The Capital Markets Platform Stack: Who Builds What?

Close to $300 billion of stablecoins now sits on public blockchains, and in December 2025 SEC staff cleared the central securities depository for US equities to pilot tokenized entitlements to large-cap stocks, index funds and Treasuries. Crypto-native exchanges, incumbent exchange operators, banks and stablecoin issuers all describe this work as tokenized assets. The label covers very different jobs. For a sponsor or allocator choosing a capital markets platform, the useful question is which layers of a working market each of them is building, and which layers still depend on someone else.

Source: https://app.rwa.xyz/

Six layers of a working market

A capital market is a chain of six jobs. Different kinds of firms do each one today, and a platform claim is only as broad as the layers it covers.

  1. Origination and underwriting. Finding the asset, confirming that it exists and who owns it, and deciding what it is worth and what can go wrong.
  2. Structuring and issuance. Placing the asset in a legal vehicle and creating the instrument investors hold: a share, a note or a fund interest.
  3. Custody and recordkeeping. Safekeeping the asset and maintaining the authoritative register of who owns the instrument.
  4. Settlement. Moving the instrument and the cash against each other so that neither side is exposed to the other.
  5. Secondary liquidity. Giving a holder a way out before maturity through a venue, a dealer, a redemption facility or a lender that accepts the position as collateral.
  6. Investor reporting and servicing. Collecting income, paying distributions and showing holders what the asset did this quarter, with evidence.

Putting an instrument on a shared ledger changes how layers two through six operate. Registers update as trades settle. Cash and asset can move in one transaction. Minimums can fall because the cost of carrying a small holder falls. Reporting can draw on data that every party sees. Our plain-English guide to what RWA tokenization is covers that mechanism. It does not change layer one.

Where the convergence is happening

Look at what the largest entrants are tokenizing and a pattern appears. The instruments were already originated, already priced and already liquid.

The depository pilot is the clearest example. Under the SEC staff no-action letter of December 11, 2025, eligible securities are limited to the constituents of a leading large-cap US stock index, exchange-traded funds that track major indices, and US Treasury securities. The token represents a participant's security entitlement, registered ownership stays with the depository's nominee, and the relief runs for three years from launch. It is a new recordkeeping and distribution format for securities that were underwritten long ago.

Source: https://www.sec.gov/files/tm/no-action/dtc-nal-121125.pdf

Stablecoins follow the same pattern on the cash side. They are a settlement asset, a tokenized claim on Treasury bills and bank deposits. Banks are building tokenized deposits for the same leg of the trade. Exchange operators, crypto-native and incumbent alike, are listing tokenized versions of public equities and funds, which is layer five applied to assets that already had a layer five.

Global securities regulators have reached a similar reading. The final report on the tokenization of financial assets from the International Organization of Securities Commissions, published on November 11, 2025, found that adoption remains limited and that tokenization has so far influenced issuance and distribution more than secondary trading, clearing or settlement. It also named two constraints on scale: weak interoperability between ledgers and a shortage of credible settlement assets.

The crowded part of the stack, then, is distribution and the cash leg of settlement. These are valuable layers. They are also the layers where licences, balance sheets and existing client relationships decide the outcome, and where a dozen well-capitalised institutions are building roughly the same thing.

The scarce layer is upstream

A Treasury bill needs no sourcing. A listed share arrives with audited financials and a closing price. Neither needs an underwriter to establish that the asset exists.

Real assets do. Before a gold position, a producing well, a carbon project or an industrial building becomes an instrument worth holding, someone has to do work that no ledger performs.

This work is local, slow and specific to each asset class. It does not gain from network effects the way a settlement rail does, and it cannot be skipped. A token inherits the quality of the underwriting behind it. A flawless on-chain record of a poorly diligenced asset is a precise record of a bad investment.

Upstream is also where the benefits investors care about are decided. Lower minimums help only if the asset is worth owning in small pieces. Same-day settlement helps only if the buyer trusts what is being delivered. Transparent reporting depends on data that was verified at origination and keeps arriving afterward from an independent source such as a custodian, a registry, a meter or a servicer. That matters more as AI agents take on screening, monitoring and reconciliation work, because software can act only on asset data that is structured and attributable.

Consider a $40 million industrial property. Layers two through six can be assembled from increasingly standard parts: a special-purpose vehicle, a digital register, stablecoin settlement, a transfer venue and automated distributions. What determines whether investors are repaid is the lease analysis, the environmental review and the sponsor's record. That work is done once, before any token exists, by people who know the asset class.

How to read a platform claim

For a sponsor choosing where to raise, or an allocator reading a pitch, the six layers convert into six questions.

  1. Who sourced this asset and who underwrote it? Is the diligence file available to investors?
  2. What legal instrument does the token represent, and against which entity is the claim?
  3. Who keeps the authoritative ownership record, and who holds the underlying asset?
  4. What is the cash leg, and do asset and payment move together?
  5. Where does a holder exit, and who is on the other side?
  6. What data arrives after closing, how often and from whom?

A provider that answers questions four through six in detail, and one through three by pointing to a partner, is a distribution or settlement venue. That may be exactly what a large fund manager with a finished product needs. An asset owner with a building, a well or a vault of metal needs the first three answered first. Our overview of what a digital capital markets platform is sets out how the layers fit together, and the Commertize marketplace shows the asset classes that structure is meant to carry.

Plumbing and product

Tokenization is plumbing in the literal sense. It is infrastructure that carries something else, and markets work badly without it. Faster settlement, shared records and lower servicing costs are real gains, and the institutions now competing to provide them will make those layers cheaper and more standard each year.

As that happens, the difference between platforms moves upstream. Settlement rails will look alike, and the assets on them will not. The view from Commertize is that a capital markets platform should be judged by the quality of what it originates across gold, energy, carbon, digital infrastructure and commercial real estate, and that the token is the last and simplest step in bringing an asset to market.

Prefer email? Send the offering memo or a short asset summary to deals@commertize.com. We reply within one business day, with no obligation to engage us.