Deloitte cautions about a risky “blind spot” in tokenized settlement that could render market manipulation nearly unstoppable.

Wall Street’s upcoming advancement might appear unexciting at first glance, yet it represents a significant shift cloaked in corporate jargon: T+0 settlement, which refers to settling a trade on the same day it occurs.

Deloitte’s 2026 forecast highlights this as a key theme for the year, alongside indications that regulators are looking to simplify regulations, promote innovation, and create avenues for blockchain-based solutions. The report’s takeaway is straightforward: if quicker settlement is implemented, businesses should assess its implications, including T+0 products “like tokenized securities and stablecoins.”

A tokenized security is a well-known asset, such as a bond or stock, represented digitally to operate on contemporary systems. The appeal of tokenization is straightforward: fewer intermediaries, quicker transfer of assets and cash, and improved record-keeping.

However, its challenge is equally clear: the real world continues to rely on settlement cycles, reconciliations, and reporting. Should settlement accelerate, tokenization could cease being a niche trial and evolve into a necessary enhancement for all.

Roy Ben-Hur and Meghan Burns, the managing director and manager at Deloitte & Touche LLP, informed CryptoSlate that the most plausible route for tokenization isn’t a sweeping transformation of the entire market. The process will likely begin with limited pilots that unveil tradeoffs before any mandates are introduced.

“Signals indicate initial market experimentation through pilots rather than a complete market overhaul.”

This is significant because pilots will determine if tokenization evolves into a more efficient, safer version of the current system or a disjointed network of new platforms and regulatory interpretations.

Why T+0 is Important

T+0 alters the financial ecosystem in a manner similar to how instant delivery impacts retail. The quicker the delivery, the greater the demands on inventory, quality assurance, and logistics. In financial markets, “inventory” refers to liquidity and collateral.

When trades settle more rapidly, there is less time available to rectify mistakes, secure cash, locate securities, or handle margin calls. Although this could mitigate certain risks, such as counterparty exposure, it may heighten others, like operational failures and unexpected liquidity requirements.

Deloitte connects this to a wider shift in market structure anticipated for 2026. Ben-Hur and Burns foresee the conclusion of the cash aspect of the US Treasury central clearing initiative and suggest “other changes could arise,” while the SEC signals its intention to propose modifications to Regulation NMS. The central theme here is plumbing: clearing, speed of settlement, and the routing of orders through an increasing number of venues.

The primary concern for crypto is the positioning of stablecoins and tokenized collateral. Ben-Hur and Burns anticipate early momentum in collateral workflows, as collateral is a daily, intraday challenge for large enterprises. If collateral can be transferred more swiftly in a reliable dollar-linked format, it diminishes friction in areas of the system where time equates to money.

“The CFTC is investigating the use of stablecoins and tokenized collateral, which may serve as an early use case that gains traction, with the key advantages being immediate settlement in a liquid, dollar-linked asset. The intraday nature of collateral commitments makes it a compelling use case for an asset featuring these characteristics and liquidity commitments. Custody and clearing will facilitate its scalability.”

This is why T+0 can mainstream tokenization without necessitating changes in behavior from retail users. If major institutions embrace tokenized assets for improved collateral movement and settlement reliability, the market can transition from within. The aspects that retail users interact with, such as an app or exchange listing, often come later.

Deloitte also highlights the competitive pressure. It states that the current approach encourages experimentation and could “result in new entrants and heightened competition,” noting that “a multitude of venues” may generate new prospects for order routing and execution.

Accelerated settlement can amplify this effect. When funds and securities circulate more swiftly, the design of venues and routing incentives become increasingly crucial.

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Pilots, No-Action Letters, and Emerging Risks

Pilots extend far beyond mere technical evaluations. When implemented effectively, they can subtly influence policy, particularly as regulators increasingly defer to the industry through mechanisms like no-action letters, self-certification, and staff non-objections, as highlighted in Deloitte’s outlook.

No-action letters are particularly crucial because they can enable a market practice to proceed without waiting for comprehensive rulemaking, provided it remains within certain parameters.

Ben-Hur and Burns mentioned that this instrument has already played a pivotal role in advancing tokenization:

“Until now, the primary tool the SEC has employed to facilitate tokenization, aside from staff guidance, has been the no-action letter. In this context, it serves as a potent mechanism to swiftly enable adjustments in industry practice or available marketplace options, and we are witnessing this already with recent approvals from the SEC.”

Nonetheless, this rapidity comes at a cost. Pilots can create a temporary scenario where the same asset exists in two forms, one tokenized and one traditional, requiring the market to determine their pricing, liquidity distribution, and the evolution of order routing. Ben-Hur and Burns characterized that transition as a likely scenario in equities.

“As the markets shift to tokenized versions of what we consider traditional assets (equities, bonds, deposits, etc.), we are likely to temporarily exist in a realm where both tokenized and non-tokenized versions of the same asset coexist. This raises numerous questions regarding how these assets are traded and valued.”

In this context, the critical question is where liquidity will migrate, and who will reap the benefits of that shift. If liquidity converges in a new, potentially crypto-native venue with quicker settlement, it may relocate price discovery away from established pools. Conversely, if it disperses across various venues, spreads may widen and market depth could diminish, even if the technology is superior.

Deloitte identifies a secondary risk that can easily be overlooked amid the enthusiasm for “streamlining.” It cautions that attempts to lessen reporting burdens can lead to increased opacity, leaving markets in the dark.

Accelerated settlement combined with reduced visibility is a perilous combination. It shortens the time available to identify manipulation, reconcile discrepancies, and respond to stress.

Deloitte advocates for enhanced controls rather than slowing development in response to this challenge. It encourages companies to simplify reporting in ways that enhance “auditability” while framing the broader environment as market-based experimentation with a focus on fraud prevention through enforcement and examinations.

Ben-Hur and Burns articulated this in practical terms: compliance programs, supervision, documentation, audit trails, surveillance, and cybersecurity become increasingly vital as systems accelerate.

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The best perspective on 2026 is this: quicker settlement serves as a stress test for how markets manage information, liquidity, and trust.

If pilots demonstrate that tokenized assets can enhance settlement and collateral workflows without diminishing transparency, tokenization will evolve from a novel concept to a foundational component.

If pilots lead to increased fragmentation and reduced visibility, regulators will tighten restrictions, causing the mainstream rollout to decelerate or even potentially halt.

In either scenario, T+0 is the pivot point. It’s the enhancement that determines whether tokenization is scalable or remains in the demonstration phase.

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