Digital Asset LABMarket Structure Research
EU TOKENISED SECURITIES MARKET MAP
One set of rules across 27 countries — but as a time-limited experiment. A single authorisation reaches the whole bloc, yet only three infrastructures had been authorised as of 31 May 2025.
01 · STATUS
“Approved,” “rule effective,” and “live in production” are different states. This site keeps them separate.
Regulation (EU) 2022/858, published on 2 June 2022 and applying from 23 March 2023. It waives parts of existing market-infrastructure rules so trading and settlement can be tried on DLT. It is not permanent law.
ESMA’s report of 25 June 2025 records that, as of 31 May 2025, only three DLT market infrastructures had been authorised — CSD Prague, 21X AG and 360X AG — with “minimal live trading activity”. Having a framework is not the same as it being used.
ESMA identified a lack of interoperability and of access to central bank money as frictions, and concluded that the current thresholds restrict wider participation. It recommends recalibrating those thresholds and clarifying the regime’s long-term status.
Spain’s CNMV is reported to have authorised Securitize as a Trading and Settlement System under the DLT Pilot Regime, with Avalanche selected as the underlying infrastructure. The firm thereby operates regulated digital-securities infrastructure in both the U.S. and the EU.
In the EU single market an authorisation obtained in one member state extends to others. Securitize is reported to have extended its December 2024 investment firm licence to Germany, France, Italy and Luxembourg. There is no need to re-apply country by country — unlike the U.S. federal and state structure.
The regime ran for an initial three years with a single extension of up to three more permitted. ESMA advises the Commission on whether it should be extended, expanded, amended and/or made permanent; its report asks for the long-term status to be clarified. Nothing has been made permanent.
02 · OWNERSHIP
Using the SEC’s January 2026 taxonomy as the anchor, classification follows legal structure and authoritative ownership records—not the appearance of the token.
Out of scope for MiCA. MiCA covers crypto-assets that are not financial instruments; tokens that are securities fall on the MiFID side. Conflating the two makes the whole picture incoherent.
There is also a cap per infrastructure: an instrument may not be admitted if it would take the aggregate market value to EUR 6 billion, and at EUR 9 billion the operator must activate its transition strategy. ESMA concluded these thresholds restrict wider participation and recommended recalibrating them.
The exemption is not automatic, and the authority may require additional measures to protect those natural persons. What is permitted and what individuals are actually doing are two different things.
03 · TRADING ROUTES
Ownership model and trading venue are separate axes. The rules and settlement path differ by route.
A multilateral trading facility that admits only DLT financial instruments. Germany’s 360X AG has held this permission since 29 April 2025.
A system that settles transactions in DLT financial instruments and allows their initial recording. The Czech Republic’s CSD Prague has held this permission since 11 October 2024 — an existing central securities depository entering the regime.
One entity performing both trading and settlement — a combination only this regime permits. Germany’s 21X AG has held the permission since 3 December 2024, and Securitize is reported to have received the same category of authorisation in Spain.
04 · REALITY CHECK
24/7 trading, instant settlement, self-custody and fractional buying are the four things most often promised. None of them apply uniformly across the models.
Important caveat: So in the EU, what is possible now and what will still be possible later must be read separately.
Important caveat: But authorisations are issued nationally, so the practice of supervision still differs by country.
Important caveat: Both are “new rules”, but they cover different things.
05 · ECOSYSTEM
This is not a regulator-approved company list. It maps roles that firms have publicly disclosed or filed, with sources.
Reports to the European Commission on how the regime is working and advises on whether it should be extended, expanded, amended or made permanent. It also publishes Q&As.
Authorisations and exemptions are actually granted by each member state’s authority — France’s AMF, the Netherlands’ AFM, Spain’s CNMV and others.
The Czech central securities depository; holds a DLT SS permission from 11 October 2024.
Germany; holds a DLT TSS permission from 3 December 2024, combining trading and settlement.
Germany; holds a DLT MTF permission from 29 April 2025.
A U.S. digital-securities platform, reported to have received the EU’s first DLT TSS authorisation in Spain and to have extended its investment firm licence to Germany, France, Italy and Luxembourg. It is the link to the U.S. map.
06 · LICENCES
Registration, effectiveness of a filing, approval and exemption are different concepts. “The SEC is involved” does not mean the same thing in each case.
CautionWith an exemption it may admit natural persons as members. It is a venue and does not settle.
CautionSettlement in central bank money is not available — a friction ESMA flagged.
CautionA combination the ordinary rules do not contemplate; it is specific to this regime.
06 · REGULATION
Statutes, SEC orders, SRO filings, no-action letters, staff views and company plans are not given the same legal weight.
The regulation establishing a pilot regime for DLT market infrastructures. It applies from 23 March 2023.
Per ESMA’s report, CSD Prague has held a DLT SS permission since 11 October 2024.
The permission for combining trading and settlement, granted by the German authority.
That brought the count of authorised infrastructures to three. ESMA’s reporting period ended on 31 May 2025.
The report required by Article 14. It finds take-up limited and live trading minimal, credits the regime with stimulating experimentation, and recommends recalibrating the thresholds and clarifying the long-term status.
The European Commission published its thinking on DLT and tokenisation. It sets a direction; it does not make the regime permanent.
07 · SOURCES
SEC, DTCC/DTC, NYSE/ICE and Nasdaq are prioritized. Company materials are clearly identified as company sources.
Official Journal of the EU (EUR-Lex) · 2022-06-02 · Primary source
ESMA · 2025-06-25 · Primary source
ESMA · 2023-06-02 · Primary source
European Commission · 2026-04-21 · Primary source
The Block · 2026-05 · Company source
Ledger Insights · Company source
AMF (France) · Primary source
AFM (Netherlands) · Primary source
08 · METHODOLOGY
First identify what the investor legally holds, then identify the trading route, and finally verify the authoritative source and operating status. The word “tokenized” alone does not determine shareholder rights, counterparty risk or settlement cycle.