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REGULATION (EU) 2022/858
OFFICIAL

A 6-year "Sandbox" framework (2023-2029) allowing MI to temporarily deviate from CSDR/MiFID obligations to test DLT technology.

CSD Exemptions A DLT market infrastructure can maintain the securities register.
✅ No longer requires a separate central CSD.
Direct Access Individuals and legal entities can be admitted directly.
✅ Partial disintermediation permitted.
Risks & Compliance Liability: The DLT operator remains liable in case of loss.
Exit: Mandatory transition plan if the regime is not made permanent.
DLT TSS Architecture (Trading & Settlement)
TSS
Trading
MTF Execution
Settlement
CSD Settlement
€500 M SHARES (Small Cap)
€1 Bn BONDS
€500 M UCITS FUNDS
*Max market capitalization thresholds for admission.

REGULATORY DETAILS

Eligibility Tester

Does your issuance fit within the EU Sandbox?

€300M Max: €1.5 Bn
✅

ELIGIBLE

This volume is below the €1 Billion threshold for bonds.

Legal Framework & Compliance

Regulation (EU) 2022/858 of the European Parliament and of the Council

Key Exemptions

  • Article 3 (DLT MTF): Exemption from intermediation obligation (direct access).
  • Article 4 (DLT SS): Exemption from CSDR recording obligation.
  • Article 6: Possibility of combining Trading and Settlement (DLT TSS).
Read the Regulation (EUR-Lex)

Supervision & Reporting

  • ESMA: Competent authority for technical advice and supervision.
  • Annual Report: Mandatory reporting on volumes and incidents.
  • Exit Strategy: Mandatory transition plan if the regime is not made permanent.
ESMA Portal

Risk Warning

  • Technological Volatility: Protocols may experience forks or bugs.
  • Irrevocability: On-chain transactions are final (Finality).
  • Liquidity: The DLT secondary market is still fragmented.

Legal Sources

  • Pilot Regime: EU regulation 2022/858 on distributed ledger technology market infrastructures.
  • MiCA: Regulation on Markets in Crypto-Assets.
  • Blockchain Ordinance: Ordinance n° 2017-1674 (France).
01

Pilot Regime Objectives

Three fundamental pillars for European financial innovation

Innovation

Encourage innovation in financial infrastructures via blockchain technology for trading and settlement.

Protection

Maintain a high level of investor protection and ensure the integrity of financial markets.

Experimentation

Allow actors to test DLT without being immediately subject to MiFID II or CSDR.

02

Concrete Impact: T+0 Settlement

Direct comparison between the traditional model and the DLT model

Criterion Traditional Model (CSDR) DLT Model (Pilot Regime)
Settlement Cycle T+2 (2 working days) T+0 (Instant / Atomic)
Intermediation Multiple (Broker -> Custodian -> CSD) Direct Access (Investor -> DLT)
Reconciliation Manual & Costly Automated (Smart Contract)
Transparency Limited (Data Silos) Total (Distributed Ledger)
03

Types of DLT Infrastructures

Three categories of authorized blockchain infrastructures

DLT MTF

Multilateral Trading Facility

Multilateral trading platform for tokenized securities. Allows the trading of financial instruments on blockchain.

Trading Order Book

DLT SS

Settlement System

Settlement system for tokenized securities. Manages the delivery-versus-payment of transactions on blockchain.

Settlement DvP

DLT TSS

Trading & Settlement System

Combined trading and settlement system. Integrated solution for trading and atomic settlement (T+0).

Trading Settlement Atomic
04

Competent Authorities

Supervision and governance of the pilot regime

AMF

Autorité des Marchés Financiers
  • Instruction of DLT MTF and TSS applications
  • Technological monitoring of protocols
  • Granting specific exemptions

ACPR

Autorité de Contrôle Prudentiel et de Résolution
  • Instruction of DLT SS and TSS applications
  • Prudential supervision and DLT solvency
  • Validation of settlement assets

ESMA

European Securities and Markets Authority
  • Harmonization of technical standards
  • Compulsory non-binding opinion
  • Publication of European reports
05

Pilot Regime Timeline

Evolution and perspectives 2022-2026

2022

Regulation Adoption

Publication of Regulation (EU) 2022/858 establishing the DLT pilot regime framework.

2023

Implementation

Entry into force of the pilot regime. First authorization requests filed.

2026

Potential Extension

Evaluation of the regime and possibility of extension or integration into the permanent regulatory framework.