The International Swaps and Derivatives Association (ISDA) and Global Digital Finance (GDF) submitted a joint response to the Central Bank of Ireland’s Discussion Paper 12 on DLT and Tokenisation in Financial Services. The response welcomes the Bank’s exploration of distributed ledger technology within wholesale financial markets and supports a regulatory framework that preserves legal certainty, financial stability, and sound risk management.
The submission highlights the potential benefits of tokenisation for collateral mobility, liquidity management, operational efficiency, and near-instantaneous settlement, while emphasising that these benefits must be underpinned by robust governance, operational resilience, legal enforceability, and internationally consistent standards. ISDA and GDF also encourage the adoption of common technical standards, including the Common Domain Model, to support interoperability across markets.
Additionally, the response outlines the significant opportunities presented by tokenised money market funds and other tokenised assets as collateral, arguing that tokenisation can reduce operational frictions and improve collateral efficiency without increasing systemic risk. Overall, the associations encourage continued international regulatory coordination to support the safe and scalable adoption of tokenisation across wholesale financial markets.
Submitted:
03/06/2026