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ARTICLE · 26 OCTOBER 2026

Tokenised Funds Gain Greater Certainty: CSSF Issues First Guidance On DLT-Based Fund Units In Luxembourg

DLA Piper
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Luxembourg's financial regulator has issued its first guidance on tokenisation, clarifying how investment funds can issue native digital units using distributed ledger technology while navigating the complex interplay of securities law, fund administration requirements, and digital resilience obligations. The FAQ addresses critical operational questions around registrar functions, control agent appointments, and hybrid token structures that market participants must resolve before launching DLT-based fund pr

LuxembourgFinance and Banking
Cathrine Foldberg Møller
Cathrine Foldberg Møller

On 2 October 2026, the Commission de Surveillance du Secteur Financier (CSSF) published its first FAQ on Tokenisation (Version 1), providing practical guidance for Luxembourg undertakings for collective investment (UCIs) and market participants considering the use of distributed ledger technology (DLT) to issue, store, and transfer fund units or shares. The FAQ addresses recurrent questions raised with the CSSF and covers two principal areas: the tokenisation of investment funds and the requirements applicable to control agents under Luxembourg's dematerialised securities framework. While the FAQ does not constitute an exhaustive guide, it provides critical signposts for fund managers, administrators, depositaries, and service providers navigating this evolving area.

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