A private equity allocation has always been the same trade: capital committed for years, a general partner who decides when it comes back, and little way to sell out early without a discount. Tokenisation is marketed as the fix. Read the product documents rather than the press release and what it changes is narrower than the pitch, and where liquidity is real it is often not the kind an investor expects.
What the investor actually buys
None of the products examined here gives the holder a direct limited partnership interest in the manager's fund. The token represents an interest in a feeder vehicle, which in turn invests in the underlying fund. Securitize's tokenised exposure to KKR's Health Care Strategic Growth Fund II, launched on Avalanche in September 2022, works this way: Securitize's chief executive described it as a feeder fund of the main KKR healthcare fund, managed by Securitize Capital rather than issued by KKR itself (Finance Magnates, 14 September 2022). Hamilton Lane followed the same route. After tokenising access to its Equity Opportunities Fund V (announced January 2023) and its Senior Credit Opportunities Fund (announced May 2023) with Securitize, it opened its $5.6 billion Secondary Fund VI through a tokenised feeder on Polygon in August 2024, with a $20,000 minimum against what the firms called a typical $5 million institutional minimum (Hamilton Lane and Securitize, 15 August 2024). The economic exposure passes through; the legal claim runs against the feeder and its manager, not directly against the underlying general partner. That distinction matters most in a dispute or a wind-down, when which entity owes the investor money is the whole question.
Apollo's product adds a further layer of difference. The Apollo Diversified Credit Securitize Fund, ACRED, launched on 30 January 2025 across Aptos, Avalanche, Ethereum, Ink, Polygon and Solana. It is a feeder that invests substantially all its assets in Apollo Diversified Credit Fund, which is itself a non-traded, closed-end interval fund. ACRED is open only to qualifying investors, is sold exclusively through Securitize Markets, and offers native redemptions at a daily net asset value (Apollo and Securitize, 30 January 2025). It is a private credit product rather than private equity, and private credit onchain covers how a feeder token inherits the redemption terms of the vehicle underneath it.
Eligibility and transfer restrictions have not moved
Tokenisation does not relax who may hold the interest. A private feeder offered under Rule 506(c) of Regulation D may sell only to accredited investors and must take reasonable steps to verify their status. On 12 March 2025 the SEC's Division of Corporation Finance agreed, in a staff no-action letter to Latham & Watkins, that a minimum investment of at least $200,000 for a natural person or $1 million for an entity, together with written representations of accredited status and of no third-party financing, can satisfy that duty (SEC Division of Corporation Finance, 12 March 2025). The tickets tokenised feeders advertise, $20,000 at Hamilton Lane and $100,000 at the KKR feeder, sit well below those thresholds, so the letter's shortcut does not reach them and verification has to be done the ordinary way. Where the underlying fund relies on the Investment Company Act's Section 3(c)(7) exclusion, investors must also be qualified purchasers, a materially higher bar: a natural person generally needs $5 million in investments. Tokenisation lowers the ticket size within the eligible pool. It does not enlarge the pool.
Transfer restrictions follow the same logic onchain as off it. The token contract enforces a permissioned list tied to the same KYC checks a paper subscription would impose, so a token cannot move to a wallet that has not been cleared. This is the eligibility control described in institutional RWA tokenisation, from pilot to production; in a private fund feeder the list also stands in for the conditions of a securities exemption, not only an operational preference.
The secondary trading that actually exists
The evidence here is thinner than the marketing, though it is not zero. At the KKR feeder's launch, holders were told they could trade on a secondary market run by Securitize after a one-year lock-up, with a $100,000 minimum ticket (PitchBook, via Yahoo Finance, 13 September 2022). That venue is Securitize Markets, which already operated an SEC-regulated alternative trading system when, in May 2026, it announced expanded FINRA approvals covering custody of tokenised securities, clearing and settlement, and atomic settlement against stablecoins; the report describes it as the first time a standard broker-dealer had been authorised to hold custody of tokenised securities (Crowdfund Insider, 6 May 2026). A venue is not a market. None of the sources reviewed for this piece gives trading volumes for these feeder tokens, and any trade still needs an eligible, whitelisted buyer on the other side.
The clearest evidence of money actually returned comes from an older, smaller product. SPiCE VC, which describes itself as the first fully tokenised venture capital fund, announced in June 2025 a third investor payout scheduled for the end of that month, taking total payouts past 2.1 times distributions to paid-in capital (Business Wire, 24 June 2025). That is liquidity through distributions as portfolio companies exit, the mechanism a conventional LP interest already offers; the announcement says nothing about secondary trading of the token.
A third form has appeared on the credit side. On 30 April 2025 Securitize and Gauntlet launched a strategy in which ACRED holders mint sACRED and deposit it in a vault on Compound Blue, a lending protocol powered by Morpho, where the tokens are used as collateral to borrow USDC that buys more ACRED, repeated to lever the yield (CoinDesk, 30 April 2025). That is borrowing against the position, not selling it, and it brings the liquidation mechanics of DeFi lending into a private credit fund interest. Resale on a licensed venue, distributions on exit, and borrowing against the token are three different things; it is worth asking which one is on offer before treating "liquidity" as a single claim.
Manager risk and platform risk sit in different places
The general partner's investment decisions and valuation judgement are unchanged by tokenisation, and that risk is the one an LP has always accepted. What is added is platform risk. In these products one platform issues the feeder token, keeps the register and runs the trading venue, so a single firm becomes a point of operational concentration across several managers' products. Digital-asset fund structures sets out why custody and control arrangements determine what happens if an intermediary fails; the same question applies to whoever issues and administers the token. A token gives an investor a clean claim on the feeder only if the platform's books are the record a court will recognise, and no source reviewed here shows that tested in a contested wind-down.
Valuation and NAV frequency
ACRED's daily NAV is a genuine departure from the quarterly valuation cycle conventional in private equity, and it comes from the interval fund structure underneath it rather than from the token. None of the sources reviewed describes daily pricing for the KKR or Hamilton Lane private equity feeders, and a token that trades continuously does not make the underlying valuation any more frequent. "Tokenised" by itself tells an allocator nothing about how often the number on the screen has actually been re-marked.
Securities law status, jurisdiction by jurisdiction
United States
Tokenised private fund feeders are sold under existing private placement exemptions and Investment Company Act exclusions, so no new rulemaking was needed for them. Separately, on 17 September 2026 the SEC issued an order granting temporary, conditional exemptive relief that lets Tokenized Securities Venues trade tokenised NMS stock through permissioned automated market makers and liquidity pools without being treated as exchanges; the relief is set to expire five years after publication, and the Commission asked for comment on possible changes (SEC, 17 September 2026). Chairman Paul Atkins called it an interim measure that "must be followed by durable rulemaking" (SEC, statement of 17 September 2026). The order covers tokenised NMS stock, meaning listed equities; it does not reach private fund interests.
Switzerland
The DLT Act has been in force since 1 August 2021, allowing securities to be issued on a blockchain and creating a licence for trading venues for them (State Secretariat for International Finance). That is settled law. FINMA granted the first DLT trading facility licence, to BX Digital, on 18 March 2025; its offer is aimed at supervised participants, usually banks (FINMA, 18 March 2025). Separately, the Federal Council opened a consultation on amending the Financial Institutions Act, covering stablecoins and other innovative financial technologies, on 22 October 2025; it closed on 6 February 2026. That is a proposal, not law.
Luxembourg
Luxembourg has built its framework in stages, with blockchain laws in March 2019, January 2021 and March 2023. Blockchain Law IV, adopted by Parliament on 19 December 2024, introduced a "control agent" that keeps the issuance account and reconciles issued securities against those held in securities accounts, a role open to settlement organisations, EU credit institutions and investment firms, and extended the regime to unlisted equity securities, which is what allows fund units to be issued and held as tokens (LPEA, on Blockchain Law IV). It changes what a fund's register can look like; it does not change who may invest, which remains a matter for the fund's own product rules.
What is genuinely unresolved
No public, contested wind-down or general partner default involving an institutional tokenised private equity feeder could be found for this piece, so whose claim survives such an event remains untested rather than answered. The Federal Reserve Bank of New York wrote in September 2025 that "it is too early to tell what impact, if any, tokenized shares will have on the financial system," and noted that because private funds are exempt from much of the regime that governs money market funds, regulators and the public have little visibility into whether they use comparable liquidity risk tools (Liberty Street Economics, 24 September 2025). The levered ACRED strategy adds a newer question: what happens to a fund token pledged as DeFi collateral when credit markets and crypto collateral markets fall together.
How institutions reach tokenised assets in practice was the subject of "How Institutions Actually Access Tokenised Assets" on the Taostats Stage at Proof of Talk's Paris 2026 edition at the Louvre Palace, on 3 June. Xavier Gomez moderated; the panellists were Fabian Dori, Julian Sawyer, Matthew Felice Pace and Moritz Platt.
This is not tax, legal, accounting or investment advice, and a jurisdiction survey like this one dates quickly.