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Proposal for an EU-pilot regime on DLT market infrastructures

  • Germany
  • Crypto assets
  • Financial services and markets regulation
  • Financial services


As part of its Digital Finance Strategy, the EU commission proposed a pilot regime in form of a Regulation to remove obstacles under the current framework to the implementation of Blockchain and Distributed Ledger Technology (‘DLT’) in financial market infrastructures. The technology is expected to improve efficiency in the entire trading and post-trading of financial instruments.

Whereas the simultaneously published MiCA proposal (see our briefing here) creates a bespoke framework for crypto-assets like Bitcoin which are not yet covered by EU regulation, this sandboxing regime proposes derogations from rules on the trading and settlement of MiFID financial instruments. Under the proposed regime, supervisory authorities can grant exemptions from provisions which currently restrict trading venues and settlement systems from harnessing the opportunities of DLT. Specifically, exemptions can be granted so that:

| transferable securities traded on DLT based multilateral trading facilities (‘DLT MTFs’) would not have to be recorded with a central securities depository (‘CSD’).

| investors could be admitted to DLT market infrastructures without intermediary.

| transactions could be settled almost instantly using DLT based payment systems like emoney tokens. The transfer of money and of the securities will occur simultaneously (delivery vs. payment).

Read full briefing here.