DLT Licence — Switzerland & Gibraltar
DLT (Distributed Ledger Technology) provider licences in Switzerland and Gibraltar represent two of the world's most reputable crypto regulatory frameworks. Both are targeted at institutional-grade operations requiring premium regulatory standing.
What is a DLT licence?
A DLT (Distributed Ledger Technology) provider licence authorises businesses to offer blockchain-based financial services under high-standard prudential and AML/CFT frameworks.
- Switzerland's FINMA introduced DLT-specific regulation under the DLT Act (effective 2021), building on the Federal Act on Financial Institutions (FINIG).
- Gibraltar was the first jurisdiction globally to introduce a DLT provider licence (2018), via the Gibraltar Financial Services Commission (GFSC).
- DLT licences are typically more demanding than standard VASP registration — capital, governance and technical requirements are higher.
- Switzerland offers FINMA banking and securities licences alongside DLT authorisation for businesses requiring full prudential regulation.
- Neither Switzerland nor Gibraltar are EU members — DLT licences do not provide EU/EEA passporting rights.
DLT licences from Switzerland or Gibraltar do not grant EU/EEA passporting rights. Businesses targeting EU retail clients must additionally obtain MiCA CASP authorisation.
Who DLT licensing is right for
Best for
- Institutional-grade exchanges, custodians and prime brokers requiring maximum-reputation regulatory standing.
- Token issuers and DeFi infrastructure providers that need FINMA-level legal clarity.
- Businesses where institutional counterparties (banks, asset managers) require premium-jurisdiction licensing.
- Operators comfortable with higher capital and governance requirements in exchange for top-tier reputation.
Not for
- Early-stage businesses with limited capital — DLT routes require substantial capital and compliance infrastructure.
- Businesses targeting primarily EU/EEA retail clients (MiCA CASP is more appropriate).
- Operators needing fast time-to-market — both routes take at least 4 months minimum.
- Models requiring cross-border EU passporting — DLT licences have no passporting mechanism.
DLT jurisdictions
Select a jurisdiction to see the full country page with FINMA / GFSC requirements, costs and application process.
Related and adjacent routes
The first three are alternative crypto routes. The last three apply where the boundary analysis above shows the project is not primarily a DLT case.
EU/EEA market access with passporting across 30 countries.
Dubai DIFC/ADGM VASP — high-reputation Middle East alternative.
Hong Kong VATP — premium regulated Asia route for institutional operations.
Tokenised securities, crypto-asset derivatives and venue operation, where the underlying is a MiFID financial instrument.
MiFID authorisation carries materially higher capital requirements and a heavier framework than any DLT provider licence.
DLT or tokenisation projects whose real regulatory weight sits in fiat payment services and safeguarding.
PI and a crypto authorisation are separate permissions. Holding both on one entity is possible but operationally complex.
Stored-value and token-linked payment models where customer balances are held as e-money.
EMI adds €350k minimum capital and full safeguarding obligations on top of any crypto permission.
Frequently asked questions about DLT licensing
A DLT licence is typically a higher-standard framework with stronger prudential requirements — higher capital, more governance scrutiny, and stricter technical requirements. VASP is the general FATF-derived term used by most jurisdictions, while DLT-specific licences (Switzerland, Gibraltar) go beyond basic VASP compliance.
No. Switzerland is not an EU/EEA member and has no passporting arrangement for DLT services. EU retail client servicing requires a MiCA CASP authorisation from an EU member state.
Capital requirements depend on service scope and the specific FINMA authorisation category sought. DLT Trading Facility operators face higher requirements than DLT Securities Depositories. Consult FINMA guidance or a Swiss regulatory adviser for current thresholds.
No, and many do not. The route depends on what the product actually does, not on the technology. Tokenised securities and trading venues are usually MiFID investment firm cases. Crypto-asset exchange and custody generally sit under MiCA CASP or a VASP regime. Fiat payment rails and stored value are payment institution or e-money institution questions. A DLT provider licence fits where ledger infrastructure, custody architecture and technical governance are the core of the regulated activity itself.
It turns on the rights the token confers, not on how it is issued or marketed. A token giving rights comparable to a share, bond or derivative is a financial instrument and falls under MiFID II, regardless of being on a distributed ledger. MiCA applies to crypto-assets that are not financial instruments, e-money or deposits. Classification should be settled in writing before any filing is budgeted, because it determines the regulator, the capital requirement and the entire application workstream.
This information is for general guidance only and does not constitute legal or regulatory advice.