Asset tokenization in Colombia: issuer's guide

A promoter from Bogotá or Medellín with a structured project has a short menu for raising capital today. Bank credit makes the operation more expensive. Crowdfunding works, but with caps and only for the local market. And anyone who asks about issuing a token backed by their asset gets the same answer everywhere: in Colombia there is still no legal figure for tokenized securities. This guide reviews what the Colombian framework allows, what has been tested in the Financial Superintendency's sandbox and when it is advisable to issue from Spain to attract European investors.

If you are going to issue from Colombia, in issuing tokenized securities from Colombia you have the three routes, who keeps the register and how the issuance with HokenFi is prepared.

What the Colombian framework allows today (and what it does not)

The Financial Superintendency of Colombia, the SFC, supervises the securities market and those who participate in it. To finance projects with many contributors, the regulated route is crowdfunding: only companies authorized and supervised by the SFC can carry it out (Decree 1357 of 2018).

The caps were expanded in 2020. A recipient can raise up to 58,000 legal monthly minimum wages, and up to 19,000 when the funds come only from non-qualified contributors (Decree 1235 of 2020). It is a useful channel for local SMEs, but it does not turn the project into a security that can be placed with European investors.

For innovation there is a formal testing space. Decree 1234 of 2020 created the controlled testing spaces, which the SFC operates under the name laArenera. In its crypto pilot, supervised entities tested deposits and withdrawals with cryptoasset exchange platforms; the exercise closed in June 2024 as a learning for the supervisor, without yet producing a permanent framework (laArenera, SFC).

The missing piece is issuance. A public offering security goes through the National Registry of Securities and Issuers and the general market regime, which does not contemplate recording securities on blockchain. As of the date of this guide, there is no Colombian figure equivalent to a DLT register of issuances.

The operational conclusion: crowdfunding solves limited local raises, and laArenera is for testing, not for issuing. For a security token aimed at European investors, the short path goes through the European Union framework.

The European route: issuing from Spain

Spain recognizes financial instruments registered in systems based on distributed ledger technology. Its Ley 6/2023 requires that annotation to be kept by an ERIR, the entity responsible for registration and record-keeping, something like the digital notary of the issuance (Ley 6/2023, art. 8).

The legal figure is set out in Real Decreto 814/2023 and already works: the CNMV authorized URSUS-3 Capital, A.V. as the first ERIR in November 2024 (RD 814/2023). How it works is explained in our guide on what an ERIR is.

Access to the European investor works in two tiers. Up to 12 million euros in 12 months, the offer can be exempt from a prospectus; each Member State can lower that threshold to 5 million. Above that, the CNMV approves a prospectus that is passported to the 27 EU countries without new approvals (Regulation (EU) 2017/1129, arts. 24-25, amended by the Listing Act, applicable from 5 Jun 2026). The full mechanism is in the guide to the European prospectus passport.

Three Colombian profiles where it fits

• Export agribusiness. A company that receives euros for coffee, avocado or flowers can issue tokenized debt in that same currency. The fundraising is aligned with its European income and reduces currency mismatch.
• Real estate developer. A project in Bogotá or Medellín attracts European investors through a Spanish vehicle that channels the funds to the project company. The property and the construction remain in Colombia.
• SME that has maxed out the local ceiling. A company that reached the caps of crowdfunding finds in the European issuance a higher fundraising ceiling and another investor base. How it is approached, in tokenization for SMEs.

In all three cases the asset remains in Colombia. What changes jurisdiction is the issuance, its registration and the offer regime.

Colombian framework vs. European route

If the target investor is in Europe, the comparison is decided by two rows: the registration figure already in force and the prospectus passport.

The process from Colombia, step by step

1. Diagnosis. What asset is tokenized, what amount is sought and which European investor fits. From here comes the structure: shares, bonds or another formula.
2. Spanish vehicle. Incorporation of a company in Spain. It is generally handled remotely, with powers of attorney granted before a Colombian notary and apostilled, and with obtaining the shareholders' NIF. Timelines depend on the notary and registry.
3. Legal structure. A law firm defines the relationship between the Spanish vehicle and the project's Colombian company, and the information package the investor will receive.
4. Registration and issuance. The ERIR registers the issuance and the platform deploys the token and the register book.
5. Fundraising. Under an exemption or with a passportable CNMV prospectus, always with identification and anti-money laundering checks on each investor.

HokenFi is the technology platform that coordinates this circuit with regulated partners. It is not an entity authorized by the CNMV nor registered with the SFC; the regulated tranche is covered by the ERIR and the advisors for each issuance. The complete map for the region is in the tokenization hub for Latin American issuers.

Related: securitization vs tokenization.

This content is informative and educational. It does not constitute legal, tax, or investment advice. Verify the current version of each regulation in the Diario Oficial de Colombia, the BOE, and EUR-Lex.

HokenFi is a software and infrastructure provider; it does not provide regulated services (CASP, ESI, EAF, or ERIR). This article is informative and does not constitute financial or legal advice.