--- title: "DLT Pilot Regime: what it is and what it means for issuers" url: "https://hokenfi.com/en/dlt-pilot-regime/" site: HokenFi published: "2026-10-02T20:20:17+00:00" modified: "2026-10-05T10:48:47+00:00" language: es-ES author: "Jesús Sánchez Fernández" description: "The EU DLT Pilot Regime (Regulation 2022/858) for issuers: DLT MTF, SS and TSS, current thresholds, the 2025 reform proposal and Spain's first DLT TSS." section: "Home > Uncategorized > DLT Pilot Regime: what it is and what it means for issuers" --- # DLT Pilot Regime: what it is and what it means for issuers **The DLT Pilot Regime is the EU framework, Regulation (EU) 2022/858, that lets market infrastructures trade and settle tokenized financial instruments on distributed ledger technology (DLT) with temporary exemptions from classic market rules. It has applied since 23 March 2023. Issuers do not apply for it: it shapes where a tokenized security can trade after issuance.** You hear «DLT Pilot Regime» at an industry event and wonder whether it concerns you. It sounds like a topic for exchanges and depositories, not for a company that wants to issue a tokenized share or bond. The practical question is narrower: does it change how your issuance can be traded or settled? This guide explains what the regime creates, its limits, the reform now under negotiation and the first Spanish authorisation. ## What the DLT Pilot Regime is EU market rules were written before blockchains existed, and some of them do not fit an infrastructure that runs natively on a shared ledger. Instead of rewriting them at once, the EU created a test bed: operators can request a specific permission from their national supervisor, with targeted exemptions and compensating measures ([Regulation (EU) 2022/858](https://eur-lex.europa.eu/eli/reg/2022/858/oj)). Each permission is valid across the Union for up to six years from issuance (arts. 8(11), 9(11) and 10(11)). What it means for you: the Pilot Regime is not a rule an issuer must comply with. It is the framework that enables the venues where your tokenized security could be traded or settled on-chain. It affects you indirectly, through the infrastructures that use it. ## The three infrastructures it creates The regulation defines three types of DLT market infrastructure (art. 2). Trading means matching buyers and sellers; settlement means transferring ownership and recording it. In traditional markets these functions sit in separate entities. On DLT they can be combined. | Infrastructure | What it does | What it does not do | | --- | --- | --- | | DLT MTF (multilateral trading facility) | Matches buy and sell orders from multiple participants under non-discretionary rules | Does not settle; settlement happens elsewhere | | DLT SS (settlement system) | Settles transactions against payment or delivery, and can handle the initial recording and safekeeping of DLT financial instruments | Does not run order matching | | DLT TSS (trading and settlement system) | Combines the services of a DLT MTF and a DLT SS in one infrastructure | Nothing; it covers both layers | What it means for you: when a platform says it operates under the Pilot Regime, ask which of the three it is. A DLT MTF gives you trading but settles outside; a DLT TSS handles both in one place, which shapes how your security moves in the secondary market. ## The thresholds that apply today The regime does not accept every instrument. Article 3 sets limits per instrument and an aggregate limit per infrastructure: - **Shares:** issuers with a market capitalisation, or tentative market capitalisation, below EUR 500 million. - **Bonds and other securitised debt:** issue size below EUR 1 billion, excluding instruments that embed a derivative or a structure that makes the risk hard to understand. - **Fund units:** UCITS with assets under management below EUR 500 million. - **Aggregate cap:** the market value of all DLT financial instruments on one infrastructure cannot exceed EUR 6 billion when a new instrument is admitted or recorded. At EUR 9 billion, the operator must activate its transition strategy. What it means for you: a small or mid-size issuance fits comfortably. The constraint is supply, not size, because few infrastructures have been authorised so far. ## The reform under negotiation (not yet applicable) ESMA’s 2025 report on the regime recommended making it permanent and more flexible. On 4 December 2025, the European Commission followed with a proposal inside its Market Integration and Supervision Package. As proposed, the reform would: - open the regime to all financial instruments, not only shares, bonds and fund units; - remove the per-instrument caps; - raise the aggregate cap per infrastructure from EUR 6 billion to EUR 100 billion; - create a simplified regime for smaller infrastructures recording up to EUR 10 billion; - remove the six-year time limit on permissions; - let crypto-asset service providers that run a trading platform under MiCA operate a DLT trading venue or a DLT TSS. The proposal is still being negotiated by the Council and the European Parliament and is not applicable. Until it is adopted, the limits of Regulation (EU) 2022/858 described above remain in force. Law firms tracking the file do not expect the new rules to apply before 2027. ## Spain: the first DLT TSS and the link with Law 6/2023 On 26 November 2025, the CNMV authorised Securitize Europe Brokerage and Markets, S.V., S.A. to operate a DLT TSS, the first authorisation of its kind in Spain. It can trade the instruments covered by art. 3(1) of the regulation, including tokenized shares and bonds. We cite it as public market context; it has no relationship with HokenFi. Spanish law connects directly to the regime. Securities admitted to trading on a trading venue must be represented either by book entries or by DLT systems within the framework of Regulation (EU) 2022/858 (art. 6.2 of [Law 6/2023](https://www.boe.es/eli/es/l/2023/03/17/6/con)). In practice, a tokenized security that wants to trade on a venue in Spain while staying on DLT needs a Pilot Regime infrastructure. The wider Spanish framework is summarised in [security token regulation in Spain](https://hokenfi.com/en/legal-framework-tokenization-spain/). ## How it fits your issuance Keep two layers apart. Issuance and the legal register of holders run through an [ERIR](https://hokenfi.com/en/what-is-an-erir/), the authorised entity that acts as the digital notary of your security. A transfer is effective against third parties from the moment it is recorded in that register (arts. 8 and 11 Law 6/2023; [RD 814/2023](https://www.boe.es/eli/es/rd/2023/11/08/814)). The first ERIR, URSUS-3 Capital, A.V., was authorised in November 2024. The Pilot Regime works on the other layer: trading and settlement of the security once it exists. Treat the regime as a near-term option, not as your exit on day one. Useful steps: - Confirm the legal nature of your token. If it is a financial instrument, MiCA does not apply ([art. 2.4, Regulation (EU) 2023/1114](https://eur-lex.europa.eu/eli/reg/2023/1114/oj)) and securities law does; see [what is a security token](https://hokenfi.com/en/what-is-a-security-token/). - Solve issuance and registration first, following [how to issue a security token in Spain](https://hokenfi.com/en/how-to-issue-a-security-token-in-spain/). - Check the offer document you need under the new thresholds in our guide to the [EU Listing Act](https://hokenfi.com/en/eu-listing-act-prospectus-exemption/). - Design the token so it can connect later to a DLT MTF or DLT TSS without being reissued, and follow the reform before building a long-term strategy on today’s limits. HokenFi provides the issuance technology on this route. It is not an entity authorised by the CNMV; the regulated functions are carried out by authorised partners. **Want your issuance ready for on-chain trading when a venue fits?** Take the [2-minute issuance assessment](https://hokenfi.com/en/issuance-assessment/) or [request a proposal](https://hokenfi.com/en/request-a-proposal/). *This content is educational. It is not legal, tax or investment advice. Check the current version of each rule on EUR-Lex and the relevant national gazettes.*