A property developer with two projects in Punta Cana sells off-plan to European buyers and wants to finance the next phase with a tokenized instrument. The starting point is this: The Dominican Republic does not have a framework for tokenized securities. The SIMV supervises the traditional securities market and the Central Bank keeps cryptoassets outside the regulated financial system.
The Dominican paradox is that the perfect asset to tokenize, tourist real estate with international demand, coexists with a regulatory vacuum that prevents doing it through the local channel. This guide reviews what exists today, why tourist real estate is the natural case for a Dominican security token and when it is advisable to structure the issuance under the European framework from Spain.
What framework exists today in the Dominican Republic
The Dominican securities market is supervised by the Superintendency of the Securities Market (SIMV), which applies Ley 249-17 del Mercado de Valores. As in most of the region, that framework was designed for traditional securities: it does not contemplate the representation of securities through distributed ledger technology, nor is there a registration figure comparable to the Spanish ERIR.
With cryptoassets, the official position is exclusion from the regulated perimeter. The Central Bank and supervisors have warned that virtual assets are not legal tender, are not supervised and whoever invests in them lacks legal protection, and regulated financial and securities market entities are prohibited from operating, intermediating or safeguarding cryptoassets. Outside that perimeter there is no prohibition: a company or an individual may hold and transfer cryptoassets at their own risk.
For the issuer, the reading is the same as in much of Latin America. A token that represents debt, equity or economic rights over a property is a security, and its public offering to Dominican investors would require fitting within Ley 249-17, with authorization from the SIMV and without rules adapted to DLT support. The SIMV has shown interest in innovation, with agreements with the fintech sector and forums on tokenization and financial inclusion, but interest is not a framework: today there is no local channel for a tokenized issuance.
Tourist real estate as the natural case
If there is a market in the region where real estate tokenization has clear economic logic, it is the Dominican one. Punta Cana, Cap Cana, Bávaro or Las Terrenas concentrate a sustained volume of hotel and residential investment whose buyer is mostly foreign: U.S., Canadian and European. The sector also relies on tax incentives for tourism development that have been attracting foreign capital for decades.
That profile fits what a security token does well. Fractionalizing entry tickets in projects that today require buying an entire unit, giving the investor a documented economic right over rents or capital gains, and reaching an audience that already knows the destination as a tourist or as an owner. Demand for fractional investment formulas in the Caribbean exists; what does not exist is the Dominican regulated channel to offer it.
Hence the structure that is repeated in practice: the asset remains in the Dominican Republic and the instrument is issued where there is a framework. The issuing vehicle, usually European, holds the asset or the economic rights over the project, and the token represents securities issued by that vehicle under a regulation that recognizes tokenized issuance from start to finish.
An honest warning about expectations. Tokenizing does not turn an apartment in Bávaro into a liquid asset overnight: the secondary market for security tokens is still in its infancy everywhere, and the investor must enter expecting to hold their position. What tokenization does provide today is a documented and registered right, smaller entry tickets and a subscription process that a buyer in Berlin or Madrid can complete without traveling. Selling the instrument with those real qualities, and not with promises of liquidity, is also what the securities regulations under which it is issued require.
When the European route makes sense from the Dominican Republic
The decisive argument is where the investors are. If the natural buyer of a Punta Cana project is European or North American, raising in euros under a European framework is not a detour: it is going to find capital where it lives. Spain has offered since 2023 a complete regime: the Ley 6/2023 permits the representation of transferable securities through DLT-based systems, and Article 8 creates the entity responsible for registration and record-keeping (ERIR), developed by the Real Decreto 814/2023. The first authorized ERIR was URSUS-3 Capital, A.V., in November 2024, and the registry of ERIRs in Spain has continued to add entities.
The cost of a first issuance has also fallen: since 5 June 2026, after the Listing Act, offers of up to 12 million euros over 12 months are exempt from a prospectus, a threshold that covers most mid-sized real estate projects. Classification of the instrument is also not ambiguous territory: ESMA guidelines on crypto-assets as financial instruments, applicable since May 2025, set out which tokens are securities, and the MiCA regulation expressly excludes financial instruments from its scope (Article 2.4).
The European route is not automatic or free. It requires setting up the vehicle, conducting due diligence on the title and the rights over the Dominican asset, and coordinating advisers in both jurisdictions. For a small project with known local investors, that cost does not pay off. For a development with real international demand, it is the difference between a commercial promise and a security registered under supervision. The same decision arises in Mexico or Colombia, with the particularity that the Dominican issuer usually has the foreign investor much closer.
Dominican framework and European route, head to head
| Criterion | Dominican Republic | European route (Spain) |
|---|---|---|
| Tokenized securities regime | Does not exist; Ley 249-17 would apply without DLT adaptation | Ley 6/2023 and RD 814/2023, with express recognition |
| Supervisor | SIMV | CNMV |
| Crypto-assets | Barred for regulated entities; no legal protection for the investor | MiCA for crypto-assets that are not securities |
| Token registration | No equivalent figure | ERIR (art. 8 of Ley 6/2023) |
| Offering documentation | Public offering subject to authorization, traditional regime | Exemption up to 12 M€ in 12 months; CNMV prospectus above that |
| Investors reached | Local market | European Union |
Process from the Dominican Republic, step by step
- Classify the asset and the token. Determine, using the ESMA guidelines criteria, whether what is going to be issued is a transferable security. In real estate tokenization it almost always is: project debt, equity interests or rights over rents.
- Structure the issuer vehicle. A Spanish company or another EU company holds the Dominican asset or the economic rights over it. Due diligence on the title deed and project permits is the critical step in real estate.
- Prepare the offer documentation. Up to 12 million euros over 12 months no prospectus is required; above that, a prospectus approved by the CNMV under the European Prospectus Regulation.
- Appoint the ERIR. An entity from the CNMV registry handles the registration and recording of the tokenized securities. It is the differential requirement of the Spanish system.
- Issue and distribute. Technical deployment of the token, investor onboarding with KYC and anti-money laundering prevention, and communication of the offering within the limits of the applicable regime. A technology platform covers this layer; reserved functions correspond to registered or authorized entities.
The full process is detailed in the guide on how to issue a security token in Spain, and the regional comparison, country by country, in the tokenization for Latin American issuers hub.
Do you want to tokenize a real estate project in the Dominican Republic? Take the issuance diagnosis (2 min) or request a proposal. If you prefer to start by reading, download the 2026 guide.
This content is informative and educational. It does not constitute legal, tax, or investment advice. Check the current version of each regulation in the BOE and on 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.
Frequently asked questions
Is real estate tokenization legal in the Dominican Republic?
It is not prohibited for private issuers, but there is no framework: virtual assets are not supervised by the SIMV and regulated financial entities cannot operate with them. If the token represents debt, equity or rights over rents, it is a security, and its public offering would be subject to Ley 249-17, which has no rules for securities on DLT.
What role does the SIMV play with digital assets?
The SIMV supervises the securities market under Ley 249-17 and has warned that anyone investing in unsupervised crypto-assets lacks legal protection. At the same time it explores innovation with the fintech sector, with agreements and forums on tokenization and financial inclusion, although for now without a specific regulatory framework for tokenized securities.
How do I tokenize a Punta Cana property for European investors?
With an issuing vehicle in Spain or another EU State that holds the asset or the economic rights of the project. The issuance falls under Ley 6/2023, with the securities registered by an ERIR and, since June 2026, the prospectus exemption for offers of up to 12 million euros over 12 months.
