Deloitte warns tokenized settlement will create a dangerous “blind spot” that makes market manipulation nearly impossible to stop
Wall Street’s next leap may look boring from the outside, but it’s a huge development that’s shrouded in corporate speak: T+0 settlement, shorthand for settling a trade the same day it happens.
Deloitte’s 2026 outlook flags it as one of the main themes of the year, alongside signals that regulators want to streamline rules, encourage experimentation, and open paths for blockchain-based products. The report’s message is blunt: if faster settlement arrives, companies should evaluate what it enables, including T+0 products “such as tokenized securities and stablecoins.”
A tokenized security is a familiar asset, like a bond or stock, represented in a digital form that can move on modern rails. The promise of tokenization is simple: fewer handoffs, faster movement of assets and cash, and clearer records.
But, its hurdle is also simple: the real world still runs on settlement cycles, reconciliations, and reporting. If settlement speeds up, tokenization stops being a niche experiment and becomes a practical upgrade everyone has to do.
Roy Ben-Hur and Meghan Burns, the managing director and manager at Deloitte & Touche LLP, told CryptoSlate the most realistic path for tokenization isn’t a sweeping flip of the entire market. The path will most likely start with contained pilots that reveal tradeoffs before anything becomes mandatory.
“Signals point towards initial market experimentation via pilots rather than a full market shift.”
That matters because pilots determine whether tokenization becomes a cleaner, safer version of today’s system or a fragmented maze of new venues and rule interpretations.
Why T+0 matters
T+0 changes the financial system in the same way instant delivery changes retail. The faster the delivery, the more pressure on inventory, quality control, and logistics. In financial markets, “inventory” means liquidity and collateral.
When trades settle faster, there’s less time to fix errors, source cash, locate securities, or manage margin calls. While that can reduce some risks, like counterparty exposure, it can increase others, like operational failure and sudden liquidity needs.
Deloitte ties this to a broader 2026 shift in market structure. Ben-Hur and Burns expect the cash portion of the US Treasury central clearing initiative to end, and it says “other changes could emerge,” while the SEC signals it intends to propose changes to Regulation NMS. The theme here is plumbing: clearing, settlement speed, and how orders route through a growing number of venues.
The main issue for crypto is where stablecoins and tokenized collateral fit. Ben-Hur and Burns expect early traction in collateral workflows because collateral is a daily, intraday problem for large firms. If collateral can move faster in a reliable dollar-linked form, it reduces friction in the parts of the system where time is money.
“The CFTC is exploring the use of stablecoins and tokenized collateral, so this may be an early use case that gains traction, the main benefits being instant settlement in a liquid, dollar-linked asset. The intra-day nature of collateral commitments makes it an attractive use case for an asset with these features and liquidity commitments. Custody and clearing will help it to scale.”
That’s why T+0 can make tokenization mainstream without requiring retail users to change behavior. If large institutions adopt tokenized assets because it improves collateral movement and settlement certainty, the market can shift from the inside out. The thing retail users see and interact with, like an app or exchange listing, often comes later.
Deloitte also points to competition pressure. It says the current approach favors experimentation and could “lead to new entrants and greater competition,” and it notes that “a preponderance of venues” may create new opportunities for order routing and execution.
Faster settlement can amplify that effect. When money and securities move faster, venue design and routing incentives matter more, not less.
Pilots, no-action letters, and the new risks
Pilots are so much more than just technical tests. If executed correctly, they can become a subtle form of policy, especially as regulators keep deferring to the industry via things like no-action letters, self-certification, and staff non-objections, as Deloitte’s outlook puts it.
No-action letters are especially important because they can allow a market practice to proceed without waiting for full rulemaking, as long as it fits within guardrails.
Ben-Hur and Burns said this tool has already been central to tokenization progress:
“So far, the main tool the SEC has been using to enable tokenization, aside from staff guidance, is the no-action letter. In this context, it is a powerful tool to quickly enable changes in industry practice or available marketplace offerings, and we are seeing this already with approvals the SEC has granted recently.”
However, that speed comes with a price. Pilots can create a temporary world where the same asset exists in two forms, one tokenized and one conventional, and the market has to decide how to price them, where liquidity gathers, and how order routing evolves. Ben-Hur and Burns described that transition as a likely reality in equities.
“As the markets transition to tokenized versions of what we think of as traditional assets (equities, bonds, deposits, etc.), we’re likely to temporarily live in a world where there are tokenized and non-tokenized versions of the same asset. This raises a lot of questions about how these assets trade and are priced.”
In that world, the key question is where liquidity will move, and who will benefit from that movement. If liquidity concentrates in a new, possibly crypto-native venue with faster settlement, it can pull price discovery away from legacy pools. If it splits across multiple venues, spreads can widen, and market depth can thin, even if the technology is better.
Deloitte flags a second risk that’s easy to miss in all of the excitement surrounding “streamlining.” It warns that efforts to reduce reporting burdens can increase opacity, leaving markets blind.
Faster settlement with weaker visibility is a dangerous combination. It compresses the time available to detect manipulation, reconcile discrepancies, and react to stress.
Deloitte’s answer to this is to build better controls, not slow down development. It urges companies to streamline reporting in ways that improve “auditability,” and it frames the broader environment as market-based experimentation with an “eye toward fraud” through enforcement and exams.
Ben-Hur and Burns put this in practical terms: compliance programs, supervision, documentation, audit trails, surveillance, and cybersecurity become more important as systems speed up.
The best way to think about 2026 is this: faster settlement is a stress test for how markets handle information, liquidity, and trust.
If pilots prove that tokenized assets can improve settlement and collateral workflows without reducing transparency, tokenization will stop being a shiny new idea and become a part of the infrastructure.
If pilots increase fragmentation and cut visibility, regulators will tighten the leash, and the mainstream rollout will slow down or even completely stop.
Either way, T+0 is the hinge. It’s the upgrade that makes tokenization either useful at scale or stuck in the demo phase.
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