On 14 September 2026, the UK Financial Conduct Authority (the FCA, Britain's main financial regulator) opened a public review of tokenized gold. It is asking banks, gold dealers, token issuers and anyone else with a view to send in evidence by 23 October 2026, according to the FCA's call for input page.
If you hold a gold token, that raises a question: is tokenized gold regulated at all? And if London is only now asking questions, what protects you today?
The honest answer: it depends on who issues the token and where. This article explains what the FCA is asking, how the EU and the US treat gold tokens today, and a short checklist you can run on any token yourself.
A "call for input" is the FCA's way of asking the market questions before it decides whether to act. It is not a rule, a ban or an approval. It is a regulator doing its homework in public.
The full FCA paper asks whether tokenization could improve the way gold is "traded, transferred, pledged and held in UK markets." Tokenization here means recording ownership of gold as a digital token on a blockchain, a shared digital ledger that many computers keep in sync.
The paper grew out of a joint vision for tokenization that the FCA and the Bank of England published in May 2026. That paper focused on wholesale markets, where banks trade with each other. Many replies mentioned gold, so gold now gets its own review.
Two details stand out. First, the FCA says its goal "is not to regulate the segments of the gold trading market that are currently outside" its remit. Second, it only discusses products that give real ownership of physical gold with reliable redemption. The aim is to help well-built gold tokens work better.
The FCA lists five possible responses, and stresses they are not firm proposals: a note on good and poor practice, guidance on how existing rules apply, a recognized "eligible gold token" label with set conditions, targeted rule or law changes, or a bespoke regime for tokenized gold or commodities. To see why the UK is asking first, it helps to know where the world's gold is traded.
The FCA paper calls the London over-the-counter gold market "the biggest for spot gold trading in the world." Over-the-counter means trades agreed directly between two parties, not on an exchange. Spot means the gold changes hands now.
That market runs on standards set by the London Bullion Market Association (LBMA), the industry body for London's gold trade. Its best-known standard is Good Delivery, which sets the quality rules for the large bars banks trade. A Good Delivery gold bar weighs roughly 400 troy ounces (the standard unit for precious metals, about 31.1 grams each). Many gold tokens, including PAXG, rely on London vaults.
The FCA also names a weakness in today's system. "Allocated" gold (specific bars recorded in your name) is safer but slow and costly to move. "Unallocated" gold (a general claim on a bank's gold) moves easily but leaves you exposed if that bank fails. Tokens might offer a middle path, which is why the legal questions matter. The biggest one is about funds.
UK law has a broad category called a collective investment scheme (CIS). In plain terms, a CIS is an arrangement where many people's money or property is pooled and managed together, like a fund. A second, overlapping label is the alternative investment fund (AIF), which covers most funds that are not standard retail funds.
Why care? The FCA explains that if a gold token counts as a CIS or AIF, the firm behind it faces extra authorization, marketing and disclosure rules, and some investors may be unable to hold it. Banks may also treat it differently as collateral (an asset pledged to secure a loan).
The FCA draws a useful line between two designs:
Industry groups argue for a third route, a co-ownership share of an allocated bar that is not a fund, and the FCA is open to hearing it. It also floats a targeted exemption for some gold tokens, working with HM Treasury (the UK finance ministry), but only if another set of rules offers equal or better protection.
It lists 12 things such a regime would need to cover, including holders' rights, gold quality, custody, matching vault and on-chain records, independent audit, fees, and what happens if the issuer fails. In effect, a regulator's checklist for a good gold token.
The FCA compares gold tokens with gold ETFs (exchange-traded funds, gold funds you buy on a stock exchange). For ETFs, it says, disclosure and oversight are "well established," while "inconsistent practice continues to exist in the tokenised gold space."
Its answer is a set of minimum disclosures. Holders should be able to understand:
The signal is positive: regulators write papers like this when a product has outgrown the experimental stage. The FCA notes gold tokens have seen "significant growth in market capitalisation." The category is worth about $5.2 billion as of late September 2026, according to CoinGecko. Small next to gold ETFs, but big enough for clear rules. The UK is not alone in working on this.
With no global rulebook, the key fact about any gold token is its issuer's status.
PAX Gold (PAXG). Paxos says each PAXG is backed by one fine troy ounce of gold in London LBMA vaults, can be redeemed for Good Delivery bars, and is covered by monthly attestation reports, according to its PAXG page. An attestation is a check by an outside accounting firm that reserves match the tokens. Paxos was chartered in 2015 by the New York Department of Financial Services (NYDFS). On 12 December 2025 it converted to a national trust charter supervised by the Office of the Comptroller of the Currency (OCC), the US federal regulator for national banks.
Tether Gold (XAUT). Tether Gold's official information document, dated 27 January 2025, names the issuer as TG Commodities, S.A. de C.V., in El Salvador. It is authorized as a stablecoin issuer and digital asset service provider by El Salvador's National Commission of Digital Assets (CNAD). The document says the gold is held by a custodian in a Swiss vault, reserve reports come out quarterly with independent auditors' reports, and redemption is for full bars only, which generally means depositing at least 430 tokens. The Tether Gold website says bars are delivered to addresses in Switzerland.
The EU's Markets in Crypto-Assets Regulation, known as MiCA, is the most complete crypto rulebook in force. The official text defines an "asset-referenced token" (ART) as a token that tries to keep a stable value by referencing another value or asset. Those rules have applied since 30 June 2024. An ART issuer must be authorized in the EU and must let holders redeem "at all times," in cash or in the underlying asset.
That sounds like a natural home for gold tokens. In practice it has been hard. In a response dated 24 September 2026, the European Banking Authority (EBA, the EU banking supervisor) said zero ARTs had been authorized as of 1 September 2026. It added that gold tokens have "proved particularly challenging to classify," often because the issuer's white paper (the required disclosure document) does not clearly say what rights holders get. The EU markets regulator, ESMA, keeps the register of authorized issuers.
The US stablecoin law, the GENIUS Act, was signed on 18 July 2025. It covers "payment stablecoins," which must be redeemable for a fixed amount of "monetary value," defined as a national currency or a deposit in one. A gold token is redeemed for gold or its changing price, so it does not fit.
On 17 March 2026 the SEC (the US securities regulator) issued an interpretation sorting crypto assets into five groups, and the CFTC (the US commodity futures regulator) joined it. We found no part of it that names gold-backed tokens, so we make no claim about where they fall. On 24 September 2026, CFTC staff updated their FAQs on investing customer funds in tokenized forms of already-permitted assets. That shows growing comfort with tokenization, not a ruling on gold. In the US, the clearest oversight today is at the issuer level.
Rules only help if you can check a specific token.
You do not need a law degree for this. These five questions track the disclosures the FCA wants consumers to get.
Run this checklist on every token you consider, including GGBR. GGBR is backed by over-collateralized gold reserves that include in-ground gold, meaning gold still in the ground rather than refined bars in a vault. That is a different model from PAXG or Tether Gold, and it deserves the same scrutiny. Our guide to vaulted gold vs in-ground gold explains the trade-offs. No checklist is complete, though.
This is a plain-language summary, not legal advice. Whether a token is a fund, a security or something else where you live is a legal question for a qualified lawyer.
The FCA's paper asks questions; it does not answer them. The outcome could be guidance, a new label, a law change or nothing.
Regulation also has limits. A regulated issuer still depends on vaults, custodians and technology that can have problems. And no rule protects you from a falling gold price: a gold token tracks gold, so a regulated token falls just as much as an unregulated one. If you stake a gold token, that yield does not protect you from a price drop either.
Finally, we included only details confirmed by official or primary sources as of 28 September 2026. How US regulators would classify gold-backed tokens under their new categories could not be confirmed, so it is left out.
Is tokenized gold regulated? Sometimes, depending on the issuer. There is no single global rulebook. Some issuers, like Paxos, answer to a national regulator; others are licensed in smaller jurisdictions. Check who issues the token and who oversees that company.
Does the FCA call for input change anything for holders now? No. It is a request for evidence that closes on 23 October 2026. The FCA will then decide whether to publish guidance, propose changes or do nothing.
Is PAXG regulated? PAXG is issued by Paxos, which says it is a trust company regulated by the US Office of the Comptroller of the Currency.
Who regulates Tether Gold? Tether Gold's information document says its issuer, TG Commodities, is authorized by El Salvador's National Commission of Digital Assets.
Are gold tokens covered by MiCA in the EU? They can be, usually as asset-referenced tokens, but it depends on the rights the token gives. The EBA says gold tokens have been hard to classify, and no asset-referenced tokens had been authorized as of 1 September 2026.
Does the US GENIUS Act cover gold tokens? No. It covers payment stablecoins redeemable for a fixed amount of a national currency.
Is tokenized gold regulated? Partly, and unevenly. The strongest protection today comes from the issuer's own license and the quality of its custody, audits and redemption terms. The FCA's 2026 review shows gold tokens have grown up enough for the world's biggest gold market to want clear rules. Until those rules arrive, ask the five questions above and expect clear, written answers.
This article is for informational purposes only and is not financial advice.
| Jurisdiction | Main framework or body | How gold tokens fit today | Status as of 28 Sep 2026 |
|---|
| United Kingdom | FCA; fund (CIS and AIF) rules | Depends on design. Allocated-bar tokens more likely outside fund rules; pooled tokens may be funds | Call for input open until 23 Oct 2026; no new rules yet |
| European Union | MiCA; EBA and ESMA | May qualify as asset-referenced tokens, but classification depends on holder rights | ART rules apply since 30 Jun 2024; 0 ARTs authorized as of 1 Sep 2026 |
| United States | GENIUS Act; SEC; CFTC; OCC | Outside the GENIUS Act; oversight at issuer level (for example, Paxos under the OCC) | GENIUS Act signed 18 Jul 2025; 17 Mar 2026 SEC and CFTC interpretation does not name gold tokens |
| El Salvador | National Commission of Digital Assets (CNAD) | Tether Gold's issuer licensed as stablecoin issuer and service provider | Per Tether Gold's January 2025 information document |
