Tokenized crowdfunding is a regulated crowdfunding offering in which the instrument investors subscribe to is issued as an electronic security under Germany's Electronic Securities Act (eWpG), in force since June 2021, while the offering itself runs on a platform authorised under the EU Crowdfunding Regulation (ECSPR). For the operator, that means one platform, one investor funnel, and one brand, with the permission set matched to the rails the platform switches on. The fear that usually ends this conversation early deserves to be retired in the first paragraph: tokenization itself adds no new licence for the operator. Register and custody sit with licensed partners, and what the operator's own permissions must cover is determined by the offering regimes it runs, never by the register technology. Tokenization is therefore a property of the individual offering, which means a subordinated loan campaign and a tokenized bond can run on the same platform at the same time.

This article covers the issuance side only, and it is written for operators, whether they already hold an ECSP authorisation or are planning the application, who treat their platform as project financing infrastructure. The practical question behind it is how far one platform can stretch before a second system becomes necessary. It works through six topics in turn: the instrument rails a German platform can offer today, what tokenization adds per offering, how the ECSPR and eWpG licence layers fit together, whether one raise can run classic and tokenized tranches in parallel, what a tokenized tranche costs and how long it takes, and whether blockchain crowdfunding is a category of its own.

Which instruments can a crowdfunding platform offer today?

A crowdfunding platform operating in Germany can offer at least four instrument rails: national investment products, ECSPR loans, transferable securities (whether issued as classic certificated securities or in electronic form under the eWpG), and MiCA crypto-assets. Most single-instrument platforms are single-instrument because of when they were built and what their permission covered at the time. The menu has a hard edge all the same, because every rail must be covered by a matching permission, held by the operator or contributed by a licensed partner, so the instrument menu is bounded by the platform's permission perimeter. This means extending the menu is a permissions question first and a technology question second, and for an operator planning a second rail the legal work starts before the product roadmap does.

• National investment products under the VermAnlG - The first decade of German crowdinvesting was built almost entirely on the subordinated loan, offered as a national investment product under the VermAnlG regime, typically within the §2a exemption of up to €6M per issuer over 12 months. That exemption disapplies the sales prospectus requirement but not the investment product information sheet under §13 VermAnlG, and it applies only where distribution runs exclusively through an internet service platform that enforces the per-investor caps: €1,000 by default, €10,000 on a self-declaration of at least €100,000 in freely available assets, or twice the investor's average monthly net income up to €25,000. That rail still works, and for many retail communities it remains the most familiar product on the platform.

  It is, however, not an ECSPR instrument. The qualified subordination that defines the product, meaning insolvency ranking plus a pre-insolvency payment bar, makes repayment conditional, which on the prevailing German reading takes it outside ECSPR's definition of a loan in Art. 2(1)(b), where the project owner must assume an unconditional obligation to repay. Neither BaFin nor ESMA has confirmed this in writing; Austria's FMA has stated it expressly for its own market. A loan carrying only an insolvency ranking clause, without the pre-insolvency bar, is a different case and may well sit inside ECSPR. Intermediating national investment products therefore needs its own permission alongside the ECSP authorisation: a licence under §34f(1) sentence 1 no. 3 GewO, available only within the scope exemption in §2(6) sentence 1 no. 8 KWG and therefore only for first public offerings and only where the platform never takes possession of client money, or a securities institution licence under §15(1) WpIG, or cover under a liability umbrella under §3(2) WpIG or §2(10) KWG. The platform stays single, one funnel and one brand, while the permission set grows with each rail that needs one.

• ECSPR loans and crowdfunding securities - The EU Crowdfunding Regulation (ECSPR, Regulation (EU) 2020/1503) added a second rail, applicable since 10 November 2021. Art. 48 gave platforms migrating from national regimes until 10 November 2022, extended to 10 November 2023 by Commission Delegated Regulation (EU) 2022/1988, with no further extension available. More specifically, it created a single authorisation for crowdfunding service providers, usable across the EU, covering the facilitation of loans and the placing of transferable securities and admitted instruments for crowdfunding purposes, for offers up to €5M per project owner over 12 months, documented through a Key Investment Information Sheet (KIIS). That €5M is not the platform's number alone, because it also absorbs the project owner's other prospectus-exempt public offers of transferable securities in the same twelve months. For the operator this is the rail that reaches investors in other member states, and for the project owner it caps the raise at €5M, at a moment when a prospectus-free securities offer in Germany runs to €12M since 5 June 2026.

• Transferable securities, classic and electronic under the eWpG - Beyond the crowdfunding-specific regimes, the same operator can host classic securities, for example a corporate bond with an ISIN and bank custody, through standard bond issuance workflows. In addition, since 2021 German law recognises electronic securities: register-based instruments under the eWpG, including crypto securities recorded on distributed ledger technology. Together with the two crowdfunding rails, that gives the operator four options to match against an issuer's size, instrument preference and investor base.

• MiCA crypto-assets - Tokens that are not financial instruments sit on a separate rail entirely. The offering runs under MiCAR rather than the VermAnlG or ECSPR, and the crypto-asset services around it need a MiCAR authorisation held by the operator or contributed by a partner. It is a neighbouring discipline rather than an extension of the crowdfunding menu, and it is treated as such in the sections below. [VERIFY: confirm framing and permission wording with Lukas]

Running tokenized instruments on a crowdfunding platform used to mean commissioning a separate system. On modular infrastructure the rails sit side by side, and the operator chooses, offering by offering, which one a project uses. This means the permission homework for each rail is done once, when the rail is switched on, and the issuer who arrives nine months later inherits a rail that is already live.

What does tokenization add to a crowdfunding offering?

Tokenization changes the form of a security while leaving the rules of the offering untouched. The investor's position is recorded as an entry in an electronic securities register, and the offering regime, whether ECSPR with a KIIS or a prospectus offering, keeps its own logic. Therefore the disclosure work, the investor checks and the thresholds an operator already knows do not change when a securities tranche is tokenized. One caveat sits upstream of this: German national investment products such as profit participation rights and subordinated loans are not securities, and the eWpG does not reach them, so tokenizing one raises a classification question rather than a form change.

The legal basis is the eWpG, in force since 10 June 2021, which lets issuers replace the paper certificate with a register entry and recognises two register types: a central register operated by a central securities depository or by a custodian the issuer has expressly authorised, and a crypto-securities register kept on a tamper-proof record system, in practice distributed ledger technology, by a registrar whose activity requires a BaFin authorisation under the KWG. Bearer bonds were the first class within the eWpG's own scope; shares followed with the Future Financing Act in December 2023, registered shares in either register type and bearer shares in a central register only. A crypto security is a fully fledged security under German law, with the register entry constitutive for issuance and for every transfer and the registered holder presumed to be the owner, which means an investor's proof of holding is a current register position.

One premise underneath the ECSPR route deserves its own sentence, because the combination rests on it: an eWpG crypto security can be placed under ECSPR only where it qualifies as a transferable security under MiFID II. ECSPR's other routes are loans and admitted instruments for crowdfunding purposes, and Germany has notified none of the latter, so for a security there is no alternative door. A plain electronic bearer bond ordinarily qualifies. A transfer restriction rarely defeats that qualification, since negotiability fails only where transfer becomes impossible or extremely difficult, but a loss of fungibility does: bespoke terms or non-standardised denominations can stop the instrument forming a class of securities at all. For the operator this is a structuring checkpoint, because the instrument terms decide whether the offering can run under the ECSP authorisation at all. The mechanics of register types and instrument classes are covered in depth in our digital securities guide; for this article, the short version above is enough.

In practice, crowdfunding tokenization removes the physical artefacts from an issuance. No global certificate needs to be printed and deposited, and investors still hold verifiable proof of their position: the register entry, and its confirmation, replaces the paper certificate. Denominations can be small without an administrative penalty because the register scales digitally, subscription, allocation and register entry run as one workflow, and interest and redemption payments run against a clean, current register. For the issuer, the result is an offering that behaves like software; for the operator, it is a second product tier that reuses the same funnel.

However, none of that makes the tokenized rail the right rail for every raise. A crypto security brings a registrar contract, a custodian contract and securities-grade documentation into an offering that a national investment product can carry with a contractual claim and an investor ledger the platform keeps itself. The verdict is a division of labour: a subordinated loan still fits a small retail raise inside the §2a exemption, where familiarity and simplicity decide whether the campaign fills, while an eWpG crypto security fits raises whose investors need a real security with a register entry, small denominations or automated servicing. The table below sets the two rails side by side.

How do ECSPR and eWpG work together on one platform?

ECSPR and eWpG regulate different layers of the same offering. ECSPR governs who may operate the platform and how the offer is conducted, while the eWpG governs the form of the security being offered. Using ECSPR and eWpG together therefore stacks no tokenization-specific licence requirements on the operator. It distributes the regulated functions across three layers, which we call the three-layer licence stack. Each layer has a different owner, and knowing which owner holds what is how an operator prices and plans a tokenized offering.

Layer 1, the operator's permission set. For ECSPR offerings, the platform operator holds the ECSP authorisation, granted in Germany by BaFin and extended across the EU through the cross-border notification procedure of Art. 18 ECSPR. Commercially that behaves like a passport; legally it is a notification that extends the home authorisation, and the distinction matters in an application conversation. In practice the operator files its list of target member states with BaFin, which passes the notification to the host authorities and ESMA within 10 working days, and cross-border services may begin at the latest 15 calendar days after that filing. The authorisation covers ECSPR services, meaning onboarding investors, hosting offers and distributing the KIIS, and rails outside ECSPR bring their own permission, as the national investment products example above shows. Two things hold across every rail: the permissions in this layer belong to the operator, and none of them changes when an offering is tokenized.

Layer 2, the partner licences. The licensed functions specific to tokenized instruments sit with specialised partners. The crypto securities register is maintained by a BaFin-authorised registrar; the permission sits with that partner, not with ONINO. Custody of crypto securities is handled by a licensed crypto custodian, payment flows run through a licensed payment institution, and the operator contracts these functions. That contracting is still a real step, with partner onboarding, due diligence, and commercial terms negotiated per platform; pre-integration shortens the path without removing it.

Layer 3, the software. The technical stack that makes the layers work together covers the subscription funnel, investor management, register connectivity and servicing. This layer needs no financial-services licence, because the licence attaches to the activity. This is where ONINO sits: white-label financing infrastructure with the layer-2 partner roles pre-integrated, run by operators as white-label infrastructure under their own brand. Therefore the software decision moves speed and cost, and the two layers above it decide what an operator is allowed to sell.

"Within its scope, the ECSP Regulation takes precedence over the national rules of the German Banking Act (KWG) and the Securities Institutions Act (WpIG). The consequence is that for issuances of security tokens or crypto securities within the scope of the ECSP Regulation, the German tied-agent model cannot apply. Only where an issuance leads to a total volume of more than €5 million over a twelve-month period do the rules of the KWG or WpIG apply."

-Dr. Konrad Uhink, Co-founder and Attorney-at-law, FIN LAW (LinkedIn)

Can one raise run parallel tranches of classic and tokenized instruments?

Yes, and parallel tranches are the cleanest illustration of tokenization as an offering-level choice. A project owner can split one raise into two tranches: a subordinated loan tranche for the platform's existing retail community, and an eWpG crypto security tranche for investors who expect a real security with a register entry.

The commercial logic is segmentation. Retail investors who have subscribed to subordinated loans for years do not need to be migrated to a new instrument; they keep the product they know. Conversely, family offices, funds and digitally native investors, who often cannot or will not hold an unlisted contractual claim, get a bond recorded in a crypto-securities register. Ticket sizes, documentation expectations and internal investment rules differ between these groups, which means parallel tranches let one raise serve both without forcing a compromise instrument on either.

Operationally, a tokenized crowdfunding tranche changes three things for the operator: the instrument documentation, the registrar and custodian contracts behind it, and the register connectivity. Everything else, KYC records, payment flows and the subscription funnel, already exists at platform level and is shared across tranches. On the platform side, the asset tokenization rail is switched on only for the tranche that needs it, and the classic tranche runs exactly as before.

Where tranches sit in different offering regimes, each keeps its own disclosures, its own investor eligibility checks, and its own threshold arithmetic: the ECSPR ceiling is calculated under Art. 1(2)(c) ECSPR, which adds the project owner's crowdfunding offers to its prospectus-exempt public offers of transferable securities, while the national investment products exemption counts its own instruments under the VermAnlG, and a raise structured to slip under thresholds by splitting should expect the supervisor to look through it. Settlement and tax specifics stay in the offering documents, where they belong. Therefore parallel tranches are a structuring exercise for the issuer's advisers before they are a configuration exercise for the operator.

The volume behind this pattern is no longer theoretical. On infrastructure built by ONINO, issuers have tokenized €50M+ in instrument volume, and live platforms operate across 7+ jurisdictions (ONINO platform data, August 2026). Those are vendor-side numbers, so what they prove is that the rails carry real volume. The transferable lesson is that those operators bought modularity first, the option to add a rail when an issuer or an investor segment asks for one, without re-platforming.

What does a tokenized tranche cost, how long does it take, and can investors trade it?

Cost, time and tradability are the three questions operators actually ask in a demo, and the answer to each begins with "it depends". What follows is what each one depends on, with working ranges.

Cost. What a tokenized tranche adds depends first on the instrument. Where the tranche is an eWpG crypto security, it adds three cost blocks: registrar setup and running fees for the crypto-securities register, custody fees, and the structuring and documentation work for the instrument itself. Where the tranche is a national investment product such as a subordinated loan or participation right, there is no crypto-securities register and no registrar fee, and the cost sits in structuring and documentation alone. On pre-integrated infrastructure the cost drivers are partner fees and documentation. As a working range, budget a low five-figure amount to set the rail up once, plus running fees that scale with volume; instrument complexity and issuance size are the main variables. A low five-figure setup means the tokenized rail prices itself out of very small raises and amortises quickly on larger ones, which is why issuance size is the first question in a structuring call.

Time. The first tokenized offering is gated by partner contracting: registrar and custodian onboarding, due diligence, and commercial terms. Where those partners are pre-integrated, plan in weeks; sourcing and integrating them from scratch is a project measured in months. Once the rail is live, each further tokenized offering is configuration, measured in days. The distance between weeks and months sits entirely in the partner layer, which means an operator who switches the rail on before a deal arrives turns that gap into days for the issuer waiting on it.

Secondary trading. A register entry makes an instrument cleanly and verifiably transferable; it does not create a market. Transfers of eWpG crypto securities work, and it is the register entry itself that transfers ownership: the registrar re-books the instrument to the acquirer, and until that happens the seller remains the legal owner. What stops there being a market is not the rail but the rules and the demand. Under ECSPR a crowdfunding platform may run a bulletin board where investors advertise buying or selling interest, but it must not match those interests into a contract without separate MiFID authorisation as an investment firm or regulated market, and it must tell investors it does not operate a trading venue. Liquid trading therefore needs a venue, and venues remain scarce: as of ESMA's June 2025 review, three DLT market infrastructures had been authorised under the EU DLT Pilot Regime, with trading activity described as low.

Lukas Wipf - Co-founder & CPO at ONINO
Most operators ask about tokenization for liquidity reasons first, and I think that is the wrong first reason. The wins you can bank in year one are operational: a register that is always current, denominations without an administrative penalty, servicing that runs itself. Liquidity arrives when venue access and investor demand exist, and not before. What venues exist and what liquidity realistically requires is the subject of our guide to secondary markets in tokenization.

Is blockchain crowdfunding a separate category?

No. Blockchain crowdfunding is the same regulated raise with a different register technology behind it. The investor still subscribes to a defined instrument from a defined issuer under a defined offering document, and the blockchain sits in the register layer, invisible to most investors. This means the questions a supervisor asks about the offering do not change with the register technology, and neither do the answers an operator has to be able to give.

The distinction matters because the vocabulary is crowded. Searches for a crypto crowdfunding platform usually mean something else entirely: launching a payment or utility token to a global crypto audience, which is a MiCAR matter and a different discipline. An ECSPR offering with an eWpG security is regulated financing, and the token describes how the register works.

Since MiCAR is in the room, one exclusion is worth stating explicitly: custody of eWpG crypto securities is safe custody business, a licensed KWG service, and sits outside MiCAR, because crypto securities are financial instruments and MiCAR excludes them. A MiCAR-authorised crypto-asset service provider cannot custody the bond on that authorisation alone. For an operator choosing partners, this means the custody question has to be answered against the KWG permission, and a MiCAR authorisation in a partner's deck does not answer it.

Ultimately tokenized crowdfunding is a capability question. A crowdfunding platform does not have to be a single-instrument machine, and on the right infrastructure, extending it is a matter of configuration, partner contracts, and the permission homework for the rails involved. Of the three layers, the operator's permission set deserves the closest attention, because it is the only one that cannot be contracted in: the registrar, the custodian and the payment institution all arrive by contract, while the ECSP authorisation and any national permission for a second rail stay with the operator on every route.

Alexandre Lehr - Founder & CEO at ONINO
My advice after working with operators across 7+ jurisdictions: treat your instrument menu as a strategy decision rather than a technical afterthought, and secure the option on your second rail before an issuer asks for it. Retrofitting under deal pressure is where platforms lose quarters. Operators should therefore put the second rail in front of their compliance counsel now, before a deal arrives.

If you operate a crowdfunding platform, or plan to apply for an ECSP authorisation and want your instrument menu open from day one, book an ECSPR platform demo and see how instrument rails are configured per offering.