Global Digital Finance (GDF), together with Web3 Harbour (W3H), supported a comment letter submitted by the Korea Web3 Blockchain Association (KWBA) to the Korea Financial Services Commission (FSC) on draft amendments to the Enforcement Decree of the Act on Electronic Registration of Stocks, Bonds, etc. and to the Regulation on Electronic Registration Business. The amendments implement the first phase of Korea’s token securities regime, which brings token securities into the electronic registration system ahead of commencement on 4 February 2027.
The submission supports the draft amendments and the FSC’s phased Token Securities Policy Direction of 4 September 2026. It does not seek permission for stablecoin settlement at this stage, but asks that the first-phase rules avoid foreclosing design choices that the second and third phases will require, and stresses that these sub-regulations will shape how open Korea’s token securities market is to foreign issuers and investors.
Key recommendations include clarifying that the requirement for no “direct consideration” for distributed ledger use does not capture participants’ shared build and operating costs, delivery-versus-payment settlement in tokenised settlement assets, or payments of dividends, interest and redemption proceeds. The letter also asks that the one-ledger rule remain in the registry’s standards rather than being elevated to the Decree, that registry-supervised transfers between ledgers be considered as a second-phase task, and that the rule not prohibit cash settlement on a separate ledger through an approved linking mechanism.
To support cross-border participation, the submission calls for early guidance on securities issued by foreign corporations, confirmation that existing custodian, standing proxy and foreign investor omnibus account structures apply to distributed-ledger account books, and that end investors need not hold a ledger address directly. It further requests advance publication of detailed ledger criteria and conformity assessment procedures, outcomes-based standards for key and node management, and broader participation of blockchain and digital asset industry associations in the public-private Token Securities Council.
Submitted:
November 2026