Global Digital Finance (GDF) submitted a response to the UK Wholesale Digital Markets Champion’s First Report, welcoming its direction of travel and its focus on moving the UK from pilots towards scalable, live tokenised markets.
The response supports the report’s focus on an end-to-end repo use case, interoperability across new and existing infrastructure, multiple forms of wholesale settlement money, and the creation of Action Groups to support practical delivery. GDF emphasises that the next phase should focus not simply on whether tokenised transactions can be executed, but whether they can be used repeatedly, economically and at institutional scale.
Key recommendations include building commercial utility and customer readiness into the programme from the outset; making collateral mobility a central objective; preserving optionality across settlement assets and permissioned, permissionless and hybrid infrastructure; developing DIGIT as a repeatable issuance and market programme; and treating interoperability as a prerequisite rather than a downstream consideration.
The response also calls for targeted action on legal, prudential, custody, financial market infrastructure, tax and accounting barriers, alongside a common institutional readiness framework to assess whether flagship use cases can move from successful technical execution to routine production-scale use.
Overall, GDF argues that much of the underlying technical capability for tokenised wholesale markets already exists. The priority now is to remove the commercial, regulatory, operational and interoperability barriers that prevent these capabilities from developing into scalable and functioning markets.
Submitted:
04/09/2026