Register and distribute your fund's units as tokenized securities.
Units of a collective investment undertaking, classes of the same fund, venture capital or private debt. They remain financial instruments, and the ERIR registers them in a digital register.
What can be tokenized by an asset manager.
A SGIIC manages vehicles subject to Ley 35/2003, de Instituciones de Inversión Colectiva. If what the token represents is a financial instrument, the securities regime applies (Ley 6/2023 and MiFID II), not the crypto-asset regime.
- Units of an IIC. The unitholder's share in the fund or in the investment company. Framework: Ley 35/2003, Ley 6/2023 and MiFID II.
- Classes of the same fund. Retail, institutional, by currency or by fees, each as a separate token. Framework: IIC prospectus and Ley 6/2023.
- Venture capital. Units in an FCR or an SCR, usually of an illiquid class. Framework: Ley 22/2014 and Ley 6/2023.
- Private debt. Units in the vehicle or debt tranches. Framework: Ley 6/2023 and MiFID II.
When it fits and when it doesn't.
It fits if…
- You manage an IIC, a venture capital fund or a private debt vehicle and want to represent its units or classes as tokenized securities.
- Marketing and advisory services are provided by an authorized entity.
- You want the unitholder register up to date and the vehicle's events automated.
It doesn't fit if…
- You expect the token to provide liquidity by itself. Liquidity depends on the product, its regime and demand.
- You want the software to market the fund or advise unitholders. That is done by an authorized entity.
How it's done with HokenFi.
Each function is provided by whoever is authorized for it, and the software does not assume any regulated function.
- 01
The asset manager
Administers the vehicle under Ley 35/2003, with its prospectus or its regulations.
- 02
The authorized entity
An ESI or an EAF markets it, receives orders and advises under MiFID II.
- 03
The ERIR
It registers the issuance and keeps the register. It is regulated by Article 8 of Ley 6/2023 and Real Decreto 814/2023.
- 04
HokenFi
The software issues and administers the tokens, keeps the register of participants up to date and automates the vehicle's events. It does not provide custody, does not manage, does not market and does not advise.
In Spain, today
Tokenized units are financial instruments. Ley 6/2023 and MiFID II apply, with the prospectus or the exemption regime, the conduct rules and the suitability and appropriateness tests. The vehicle remains subject to its own law, and tokenizing does not exempt it from any obligation.
As financial instruments, they fall outside MiCA, the European crypto-asset regulation, under its Article 2.4.
The ERIR is the entity that registers tokenized securities. Today the only one listed by the CNMV is Ursus-3 Capital. As of 1 October 2026, the CNMV register includes 21 tokenized issuances for 77,925,715 €, all with Ursus-3 Capital as ERIR.
Source: CNMV public register, as of 1 October 2026.
What beginners usually ask.
Is a tokenized fund unit a crypto-asset?
No. It is a financial instrument represented by a token. It is governed by Ley 6/2023 and MiFID II, and falls outside MiCA under Article 2.4 of Regulation (EU) 2023/1114.
Does the management company need an ERIR to tokenize?
Yes. The registration of an issuance of tokenized securities is handled by an ERIR, under Article 8 of Ley 6/2023 and Real Decreto 814/2023. The software does not replace that function.
What does HokenFi do and what does it not do?
HokenFi is the software that issues and administers the tokens, keeps the register of participants up to date and connects the flow with the ERIR and with the ESI or the EAF. It does not provide custody of assets, does not manage the fund, does not market it and does not advise.
Does tokenization provide liquidity to the fund?
Not automatically. The token improves the register and operations, and enables a secondary market when the vehicle's regime allows it. Liquidity depends on the product, its regime and demand.
Can a venture capital or private debt fund be tokenized?
Yes. Units in an FCR or an SCR under Ley 22/2014, or in a private debt vehicle, are financial instruments and can be represented by a token under Ley 6/2023, while maintaining the vehicle's own regime.
Do you manage a fund? Assess the fit with your vehicle.
We analyze your case: the regulatory and operational fit of your vehicle with the ERIR and with your ESI. Start with the 2026 guide or tell us what you want to tokenize.
