AN OVERVIEW OF THE SWISS DISTRIBUTED LEDGER TECHNOLOGY (DLT) ACT

Last updated: June 19, 2025, 19:36 | Written by: Cameron Winklevoss

Switzerland has long been recognized as a global hub for finance and innovation, and its proactive approach to regulating emerging technologies like blockchain and distributed ledger technology (DLT) further solidifies this reputation. The new Swiss DLT bill provides the legal basis for tokenization, issuing DLT securities and DLT trading facilities, affecting investments and capital markets. An overview of the Swiss DistributedThe Swiss Distributed Ledger Technology (DLT) Act, formally known as the Federal Act on the Adaptation of Federal Law to Developments in Distributed Electronic Register Technology, represents a comprehensive effort to provide a clear legal framework for the burgeoning digital asset space. In September 2025, the Swiss Parliament adopted the Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology (DLT bill). This blanket act adapts various federal laws. The amendments to the Code of Obligations, the Federal Intermediated Securities Act and the Federal Act on International Private Law havePassed by the Swiss Parliament in September 2025 and largely brought into force on February 1, 2025, along with its associated ordinance, this legislation adapts existing federal laws to accommodate the unique characteristics of DLT.The DLT Act focuses on creating legal certainty in areas crucial to the financial sector, ensuring that existing laws like the Anti-Money Laundering Act and the Financial Services Act also apply to DLT-related activities. With the Federal Act on the Adaption of Federal Law to Developments in the Distributed Ledger Technology (DLT Act) and the corresponding Ordinance on the adjustments of the existing law, which came into force on 1. August 2025, and the subsequent license requirement guidelines by the Swiss Financial Markets Authority Switzerland offers an attractive legal and regulatory framework for DLTs.This forward-thinking approach has positioned Switzerland as an attractive jurisdiction for businesses operating within the digital asset ecosystem, offering a blend of regulatory clarity and innovative freedom. Published on . Federal Council brings DLT Act fully into force and issues ordinance. Bern, - During its meeting on, the Federal Council brought the Federal Act on the Adaptation of Federal Law to Developments in Distributed Electronic Register Technology fully into force as of .But how exactly does this act impact the blockchain and cryptocurrency landscape in Switzerland? The DLT Act addresses open questions that were highlighted in a December 2025 report from the Swiss Federal Council (the Swiss government) titled the Legal Framework for Distributed Ledger Technology and Blockchain in Switzerland. Content of the DLT Act. Trading of Rights through Electronic RegistersLet's delve deeper.

Understanding the Core of the Swiss DLT Act

The DLT Act isn't a single, standalone piece of legislation.Instead, it's a ""blanket act"" that amends various existing federal laws to address the specific challenges and opportunities presented by DLT. Technology of Distributed Electronic Registers. FA . 3 . Art. 973e . II. Effects 1. The obligor under a ledger-based security is entitled and obliged to render performance only to the creditor indicated in the securities ledger and subject to appropriate modification of the ledger. 2. By rendering the performance due at maturity to the creditorThis approach allows for flexibility and adaptability, ensuring that the Swiss legal framework can evolve alongside the rapidly changing technological landscape.The key amendments touch upon areas such as the Code of Obligations, the Federal Intermediated Securities Act, and the Federal Act on International Private Law.

Key Amendments and Their Impact

Here's a breakdown of some of the most important amendments introduced by the DLT Act:

Introduction of Ledger-Based Securities (DLT Securities): Perhaps the most significant aspect of the DLT Act is the introduction of a new type of negotiable instrument called ledger-based securities, also known as DLT Securities or Registerwertrechte.This allows for the tokenization of various rights, claims, and financial instruments, enabling them to be represented and traded on a distributed ledger.
Legal Certainty for Tokenization: By defining DLT securities within the Code of Obligations, the DLT Act provides legal clarity regarding their ownership, transfer, and enforcement. Check out my latest Cointelegraph article, which overviews the Swiss Distributed Ledger Technology Act. 🤓 🧐 Technological progress and innovation often lead to legal questions being raisedThis clarity is essential for fostering trust and encouraging the adoption of tokenization in Switzerland.
Adaptation of the Intermediated Securities Act: The amendments to the Federal Intermediated Securities Act ensure that DLT securities are treated similarly to traditional securities held through intermediaries, providing a level playing field and facilitating interoperability.
Clarification of International Private Law: The DLT Act clarifies the rules of jurisdiction and applicable law in cross-border DLT transactions, reducing legal uncertainty and promoting international cooperation.

One crucial aspect of this legislation is its technology-neutral approach. During its meeting on, the Federal Council brought the Federal Act on the Adaptation of Federal Law to Developments in Distributed Electronic Register Technology fully into force as of . The associated blanket ordinance will also enter into force on the same day.The Act doesn't prescribe any specific type of DLT or blockchain technology, recognizing that the field is constantly evolving.Instead, it focuses on principles-based regulation that can be applied to various DLT systems.

The DLT Trading Facility License

In addition to defining DLT securities, the DLT Act also introduces a new licensing category for DLT trading facilities. Published on . Federal Council brings part of DLT bill into force. Bern, - During its meeting on, the Federal Council brought into force, with effect from, the parts of the DLT bill that enable ledger-based securities to be introduced.This recognizes the emergence of specialized platforms for trading digital assets and aims to regulate them appropriately.The Swiss Financial Market Supervisory Authority (FINMA) plays a critical role in granting these licenses and overseeing the operation of DLT trading facilities.

Requirements and Scope of the DLT Trading Facility License

A DLT trading facility license allows a platform to operate a regulated marketplace for digital assets. In September 2025, Parliament passed the distributed ledger technology (DLT) blanket act, which selectively adapts ten existing federal laws. The blanket ordinance that has now been adopted summarises the necessary adjustments to ten ordinances.The requirements for obtaining and maintaining this license are rigorous, including:

Robust risk management: DLT trading facilities must have systems and controls in place to manage risks related to market manipulation, cybersecurity, and operational failures.
Compliance with anti-money laundering (AML) regulations: These facilities must comply with AML requirements to prevent the use of the platform for illicit activities.
Clear rules and procedures: DLT trading facilities must establish clear rules for trading, settlement, and dispute resolution.
Protection of client assets: Measures must be in place to safeguard client assets held on the platform.

The DLT trading facility license is a significant step towards creating a regulated ecosystem for digital asset trading in Switzerland. The Swiss Financial Market Supervisory Authority (FINMA) has granted B rse Stuttgart subsidiary BX Digital the first license for a Distributed Ledger Technology (DLT) trading system since the Swiss DLT Act was passed in 2025. The DLT Act in Switzerland defines a DLT trading system as a system that enables the trading of digital assets, such asThe first license of this kind was granted to BX Digital, a subsidiary of Boerse Stuttgart, demonstrating Switzerland's commitment to fostering innovation within a well-regulated environment.

The DLT Act and Anti-Money Laundering (AML)

A key consideration in the regulation of DLT and cryptocurrencies is the prevention of money laundering and terrorist financing. Check out my latest Cointelegraph article, which overviews the Swiss Distributed Ledger Technology Act. 🤓 🧐 Technological progress and innovation often lead Alexandra Overgaag on LinkedIn: An overview of the Swiss Distributed Ledger Technology (DLT) ActThe DLT Act explicitly clarifies that existing AML laws also apply to DLT-related activities.This ensures that Switzerland's AML regime remains effective in the digital asset space.

How the DLT Act Strengthens AML Compliance

The DLT Act strengthens AML compliance in the following ways:

Extending AML obligations to DLT service providers: Companies providing services related to DLT, such as custody, trading, and issuance of digital assets, are subject to the same AML obligations as traditional financial institutions.
Implementing know-your-customer (KYC) requirements: DLT service providers must conduct KYC checks on their customers to verify their identity and assess the risk of money laundering.
Monitoring transactions for suspicious activity: DLT service providers must monitor transactions for patterns indicative of money laundering and report any suspicious activity to the authorities.

By integrating DLT activities into the existing AML framework, the DLT Act helps to mitigate the risks associated with illicit use of digital assets.

The FinTech License and its Relation to the DLT Act

Prior to the DLT Act, Switzerland introduced the FinTech license to facilitate innovation in the financial sector.This license, governed by the Banking Act (Art. 1b BA), allows companies to accept public deposits up to CHF 1 million without being subject to the full banking regulatory regime.

How the FinTech License Complements the DLT Act

The FinTech license and the DLT Act are complementary, providing a range of regulatory options for companies operating in the digital asset space. So, how are DLT and cryptocurrency regulated in Switzerland? To help answer this question, this article explores in depth the Swiss Distributed Ledger Technology Act on the adaptation of the federal laws to developments in Distributed Electronic Register Technology, or the Swiss DLT Act. What is the Swiss Distributed Ledger Technology Bill?The FinTech license is suitable for companies offering innovative financial services that don't involve traditional banking activities, while the DLT Act provides a framework for regulating specific DLT-related activities, such as the issuance and trading of DLT securities.

For example, a company offering a platform for lending and borrowing cryptocurrencies might obtain a FinTech license to accept deposits from users.If that same company also issues its own tokenized security, it would need to comply with the regulations outlined in the DLT Act.

Comparison with Liechtenstein's Blockchain Act

Switzerland isn't the only country in Europe with a comprehensive legal framework for blockchain and digital assets. Switzerland passed reforms collectively referred to as the Distributed Ledger Technology (DLT) Act in September 2025. Those parts of the DLT Act that enable ledger-based securities to be introduced entered into force on . Part of this act introduces the newly defined uncertificated register securities or Registerwertrecht digital securities that can be transferredLiechtenstein's so-called Blockchain Act, which came into force in January 2020, is another notable example. This will enable rapidly developing DLT technology to be flexibly integrated into the Swiss legal framework if required. The DLT proposal creates legal certainty in numerous areas that are very important for the financial sector: among other things, it ensures that the Anti-Money Laundering Act and the Financial Services Act also apply toUnderstanding the differences between these two approaches can provide valuable insights into the evolving regulatory landscape.

Key Differences Between the Swiss DLT Act and Liechtenstein's Blockchain Act

While both the Swiss DLT Act and Liechtenstein's Blockchain Act aim to provide legal certainty for the digital asset space, there are some key differences in their approach:

Scope: Liechtenstein's Blockchain Act takes a broader approach, covering a wider range of blockchain-related activities, including token offerings, digital identity, and tokenized rights. So, how are distributed ledger technology (DLT) and cryptocurrencies governed in Switzerland? To assist address this issue, this article delves into the Swiss Distributed Ledger Technology Act, which governs the application of federal regulations to advancements in Distributed Electronic Register Technology, also known as the blockchain.The Swiss DLT Act focuses primarily on the adaptation of existing laws to accommodate DLT securities and trading facilities.
Structure: Liechtenstein's Blockchain Act is a standalone piece of legislation, while the Swiss DLT Act is a blanket act that amends existing laws.
Specific regulations: Liechtenstein's Blockchain Act includes specific regulations for token offerings and digital identity, which are not explicitly addressed in the Swiss DLT Act.

Despite these differences, both Switzerland and Liechtenstein have emerged as leading jurisdictions for blockchain and digital assets, attracting businesses and investment from around the world.

Practical Implications of the DLT Act

The DLT Act has significant practical implications for businesses and investors operating in the Swiss digital asset space.It provides a clear legal framework for a variety of activities, including:

Issuing and trading tokenized securities: Companies can now issue and trade tokenized securities on regulated platforms, attracting new investors and unlocking new sources of capital.
Developing innovative DLT-based financial products: The DLT Act encourages the development of innovative financial products based on DLT, such as decentralized lending platforms and tokenized investment funds.
Providing DLT-related services: Companies can provide DLT-related services, such as custody, trading, and consulting, with greater legal certainty.

For investors, the DLT Act provides greater confidence in the security and legality of digital asset investments.It also facilitates access to a wider range of investment opportunities.

Challenges and Future Developments

While the DLT Act represents a significant step forward, it's important to acknowledge that the regulatory landscape for digital assets is still evolving.Some of the challenges and future developments to watch out for include:

International harmonization: As other countries develop their own regulations for digital assets, it will be important to ensure international harmonization to avoid regulatory arbitrage and facilitate cross-border transactions.
Technological advancements: The DLT Act must remain adaptable to technological advancements, such as the emergence of new types of DLT systems and digital assets.
Clarification of tax treatment: The tax treatment of digital assets remains a complex and evolving area. The Swiss Distributed Ledger Technology (DLT) Act, which took effect on Febru, has established a robust and forward-looking legal framework for asset tokenization. Designed with technology-neutral principles, the Act does not mandate the use of blockchain specifically, yet it addresses the distinct needs of distributed ledgerFurther clarification is needed to provide certainty for businesses and investors.

Switzerland is actively involved in international efforts to develop consistent standards for the regulation of digital assets. On Septem, the Swiss Parliament approved the Law on Distributed Ledger Technology ( DLT-Law ). The DLT-Law constitutes an umbrella legislation that introduces a new concept of so-called DLT-Securities under the Swiss Code of Obligations allowing for the tokenisation of rights, claims and financial instruments (seeThis collaborative approach is essential for fostering innovation and protecting investors in the long term.

Frequently Asked Questions (FAQs) About the Swiss DLT Act

Here are some frequently asked questions about the Swiss DLT Act:

What is a DLT security?

A DLT security, also known as a ledger-based security or *Registerwertrecht*, is a right, claim, or financial instrument that is represented and transferred on a distributed ledger.This allows for the tokenization of assets, making them easier to trade and manage.

Does the DLT Act cover all cryptocurrencies?

The DLT Act doesn't specifically address all cryptocurrencies. The introduction of the Swiss DLT Act comes at a time when jurisdictions around the world are ramping up digital assets and blockchain regulatory efforts. Liechtenstein s so-called Blockchain Act came into force on Janu, introducing a comprehensive legal framework for the blockchain industry that covers cryptocurrencies, utilityHowever, it clarifies that existing laws, such as AML regulations, apply to cryptocurrency-related activities.The Act primarily focuses on DLT securities and DLT trading facilities.

How do I obtain a DLT trading facility license?

To obtain a DLT trading facility license, you must apply to the Swiss Financial Market Supervisory Authority (FINMA). At the same time, the regulatory principles for the Distributed Ledger Technology (DLT) Act were further developed, with the DLT trading facility offering a new licence type for innovative business models. Experience with the FinTech licence. The FinTech licence in accordance with the Banking Act (Art. 1b BA) entered into force at the start ofThe application process is rigorous and requires demonstrating compliance with various regulatory requirements, including risk management, AML compliance, and client asset protection.

What are the benefits of the DLT Act for businesses?

The DLT Act provides legal certainty for businesses operating in the digital asset space, allowing them to develop innovative products and services with greater confidence.It also facilitates access to new investors and sources of capital.

What are the benefits of the DLT Act for investors?

The DLT Act provides greater confidence in the security and legality of digital asset investments.It also facilitates access to a wider range of investment opportunities.

The Future of DLT in Switzerland

Switzerland's proactive approach to regulating DLT has positioned it as a leading hub for innovation in the digital asset space. On Septem, the Swiss Parliament adopted the Federal Act on the Adaptation of the Federal Legislation to Developments in Electronic Distributed Ledger Technology (hereafter DLT Act ). The DLT Act created a new type of negotiable instrument called ledger-based rights ( Registerwertrechte / droits-valeurs inscrits ), set out underThe DLT Act provides a clear and adaptable legal framework that encourages the development of new products and services while protecting investors and preventing illicit activities.As the technology continues to evolve, it is likely that the regulatory framework will also adapt to ensure Switzerland remains at the forefront of the digital asset revolution.The ongoing developments are being carefully monitored by stakeholders globally, with many countries looking to Switzerland as a model for responsible and innovative regulation of blockchain technologies.

Conclusion

The Swiss Distributed Ledger Technology (DLT) Act is a landmark piece of legislation that has significantly shaped the digital asset landscape in Switzerland.By adapting existing laws to accommodate DLT securities, trading facilities, and other related activities, the DLT Act provides a clear and predictable regulatory framework for businesses and investors.Key takeaways include the introduction of ledger-based securities, the creation of a DLT trading facility license, and the integration of DLT activities into the existing AML regime.While challenges remain, Switzerland's proactive approach to regulating DLT has solidified its position as a global leader in the digital asset space.Companies considering operating within the DLT sphere should familiarize themselves with the Act and consult with legal experts to ensure full compliance.Want to explore the opportunities the DLT Act unlocks for your business?Start by researching your specific use case and consulting with a Swiss legal expert specializing in DLT and blockchain regulations.