Markets of the Future: if the UK and US want to lead, they must build

Sometimes a taskforce is theatre: good lighting, careful lines, a programme note promising transformation. Sometimes, if the cast is right and the staging is ruthless, it becomes machinery. The UK–US Transatlantic Taskforce for Markets of the Future will be one or the other. It was announced on 22 September with the right noises about smoothing cross-border capital-markets access and coordinating on crypto and tokenised market infrastructure. The brief is brisk, a report in 180 days, and the cast includes both Treasuries with regulators in the wings. 

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You don’t need to be a cynic to hear the risk in that choreography. “Cooperation” can be a synonym for “defer,” and 180-day reports have a long history of being filed and forgotten. But the timing is unusually propitious. The United States has already moved to T+1 settlement (as of May 2024); not a lifestyle choice but a statement about market plumbing becoming real-time. 

The UK, after the usual dignified consultation, has fixed 11 October 2027 as its own T+1 changeover date. That is both sobering and useful: it creates a genuinely shared deadline with the EU and Switzerland and gives the taskforce a hard milestone against which to design cross-border processes. 

At the same time, tokenisation, a word that once lived only in slide decks, is now installed behind the walls. DTCC’s Project Ion has run in parallel production since 2022, processing six-figure daily transactions; the Digital Securities Sandbox (DSS) in the UK is open for live issuance, trading and settlement under adapted rules with the Bank of England and FCA supervising the experiment. 

And crucially, the international scaffolding that regulators like to wave before action, in this case IOSCO’s crypto and DeFi recommendations, the FSB’s global stablecoin framework, and the Basel capital standard for banks’ crypto exposures, all already exists. 

In short: the stars are, for once, aligned. The question is whether the taskforce will seize the moment or memorialise it. Here is a plan for the former.

What the taskforce is for (and what it isn’t)

The temptation with transatlantic endeavours is to treat them as diplomatic art: communiqués, workstreams, tasteful acronyms. The Markets of the Future taskforce has a simpler, sterner purpose. It’s a joiner’s shop. Its job is to take components already sitting on the bench (standards, pilots, plumbing, law) and fit them so that capital, collateral and compliance can move across the UK–US seam without splitting at the grain.

Harmonisation is the wrong aspiration. The UK and US will never regulate identically, nor should they. This is a project in comparability: two legal systems, one set of supervisory outcomes, a shared experience for issuers and investors.

Done properly, it will let a UK instrument live credibly in US markets (and vice versa) without bespoke legal choreography. Done badly, it will generate a handsome report and leave the choreography intact.

Why now is different

Three things have changed.

First, the market plumbing is moving. Once the US went to T+1, the rest of the developed world lost the option to dawdle. T+1 is not just a shorter deadline; it is a stress test for how posttrade actually works: affirmations, allocations, FX prefunding, exception handling. The UK’s 11 October 2027 date aligns the calendar with the EU and Switzerland, which means fewer excuses and more pressure to solve cross-border seams on purpose rather than by accident. 

Second, tokenised infrastructure has crossed from trial to tooling. DTCC’s Project Ion is no longer a demo. The DSS is not a sandbox in the marketing sense; it is statutory permission to run new market infrastructure under adapted rules. That matters: it means the taskforce can design against systems that exist, not PowerPoint promises. 

Third, the legal and prudential underlay is maturing. IOSCO, FSB and Basel have finished their first passes. Meanwhile, the UK Law Commission has done the heavy conceptual lift on recognising certain digital assets as a new, third category of personal property, and Parliament has put digital possession in statute via the Electronic Trade Documents Act 2023. The US analogue,  UCC Article 12 for “controllable electronic records”, gives the American system a way to recognise control and transfer under state law. Accounting is inching forward too: under US GAAP, many crypto assets now sit at fair value; IFRS remains more hesitant, but at least the fault lines are visible. 

One more brick in the wall: the UK–US Data Bridge took effect in October 2023, giving a lawful route for compliant personal-data transfers to certified US organisations. That is the beginning of a cross-border compliance spine. 

With those pieces set, what should the taskforce actually do?

A plan in five movements (that only works if played together)

1) Write the outcomes, not the poetry

The first deliverable should be dry, short and decisive: a UK–US outcomes framework for tokenised and digitally-native market activity. Not a model law. Not a doctrinal essay. A table. In one column: the outcomes both sides require (market-abuse surveillance that works; auditable custody control; comparable disclosures; operational resilience; incident reporting within hours not days; finality that means something in court). In the second column: how each jurisdiction’s rules and expectations deliver those outcomes today, or will deliver them within the T+1 timetable.

This takes the international baseline (IOSCO/FSB/Basel) and turns it into a translation layer rather than a sermon. It gives supervisors an explicit way to read each other’s rules. And it gives firms an engineering spec: if you can meet these outcomes and prove it, you will not be punished for the different words we use.

The clever part is making that table actionable. That means instructing regulators to publish short “interpretations” mapping the table into their rulebooks and supervisory letters. It doesn’t bind courts. It doesn’t need to. It binds the day-to-day life of approvals, examinations and enforcement discretion, where certainty lives.

2) Open the corridor and run real traffic

Every industry has a graveyard of sandboxes. The point here is not more permission to experiment; it is permission to interoperate. The taskforce should set up a live corridor with two concrete, ordinary use cases:

• A UKissued, USD-settled corporate bond, native to the DSS, traded on a US ATS, settled through DTCC’s Ion rails, with on-chain lifecycle events mirrored into both supervisors’ dashboards.

• A tokenised collateral upgrade between UK and US counterparties, with intraday movements and end-of-day netting, proving that a programmable instrument can reduce fails and funding friction without sacrificing control or auditability.

Neither use-case is glamorous. That is the point. If tokenisation cannot make these humdrum workflows cheaper, faster and safer, it isn’t ready. And if it can, the telemetry will show it: fail rates, latency, margin impact, exception leaves, cyber incidents. Publish those numbers. If you want the Street to migrate, you must show the Street the spreadsheet.

The corridor also forces the awkward questions forward: which smart-contract pattern counts as custody? What does “finality” mean when both ledgers and law are involved? Which events need to be reported, in which format, and to whom? Vague principles dissolve when you have to settle a trade at 15:59.

3) Build the identity and data spine

Crypto’s most persistent fiction is that decentralised finance does not need centralised identity. Markets do. The UK–US Data Bridge gives a lawful path for personal-data transfers. The CFPB’s Section 1033 “open banking” rulemaking in the US is rebuilding the authorisation model for financialdata sharing. The FATF has already written what “Travel Rule” payloads should contain and how digital identity should be assured.

Stitch those together into a passportable compliance artefact: one re-usable KYC profile (with agreed assurance levels), one encrypted Travel Rule schema, one audit trail format. Make it optional to start; make it attractive by design; make it boring in operation. Boring is a feature. The less bespoke the identity bridge, the more attention can go to the parts of markets that create value.

This is also where the politics must be candid. There is no such thing as zero-knowledge bureaucracy. If you want cross-border liquidity, you will need cross-border identity. The job is to minimise the data (lawfully), maximise the assurance, and standardise the pipes. “Privacy by architecture” and “compliance by artefact” are not slogans; they are the only way this scales.

4) Line up the pipes, then test a sprint, not a marathon

“Speed” is the wrong obsession. Markets do not need every instrument to settle at the speed of a meme. They need predictability: fewer breaks, fewer fails, fewer margin cliffedges. The UK’s and EU’s decision to land T+1 on 11 October 2027 is a gift because it forces the dullest but most consequential alignment (affirmation deadlines, allocation cutoffs, FX funding windows, exception playbooks, settlement-discipline penalties) to happen on a calendar everyone can see.

Once that is genuinely aligned, test T+0 netting in places where it helps rather than excites: repo, ETF basket settlement, intraday collateral substitutions. Do it with the corridor’s telemetry switched on. If netted T+0 reduces reconciliations and liquidity drag without lighting operational fires, keep it. If not, write it up and walk away. The fastest way to discredit tokenisation is to declare it the answer to questions nobody asked.

And then there is custody. The hardest definitional gap is also the most fixable: what does it mean to hold a token? Is it private-key control? Is it enforceable control under law? Is it control by contract via an FMI? The answer can differ by instrument and venue. The task is to publish the interpretations that let auditors sign, insurers price risk, and supervisors examine with a straight face. Write down the tests; make firms prove them; move on.

5) Nail the foundations: law, accounting, capital

Innovation collapses if the balance sheet cannot carry it. Three foundational layers must be made to cohere across the Atlantic.

Property law. The UK has done the philosophical dig and passed ETDA; the US has UCC Article 12. The taskforce should publish joint guidance on conflict-of-law questions (what happens when an Englishlaw token meets a New Yorklaw custody agreement), and endorse model terms that travel cleanly between English and New York law. Lawyers will argue anyway; your job is to narrow the battlefield.

Accounting. Under US GAAP (ASU 202308), many crypto assets are at fair value through P&L; under IFRS they often remain intangibles, with unhelpful impairment gymnastics. The taskforce cannot tell the IASB what to do, but it can convene a Treasury-to-Treasury working group with standard-setter observers to produce practical guidance for common cases: treasury holdings, staking rewards, tokenised liabilities. If a CFO cannot predict the audit treatment on both sides of the ocean, they will not hold the asset.

Prudential capital. Basel’s crypto standard is the floor. The UK and US should avoid interpretive drift, particularly on tokenised real-world assets. If a tokenised bond gets treated like “crypto” with a punitive risk weight in one jurisdiction but not the other, the corridor will become a canal for capital arbitrage, and then a crime scene.

Two objections, and why they’re wrong

Objection one: “This is just more work for uncertain gain.”
No. The gain is certainty itself. We know from every chapter of financial history that standards which reduce friction and increase predictability pull activity to them. “Comparable outcomes” is not a slogan. It is a liquidity attractor.

Objection two: “If this is so obvious, why hasn’t it been done already?”
Because it requires two unfashionable virtues: humility (accepting that the other jurisdiction may be right in its way) and discipline (writing interpretations that limit your own discretionary theatre). The payoff is power: the power to set the de facto global spec for how tokenised markets will work in practice. New York and London have done this before. They can do it again.

What success looks like (and when we’ll know)

By the end of Q1 2026 (the taskforce’s own timeframe) we should be able to tick off four very ordinary miracles.

First, a published outcomes table with regulator-signed interpretations, so lawyers and supervisors stop arguing about theology and start testing controls.

Second, a corridor running a couple of unromantic use cases with public telemetry, so the debate moves from “belief” to “evidence”.

Third, a passportable compliance artefact that lets a customer onboarded in London be recognised in New York with only incremental checks, not a full re-paper.

Fourth, a short joint note on property, accounting and capital treatment for tokenised instruments that avoids obvious arbitrage and gives boards the comfort to proceed.

If those four things exist, the rest will follow, because capital likes certainty more than speeches.

The politics beneath the plumbing

None of this is happening in a vacuum. The EU will defend MiCA and try to export it; Asia will keep building corridors of its own; the US will oscillate between legislative appetite and enforcement muscle memory; the UK will occasionally confuse consultation with completion. The trick is to be shamelessly pragmatic. The taskforce should borrow where others have already solved a problem, and publish where it has solved a problem that others keep hand-waving.

It should also be honest about where coalitions of convenience beat grand convergence. You do not need a universal rulebook to run a universal market. You need a few sharp, boring, shared guarantees, and a willingness to route around everything else.

There is also a geopolitical undertone. A world fragmented into payment blocs and data regimes is a world in which the transatlantic axis is either a standard-setter or a standard-taker. The former is harder but more profitable. The latter is easier and ends in committees.

A final, unfashionable point about craft

The future of markets will be decided less by the eloquence of speeches and more by the literacy of interfaces. If the taskforce can normalise a handful of operational artefacts (the outcomes table, the corridor playbook, the compliance passport, the legal/accounting capital note) it will have achieved more than a dozen strategy papers.

We have the parts. We have a deadline. We have a plausible cast. The only thing left is to refuse the comfort of poetry and ship the prose.

Subscribe or not, markets will deliver a verdict either way.

Oliver Linch is the Head of the Adam Smith Institute’s Future Markets Policy Unit and the Founder of OJL Law, a boutique law firm specialising in fintech and digital asset regulation.

You can read more on his Substack, where he writes on a range of legal and regulatory issues in fintech, and publishes the Linch Ledger, a weekly take on how regulation is shaping crypto, and how crypto is testing boundaries of the law.