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The 2021 DLT Act creates 'ledger-based securities', giving legal effect to ownership transfers of securities recorded on a distributed ledger, without a separate license requirement for tokenization itself, in force since 2021-08-01. Other on-chain activity categories (staking, DeFi, mining, node/validator operation) remain unevidenced this run -- a coverage gap, not a finding of no regulation.
Beyond tokenization, this module currently carries no independently sourced evidence on other categories of on-chain activity: staking, DeFi lending, decentralised-exchange operation, mining, node operation, or validator activity have not been researched against FINMA guidance this cycle. This is recorded as a coverage gap rather than as a finding that these activities are unregulated or informally tolerated -- the absence of evidence here reflects a research gap, not a regulatory vacuum, and should not be read as either.
Outlook
This module's amber status reflects a genuine asymmetry in the evidence base: tokenization is well-evidenced and settled, while every other on-chain activity category is unaddressed this cycle. This asymmetry is itself worth tracking, since DeFi and validator-level activity -- areas where no regulator has yet spoken in many jurisdictions -- represent a known under-indexed vector generally. A future cycle should prioritise direct research into FINMA's posture (if any) on staking rewards at the protocol level, DeFi protocol operation, and node/validator activity, distinct from the staking income-tax treatment already captured under the tax_treatment module. Absent that research, this module's coverage will remain structurally narrower than its green-rated neighbours (crypto_licensing, token_classification) despite sitting within the same overall regulatory architecture.
No new data since the standing brief. 1 periodic run re-emitted it unchanged.
Sources and findings (1)
- T3 · CoinDeskSwitzerland (DLT Act, 2021) — 'ledger-based securities', giving legal effect to ownership transfers of securities recorded on a distributed ledger, without a separate license requirement for the tokenization activity itselfretrieved M4bindingin force