What Does Tokenisation Cost? Cost Blocks at a Glance

Short answer

The costs of tokenisation consist of one-off costs (structuring, legal advice and documentation, BaFin fee, technical set-up) and ongoing costs (register management, custody, platform, payment processing, reporting), plus the issuer's distribution costs. The BaFin fee is set in the FinDAGebV: EUR 5,923 for permitting a securities information sheet and EUR 16,915 for approving a prospectus drawn up as a single document (fee schedule, items 3.2 and 3.1). heartstocks charges the issuer a one-off structuring fee of 1% on the issuance volume and ongoing costs of 0.35% p.a. on the outstanding volume throughout the term. Investors bear a one-off transaction fee of 1% per subscription, which does not burden the issuer.

At a glance

BaFin fee for a WIB: EUR 5,923; administration of an updated WIB: EUR 354 (FinDAGebV, items 3.2 and 3.5).
BaFin fee for a prospectus as a single document: EUR 16,915; tripartite prospectus: EUR 5,577 (registration document) plus EUR 5,851 (securities note and summary); supplement: EUR 230 (FinDAGebV, items 3.1, 3.3, 3.4, 3.7).
Fees are charged per WIB or prospectus; a WIB may relate to one specific security only (section 4(7) sentence 4 WpPG).
heartstocks charges the issuer a one-off structuring fee of 1% on the issuance volume and ongoing costs of 0.35% p.a. on the outstanding volume throughout the term. Investors bear a one-off transaction fee of 1% per subscription, which does not burden the issuer.

Which cost blocks make up a digital issuance?

A digital issuance incurs costs in three phases: before the offer (structuring, documentation, filing), during the subscription period (platform, identification, payment processing, distribution) and over the term (register management, custody, interest and redemption processing, reporting). Only the BaFin fees are fixed by binding rules (FinDAGebV); all other items depend on the provider, the security and the volume.

Cost block	Incurred	What drives the amount
Structuring	one-off	type of security, direct issuance or SPV, complexity of terms
Legal advice and documentation	one-off, again for amendments	bond terms or terms of issue, WIB or prospectus, agreements
BaFin fee	one-off per document	WIB or prospectus, number of securities, updates and supplements
Register management	one-off and ongoing	number of investors and transfers, term
Custody	ongoing	number of investors, term
Platform and KYC	one-off and per investor	white label or standard, number of identifications
Paying agent or payment processing	ongoing	number of interest and redemption dates
Administration and reporting	ongoing	scope of reporting, update obligations
Distribution	one-off and ongoing	channels, marketing, intermediaries

How high are BaFin fees for a WIB and a prospectus?

BaFin's fees are set out in the Financial Services Supervision Fees Ordinance (FinDAGebV), fee schedule section 3 for services under the WpPG and the Prospectus Regulation. The amounts apply in euros per prospectus or per WIB for one security. If several prospectuses or WIBs are combined in one document, the fee is charged for each individual one.

BaFin service	Fee	FinDAGebV item
Permission to publish a WIB (section 4(1) and (2) WpPG)	EUR 5,923	3.2
Administration of a filed updated WIB (section 4(8) WpPG)	EUR 354	3.5
Approval of a prospectus or base prospectus as a single document (single-document prospectus)	EUR 16,915	3.1
Approval of a tripartite prospectus: registration document and securities note with summary	EUR 5,577 + EUR 5,851	3.3 and 3.4
Approval of a supplement (Art. 23 Prospectus Regulation)	EUR 230	3.7

Which fee applies depends on the prospectus requirement. Since 5 June 2026, public offers below EUR 12m per issuer or offeror over 12 months are prospectus-free, provided they are not subject to notification under Art. 25 Prospectus Regulation (Art. 3(2) Prospectus Regulation). In Germany, such offers generally require a WIB from EUR 100,000 (section 4(1) WpPG; exemptions in section 4(1) sentence 2 WpPG). Offers only to qualified investors or with a minimum denomination of EUR 100,000 need neither a prospectus nor a WIB (Art. 1(4) Prospectus Regulation) and therefore incur no BaFin fee in this respect.

Which ongoing costs arise over the term?

The ongoing costs of a digital issuance arise mainly from the infrastructure needed for crypto securities. A crypto securities register must be kept on a tamper-proof recording system (section 16(1) eWpG), and register management is a financial service that generally requires a licence (section 32(1) in conjunction with section 1(1a) sentence 2 no. 8 KWG). Safeguarding private cryptographic keys for investors is also licensable as qualified crypto custody business (section 32(1) in conjunction with section 1(1a) sentence 2 no. 6(b) KWG). Both services are required over the entire term.

In addition, there is the processing of interest and redemption payments, reporting to investors and maintenance of the subscription documents. If, after permission and before the offer closes, a significant new factor arises or a material inaccuracy is identified, the WIB must be updated without undue delay and submitted to BaFin (section 4(8) WpPG); each update incurs an administration fee of EUR 354. For issuers not required to publish their accounts, the annual accounts must be attached to the WIB (section 4(6) WpPG).

Which fees does heartstocks charge?

heartstocks charges the issuer a one-off structuring fee of 1% on the issuance volume and ongoing costs of 0.35% p.a. on the outstanding volume throughout the term. Investors bear a one-off transaction fee of 1% per subscription, which does not burden the issuer. The following example refers to an issuance volume of EUR 5m.

The example only applies the rates published on the website and assumes that the volume is fully outstanding. It is not a calculation for a specific issuance.

Item	Calculation	Amount
Structuring fee (one-off)	1% × EUR 5,000,000	EUR 50,000
Ongoing costs per year	0.35% × EUR 5,000,000	EUR 17,500

heartstocks GmbH, based in Hamburg, has been active in the market since 2021 and, according to its own figures (as of 2026), has supported more than 15 tokenisation projects and structured more than EUR 200m in volume. When several tranches are bundled, for example a bond and a preference share, cost advantages can arise because structuring and documentation are set up jointly; regulatory fees are charged separately for each WIB or prospectus.

More at heartstocks: Fees and security types for asset managers FAQ on costs and process

How do costs differ from a traditional issuance?

A traditional bond is issued via a certificate, often a global certificate held by a central securities depository, and placed through banks. The BaFin fees for a WIB or prospectus are the same for traditional and digital issuances, because the FinDAGebV does not distinguish by form of issuance. Differences arise in the infrastructure: the digital bond replaces the certificate with an entry in the register (section 2(1) eWpG) and bundles subscription, identification, payment and investor administration on one platform. The traditional issuance, by contrast, works with custodian banks, a paying agent bank and, where applicable, a bank syndicate.

Which option is cheaper in an individual case depends mainly on volume, number and type of investors and the distribution channel. Room for savings arises in infrastructure and administration when subscription, identification, payment, register and reporting run on one platform. Reliable comparisons require a specific quote for both options for the same issuance.

How can tokenisation costs be reduced?

Bundle tranches: When several tranches are bundled, for example a bond and a preference share, cost advantages can arise because structuring and documentation are set up jointly; regulatory fees are charged separately for each WIB or prospectus.
Prepare documents completely: missing information extends the review because BaFin's deadline only runs from complete receipt (section 4(2) WpPG).
Choose volume and target group deliberately: below EUR 12m per issuer or offeror over 12 months no prospectus is required, but from EUR 100,000 a WIB generally is; for offers only to qualified investors, neither is required.
Avoid updates: accurate information from the start reduces WIB updates and supplements.
No in-house IT: heartstocks provides the technical and regulatory infrastructure as a managed service, with no blockchain node and no smart-contract development on the client side.
White-label platform: at heartstocks, white-label pricing scales non-linearly with volume.

This article provides general information and does not replace legal or investment advice. For investors: digital securities carry issuer risk up to total loss and may have limited tradability.

More at heartstocks: heartstocks white-label platform

Frequently asked questions

How high is the BaFin fee for a securities information sheet?

Permission to publish a WIB costs EUR 5,923 (FinDAGebV fee schedule item 3.2). Each filed updated WIB costs an additional EUR 354 (item 3.5). The fee is charged per security.

What does approval of a securities prospectus cost?

For approval of a prospectus or base prospectus drawn up as a single document, BaFin charges EUR 16,915 (FinDAGebV item 3.1). For a tripartite prospectus, the fees are EUR 5,577 for the registration document and EUR 5,851 for the securities note and summary (items 3.3 and 3.4); a supplement costs EUR 230 (item 3.7). Since 5 June 2026, a prospectus is required for public offers only from EUR 12m per issuer or offeror over 12 months.

Which fees does heartstocks charge for an issuance volume of EUR 5m?

The one-off structuring fee of 1% amounts to EUR 50,000. The ongoing costs of 0.35% p.a. on the outstanding volume amount to EUR 17,500 per year if the volume is fully outstanding. Investors bear a one-off transaction fee of 1% per subscription, which does not burden the issuer.

Is a digital issuance cheaper than a traditional one?

Not as a general rule, because the BaFin fees are the same. Room for savings arises in infrastructure and administration: subscription, identification, payment, register and reporting run on one platform. At heartstocks, reporting, investor communication and document delivery are automated, and the transaction fee is borne by the investor, not the issuer. For a reliable comparison, you need specific quotes for the same issuance.