Iran’s online gold market, with approximately 12 million users, has been left in limbo between the Central Bank of Iran (CBI) and the Deregulation Board. The executive directive on online buying and selling of gold and silver was issued in Aban 1404 (October–November 2025), and the CBI was required to launch a supervisory system within three months. Nevertheless, legal doubts over final supervisory authority and the CBI’s unresolved regulations have kept the market in ambiguity. The experience of leading countries shows that, without a transparent regulatory framework, this market cannot achieve healthy growth.
China: A Centralized Licensing Model. In 2018, the People’s Bank of China (PBOC) issued three regulations simultaneously, setting out a stringent framework for the online gold market. Under the Interim Measures for the Administration of Internet Gold Business of Financial Institutions, gold products may only be offered by financial institutions and gold exchanges approved by the State Council, and internet institutions have no right to provide any form of gold account services. Gold accumulation services are also restricted exclusively to financial institutions with deposit-taking licenses. This model ensures regulatory concentration in the central bank and official exchanges and prevents overlapping and gaps in supervision.
Turkey: Exchange Integration with Innovative Classification. In July 2026, Turkey’s Ministry of Treasury and Finance adopted new regulations under which digital assets backed by physical gold and silver may be traded on Borsa Istanbul, subject to ministry approval and physical custody in the mint or the exchange. The key feature of this regulation is its definition of “digital precious metals” as a separate category that is neither a security nor a crypto-asset. This innovative solution avoids the classification uncertainty that is the main obstacle to regulation in many countries.
United Kingdom: Investor Protection through Leverage Limits. The FCA approach focuses on risk disclosure requirements and strict leverage limits. Under COBS 22.5, platforms must display standardized risk warnings stating the percentage of loss-making traders, and the leverage cap for retail clients is set at 20:1 (5% margin). In addition, if a retail client’s net asset value falls below 50% of the required margin, the firm must close open positions. This model prioritizes investor protection over trading freedom.
Singapore: A Technology-Neutral Model. The MAS has adopted a “technology-neutral and substance-based” approach: tokenized products that are in substance capital market instruments are subject to the same licensing and securities offering requirements under the Securities and Futures Act 2001. This approach treats tokenization not as a new technology but as a new form of existing assets, preventing parallel regimes and regulatory arbitrage.
Key Lessons for Iran. First, the multiplicity of regulatory bodies is the main obstacle. In Iran, more than 20 bodies are named in the gold sector, whereas advanced markets have only two main regulators. China’s experience shows that concentrating authority in the central bank and approved exchanges prevents overlapping and gaps in supervision. Second, the physical backing requirement must be established first and foremost. The Governor of the CBI has explicitly stated that platforms “must not perform gold-backed deposit-taking functions” and “must possess the gold they sell rather than sell first and buy later.” This requirement aligns with the approaches of China and Turkey and must be continuously monitored in the CBI’s supervisory system. Third, uncertainty over asset classification is a serious obstacle. Turkey’s innovative solution can serve as a model for Iran: defining a “digital asset backed by physical gold” as an independent category that is neither a security nor a crypto-asset reduces legal complexity and enables effective supervision. Fourth, leverage limits and investor protection must be prioritized. With 12 million users and significant turnover, adopting the FCA approach to leverage limits and risk disclosure can prevent potential crises.
Global experience shows that no country’s online gold market has achieved healthy growth without a clear and stable regulatory framework. Iran now stands at a critical juncture: the executive directive has been issued, the supervisory system is being designed, but the final supervisory authority remains contested. Establishing the CBI’s authority as the main supervisor of infrastructure (custody, settlement, AML) while delegating market conduct and investor protection supervision to the Securities and Exchange Organization could be a practical solution. Without this transparent framework, the online gold market will continue to wander among multiple institutions, and the cost of this uncertainty will be borne by investors—and ultimately by public trust in the gold market.
