LX20 LAW FIRM
IT

Topic

DLT Pilot

EU Regulation 2022/858 (DLT Pilot Regime) allows the experimentation of DLT-based market infrastructures (DLT MTF, DLT SS, DLT TSS) with targeted exemptio

In a nutshell

EU Regulation 2022/858 (DLT Pilot Regime) allows the experimentation of DLT-based market infrastructures (DLT MTF, DLT SS, DLT TSS) with targeted exemptions from MiFID II, CSDR and Settlement Finality. In Italy Decree-Law 25/2023 (DL Fintech), converted by Law 52/2023, complements the EU regime by introducing the digital form of financial instruments and rules on issuance and circulation on DLT. The pilot regime lasts three years (extendable), with quantitative thresholds on capitalisation and volumes, and requires authorisation by CONSOB (with Banca d'Italia and ESMA) of concrete pilot projects. The first authorisations were granted in 2025–2026. LX20 advises banks, investment firms, market infrastructures and fintechs on feasibility assessment, choice of DLT perimeter (permissioned/permissionless), drafting of the authorisation application, supervisory dialogue with CONSOB and contractual and technical documentation.

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Banking, Finance & Capital Markets

Banking, financial and insurance law. Financial instruments, alternative and complementary finance, Islamic finance. Counsel to banks, asset managers, supervised intermediaries and issuers.

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Specialised team

Alessandro Negri della Torre

Founder & Managing Partner

Gian Marco Iulietto

Senior Associate

Carlo Giuliano

Partner

Giulio De Bruno

Of Counsel

Cristina Carati

Of Counsel

Nabil Ryah

Of Counsel

Frequently asked questions

What is the DLT Pilot Regime?
An EU experimental regime to test DLT market infrastructures with MiFID/CSDR exemptions, in force since 23 March 2023.
Who may apply in Italy?
Investment firms, regulated-market operators, central securities depositories and new operators authorised ad hoc, after CONSOB / Banca d'Italia review.
Which financial instruments are eligible?
Shares with market cap < EUR 500m, bonds < EUR 1bn per issuance and UCITS units with NAV < EUR 500m, unless adjusted by the Commission.
What does the DL Fintech change?
It enables issuance of financial instruments in Italian digital form on a DLT register, replacing the shareholders book / intermediary register.
Is a register controller required?
Yes: the register controller for DLT circulation is an authorised entity listed in a CONSOB register.
What exemptions are available?
Targeted exemptions from MiFID/CSDR rules on access, segregation, settlement and transparency, to be specified in the application.
How long does a pilot project last?
Up to 6 years (3+3 extendable). At expiry, either transition to standard regime or wind-down.
Can a public blockchain be used?
In theory yes, but operators in practice choose permissioned chains for compliance, register governance and asset segregation.

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