Deloitte warns that while T+0 and tokenized securities have the potential to improve speed and collateral efficiency, delays in reporting and monitoring can create dangerous blind spots.
summary
- Deloitte’s 2026 outlook identifies same-day T+0 payments and tokenized securities as important experiments, likely to be launched on limited trials rather than a complete market overhaul.
- Faster settlements reduce the time it takes to raise cash, correct errors, and manage margin, which, when combined with reduced reporting and fragmented liquidity, increases liquidity and operational risk.
- Tokenized collateral and stablecoins have been early targets, with the CFTC and SEC offering do-nothing remedies to pilots, while Deloitte is calling for strong compliance, audit trails, and cyber controls.
Deloitte identified potential risks in the financial industry’s transition to same-day payments and tokenized securities, and warned that relaxed reporting requirements and accelerated trading schedules could create dangerous gaps in market oversight, according to the firm’s 2026 Outlook report.
Deriot warns regarding T+0 payments
The report highlights T+0 payments, which allow transactions to settle on the same day they occur, as a key development in 2026. Deloitte noted that regulators have expressed interest in streamlining rules and creating a pathway for blockchain-based products, including tokenized securities and stablecoins.
Tokenized securities are traditional assets such as bonds or stocks that are represented in digital form and can be transferred on blockchain infrastructure. The technology is expected to reduce intermediaries, speed the movement of assets and cash, and improve record-keeping, according to the report.
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Roy Ben-Hur, managing director at Deloitte & Touche LLP, and Meghan Burns, the firm’s manager, told CryptoSlate that the most realistic implementation method involves a subdued pilot program rather than an overhaul of the market.
“This signals a direction for initial market experimentation with pilots rather than a full market transition,” the executives said.
According to Deloitte, accelerated settlement schedules reduce the time available to correct errors, raise cash, identify securities, and manage margin calls. The report said faster settlements could reduce counterparty exposure risk, but could increase operational failures and sudden liquidity pressures.
Deloitte linked these developments to broader market structure changes in 2026, including the expected end of the cash portion of the U.S. Treasury Central Clearing Initiative and the anticipated Securities and Exchange Commission proposal to amend Regulation NMS.
The company identified collateral workflows as an area where tokenized assets are likely to see early adoption. Ben-Hur and Burns noted that the Commodity Futures Trading Commission is considering stablecoins and tokenized collateral as use cases involving instant settlement of liquid dollar-linked assets.
“The intraday nature of collateral commitments makes them an attractive use case for assets with these capabilities and liquidity commitments. Custody and liquidation help drive scale,” executives said.
The report notes that faster payments could enable new market entrants, increase competition, and create additional venues for order routing and execution.
Deloitte noted that the SEC primarily uses no-action letters and staff guidance to allow tokenization to proceed. No-action letters allow market practices to proceed without a full rulemaking process, as long as they work within established parameters.
“In this context, this is a powerful tool that enables rapid changes to industry practices and available market services, and we have already confirmed this with the approval recently granted by the SEC,” Ben-Hur and Burns said.
According to executives, the transition period could create a market environment where tokenized and non-tokenized versions of the same asset coexist, raising questions about pricing, liquidity concentration and order routing.
Deloitte warned that efforts to reduce reporting burdens could increase market opacity and, when combined with faster payment speeds, could create a dangerous combination. When timelines are compressed, the window available to detect manipulation, reconcile discrepancies and respond to market stress shrinks, the report said.
The company recommended that businesses implement streamlined reporting systems that maintain auditability while supporting quick settlements. Ben-Hur and Burns emphasized that as payment systems accelerate, compliance programs, oversight, documentation, audit trails, monitoring and cybersecurity measures will become more important.
The report positions 2026 as a testing period for whether tokenized assets can improve payment and collateral workflows while maintaining transparency. According to Deloitte, the results of the pilot program will determine whether tokenization will be integrated into market infrastructure or remain limited in scope.
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