The EU DLT Pilot Regime provides a route for eligible market infrastructure operators to trade or settle certain financial instruments recorded using distributed ledger technology. It is not a blanket license for token issuance, and a venue's permission does not establish that your instrument can be admitted.
The EU DLT Pilot Regime provides a route for eligible market infrastructure operators to trade or settle certain financial instruments recorded using distributed ledger technology. It is not a blanket license for token issuance, and a venue's permission does not establish that your instrument can be admitted.
Start with the service, not the blockchain
| Infrastructure | Core function to verify |
|---|---|
| DLT MTF | Trading on a multilateral trading facility |
| DLT SS | Settlement of transactions in eligible DLT financial instruments |
| DLT TSS | Trading and settlement within a combined system |
Identify which entity performs each function. Request the named operator's permission and any conditions, restrictions or exemptions granted by the competent authority. Check instrument eligibility and applicable limits separately; they are not inferred from the technical ability to mint or transfer a token.
Walk one trade through settlement
Ask the operator to show how an order becomes a trade, what record establishes ownership, how the cash leg settles and what happens when cash or securities do not arrive on time. Identify who can repair records and which evidence your operations team gets. If settlement uses an external provider, document the point where responsibility changes hands. Also request the transition plan: who services outstanding instruments if the operator loses permission or exits the arrangement?
Separate the rules from reform proposals
Use Regulation (EU) 2022/858 as the baseline and confirm the current consolidated text and the operator's live permission before acting. ESMA has recommended changes, including making the regime permanent. A recommendation or Commission proposal is not itself an applicable exemption. Also avoid treating a MiCA authorization as interchangeable with permission to operate securities market infrastructure.
This is an operational guide, not legal advice.
Primary sources
Check the instrument and venue separately
Article 3 of Regulation (EU) 2022/858 sets separate tests for shares, debt and certain collective investment units, as well as an aggregate limit for instruments on an infrastructure. Ask the venue which threshold applies to your instrument and whether its permission sets a lower one. ESMA's list of authorised infrastructures is the place to check named permissions. Its Article 14 review records that 21X AG's specific DLT TSS permission began on 3 December 2024; that date is not evidence that any particular instrument can trade there today.
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