DLT Licence (Distributed Ledger Technology) is a regulatory authorisation to provide financial services that rely on distributed ledger technology, such as holding or transferring crypto-assets for clients or running a market in tokenised securities. The term covers several regimes, so the first question in any deal is which regulator issued it and what it permits. Gibraltar's stand-alone regime requires Financial Services Commission authorisation for using DLT to store or transmit value belonging to others. In the EU it usually means a DLT Pilot Regime permission held by an existing investment firm, market operator or central securities depository, covering tokenised financial instruments only. Switzerland's DLT trading facility combines trading, custody and settlement. None replaces MiCA CASP authorisation for EU crypto clients.
Gibraltar DLT provider licence
Gibraltar created the best-known stand-alone regime. Under the Financial Services Act 2019 (Schedule 2, Part 16) and the Financial Services (Distributed Ledger Technology Providers) Regulations 2020, any firm carrying on, by way of business in or from Gibraltar, the use of DLT for storing or transmitting value belonging to others needs authorisation from the Gibraltar Financial Services Commission.
The GFSC's March 2025 scope guidance lists custodial wallet providers, crypto ATM operators, spot and derivatives exchanges, OTC desks, escrow providers and lending platforms as in scope, and assesses smart-contract, DEX and stablecoin models case by case. Non-custodial wallet providers, pure investment advice and open-source development are out of scope. The guidance also states that all DLT providers fall within the FATF definition of a virtual asset service provider.
EU DLT Pilot Regime permissions
In the EU, "DLT licence" usually refers to a permission under the DLT Pilot Regime, Regulation (EU) 2022/858, applied since 23 March 2023. It is not a new licence type: an authorised investment firm, market operator or central securities depository obtains specific permission to run a DLT multilateral trading facility, a DLT settlement system or a combined DLT trading and settlement system, with exemptions from parts of MiFID II and the Central Securities Depositories Regulation.
The limits are tight. Eligible shares must come from issuers worth less than €500 million, bonds must be below €1 billion of issuance, UCITS units below €500 million, and the total market value on the infrastructure must stay under €6 billion at admission. Each permission lasts at most six years.
Switzerland's DLT trading facility
Switzerland added a DLT trading facility licence to its Financial Market Infrastructure Act, supervised by FINMA. It allows one entity to admit DLT securities to trading and also offer custody and settlement, combining roles that conventional market infrastructure keeps in separate licences.
DLT licence vs CASP licence
Since MiCA, Regulation (EU) 2023/1114, firms offering crypto-asset services to EU clients need a CASP authorisation from an EU member state. A Gibraltar DLT licence does not passport into the EU, and an EU Pilot Regime permission covers tokenised financial instruments, not crypto-assets such as bitcoin.
What a DLT licence is worth in a deal
Take an illustrative Gibraltar DLT provider with 8,000 clients, 70% of them in the EU. Its licence supports the non-EU book, but the EU clients need a MiCA route, which may mean acquiring or building an EU CASP alongside. A buyer pricing the target should separate revenue the existing licence can legally support from revenue that depends on a second authorisation, and check that the regulator's prior approval of a new controller is a condition of completion.