Tokenization: Argentina vs Europe, Two Regulatory Models

Tokenization: Argentina vs Europe, two regulatory models

Overview

How is tokenization regulated on each side of the Atlantic? In this MERGE Madrid dialogue, Argentina's National Securities Commission (CNV) and a European regulatory expert compare two very different approaches: Argentina's “mirror token” model versus the European Union's “native token” model, reviewing MiCA, MiFID, the provider registry and market infrastructure.

What you'll learn

• Mirror token vs native token: two ways to represent a security
• Argentina's approach: VASP registry and integration with capital markets
• Europe's approach: MiCA, MiFID, DORA and the pilot regime
• What each regime covers: crypto assets, financial instruments and stablecoins
• Settlement: from T+2 to T+0 and atomic settlement
• Challenges: legal reforms, tokenized money and investor trust

Session summary

The Argentine model: the CNV of Argentina explains how, without a crypto framework law, it created regulation for virtual asset service providers (VASPs, with more than 100 registered according to the talk) and opted for the “mirror token”: the token is a new form of representation of a security, with a guarantee of being able to return to the traditional representation.

The European model: the regulatory expert describes how MiCA regulates crypto asset providers, products and markets (except financial instruments, which go to MiFID, and stablecoins) and how the “native token” model allows issuing and trading on-chain, with DLT registration having full legal effect.

Licenses and infrastructure: the Argentine VASP registry is compared with the European regime (MiCA passport, MiFID licenses, the Spanish ERIR figure and the pilot regime), noting DORA's effect on authorization timelines.

Other approaches: issuances by large providers in the US (backed or as derivatives) are mentioned, and it is clarified that, in Argentina's mirror model, there is no “underlying asset” but rather a form of representation of the security itself.

Settlement and challenges: both highlight the move toward instant settlement (T+0 and atomic settlement) and the pending challenges: in Argentina, legal and tax reforms and legal stability; in Europe, tokenized money and the wholesale digital euro, insolvency law and institutional culture.

Watch the full talk

Watch the full recording on MERGE's YouTube channel, with Argentina's CNV and a European regulatory expert on tokenization models.

FAQs

What is the difference between a mirror token and a native token?
According to the talk, the mirror token (Argentina) reflects a security with a traditional representation it can return to; the native token (Europe) is born and traded on-chain.

What does MiCA regulate and what does it not?
According to the talk, MiCA regulates crypto assets, providers and markets, except financial instruments (MiFID) and stablecoins (banking supervision).

What are VASPs in Argentina?
According to the talk, virtual asset service providers, registered and integrated with the capital markets.

Is this investment advice?
No. This content is informational and summarizes what was presented in the dialogue; it does not constitute investment or legal advice. Consult a professional for your specific situation.