Why it flips: blocked URLs, ₹200/day penalties from Apr 2026 and CARF reporting from 2027 all push this flow toward compliant venues. A new, well-run exchange is in a good position to take it.
0.05% (Delta taker) to 0.25% blended take across spot and derivatives
Venue share
10% of flow, before internalisation spread and float income
Spot fees in India run up to 0.5%, so the upper end may be conservative. IMARC's sizing is $3.0bn (2025) growing to $14.2bn (2034).
Our estimate. Volumes: TIOL-TKF Nov 2025, Esya. Take rates: Delta fee schedule; the 0.25% upper bound is our blended assumption. Treat this as directional, not a forecast.
Chapter 04
CoinDCX rented its liquidity. Delta built its own book.
Both work. The difference is who owns the order book, and the margin and risk that come with it.
The bridgeThe own book
Model A · the CoinDCX-style bridge
Live in 9–12 months Est.
You own the user. Someone offshore owns the order book.
UserYour appINR in, KYC at sign-up
You · front endOrder routerFIU-registered, collects TDS
PartnerOffshore exchangeIts book and its depth (OKEx at CoinDCX's 2020 launch)
Why start here
Fastest launch and deep global liquidity on day one, with no market-making risk on your balance sheet.
What it costs you
You share fees with the partner and its rules bind you. Counterparty risk is real: in Jul 2025, $44M was taken from CoinDCX's liquidity wallet on a partner exchange.
You run the matching engine. Market makers bring the depth.
TradersBuyers & sellersINR-settled futures and options
You · exchangeOwn order bookYour own matching engine, risk engine and fee schedule
LiquidityMarket makersQuote both sides and hedge on global venues
~$2.5B / day
Delta Exchange India volume co. claim
0.02 / 0.05%
maker / taker fees, all of it kept
Options
full product control: options, new contracts, your own listings
Sources: Analytics Insight interview with Delta's CEO, Jun 2025 · Delta India fee schedule · Delta T&C §4.13 (may act as counterparty)
Side by side
The bridge buys you time. The book is where the margin is.
Dimension
A · Bridge (CoinDCX-style)
B · Own book (Delta-style)
Time to market
9–12 months
24–36 months
Revenue per trade
Fee share or rebate (e.g. Bybit Broker up to 45%)
100% of fees, plus spread
Liquidity
Borrowed and deep from day one
Owned; depends on MM contracts
Key risk
Partner custody and offshore de-risking
Thin books, MM withdrawal, tech ops
Product control
Whatever the partner lists
Your own contracts: INR perps, options, NIFTY-style
Build cost
Low: white-label and API
High: engine, risk, surveillance
Sources: Bybit Broker programme · vendor research (AlphaPoint, B2Broker) · time and cost are our estimates
Our recommendation
Don't choose between the two models. Run them in sequence.
Step 1 · year 1
Launch on a bridge
Plug into partner liquidity and go live fast. Learn what your users actually trade.
Step 2 · years 2–3
Build your own book
Your own matching engine, with contracted market makers quoting INR pairs.
Step 3 · by year 3
Internalise the flow
Match opposing user orders in-house before routing out. You keep the spread, pay fewer partner fees and get better fills.
Step 3 is where I can help most: internalisation and fast-track onboarding.
Internalisation Illustrative
Every trade you match in-house is a fee you keep.
When one user buys while another sells, there's no reason to send both orders offshore and pay a fee on each. You net them internally and route out only the residual.
01
Lower cost per trade: no partner fee on the matched portion
02
Better fills: matching at mid, with no external spread
03
Order-flow data that tells you which markets to build next
What happens to 100 user ordersillustrative
~60 netted between users~40 routed out
Orders that pay a partner fee
Bridge only100
With internalisation~40
Illustrative. The ~60% match rate is an assumption for explanation only, not a measured figure.
Fast-track onboarding
Sign-up to first trade in minutes, not days.
Digital KYC in one flow
PAN, Aadhaar and bank checks over API, plus the crypto-specific consent and risk disclosure.
Fund in a tap
INR on-ramp and stablecoin deposits from day one, with fast, clear withdrawals.
Tax handled for the user
Every trade logs TDS automatically, and the tax report downloads in one click.
Note: Serving Indian users needs FIU-IND registration and PMLA-compliant KYC. Vendor choice needs legal review.
Real-world assets on-chain
$39.54B of real assets are already on-chain.
Treasuries lead, and tokenised stocks are the fastest-growing slice. This is where a new venue can list products incumbents don't.
$16T
BCG, tokenised illiquid assets by 2030
$4–5T
Citi, tokenised securities by 2030
Distributed RWA value$B · Oct 2026
US Treasuries14.54
Private credit8.41
Commodities5.22
Stocks3.77
Funds0.94
Tokenised stocks by issuer$B
bStocks1.40
Ondo0.93
xStocks0.63
Securitize0.29
Robinhood0.15
Sources: rwa.xyz (accessed 30 Oct 2026) · BCG × ADDX 2022 · Citi GPS 2023
Nine types of tokens
"Tokenisation" covers nine different products. Each has different rules.
Native crypto
BTC, ETH. A bearer asset with no issuer.
Stablecoins
USDT, USDC. Fiat-backed, $288B in supply.
Perpetual futures
Synthetic exposure with no expiry. Most of all crypto volume.
Tokenised treasuries
BUIDL, OUSG. Yield-bearing T-bill claims.
Tokenised equities
Backed 1:1 by shares (xStocks) or synthetic (NIFTY perps).
Commodities
PAXG, XAUT. Vault-backed gold.
Private credit & funds
Loan pools and fund units, for accredited investors only.
Money already crossing borders: the natural INR/USDT on-ramp audience
India150.7
Philippines41.6
Nigeria22.8
Indonesia17.6
Brazil4.8
Tier 1 targetWatchlist
Sources: World Bank remittance inflows 2025 (API, 30 Oct 2026) · Chainalysis Global Adoption Index 2025 · VARA public register (Jul 2026) · OJK (Dec 2025). Licence time and cost are consultant ESTIMATES. UAE is a net sender, so not in the chart.
The watchlist
Big demand, but the door is not open yet.
Country
Rank 25 / 26
The pull
The blocker
Call
Brazil
5 / 1
$318.8B on-chain; BCB rules live Feb 2026
Crowded: Avenue, Nomad already sell US stocks
Watch
Vietnam
4 / 18
17–21M holders; US stocks legally shut
VND 10T capital, 49% foreign cap, no licences yet
JV only
Philippines
9 / 19
$41.6B remittances; English-speaking
Central bank paused new crypto licences in Sep 2025
Wait
Nigeria
6 / 3
$92.1B on-chain; #1 for P2P
Approvals in principle only; FX friction
Revisit
Turkey
14 / 20
~$200B on-chain; Midas has 3.5M users
76 firms queued, zero permits issued
Watch
Parked: Thailand (saturated, heavily policed) · Bangladesh and Nepal (crypto banned) · Sri Lanka (no regulator to licence with)
Sources: Chainalysis Global Adoption Index 2025 & 2026 (method changed in 2026) · Chainalysis regional reports 2025 · World Bank 2025 · BCB Res. 519–521 · Vietnam Res. 05/2025 · SEC Nigeria · CMB Turkey · BSP. Vietnam holder count from local government media.
The partner stack
Buy the commodity layers. Build the ones that differentiate.
Liquidity (bridge)
Binance LinkBybit BrokerOKX Broker
Rebates of up to 45% (Bybit)
Market makers
WintermuteB2C2GSR
Two-sided quotes on your book
Custody
BitGoLiminal (India)
MPC wallets, insured
I help choose the vendors and negotiate the terms, and I know these firms from the exchange side.
CoinDCX
CoinSwitch
Delta
Mudrex
Pi42
WazirX
Binance
Bybit
OKX
KuCoin
MEXC
Binance LinkBybit BrokerOKX Broker
WintermuteB2C2GSR
BitGoLiminal (India)