest in bullion.

Another might provide only economic exposure.

Another might permit physical redemption.

Another might settle only in cash.

Those differences matter more than the token symbol.

A serious asset record therefore needs to separate:

physical backing;
legal ownership;
beneficial ownership;
custody;
issuer obligation;
redemption right;
transfer right;
pledge right;
insolvency treatment; and
regulatory classification.

DBS shows what an operational backing chain can look like

Singapore’s DBS announced its Physical Gold Token offering in June 2026.

The bank says:

each token is backed by one gram of physical gold;
the backing gold is held by DBS in a dedicated vault in Singapore;
customers can hold and trade fractions of physical gold digitally;
transactions can use atomic settlement; and
token holders can have the option to redeem tokens for physical gold.

DBS: Tokenised physical gold for customers in Singapore

That creates a clear operational chain:

1 gram physical gold
    ->
Dedicated vault
    ->
DBS backing record
    ->
Gold token
    ->
Digital holder
    ->
Transfer or redemption

The chain is useful precisely because it identifies both the digital object and the physical anchor.

One gram is a unit, not necessarily a unique bar identity

A token can represent one gram of gold without necessarily identifying a unique one-gram physical object.

Institutional infrastructure should therefore ask:

is the backing allocated or pooled;
is specific bullion identified;
are bar numbers recorded;
what fineness standards apply;
who maintains the bar list;
how often backing is reconciled;
whether backing can be substituted;
whether the holder has title to specific bullion or another form of entitlement; and
what happens if the custodian or issuer fails.

The answers come from the product and custody structure.

They should not be inferred from the word token.

Custody remains part of the asset

Tokenisation does not eliminate custody.

It makes custody more important.

If the token depends on physical gold existing in a vault, the system needs a current record of:

Custodian
Vault
Location
Quantity
Quality
Ownership
Backing allocation
Reconciliation date

A token can continue moving while a custody record becomes stale.

That creates a dangerous split between:

Digital state

and:

Physical state

An institutional-grade system needs to keep them connected.

A vault receipt and a token are different records

Traditional bullion markets already use documents and records to evidence possession, title and custody.

Tokenisation introduces another representation layer.

That means the information architecture may need to connect:

Bullion
    ->
Vault record
    ->
Custody evidence
    ->
Ownership record
    ->
Token issuance

The token should not erase the records that came before it.

It should point back to them.

Redemption is a state transition

A redeemable gold token contains more than a market value.

It contains a potential future process.

For example:

Token outstanding
    ->
Redemption requested
    ->
Eligibility checked
    ->
Token locked / burned
    ->
Gold allocated
    ->
Delivery arranged
    ->
Physical gold released

A platform that stores only:

Token balance: 10

cannot represent that lifecycle.

A redemption request can exist while the tokens are still technically visible.

Physical delivery can be pending.

Fees may be due.

Minimum quantities may apply.

Jurisdictional restrictions may matter.

The record needs state, not only balance.

Pledging creates another rights layer

The FCA explicitly asks about tokenised gold being pledged.

That is especially important for DaDepo.

A token holder can appear to own an asset while the asset is economically unavailable because it has been pledged as collateral.

The structure becomes:

Gold
    ->
Ownership
    ->
Token
    ->
Holder
    ->
Pledge
    ->
Secured obligation

The asset may still exist.

The token may still exist.

The holder may still be visible.

But the available rights have changed.

Ownership and availability are not the same

For collateral management, the key question is not only:

Who owns it?

It is also:

Is it available?

Possible states include:

Owned + unencumbered
Owned + pledged
Owned + subject to lien
Transferred
Frozen
Pending redemption
Redeemed

That is why a tokenised collateral asset needs an encumbrance lifecycle.

A digital transfer does not automatically prove a legal title transfer

A blockchain can record:

Wallet A -> Wallet B

That proves something happened in the digital system.

It does not, by itself, answer:

whether legal title to the underlying gold moved;
whether all transfer conditions were satisfied;
whether the transferee is eligible;
whether sanctions or market rules restricted the transfer;
whether the custodian recognised the new holder;
whether the token was subject to a prior pledge; or
whether the transfer is legally effective against third parties.

Those questions depend on the governing framework.

Regulatory classification is itself part of the asset state

The FCA consultation highlights uncertainty around the boundary of:

collective investment scheme rules; and
alternative investment fund rules.

The regulator is considering whether guidance or a bespoke regime may be needed.

That means two tokenised-gold structures can have different regulatory treatment even if both refer to physical gold.

A useful Asset Passport could therefore record:

Product structure
Regulatory classification
Jurisdiction
Applicable permissions
Investor restrictions
Source
Effective date

The classification should be source-backed.

It should not be guessed from branding.

Tokenisation can make collateral more mobile

The commercial promise is clear.

Physical gold is cumbersome to move repeatedly.

A digital representation can potentially allow rights over that gold to move faster.

That can support:

trading;
transfer;
collateral allocation;
intraday financing;
settlement;
fractional ownership; and
redemption workflows.

But greater mobility increases the importance of current state.

A fast-moving representation attached to a slow-moving source of truth can create operational risk.

Collateral mobility requires collateral identity

Before tokenised gold can be used efficiently as collateral, the parties may need to know:

what the asset is;
how much exists;
where it is held;
who owns it;
whether the ownership record is current;
whether the token accurately represents that holding;
whether it is already pledged;
whether the counterparty accepts it;
how it is valued;
what haircut applies;
whether it can be substituted;
how corporate or custody events are handled;
when the pledge becomes effective; and
when the asset becomes available again.

The token can help move the asset state.

It cannot eliminate the need to define it.

The physical asset can change while the token survives

Suppose the custodian substitutes one bar for another.

The investor may experience no visible change.

But the backing record changed.

Or suppose gold moves from one vault to another.

Again, the token may remain unchanged.

A durable record needs to preserve events such as:

Bar substitution
Vault transfer
Custodian change
Audit
Reconciliation
Backing adjustment
Insurance change

That is the difference between a static token registry and a physical-asset lifecycle.

The token can change while the physical asset stays still

The reverse can also happen.

The same bullion may remain in the same vault while:

ownership changes;
tokens are split;
tokens are consolidated;
a pledge is created;
a pledge is released;
the holder changes;
redemption is requested; or
investor eligibility changes.

The physical object can be static while the legal and economic state changes repeatedly.

That is why the Asset Passport needs multiple linked layers.

A tokenised-gold Asset Passport should preserve the whole chain

Physical asset

commodity type;
quantity;
weight unit;
purity or fineness;
refiner;
bar or lot identifiers where applicable;
physical location;
vault;
custodian;
inspection or audit source; and
current physical status.

Ownership

legal owner;
beneficial owner where relevant;
ownership basis;
transfer date;
title evidence;
restrictions;
jurisdiction; and
current ownership state.

Token representation

token identifier;
network;
smart contract;
issuer;
issuance date;
unit represented;
total tokens issued;
backing ratio;
minting rules;
burning rules;
transfer rules; and
current token state.

Custody and backing

custodian;
vault;
backing account;
allocation model;
bar list or equivalent source;
quantity reconciled;
reconciliation date;
auditor or reviewer;
substitution rules; and
exception history.

Rights

ownership entitlement;
contractual claim;
redemption right;
transfer right;
pledge right;
voting or governance rights where applicable;
fees;
minimum redemption;
delivery conditions;
investor restrictions; and
insolvency treatment.

Encumbrance

pledged quantity;
secured party;
underlying obligation;
pledge date;
perfection evidence where applicable;
priority;
collateral eligibility;
valuation;
haircut;
release conditions; and
current availability.

Lifecycle

issuance;
mint;
transfer;
pledge;
release;
freeze;
redemption request;
burn;
physical delivery;
backing substitution;
custody transfer; and
closure.

Provenance

product terms;
custody agreement;
vault statement;
bar list;
audit;
blockchain transaction;
legal opinion where available;
regulatory classification;
timestamp;
version; and
reviewer.

The purpose is not to make the Asset Passport the source of legal title.

It is to make the chain inspectable.

AI can reconcile records but should not invent title

AI can help:

extract bullion quantities;
reconcile token supply against custody reports;
detect stale backing statements;
identify missing redemption documents;
compare vault records across dates;
flag token balances larger than documented backing;
classify pledge and custody documents;
detect conflicting owner names; and
build a timeline of transfers and encumbrances.

AI should not independently decide:

who legally owns the gold;
whether title validly transferred;
whether a pledge is perfected;
whether the token is a security or fund interest;
whether backing is bankruptcy-remote;
whether redemption is enforceable;
whether collateral is legally available; or
whether a regulatory exemption applies.

Those states need authoritative records and professional review.

What DaDepo can contribute

DaDepo does not need to operate a bullion vault or blockchain.

The useful role is the asset-information layer.

A tokenised commodity record can connect:

Physical commodity
    ->
Custody
    ->
Ownership
    ->
Digital representation
    ->
Holder
    ->
Encumbrance
    ->
Transfer
    ->
Redemption

That makes it easier to answer:

what the underlying asset actually is;
what the token represents;
who holds which rights;
where the asset is held;
whether the backing was recently reconciled;
whether the asset is already pledged;
what changed after a transfer;
whether redemption is pending; and
which evidence supports the current state.

The token can be one component of the passport.

It should not become the passport.

What DaDepo does—and does not do

Creating or reviewing a tokenised-gold Asset Passport does not mean that DaDepo has:

issued a token;
tokenised physical gold;
operated a blockchain;
acted as bullion dealer;
provided a vault;
acted as custodian;
confirmed legal title;
confirmed beneficial ownership;
audited backing;
guaranteed token-to-gold reconciliation;
created or perfected a pledge;
determined collateral eligibility;
valued gold;
set a haircut;
approved redemption;
delivered bullion;
determined regulatory classification;
provided brokerage;
settled a trade; or
provided legal, regulatory, investment, custody, collateral-management, tax or valuation advice.

Important: DaDepo provides technology and information tools. It does not provide bullion dealing, commodity trading, token issuance, custody, vaulting, brokerage, clearing, settlement, collateral-management, legal, regulatory, tax, investment or valuation advice or services unless a specific service is expressly identified and lawfully provided. Ownership, custody, backing, pledge, redemption and regulatory treatment depend on the governing documents, authoritative records, applicable law and qualified professional review.

A practical tokenised-commodity checklist

Underlying asset: What exact physical commodity backs the representation?
Quantity: How much physical asset exists?
Quality: Which purity, grade or specification applies?
Location: Where is it physically held?
Custodian: Who controls the physical asset?
Owner: Who legally owns the underlying asset?
Evidence: Which authoritative record supports that ownership?
Representation: What exactly does each token represent?
Backing model: Is backing allocated, pooled or structured another way?
Reconciliation: When was token supply last reconciled to physical backing?
Transfer: What legal effect does a token transfer have?
Issuer: Who creates and retires tokens?
Holder rights: Does the holder have title, a contractual claim or another entitlement?
Redemption: Can the token be exchanged for physical gold?
Redemption state: Is any redemption currently pending?
Encumbrance: Is the asset or token pledged?
Priority: Which rights rank ahead of the holder?
Collateral: Is the token eligible for the intended financing arrangement?
Availability: How much is currently unencumbered?
Valuation: Which price source and timestamp apply?
Custody change: Has the vault or custodian changed?
Backing change: Has physical backing been substituted?
Regulatory status: Which regime applies in the relevant jurisdiction?
Investor restrictions: Who may hold or trade the token?
Audit: Which independent verification exists?
Provenance: Can every current state be traced to a source and date?

If the answer to “what does this token legally and operationally give me a right to today?” is unclear, the digital representation is not enough.

The broader lesson goes beyond gold

The same structure appears in other tokenised commodities and physical assets:

silver;
precious metals;
warehouse commodities;
carbon units linked to projects or registries;
inventory;
energy products;
agricultural goods;
collectibles; and
other custody-dependent assets.

The physical object and the transferable right can have different lifecycles.

Infrastructure needs to preserve both.

The gold can stay still while the rights move

That is what makes tokenised gold a strong infrastructure case.

The physical asset may remain in the same vault.

The legal and economic state can still change.

Ownership can move.

A pledge can be created.

A token can be transferred.

A redemption can begin.

Collateral can become unavailable.

A custodian can change.

The important question is therefore not:

Is there a token?

It is:

Can the token be continuously reconciled to the current rights over the real asset?

Tokenisation becomes institutional infrastructure only when the digital representation, physical backing and legal rights remain connected through time.

The gold stays in the vault.

The rights move.