DLT Trading Facility License
License for operating multilateral DLT-based trading venues for tokenized securities and crypto assets with custody and settlement capabilities.
FMIA Art. 73a et seq., DLT Act 2021
Capital Required
CHF 1,000,000-5,000,000 depending on scope (small facility CHF 500,000)
Timeline
12-18 months
Fees
CHF 50,000-100,000 application + CHF 10,000-60,000 annual
Regulatory Body
Swiss Financial Market Supervisory Authority (FINMA)
Legislative Framework
Financial Market Infrastructure Act (FMIA), Banking Act (BankA), Financial Institutions Act (FinIA), DLT Act 2021, Anti-Money Laundering Act (AMLA)
Last updated: June 2025
Key Requirements
Robust IT systems and cybersecurity protocols compliant with FINMA Technology Risk Management guidelines
DLT infrastructure capable of providing real-time settlement and atomic finality
Market surveillance and trade reporting capabilities in accordance with FMIA Art. 75
Qualified operational and compliance management team with at least 2 FTE dedicated staff
Membership or direct access to a Swiss clearing and settlement entity
Segregated client account structure and comprehensive custody safeguards
Comprehensive business continuity and disaster recovery plans tested annually
Detailed risk management framework for operational, legal, and financial risks
Application Process
Submit formal application to FINMA with business plan, organizational structure, and technical documentation
FINMA preliminary review (2-4 weeks) to assess completeness and initiate enhanced due diligence
Conduct independent IT security audit by FINMA-approved external assessor covering infrastructure and controls
Provide detailed responses to FINMA information requests regarding governance, risk management, and AML procedures
Complete legal and regulatory review phase with final documentation of rules of conduct and client agreements
FINMA decision and issuance of license conditions and operational requirements
Expected Total Timeline
12-18 months
Ongoing Obligations
After obtaining your DLT Trading Facility License, these are the continuing compliance requirements you must maintain.
File annual financial statements and regulatory capital reports to FINMA within 4 months of fiscal year-end
Conduct annual internal audit and independent IT security audit, submitting results to FINMA quarterly
Maintain capital ratios and segregated client funds at mandated levels with monthly internal reconciliation
Report any significant operational incidents, cyber incidents, or market abuse suspicions to FINMA within 5 days
Update compliance manual and notify FINMA of any material changes to systems, governance, or risk controls within 10 days
Conduct stress testing and liquidity assessments semi-annually and submit results with remediation plans
Cost Summary
Capital Requirement
CHF 1,000,000-5,000,000 depending on scope (small facility CHF 500,000)
Application & Licensing Fees
CHF 50,000-100,000 application + CHF 10,000-60,000 annual
Jurisdiction Setup Cost
$55,000-$220,000
Annual: $80,000-$200,000
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