Deloitte warns that tokenized markets face make‑or‑break test as T+0 settlement goes live

Deloitte warns that T+0 and tokenized securities could boost speed and collateral efficiency while creating a dangerous blind spot if reporting and oversight lag.

Deloitte has identified potential risks in the financial industry’s shift toward same-day settlement and tokenized securities, warning that accelerated trading timelines combined with reduced reporting requirements could create dangerous gaps in market oversight, according to the firm’s 2026 outlook report.

Deliotte offers warnings with respect to T+0 settlements

The report highlights T+0 settlement, which allows trades to settle on the same day they occur, as a major development for 2026. Deloitte noted that regulators are signaling interest in streamlining rules and creating pathways for blockchain-based products, including tokenized securities and stablecoins.

Tokenized securities are traditional assets such as bonds or stocks represented in digital form that can be transferred on blockchain infrastructure. The technology promises fewer intermediaries, faster asset and cash movement, and improved record-keeping, according to the report.

Roy Ben-Hur, managing director at Deloitte & Touche LLP, and Meghan Burns, manager at the firm, told CryptoSlate that the most realistic implementation path involves contained pilot programs rather than a complete market overhaul.

“Signals point towards initial market experimentation via pilots rather than a full market shift,” the executives stated.

The accelerated settlement timeline reduces the window available to correct errors, source cash, locate securities, or manage margin calls, according to Deloitte. While faster settlement may reduce counterparty exposure risks, it could increase operational failures and sudden liquidity pressures, the report stated.

Deloitte connected these developments to broader 2026 market structure changes, including the expected conclusion of the cash portion of the U.S. Treasury central clearing initiative and anticipated Securities and Exchange Commission proposals to modify Regulation NMS.

The firm identified collateral workflows as an area likely to see early adoption of tokenized assets. Ben-Hur and Burns noted that the Commodity Futures Trading Commission is exploring stablecoins and tokenized collateral for use cases involving instant settlement in liquid, dollar-linked assets.

“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,” the executives stated.

The report indicated that faster settlement could enable new market entrants and increased competition, potentially creating additional venues for order routing and execution.

Deloitte noted that the SEC has primarily used no-action letters and staff guidance to enable tokenization progress. No-action letters allow market practices to proceed without full rulemaking processes, provided they operate within established parameters.

“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,” Ben-Hur and Burns stated.

The transition period may create a market environment where tokenized and non-tokenized versions of the same asset coexist, raising questions about pricing, liquidity concentration, and order routing, according to the executives.

Deloitte warned that efforts to reduce reporting burdens could increase market opacity, creating what the firm characterized as a dangerous combination when paired with faster settlement speeds. The compressed timeline reduces the window available to detect manipulation, reconcile discrepancies, and respond to market stress, the report stated.

The firm recommended that companies implement streamlined reporting systems that maintain auditability while accommodating faster settlement. Ben-Hur and Burns emphasized that compliance programs, supervision, documentation, audit trails, surveillance, and cybersecurity measures become more critical as settlement systems accelerate.

The report framed 2026 as a testing period for whether tokenized assets can improve settlement and collateral workflows while maintaining transparency. The outcome of pilot programs will determine whether tokenization becomes integrated into market infrastructure or remains limited in scope, according to Deloitte.