Token Regulation Paper

Token Regulation Paper

The Blockchain Bundesverband publishes its position paper on token regulation. After the publication of our first general position paper on blockchain we continue to work hard to address the most pressing issues of the blockchain ecosystem.


The purpose of this Token regulation paper is to analyse the status quo of the current regulation of Token sale related matters under EU law. Where we deem it sensible as to picture national specifics and/or problems that arise from applying (EU law based) German law we will also give an overview on the same.


The assessment is divided into six parts, the first of which is this introduction. In part two, we will assess if and when Tokens may be regarded as securities because the findings relating hereto to some extent set the course for the assessment in the following sections. The following parts will to some extent follow the “lifecycle” of a Token: Part three will review the regulation dealing with the issue of Tokens, specifically focussing on information obligations of the issuer as well as obligations resulting from anti-money-laundering regulation. Part four shall analyse the existing regulation regarding the trade of Tokens on secondary markets. Part five will review which approval requirements exist with respect to certain business models relating to Tokens. Where we deem necessary, each section will contain specific proposals for a Token focussed regulation. Part six will provide an overview of our findings as well as our recommendations. Kindly note that this paper may not be regarded as legal advice.


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The association would like to thank all the authors, consultants, fellow thinkers and helpers who have put countless hours in the preparation of this paper.


Joachim Lohkamp

Treasurer at Blockchain Bundesverband. Founder and CEO of Jolocom

Gründung der Landesgruppe Hessen des Blockchain Bundesverbands


Meetup on Token Regulation in the EU, Berlin

re:publica18 at Station Berlin

Token Investment Summit, Wien


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