DLT and tokenisation routes for regulated infrastructure projects
This route covers distributed-ledger and tokenisation projects whose main question is infrastructure, tokenised-market structure or DLT operating model, not a generic crypto exchange launch. It is intentionally broader than the crypto-only DLT hub at /licenses/crypto/dlt/ and helps separate DLT, MiCA CASP, MiFID and payments intent before jurisdiction selection.
What this DLT route family covers
Use this page when the business model is centred on ledger infrastructure, tokenised market rails, venue design or specialist DLT operations. The route may still resolve into MiCA CASP, MiFID trading or a crypto-country DLT framework, but this page should not pre-commit the user to one of those outcomes.
- DLT provider and infrastructure routes such as Gibraltar DLT or Swiss-style ledger frameworks where governance and technical controls are central.
- Tokenised market and trading structures where the first question is whether the asset or venue falls into MiCA, MiFID or another infrastructure regime.
- Institutional-grade operating models that need a route-selection layer before choosing a country-level crypto DLT page.
- Adjacent structures where payments, e-money, investment services or banking permissions may become relevant alongside a DLT build.
This route should not duplicate /licenses/crypto/dlt/. Use the crypto DLT hub for country-level DLT provider routes; use this page to decide whether the project belongs in DLT, MiCA CASP, MiFID trading, PI/EMI or banking.
This DLT hub vs the crypto DLT hub
The project contains two different DLT routes on purpose. They should not be merged in the user's mind.
- /licenses/dlt/Covers: Broad route-selection layer for DLT, tokenisation and infrastructure-heavy projects that may still resolve into MiCA, MiFID, PI/EMI or banking.Not for: Not the final country-comparison page for crypto DLT provider routes.
- /licenses/crypto/dlt/Covers: Crypto-specific DLT provider hub focused on live jurisdiction comparisons such as Gibraltar and Switzerland.Not for: Does not replace wider route analysis where the product may actually belong in MiFID, MiCA CASP or payments.
What this DLT route does not automatically give you
DLT is not a shortcut label for every regulated ledger-based business. Several adjacent outcomes require a different primary route.
- Tokenised securities, broker-dealer activity and investment venues usually point to MiFID investment firm analysis, not a generic DLT route.
- Pure crypto exchange, custody and wallet services for non-financial-instrument crypto-assets usually belong in MiCA CASP or the crypto DLT/VASP catalogue.
- Fiat payment rails, safeguarding of client money or e-money issuance point to PI or EMI analysis.
- Deposit-taking, balance-sheet lending and bank-style products point to a banking route.
DLT vs MiCA CASP vs MiFID / payments — decision matrix
Use this matrix to identify whether the project is really an infrastructure/DLT case or whether it belongs in MiCA CASP, MiFID or payments instead.
| Criteria | DLT / InfrastructureTokenisation and ledger operations | MiCA / MiFIDService or instrument regime | PI / EMI / BankFiat and balance-sheet routes |
|---|---|---|---|
| DLT infrastructure, ledger governance, tokenised market rails | review MiCA or MiFID boundary | ||
| Non-financial-instrument crypto exchange or custody | sometimes | MiCA / crypto route | |
| Tokenised securities, venue operator, broker-dealer | sometimes | MiFID | |
| Fiat payments, safeguarding, e-money or deposits | PI / EMI / Bank | ||
| Country-level DLT provider comparison | Use /licenses/crypto/dlt/ | not this page | not this page |
DLT-oriented activity scope
The table below helps separate DLT-heavy projects from adjacent regulated routes.
Covered by this licence
- Operate ledger-based infrastructure or tokenised market rails
- Build a DLT provider control framework for institutional counterparties
Not covered — separate licence required
- Run a pure crypto exchange or wallet serviceUsually a crypto route question first
- Trade tokenised securities or derivativesMiFID analysis required
- Provide fiat payment services or stored-value balancesPI or EMI analysis required
- Accept depositsBanking route required
DLT route compliance themes
DLT projects usually converge on the following workstreams before a final route is selected.
Confirm whether the product belongs in DLT infrastructure, MiCA CASP, MiFID investment services, PI/EMI or banking before budgeting the filing.
Document ledger architecture, incident response, key controls, change management, outsourcing and service continuity.
Assign accountable management for compliance, risk, technology, market operations and regulator-facing communication.
Prepare ownership, customer-risk, fiat-flow and counterparty materials early because route selection alone does not solve onboarding.
For tokenised products, confirm whether the underlying instrument is a MiFID financial instrument, MiCA crypto-asset or outside both perimeters.
Is a DLT route right for your project?
This page is for projects that start with infrastructure or tokenisation questions rather than a generic crypto-service launch.
Best for
- DLT provider, tokenisation or infrastructure-sensitive projects that need route selection before country comparison.
- Teams deciding between crypto DLT, MiCA CASP and MiFID trading treatment.
- Institutional projects where governance, technical controls and regulatory perimeter matter more than launch-speed marketing.
Not for
- Users who already know they need a specific crypto-country DLT page in Gibraltar or Switzerland.
- Simple payments businesses with no DLT infrastructure question.
- Projects that are clearly MiFID, MiCA CASP or banking cases from the outset.
DLT route readiness
Route-selection mistakes are expensive. Validate these items before committing to a jurisdiction or framework.
- Regulatory classificationCritical
Confirm whether the product belongs in DLT, MiCA, MiFID, PI/EMI or banking before designing the filing workstream.
- Technology and control modelCritical
Document ledger architecture, outsourcing, cyber controls, wallet or key controls where relevant, incident response and operational resilience.
- Governance and substanceCritical
Show accountable management, local presence where needed, risk ownership and regulator-facing decision lines.
- Banking and counterparty narrativeCritical
Prepare ownership, source-of-funds, customer, fiat-flow and operating-model evidence in parallel with route selection.
- Commercial route rationaleImportant
Be able to explain why the project belongs in a DLT/infrastructure route rather than MiCA CASP, MiFID or payments.
- Country-level follow-upAdvisory
Once the route is confirmed, move to the correct country page or specialised hub rather than treating this page as the final jurisdiction answer.
The main failure mode on DLT projects is picking the wrong route family too early and then forcing the facts to fit it.
How this page differs from /licenses/crypto/dlt/
Use /licenses/dlt/ to decide whether the project is truly a DLT/tokenisation case or whether it belongs in MiCA CASP, MiFID trading, PI/EMI or banking. Use /licenses/crypto/dlt/ when the route is already confirmed as a crypto DLT provider comparison between live country pages such as Gibraltar and Switzerland.
Related and adjacent routes
Depending on your model, one of the following routes may apply alongside or instead of CASP authorisation.
DLT or tokenisation projects that also need fiat payment services, safeguarding or e-money functionality.
PI and CASP are separate authorisations. Running both on the same legal entity is possible but operationally complex and may require NCA approval.
Stored-value or token-linked payment models where EMI treatment may sit alongside a DLT proposition.
EMI authorisation adds €350k minimum capital and full safeguarding obligations on top of CASP requirements.
Businesses trading tokenised securities or crypto-asset derivatives that are financial instruments under MiFID II.
MiFID investment firm authorisation has materially higher capital requirements and is a more complex regulatory framework than MiCA CASP.
DLT route — frequently asked questions
This page is a broader route-selection hub for DLT and tokenisation projects. The crypto DLT hub is the narrower country-comparison route once you already know the project belongs in a crypto DLT framework.
No. Some projects become MiCA CASP, some are MiFID investment-firm cases, some remain infrastructure/DLT routes, and some touch PI/EMI or banking issues. That boundary analysis is the point of this page.
Leave for /licenses/crypto/dlt/ once the route is clearly a crypto DLT provider comparison; leave for /licenses/trading/ if the instrument is MiFID-like; leave for /licenses/emi/ or /licenses/pi/ if fiat payments become primary.
This page provides general educational information about DLT and tokenisation route selection. Route classification must be checked before relying on any specific filing strategy.