When you ask investors in Davos, London or New York where the world of tokenised securities has its centre, the answers often confuse. Singapore? Dubai? Maybe Liechtenstein? The fewest name Switzerland. This is astonishing, because currently this small country of just under nine million inhabitants leads in a market likely to develop into one of the most important asset classes of the coming decade. How did this happen? And why does no one talk about it?

A law that makes the difference

On 1 August 2021, the DLT Act came into force in Switzerland. DLT stands for Distributed Ledger Technology — the family of technologies to which blockchain belongs. The Act is a technical adaptation of several existing laws, especially the Code of Obligations, the Debt Collection and Bankruptcy Act, and the Banking Act. It reads dryly to laypeople. For tokenisation projects, it has groundbreaking consequences.

The Act creates the legal concept of register value rights. These are securities that exist not as a physical document but as an entry on a decentralised register — typically on a blockchain. Before 2021, tokenised securities in Switzerland lived in a grey zone. They were formally securities, but no one knew exactly how ownership is transferred, how courts decide in dispute, what rights they precisely embody. With register value rights, all of this is resolved. A token on the blockchain has the same legal status in Switzerland today as a classical share or bond.

In addition, the Financial Services Act FinSA (FIDLEG) has regulated conduct duties for financial service providers since 2020 — including prospectus requirements for public offers, transparency, investor protection and suitability assessment. Asset tokens fall under this regime. This may sound like extra effort, but it is precisely what distinguishes tokenised securities from speculative cryptocurrencies: a clear legal framework with clear protections.

This combination of the DLT Act and FinSA is uniquely clear globally. There is no other major financial jurisdiction in which tokenised securities are so unambiguously regulated.

The comparison with other jurisdictions

Why are other countries not speaking up more strongly? Let us look at the competition.

The European Union has established its own regulation from 2024 with the MiCAR framework. MiCAR is a step in the right direction, but primarily regulates crypto-assets in the broader sense — stablecoins, utility tokens, ART tokens. For tokenised securities, the existing MiFID II regulation continues to apply, which was not designed specifically for blockchain technology. This produces uncertainties that do not exist in Switzerland.

The US is in a complicated position. The SEC under changing leadership has followed different lines — sometimes restrictive, sometimes more liberal. Asset tokens in the US market must fight their way through a tangle of Federal Securities Law, State Blue Sky Laws and SEC statements. There is no own legislation for tokenised securities. The result: many US projects incorporate their operating company in Switzerland or Liechtenstein for clarity.

Singapore under MAS supervision has created a practical framework, but it is designed primarily for institutional actors. For the broader application of tokenised assets, clear structures are missing.

Liechtenstein created a tokenisation framework even earlier than Switzerland in 2019 with the TVTG. It is excellently structured — but Liechtenstein, with just under 40,000 inhabitants, is too small to build a complete financial ecosystem. Many Liechtenstein projects in practice work with Swiss banks.

Dubai has a modern regulation with VARA that has gained much international attention. But it focuses primarily on speculative crypto assets rather than on tokenised securities in the classical sense.

Switzerland’s lead in this landscape rests on three factors: an own law specifically for tokenised securities, an established financial ecosystem with global reputation, and a supervisor (FINMA) that has systematically engaged with crypto topics since 2018 and follows consistent lines.

The ecosystem

A law alone does not make a location. What makes Switzerland special is the ecosystem of companies that has emerged on this legal foundation. Some examples.

Sygnum Bank was founded in Zurich in 2018 and in 2019 was the world’s first bank to receive a FINMA licence for banking services in digital assets. Sygnum tokenises classical securities for institutional clients and offers a fully integrated banking platform for digital assets. With over three billion Swiss francs in assets under custody, Sygnum is today one of the largest players in tokenised securities.

Aktionariat from Zurich enables Swiss SMEs to issue employee shares and participation rights as tokens. Over 50 Swiss companies have used this to digitise their ownership structure — from small startups to established mid-sized firms.

SIX Digital Exchange (SDX) is the digital trading platform of the Swiss exchange SIX. Since 2021 it has operated a fully regulated infrastructure for tokenised securities — from issuance through trading to custody. With FINMA licence as securities exchange and central securities depository, SDX is the institutional answer to the question of how tokenised securities can be traded in regulated markets.

Taurus from Geneva offers custody and token issuance solutions for banks worldwide and works with major European banks.

Beep Labs AG, our company, is part of this ecosystem. With beep, we build an asset token backed by a real robot fleet — a different kind of tokenisation than at Sygnum or Aktionariat, because we are not tokenising an existing security but building a new asset class. That we do this in Switzerland is no coincidence. It is the only jurisdiction in which our model can be cleanly structured legally.

This list is not complete. But it shows: Switzerland today has a complete ecosystem of banks, platforms, custody providers, issuers and specialised companies — an ecosystem that does not exist with this depth in any other country.

The Crypto Valley as location factor

Added to this is a geographic concentration unique in the tokenisation world: the Crypto Valley around the canton of Zug. What began in the early 2010s as a small cluster of early blockchain projects is today an ecosystem of more than 1,500 companies with over 6,000 employees. The Ethereum Foundation has its legal seat in Zug. Cardano, Polkadot, Solana — all have Zug connections.

What makes Zug attractive is not only legal clarity. It is the combination of pragmatic administration, low taxes, geographic proximity to important European markets, and a density of specialists and advisors not existing in this concentration anywhere else. Anyone building a tokenisation project in Zug has within ten kilometres access to lawyers who accompanied the DLT Act from the start, banks working with digital assets, and investors who understand the topic.

Beep Labs is headquartered in Zug. This is not a marketing decision but an operational one — we benefit daily from the ecosystem Switzerland and especially Zug have built.

Why no one talks about it

The final question of this article: if Switzerland is really so far ahead, why does it barely appear in international discussions of tokenisation? Three reasons.

First — Switzerland does not like talking about itself. Swiss companies are culturally restrained with marketing claims. The supervisor and politics communicate soberly without great staging. This fits Swiss mentality but harms international visibility. While Singapore and Dubai generate attention with press conferences, glossy brochures and conferences, Switzerland works in the background.

Second — the spectacular stories happen elsewhere. FTX collapse, Binance investigations, stablecoin drama: these are the stories that make headlines. Switzerland has largely avoided such scandals because its regulation was stricter from the start. This is an advantage for serious actors, but does not create headlines.

Third — the most important Swiss tokenisation projects often work in the institutional space, not retail. Sygnum custodies assets for wealthy private and institutional clients. SDX trades between banks. Taurus works in the backend of major financial houses. All of this happens quietly, far from end consumers and retail investors. Beep is a deliberate exception here — we want to make the legally clean Swiss structure accessible to private individuals too.

What this means for investors

Anyone wanting to invest in tokenised assets today has a simple rule of thumb: where is the operating company registered? If the answer is “Cayman Islands, BVI, Estonia” or another low-regulation country, caution is advised. If the answer is “Switzerland, Liechtenstein or a comparable country with clear tokenisation framework”, the probability is higher that the project is legally solidly built.

This is no guarantee. There are bad projects in Switzerland too. But the hurdle of running a bad project cleanly through FinSA and the DLT Act is high enough that many unserious actors do not even try. Those that do at least pass the formal exam.

In the coming years, the world will catch up. The EU will refine its regulation, the US will create clarity, Singapore and Dubai will further develop their frameworks. But Switzerland has a head start of years — and uses it every day, in every contract negotiation, in every token issuance, in every custody service.

Perhaps someone will talk about it soon. Perhaps not. The Swiss have learned to live with that — they simply keep going.