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How to Tokenize an Asset in the EU: A Step-by-Step Solar Park Example
How to tokenize an asset in the EU: follow one solar park through all seven steps, see who acts at each step, and how six EU countries differ.

Kristina Stark
Junior Growth Manager
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ONINO provides infrastructure for digital & tokenized financing to make your next financing a success.
Key Takeaways
Tokenizing an asset usually means your company issues a bond and records who owns it on a digital register, not a spreadsheet. It takes seven steps: structure the company and the bond, choose how ownership is recorded, prepare the offer document, reach your investors, onboard and verify them, record ownership and deliver the tokens, then pay interest and report. This guide follows one illustrative solar park through each step and shows how six EU countries differ.
Say your company runs two solar parks in the EU, part-financed by about 400 private investors. Park three needs EUR 4M. You want every holding on a digital register, so the next round does not start from a spreadsheet. New to the idea? Start with asset tokenization explained.
Can you tokenize a physical asset like a solar park?
Yes, a solar park can be tokenized, like most assets with a clear owner and a value investors can check. That includes buildings, funds, and the goods in our guide to tokenizing metals and commodities. The register records the investor's claim. The asset stays where it is.
Park three sits in a company set up for this one project. That company builds and runs the park. Investors buy its bond: a loan to the company that pays interest and is repaid at the end.
How do you tokenize an asset, step by step?
To tokenize an asset in the EU, you go through seven steps: structure the company and the bond, choose how ownership is recorded, prepare the offer document, reach your investors, onboard and verify them, record ownership and deliver the tokens, then pay interest and report. At each one, either your company or a licensed partner acts.
The rules inside a step can differ by country; the table further below shows how. Where the table is silent, check with a local lawyer.

How to read the graphic: each tag shows who acts at that step: your company, the register keeper, or another licensed partner such as a payment provider. On the right: the example bond, EUR 4M from 400 existing investors.
Step 1: Structure the company and the bond
Your company and its lawyer decide what investors buy, usually a bond. Under EU fund rules, a company running its own business, like a solar park, is generally not a fund. A fund collects money from several investors and invests it for them under a set policy.
Agree in the bond terms how holders vote on changes. Park three's bond pays fixed yearly interest, and its terms set how the 400 holders vote.
Step 2: Choose how ownership is recorded
You choose how ownership is recorded. One option is a digital register: an online record of who owns which bond. Think of it as a land registry for your bond. The other option is a classic bond held through a bank.
Some countries let the digital register be the official ownership record; others do not yet. Who may keep it also depends on the country. We call whoever keeps it the register keeper (also called registrar).
Park three's company chooses a digital register, so all 400 holdings sit in one record. A classic bond would also work; tokenization is an option, not a requirement.
Step 3: Prepare the offer document
A prospectus is the long offer document a regulator approves before a large public offer. In the EU, public offers under EUR 12M in 12 months need none. The limit counts all your company's offers across the EU. A country may set a lower limit of EUR 5M.
Some countries ask for a short national document instead. More in our guide to launching a token offering in the EU.
Park three raises EUR 4M and made no other public offer in the past 12 months. So its offer at home needs no EU prospectus; any national document depends on the country.
Step 4: Reach your investors
Your company invites the investors it already has. Whether it may sell the bond itself, without a licensed firm, depends on the country. See the country table and the note under it.
Park three's company writes to its 400 investors. Tokenization does not find investors. You bring them. Your company runs the online sign-up on the software, under its own name.
Step 5: Onboard and verify investors
EU anti-money-laundering rules make banks, payment providers and other regulated firms check who their customers are. These are ID checks, also called know your customer (KYC). Agree with your partners which of them checks each investor.
Investor money goes to the company's own bank account or through a licensed payment provider. The software never holds it. Each of park three's 400 investors passes the ID check, then pays.
Step 6: Record ownership and deliver the tokens
The register keeper records the bond and each investor's holding. Holdings take the form of tokens: digital units that each stand for a share of the bond.
Some investors keep tokens in their own wallet, an app that holds the access keys. Others leave them with a custodian, a firm that holds tokens for others. Whoever holds tokens for others must have any licence its country requires. The register keeper agrees the technical setup with you before issue.
Park three's register now lists all 400 holdings.
Step 7: Pay interest and report
Your company pays interest to the holders the register shows and reports to them. Who withholds tax differs by country; agree it with your tax adviser. Park three pays interest yearly to the holders on the register on the date its terms set.
Investors who want out early need a buyer, found directly or on a trading venue. Nobody can promise one; see how secondary trading works.
Who does what at each step, and who needs a licence?
The licence sits with whoever does the regulated task. Park three's map:
Step | Who acts | Who needs a licence |
|---|---|---|
1. Structure | Your company, its lawyer | Nobody |
2. Recording | Your company chooses; register keeper keeps it | Register keeper, where the country requires |
3. Offer document | Your company | Nobody; some regulators review it |
4. Investors | Your company | Depends on the country |
5. ID checks, payments | Bank, payment provider, partners as agreed | Each regulated firm |
6. Recording, tokens | Register keeper, custodian | Both, where the country requires |
7. Interest | Your company | Nobody; tax rules vary |
ONINO supplies issuance software with pre-integrated licensed registrar and custody partners. You contract those partners; each holds the permission and performs the licensed service. Tokenization is one optional rail in that setup. The asset tokenization software page shows what the software does and where partners come in.
What drives the cost and time of tokenizing an asset?
Legal work, the offer document, the register keeper, ID checks, payments and investor updates drive cost. To budget, ask each partner for its one-off, yearly and per-investor fees, and for its lead time.
Park three's slowest parts: the bond terms, any national offer document, the register keeper contract and 400 ID checks. Its investors already exist. Park four can reuse the same register keeper and software, with its own bond terms and offer document.
How does the process change in other EU countries?
The seven steps run in the same order in every EU country. The table below shows two things that differ: whether a bond can sit on a digital register, and what a EUR 4M offer needs.
Say park three's company sat in one of these six countries. At EUR 4M, its offer at home would still need no EU prospectus.
Country | Bond on a digital register? | What a EUR 4M offer needs |
|---|---|---|
Germany | Yes, with a register keeper licensed by BaFin, Germany's regulator. | Information sheet of up to 4 pages (WIB), BaFin decides in 10 working days; you may sell it yourself. |
Austria | No law found; ask an Austrian lawyer. | Simplified prospectus approved by the FMA, Austria's regulator, from EUR 2M. |
France | Yes, for unlisted bonds, per the AMF, France's financial markets regulator. | Short information document (DIS) filed with the AMF, not approved; limit: see note. |
Italy | Yes, with a register keeper on the list of CONSOB, Italy's financial markets regulator. | No document; CONSOB may require one only above EUR 8M. |
Netherlands | Not directly; only through an intermediate structure for now. | Information document of up to 7 pages, filed with the AFM, the Dutch financial markets regulator, and made public before the offer. |
Spain | Yes, with an authorised register entity the company names. | No prospectus; possibly an information document; limit: see note. |
France and Spain: the EU limit is EUR 12M, but national text still says EUR 8M while an update is pending. For these limits, for selling the bond yourself outside Germany and for offers across borders, check with a local lawyer.
Country rules verified as of 28 October 2026. Each link in the table goes to the law or regulator page it rests on.
Where do first tokenization projects stall?
Four details can stop a first project.
Fund status. A company that only holds the park for investors may count as a fund. Park three's company runs the park itself, which is why Step 1 matters.
Interest tied to power prices. This can bring the bond under the EU rules for packaged retail investment products. These cover investments whose payout moves with a market price. Selling it to private investors then needs a key information document (KID), a standard fact sheet. Park three pays fixed interest.
Licensed tasks. Keeping the register, holding tokens for others or handling others' payments can need a licence. That depends on the country. In park three's setup, licensed partners do these tasks.
The crypto question. Is this a crypto product? No. A tokenized bond is still a bond; MiCAR, the EU crypto rulebook, does not apply.
What should you prepare before you start?
Start with the investors. For park three:
Confirmed interest from the 400 investors, and how much each wants to invest.
The issuing company and the bond terms, including how holders vote on changes.
A lawyer in your country, with one question: "Can we sell this bond ourselves, and which document do we need?"
A register keeper, plus a custodian for investors without their own wallet.
Someone responsible for ID checks, payments and investor updates.
Planning your own park three? See what the software does and where licensed partners come in.
General information only, accurate at the date shown. Not legal, tax or investment advice. Confirm your own position with qualified counsel.
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How to tokenize an asset in the EU: follow one solar park through all seven steps, see who acts at each step, and how six EU countries differ.



