RWA LEGAL
INDEX
Report · Q3 2026

RWA Tokenization Cost Report — Q3 2026

The first edition. What the public pricing record for tokenizing real-world assets actually contains as of September 2026 — how much of it is vendor-authored, how far it contradicts itself, and where it is simply absent.

Last verified 3 September 2026 · 19 sources

This is a report about a market's information, not about the market. We collected every public cost figure we could find for tokenizing real-world assets, recorded each with its source, currency, cadence and date, and looked at what the record adds up to. The short version: it is smaller, more conflicted and more vendor-authored than the confident numbers in circulation suggest.

130
Published figures
100/130
From vendors pricing themselves
19
Providers
10000×
Widest single-component spread

Finding 1 — the record is overwhelmingly self-interested

100 of 130 figures come from a source selling the service it is pricing. That is not an accusation; vendors are often the only party with any incentive to publish. But it means the public price of tokenization is, in aggregate, a marketing artefact that has been quoted secondhand until it hardened into something people repeat as fact.

The institutional reports that exist — from the IMF, EY and others — measure the savings tokenization is expected to deliver, not what an issuer spends to get there. We found no issuer publishing a completed project's actual costs. That absence is the single biggest gap in this market's evidence base.

Finding 2 — components contradict themselves, not each other

Spread is the highest published figure divided by the lowest, within one component and one currency.

ComponentRange (largest currency group)SpreadRowsVendor-authored
platform fee $300–$3,000,000 10000× 17 11/17
smart contract dev $1,248–$300,000 240× 12 10/12
marketing $5,000–$1,000,000 200× 2 2/2
legal structuring $5,000–$800,000 160× 22 17/22
audit $2,000–$150,000 75× 9 7/9
ongoing compliance $3,000–$200,000 67× 15 12/15
kyc per investor $2–$100 50× 3 1/3
spv govt fee $110–$4,000 36× 2 2/2
spv legal setup $5,000–$75,000 15× 8 6/8
TOTAL $50,000–$720,000 14× 13 10/13

These are not competitive ranges. They are the same word covering different work: a classification memo and a full prospectus both filed as "legal structuring"; a USD 110 state filing fee and USD 25,000 of legal work both called "SPV formation"; a self-serve mint price and a bespoke build both called "smart contract development". The full mechanism is in why costs disagree by 10,000×.

Finding 3 — the sharpest contradictions

Dubai VARA, year one — an order of magnitude apart
An official fee schedule gives AED 40,000–100,000 on application. One advisory source gives USD 100,000–330,000 all-in. A third gives AED 2.1 million. The last most plausibly folds paid-up capital into "cost" without saying so — capital you must hold is not money you spend.
MiCA CASP authorisation, year one — 4× apart, both defensible
EUR 92,000–110,000 from one adviser against EUR 415,000–690,000 from another. The first counts documents and staffing; the second adds a full compliance-officer stack, ICT obligations and external audit. Neither is wrong. They are pricing different scopes of the same authorisation.
A single vendor against itself, same quarter
One provider publishes a cost index putting a USD 10M tokenised private fund at USD 25,000–90,000, and a playbook putting a USD 5–50M deal at "low-to-mid six figures inclusive of legal". Neither document flags the other.

Finding 4 — where the record is simply empty

Absence is a finding, and we publish it rather than filling it:

What changed this quarter

This is the first edition, so there is no prior period to compare. From Q4 2026 this section will record what moved: figures added, figures corrected, sources that went dead, and regimes whose published cost picture changed. Corrections are logged as they arrive on the changelog.

Method, in brief

A figure is recorded only if it appears in a public source with an attributable URL. Every row keeps its verbatim quote, currency, cadence and source date, and is tagged for whether the source sells what it prices. Figures are never averaged across sources, and ranges never mix currencies — averaging incompatible scopes produces a number that describes nothing. Where sources disagree we publish the disagreement rather than resolving it. Full rules, exclusions and our own commercial relationships are on the methodology page.

Use the data

The underlying dataset is downloadable and citable: CSV and JSON, version 2026-07-22, every row carrying its own source URL and date. If you cite a figure, carry its source and date with it — a number from this report without those is not a fact.

If you hold a published figure we missed, or one of ours is wrong or out of scope, tell us. Corrections are not conditional on any commercial relationship, and they are logged with their date.