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The State of Real-World Assets (RWAs)
Over the past few years, real-world assets (RWAs) have gained considerable attention in the blockchain space. However, many observers feel a sense of anticipation; they’re waiting for a significant breakthrough. Currently, many “tokenized” assets remain ambiguous legal promises rather than fully-realized rights. Issues such as unclear token rights, makeshift custody arrangements, and a lack of transfer controls contribute to a perception of RWAs as speculative ventures. Although the tokenized RWA market is valued at around $25 billion—a testament to its growth—it’s still relatively small compared to the vastness of global markets.
Key Insights
- Legal Ambiguity: Many RWAs function as legal promises hidden behind blockchain technology. The absence of enforceable rights and adequate controls maintains a speculative environment.
- Regulatory Initiative in the UAE: The UAE is actively developing its legal framework for tokenized real estate, treating it as a regulated market rather than a mere crypto experiment.
- Focus on Rights: The trillion-dollar opportunity in RWAs will favor jurisdictions that provide clear and enforceable rights for token holders, rather than those that prioritize rapid transaction throughput.
Developments in Dubai
The momentum in Dubai is undeniable. The Dubai Land Department has kicked off Phase II of its Real Estate Tokenization Project, with plans for secondary-market resales to launch on February 20, 2026. Meanwhile, the Dubai Financial Services Authority’s (DFSA) regulatory sandbox has attracted 96 expressions of interest, indicating a robust appetite from serious firms. Overall, the UAE is laying down the regulatory and institutional foundations necessary for scalable tokenized real estate, a development that deserves attention.
The Myths of RWAs in Crypto
The most compelling argument for RWAs in the crypto world is deceptively straightforward: take an asset like a deed or a share, place it on the blockchain, and let liquidity take over. In reality, this often results in a minting interface tied to a legal obligation that exists externally. Although tokens can be traded around the clock, the underlying rights are not so flexible.
When market conditions tighten, the truth emerges: a token does not equate to ownership or legal authority. Instead, it serves as a digital representation maintained on a programmable platform, and achieving legal equality with the asset it purports to represent remains a significant hurdle.
This dilemma surfaces in three key areas. First, consider enforceability. If token holders lack clarity about their ownership terms, applicable jurisdiction, and enforcement mechanisms, any notion of ownership becomes merely a matter of marketing. The International Organization of Securities Commissions (IOSCO) highlights the legal uncertainties surrounding tokenized assets, identifying them as a significant barrier to widespread adoption.
Next, focus on controlled transfer. Unlike cryptocurrencies, real assets require stringent protocols for transfer, including eligibility checks and compliance with legal orders. Research from the OECD suggests that implementing measures like trading restrictions can be particularly complex in public, permissionless networks.
Finally, there’s the matter of servicing. Real estate operates as a dynamic system encompassing taxes, insurance, maintenance, tenant relations, and more. While tokenization can enhance record-keeping, it does not eliminate the essential administrative functions that validate cash flows and ensure compliance. Unless these challenges are addressed, RWAs may find themselves at a standstill.
UAE’s Regulatory Blueprint
If the UAE leads the charge in real estate tokenization, it will be due to its approach of treating tokenization as a regulated financial product, supported by comprehensive rules and institutions.
- The DIFC’s DFSA has established a dedicated tokenization regulatory sandbox, signaling that serious enterprises are seeking a regulated path.
- In Abu Dhabi, the Abu Dhabi Global Market (ADGM) is strategically positioning itself as a hub for digital asset regulation, implementing a DLT Foundations regime for token issuance.
- In 2025, the DIFC already recorded 8,844 active companies, indicating robust growth.
- The Dubai Land Department is conducting a controlled pilot testing governance and investor protection while preparing for secondary market transactions in 2026.
- The UAE is also equipped with significant financial resources, with Mubadala managing AED 1.2 trillion in assets, positioned to support compliant token issuance when the infrastructure becomes credible.
Essentially, the UAE is developing a standardized regulatory framework for RWAs, creating the necessary conditions for real estate tokenization to succeed.
The Winning Framework
The projects that thrive in the UAE are likely to operate as regulated market infrastructures that leverage blockchain technology. The approach begins with licensing; the DFSA’s regulatory sandbox in DIFC allows firms to test their ideas in a controlled space, with the potential to transition to full authorization upon success.
Additionally, the framework must employ familiar packaging. The DIFC Special Purpose Vehicles (SPVs) are designed to safeguard and separate assets and liabilities, which is vital for institutional understanding and underwriting. Tokenization then becomes a streamlined method for distribution and settlement.
Moreover, institutional markets demand stringent governance, secure custody, and meticulous oversight. The ADGM’s Financial Services Regulatory Authority (FSRA) has provided unequivocal guidance on addressing safe custody and market abuse through a comprehensive regulatory framework.
Finally, the winning framework will connect deeply to the registry. The Dubai Land Department is actively testing tokenization on property deeds within a regulated model, collaborating with VARA to prepare for secondary market activities that prioritize governance and investor rights.
Implications for the Crypto Landscape
The critical insight for the crypto world is clear: the trillion-dollar potential of RWAs will go to those who can clearly define token-holder rights, facilitate compliant transfers, and ensure serviceable cash flows at scale.
IOSCO’s observations underline that investors may find themselves uncertain about whether they own the actual asset or simply a digital proxy, with risks heavily concentrated around legal frameworks and intermediaries rather than transaction speed.
This makes the developments in the UAE pivotal for the broader market. The Dubai Land Department’s controlled pilot for tokenization, set to expand into secondary market activities, is framed around governance and operational readiness, with DIFC’s regulatory authority working at the structural level.
For the future of crypto, the blockchain must serve as a transparent, automated settlement layer within this regulated environment. Its programmability, auditability, and interoperability are crucial—yet, the focus should be on jurisdictions and infrastructure providing enforceable rights.

