Token issuers
Token classification ruling
Whether an instrument is a DLT security, and so admissible to the venue, turns on the classification a ruling settles.
Token classificationDLT trading facility
licence Switzerland
The DLT trading facility is Switzerland’s FINMA-regulated venue for multilateral trading of tokenised securities. Uniquely, one licence can combine trading, custody and settlement, and admit retail participants directly. It is not theoretical: FINMA authorised the first such venue in 2025. We assess feasibility, confirm you actually need it, structure the infrastructure, and run the authorisation.
At a glance
A regulated venue built for tokenised securities.
Trading, custody and settlement under one licence, with retail access.
- What trades
- DLT securities (tokenised)
- Access
- Retail admitted directly
- Scope
- Trading + custody + settlement
- Legal basis
- FinMIA & DLT Act
- Precedent
- First licensed in 2025
The essentials
What a DLT trading facility is
A DLT trading facility is a Swiss financial market infrastructure, licensed by FINMA, for the multilateral trading of DLT securities, the securities recorded on a distributed ledger. Created by the DLT Act and placed within the Financial Market Infrastructure Act, it does what a stock exchange cannot: combine trading, custody and settlement of tokenised securities under a single licence, and admit retail participants directly to the venue. It is purpose-built market infrastructure for tokenised assets.
Who this is for
- operators building a venue to trade tokenised shares, bonds or other securities;
- infrastructure projects integrating trading with on-ledger settlement;
- ventures intending to admit retail participants to trade security tokens;
- groups bringing existing market infrastructure into tokenised assets.
A working precedent
FINMA licensed the first DLT trading facility in 2025, so the regime has a live example rather than only a statute. What trades on it ties to token classification, and the custody it provides connects to crypto custody.
The distinction
How it differs from an exchange
The DLT trading facility is not a crypto exchange and not a traditional stock exchange. It is a third thing, designed for tokenised securities, and the differences define what it can do.
| DLT trading facility | Traditional exchange | |
|---|---|---|
| Who can trade | Retail admitted directly | Regulated members only |
| What trades | DLT (tokenised) securities | Conventional securities |
| Custody & settlement | Can be under one licence | Separate infrastructures |
| Legal basis | FinMIA, via the DLT Act | FinMIA |
| Lighter regime | Small-facility thresholds | No equivalent |
The integration of trading, custody and settlement, plus direct retail access, is the whole point. It is what tokenisation enables and what the licence authorises. It is also why authorisation is demanding: reaching retail and bundling functions brings the full weight of financial-market-infrastructure regulation.
How it runs
From feasibility to authorisation
This is an infrastructure-grade licensing project. The structuring is heavy and front-loaded, and the technology is examined as closely as the law.
- Stage 1
Feasibility & need
Confirming the model is a genuine multilateral venue that needs this licence, not a lighter custody or dealer setup, and whether the small-facility regime fits.
- Stage 2
Venue structuring
The organisation, governance, capital, admission and trading rulebook, and the custody and settlement model for the DLT securities.
- Stage 3
Technology & controls
The on-ledger settlement, delivery-versus-payment, operational and IT security framework that FINMA scrutinises closely.
- Stage 4
Authorisation
Preparing and running the FINMA application for a financial market infrastructure through to an effective licence.
- Ongoing
Operate & supervise
The continuing supervisory, reporting and threshold obligations of a regulated venue, and growth within or beyond the small-facility limits.
Budget
What it costs
A DLT trading facility is the heaviest crypto authorisation in the Swiss regime, and the cost reflects it: a financial-market-infrastructure application, capital requirements, a full rulebook, and a technology and security build FINMA examines in depth. The small-facility regime reduces the supervisory weight but not the seriousness of the project.
We scope honestly against the venue’s design and scale. Pricing is on request, and the conversation starts with whether you need this licence at all.
Discuss the venue
What you need
What authorisation requires
As a financial market infrastructure, a DLT trading facility must satisfy demanding, infrastructure-level requirements:
- appropriate organisation, governance and fit-and-proper management;
- adequate capital for the scale and functions of the venue;
- clear, fair rules for admission, trading and participants;
- sound on-ledger settlement, custody and delivery-versus-payment;
- strong operational and IT security, examined closely by FINMA.
Most projects do not need this licence — and that is good news
The trading-facility licence is the heaviest authorisation in Swiss crypto, and ambition sometimes reaches for it when the business does not require it. If you are issuing your own tokens, trading bilaterally, or offering custody without running a multilateral venue, a lighter route applies and pursuing the full infrastructure licence would burn time and capital for no benefit. We will tell you plainly when a model does not need this licence, saving a venture-scale cost, and take on the full authorisation only when the model genuinely is market infrastructure.
Why Goldblum
What building the venue involves
A DLT trading facility sits where market-infrastructure law, securities law and ledger technology meet. Structuring it and running the authorisation is the most demanding financial-regulation work in this field.
Honest
Whether you need it at all
A candid feasibility view first, so a venture does not pursue the heaviest licence in the regime when a lighter route would serve.
Infrastructure
Venue, rulebook and tech
The organisation, capital, admission rules, custody, settlement and technology framework structured to the standard a financial market infrastructure is held to.
Proportionate
The small-facility option
An assessment of whether the reduced-supervision regime fits, so an earlier-stage venue is not over-built for the volumes it will actually handle.
Related
What a venue connects to
Custodians · 2027
Crypto custody
The custody and settlement a DLT trading facility integrates: segregation, the deposit boundary and the custody licence ahead.
Crypto custodyThe wider regime
Financial regulation
FINMA licences, market-infrastructure authorisation and the wider regime: the practice the crypto desk sits inside.
Financial regulation
FAQ
DLT trading facility: FAQ
01What is a DLT trading facility?
A DLT trading facility (DLT trading system) is a Swiss financial market infrastructure, licensed by FINMA, for the multilateral trading of DLT securities, meaning tokenised securities recorded on a distributed ledger. It was created by the DLT Act and sits in the Financial Market Infrastructure Act alongside stock exchanges and other trading venues. What makes it distinctive is that one licence can combine trading with custody and settlement of the tokenised assets, and that it can admit retail participants directly, neither of which a traditional exchange does.
02How is it different from a stock exchange?
Two ways that matter. First, a traditional stock exchange admits only regulated members (banks and securities firms), whereas a DLT trading facility can admit retail participants to trade directly on the venue. Second, an exchange handles trading while custody and settlement sit with separate infrastructures; a DLT trading facility can bundle trading, custody and settlement of DLT securities under a single authorisation. It is purpose-built for tokenised securities and the disintermediated way they can be held and transferred, rather than retrofitting old market structure onto new assets.
03Has any DLT trading facility actually been licensed?
Yes. FINMA granted the first DLT trading facility licence to BX Digital AG, with the authorisation issued in March 2025 and taking legal effect in May 2025 once all conditions were met. BX Digital is part of the group behind the BX Swiss exchange. The significance is that the regime is not theoretical. Switzerland has authorised real, regulated infrastructure for trading and settling tokenised securities, which gives the licence category a working precedent that few jurisdictions can point to.
04What can be traded on a DLT trading facility?
DLT securities: securities issued or recorded on a distributed ledger, such as tokenised shares, bonds and other standardised investment instruments that qualify as securities. It is a venue for security tokens, not for payment tokens or pure cryptocurrencies. This ties directly to token classification: whether an instrument is a DLT security, and therefore admissible, depends on it being a security in the first place, which is what a token classification settles. The venue and the classification questions are connected.
05Can retail investors trade on a DLT trading facility?
Yes, and that is one of its defining features. Unlike a conventional exchange restricted to regulated members, a DLT trading facility can admit retail participants to trade directly. That openness is also why it is fully regulated as a financial market infrastructure: admitting the public brings investor-protection, organisational and operational requirements with it. The licence is demanding because the venue can reach retail; the access and the rigour are two sides of the same regime.
06Is there a lighter regime for a smaller venue?
Yes. The framework provides for a small DLT trading facility subject to reduced supervisory requirements, below defined thresholds for trading, custody and settlement volumes. This lets a smaller or earlier-stage venue operate under a proportionate version of the regime rather than the full weight applied to a large infrastructure. The first licensed facility used this small-scale option. We assess whether a venue qualifies for the lighter regime and structure it to stay within or graduate from the thresholds deliberately.
07What does it take to be authorised?
A DLT trading facility is a financial market infrastructure, so the bar is high: appropriate organisation and governance, adequate capital, sound operational and IT security, clear rules for admission and trading, and arrangements for the custody and settlement it offers. FINMA examines the technology (including how settlement and delivery-versus-payment work on the ledger) as closely as the legal structure. Authorisation is a substantial undertaking, which is why it suits serious infrastructure projects rather than light ventures.
08How long does authorisation take?
It is a major licensing project measured in many months, not weeks, reflecting that a trading venue is among the more heavily regulated financial institutions. The timeline is driven by the depth of the organisational, capital, technological and rulebook work FINMA expects, and by the iteration with the regulator. The first licence took a sustained process before it became effective. We scope the realistic timeline honestly at the outset, because a venue project mis-planned on timing is a venture-level risk.
09Do I need a DLT trading facility licence, or something lighter?
Only if you operate a multilateral venue where many participants trade DLT securities against each other. If you are issuing your own tokens, or dealing bilaterally, or providing custody without running a trading venue, a different and usually lighter authorisation applies: SRO membership, a custody structure, or a securities-dealer analysis. The trading-facility licence is for genuine market infrastructure. We confirm whether your model actually needs it before you take on the heaviest crypto authorisation in the regime.
10How does custody and settlement fit in?
A DLT trading facility can provide the custody and settlement of the DLT securities traded on it under the same licence, one of the efficiencies of the category. Settlement on a distributed ledger, often with delivery-versus-payment enforced by smart contract and a link to a payment system, is part of what FINMA assesses. This integration of trading, custody and settlement is what tokenisation makes possible and what the licence is designed to authorise. The custody questions connect to our crypto custody work.
11What does Goldblum do on a DLT trading facility project?
We assess feasibility, confirm the model genuinely needs the licence, and structure the venue (its organisation, capital, rulebook, custody and settlement arrangements and the technology framework FINMA will scrutinise), then prepare and run the authorisation application. We advise on whether the small-facility regime fits and how to position for it. This is one of the most demanding authorisations in Swiss crypto, and we take it on as the infrastructure-grade financial-regulation work it is.
Building a tokenised-securities venue?
Tell us what will trade and who will access it. A partner confirms whether you need the licence, structures the venue, and runs the FINMA authorisation as the infrastructure project it is.