DLT Trading Facility — FINMA License Category for Blockchain Exchanges

DLT Trading Facility License

The DLT trading facility license is a FINMA authorization category introduced by the DLT Act of 2021 specifically for platforms that trade, custody, clear, and settle DLT securities (blockchain-based financial instruments). The license presupposes that the platform provides at least one of these services for Registerwertrecht (ledger-based securities), utility tokens, or payment tokens.

SDX Trading AG received the first FINMA stock exchange license for digital securities, and SIX Digital Exchange AG received the first FINMA central securities depository license — making SDX the world’s first fully regulated financial market infrastructure for digital securities. BX Digital was approved in 2025 as the second DLT trading facility.

DLT trading facilities must comply with FINMA organizational requirements, capital requirements, and conduct rules adapted from existing financial market infrastructure regulation. They may serve both institutional and retail clients, depending on the specific license conditions. The facility must implement AML/KYC controls, transaction monitoring, and market abuse surveillance.

Legal Basis and Regulatory Framework

The DLT trading facility license was introduced by the DLT Act of 2021 through amendments to the Financial Market Infrastructure Act (FMIA). Article 73a et seq. FMIA defines the DLT trading facility as a regulated institution that admits DLT securities to trading, enables multilateral trading, and may combine trading with post-trade services (clearing, settlement, custody) in a single entity. This integration of trading and post-trade functions within a single license is a distinctive feature — traditional financial market infrastructure separates these functions across different entities (stock exchange, clearing house, central securities depository).

The integrated license model reflects the efficiency potential of DLT infrastructure, where trading, clearing, settlement, and custody can operate on a single distributed ledger without the complex messaging and reconciliation systems required between separate entities in traditional infrastructure. FINMA recognized this architectural advantage when designing the license category, enabling DLT trading facilities to offer end-to-end services that reduce operational complexity and settlement time.

Authorization Requirements

Obtaining a DLT trading facility license requires satisfaction of FINMA’s organizational, capital, and conduct requirements. Organizational requirements include qualified management, adequate internal controls, risk management frameworks, business continuity planning, and IT security standards appropriate for financial market infrastructure. Capital requirements are calibrated based on the facility’s risk profile, transaction volume, and scope of services — facilities providing custody and settlement face higher capital requirements than those offering trading only.

Conduct requirements include fair and orderly trading rules, market abuse surveillance systems, listing standards for admitted securities, and investor protection mechanisms. The facility must implement AML/KYC controls consistent with Swiss AMLA requirements, including customer identification, transaction monitoring, and suspicious activity reporting. Market surveillance systems must monitor for insider trading, market manipulation, and abusive trading patterns — obligations that apply equally to tokenized and traditional securities under Swiss financial market law.

SDX: First Licensed DLT Trading Facility

SDX Trading AG received the first FINMA stock exchange license for digital securities, while SIX Digital Exchange AG received the first FINMA central securities depository license. Together, these licenses enable SDX to provide the world’s first fully regulated financial market infrastructure for digital securities — combining trading, settlement, custody, and asset servicing within a single DLT-based system.

SDX’s institutional significance extends beyond symbolism. The platform has settled over CHF 750 million in digital bonds using wholesale CBDC through Project Helvetia, with issuers including the World Bank, City of Lugano, and the Swiss National Bank itself. The platform’s participant roster includes major Swiss and European financial institutions — UBS, Zurcher Kantonalbank, Commerzbank, Citi — demonstrating institutional confidence in the regulated DLT trading facility model.

BX Digital: Second Licensed Facility

BX Digital, approved by FINMA in 2025, operates as the second licensed DLT trading facility in Switzerland. Operated by BX Swiss (the Bern Stock Exchange), BX Digital targets retail and professional investors with tokenized versions of existing listed securities — initially 100+ tokenized US stocks and ETFs. This retail-oriented approach complements SDX’s institutional focus, creating a two-tier market structure for Swiss tokenized securities.

BX Swiss’s heritage as a traditional stock exchange brings decades of market operations expertise to BX Digital, including market surveillance, listing standards, trading halt procedures, and investor protection mechanisms that crypto-native platforms typically lack.

Comparison with Traditional Exchange Licenses

The DLT trading facility license differs from traditional Swiss exchange licenses in several important respects. Traditional stock exchange licenses (held by SIX Swiss Exchange and BX Swiss for their traditional operations) require separate licensing for each post-trade function — clearing through a licensed central counterparty, settlement through a licensed CSD, and custody through licensed custodians. The DLT trading facility license enables integration of these functions within a single entity, reflecting the architectural efficiency of DLT-based infrastructure.

The integrated model reduces the number of entities involved in a securities transaction from typically four or five (exchange, clearing house, CSD, custodian, transfer agent) to potentially one (the DLT trading facility). This consolidation reduces operational complexity, settlement time, and counterparty risk — advantages that institutional investors value. However, the integration also concentrates risk within a single entity, which FINMA addresses through enhanced capital, operational resilience, and governance requirements for DLT trading facilities.

Eligible Assets and Trading Rules

DLT trading facilities can admit Registerwertrecht (ledger-based securities), utility tokens, and payment tokens to trading. The specific listing criteria are defined by each facility — SDX focuses on institutional-grade bonds, pre-IPO shares, and tokenized securities issued by sovereign and corporate entities, while BX Digital targets tokenized versions of existing listed equities and ETFs.

Trading rules must ensure fair and orderly markets, prevent market abuse, and protect investors. DLT trading facilities are subject to the same market abuse provisions (insider dealing, market manipulation) that apply to traditional exchanges under the Financial Market Infrastructure Act. The facility must implement real-time surveillance systems that detect suspicious trading patterns, unusual price movements, and potential insider activity across all traded instruments.

Impact on Swiss Capital Markets

The existence of two FINMA-licensed DLT trading facilities positions Switzerland as the world leader in regulated tokenized securities infrastructure. No other jurisdiction offers both a primary issuance platform with wholesale CBDC settlement (SDX) and a secondary trading platform with retail access (BX Digital) — both operating under unified regulatory supervision by a single financial market authority (FINMA).

This institutional infrastructure supports the broader Swiss tokenization ecosystem. Companies seeking to tokenize equity can issue shares as Registerwertrecht using the CMTA Token Standard, list them on SDX or BX Digital for regulated secondary market trading, and have them custodied by FINMA-licensed institutions (Sygnum, AMINA). The global RWA tokenization market — $22.1 billion and projected to reach $50 billion by end of 2025 — represents the addressable opportunity that this Swiss infrastructure serves.

Future Development Under Proposed License Categories

The Federal Council’s October 2025 proposal for payment institution and crypto institution licenses will create additional regulatory pathways for entities operating adjacent to DLT trading facilities. The proposed crypto institution license would cover wallet service providers, exchange operators, and market makers that interact with DLT trading facilities without being the facilities themselves. This layered regulatory approach creates a comprehensive ecosystem where the DLT trading facility provides the core infrastructure, and surrounding service providers (custody, market-making, distribution) operate under dedicated licenses calibrated for their specific activities.

Participant Access Models and Investor Protection

DLT trading facilities can serve both institutional and retail clients, with access models tailored to each participant category. Institutional access typically involves CSD membership (for direct participation in issuance and settlement) or intermediated access (through banks and securities firms that are CSD members). Retail access, as BX Digital’s model demonstrates, can be provided through integration with retail banking infrastructure — enabling investors to trade tokenized securities through their existing bank accounts.

Investor protection mechanisms on DLT trading facilities include standardized complaint handling procedures, suitability assessments for complex products, and information obligations ensuring investors understand tokenized securities characteristics and risks. The FINMA DLT trading facility license requires organizational safeguards — internal controls, conflict of interest management, and business continuity planning — that protect investors against operational failures and institutional misconduct. These protections parallel the investor safeguards available on traditional stock exchanges, ensuring that the migration to DLT-based infrastructure does not reduce investor protection standards.

Economic Significance for Swiss Capital Markets

The two DLT trading facilities collectively represent a significant innovation in Swiss capital market infrastructure. SDX’s CHF 750+ million in settled digital bonds demonstrates production-scale institutional adoption. BX Digital’s planned launch of 100+ tokenized US stocks signals retail market accessibility. Together, they create a comprehensive tokenized securities ecosystem that positions Switzerland’s capital markets for the structural shift toward blockchain-based ownership, trading, and settlement that global securities markets are undergoing.

The economic significance extends to the broader Swiss financial industry. Banks, custodians, legal advisors, compliance firms, and technology providers all benefit from the growing tokenized securities market. The CMTA standards development process creates interoperability that enables new market participants to enter without custom integration, reducing barriers to entry and fostering competition that benefits investors through lower costs and better services. The Federal Council’s recognition of blockchain as a strategic priority for Swiss financial market competitiveness reinforces the institutional commitment to supporting DLT trading facility growth.

Ongoing Regulatory Compliance and Supervision

DLT trading facility operators face continuous regulatory oversight from FINMA. Annual regulatory reporting requires detailed disclosures on trading volumes, participant activity, market surveillance findings, operational incidents, and financial condition. FINMA conducts periodic on-site examinations to assess operational resilience, compliance effectiveness, and governance quality. External audits by FINMA-recognized audit firms provide independent assurance on the facility’s financial statements, operational controls, and regulatory compliance. The intensity of FINMA supervision reflects the systemic importance of DLT trading facilities within Swiss financial market infrastructure, particularly as settlement volumes grow and more institutional participants rely on DLT-based securities infrastructure for their investment operations. The facility must maintain adequate capital buffers, operational resilience standards, and business continuity capabilities that ensure uninterrupted service delivery to institutional and retail participants who depend on the platform for securities trading and settlement.

Listing Standards and Security Admission

DLT trading facilities establish listing standards that determine which securities can be admitted to trading. These standards cover issuer qualifications (corporate governance, financial disclosure, management quality), security characteristics (legal structure, compliance controls, smart contract audit status), and ongoing obligations (continuous disclosure, corporate action execution, regulatory reporting). The listing standards for DLT trading facilities parallel those of traditional stock exchanges, ensuring that tokenized securities listed on regulated platforms meet equivalent quality standards. For CMTAT-compliant tokens, the standardized smart contract architecture simplifies the listing assessment process, as the audited open-source framework provides baseline assurance on token functionality, compliance controls, and register management capabilities. Issuers seeking to list tokenized securities on SDX or BX Digital engage in a listing application process that evaluates both the issuer’s institutional quality and the token’s technical compliance with platform requirements.

The two licensed DLT trading facilities in Switzerland serve complementary market segments that together create a comprehensive tokenized securities ecosystem. SDX targets institutional issuers and investors with wholesale CBDC settlement capabilities, while BX Digital targets retail and professional investors with tokenized versions of existing listed securities. This two-tier market structure mirrors the traditional division between primary market infrastructure and secondary trading venues while operating entirely on DLT-based infrastructure under unified FINMA supervision. The DLT trading facility license category represents one of the DLT Act’s most impactful innovations, creating a purpose-built regulatory framework that enables blockchain-based financial market infrastructure to operate with the same institutional credibility and investor protections as traditional stock exchanges while leveraging the efficiency advantages of distributed ledger technology for trading, settlement, custody, and lifecycle management of tokenized securities. The two licensed facilities in Switzerland collectively demonstrate that regulated DLT trading infrastructure can achieve production-scale institutional adoption, attracting sovereign issuers, central bank participation, and global institutional distribution that validates the regulatory model for international adoption and replication.

For detailed analysis, see our DLT Act framework coverage. For entity comparisons, see SDX vs BX Digital. For FINMA token classification of tradeable assets, see our regulatory section. For DAO governance of tokenized securities, explore our governance analysis. For settlement data, visit dashboards.