Tokenisation and Market Infrastructure: the Swiss comparison

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Switzerland and Singapore have taken opposite approaches to the same problem and have, so far, arrived at different market structures. Switzerland changed its private law. The DLT Act of 2021 created the ledger-based security under Art. 973d ff. CO, under which the ledger is the register and the token is the security, and created the DLT trading facility licence under Art. 73a ff. FinMIA for venues that trade, clear and settle such securities (see Part D, Chapter III and Part E, Chapter V). SIX Digital Exchange holds that licence and has issued digital bonds for the Swiss government, cantons, banks and corporates, settled in tokenised Swiss francs issued by the Swiss National Bank under the Helvetia programme.

Singapore changed nothing in its private law and built on its existing securities regime through an industry programme under MAS's leadership. It has no ledger-based security and no DLT trading facility licence. Its tokenised securities are beneficial interests held through nominees, its venues are RMOs and bank platforms, and its settlement assets are tokenised deposits, stablecoins and a wholesale CBDC testnet. The Swiss model gives the token holder a direct legal right and the venue a single licence for the whole chain. The Singapore model gives the market scale through the participation of the largest global banks and asset managers and a direct link to Asian capital.

For an issuer the choice depends on the investors and the instrument. A Swiss franc bond for European institutional investors is well served by a ledger-based security on SDX. A US dollar money market fund for Asian private banks is well served by a tokenised VCC distributed through a Singapore network. Groups active in both hubs increasingly issue in one and distribute in the other. The Project Guardian policymaker group's work on interoperability is intended to make such cross-border structures routine. Part P, Chapter IV discusses the structures in detail.

For general information only. This article does not constitute legal or tax advice, does not replace advice on an individual case and creates no lawyer-client relationship. It reflects the legal position as of October 2026.

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Dr Alexander Ressos, TEP

Of Counsel, KGP Legal LLC

I am Of Counsel with KGP Legal LLC in Singapore, where I work with a global client base of successful entrepreneurs and their families, independent asset managers, commodity trading houses and other commercial clients. I am a German and Swiss attorney-at-law, also admitted as a solicitor in England & Wales and in Hong Kong. I divide my time between Zug in Switzerland, Singapore and Hong Kong. Since 2017 I have advised international clients on more than 700 crypto and digital asset projects. I also have extensive experience in cross-border litigation and arbitration in Singapore, Hong Kong and other markets in South-East Asia and Greater China.

I operate across the key financial centres in South-East Asia, the Middle East and Switzerland, with a particular focus on asset protection, international tax and estate planning, as well as trusts, company administration and other fiduciary services. My philosophy is to serve as a trusted advisor working closely with my clients and to help them achieve their commercial objectives.

All Singapore law advice is provided through KGP Legal LLC, an established and duly licensed firm of Singapore advocates and solicitors.

KGP Legal LLC is a medium-sized law firm in Singapore that is capable of providing the full range of legal services and corporate administration work. Please contact me directly at [email protected] if you need any further information.

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SingaporeIQ is edited by Dr Alexander Ressos, an international business lawyer with more than 15 years of local experience in Singapore as a permanent resident, a Singapore registered foreign lawyer and managing partner of a Singapore foreign law practice. In addition to significant experience in cross-border investments and transactions, UHNWI private client work and sanctions/export controls, Dr Ressos has extensive experience in cross-border business and in crypto and digital-asset projects in Singapore, drawn from more than 700 projects since 2017.

If you are planning a company incorporation, an investment, a holding structure or a market entry through Singapore, you can reach Dr Ressos directly at [email protected]. Singapore law advice is provided by KGP Legal LLC, a licensed firm of Singapore advocates and solicitors. As a Singapore law practice, KGP Legal LLC is authorised under the Legal Profession Act 1966 to advise on Singapore law and to represent clients before the Singapore courts; foreign law practices with an office in Singapore are, as a rule, not permitted to do either. Dr Ressos and his team facilitate the full range of Singapore legal, compliance and company administration services, including company incorporation, corporate transactions, commercial contracts, crypto and digital assets, financial regulatory work and dispute resolution, including litigation in the Singapore courts. For legal, tax and fiduciary services in Switzerland, see helveticaregister.com.