Luxembourg has passed four blockchain laws since 2019, each building on the last. The most recent removed a whole layer from the custody chain. What none of them hands you is the platform, and that’s where we come in.
Whilst other markets are working out whether a blockchain can directly hold a security on-chain. Luxembourg answered that in 2019 and has spent six years refining the framework.
Blockchain I in 2019 recognized DLT (Distributed Ledger Technology) whereby the blockchain itself is used to maintain the securities register for registered financial instruments. II in 2021 allowed issuance on a blockchain. III in 2023 covered collateral and the EU pilot regime. IV took effect at the end of 2024 covering the full tokenization cycle.
A new role that maintains the issuance account on the blockchain, monitors the ownership chain and reconciles issued against held securities. A bank, investment firm or a settlement organisation can be the transfer agent.
The control agent has no custody relationship with the downstream custodians. Securities can be issued broadly while one party keeps the issuance record straight through reconciliation. Fewer intermediaries, lower cost.
The issuer notifies the regulator of the control agent appointment at least two months before it starts. The regulator checks professional experience, internal governance and IT systems.
The 2024 law widened the framework to equity securities, including shares, partnership interests and fund units, and to the tokenisation of physical assets such as real estate.
What you own and what you want to raise. We say plainly whether this fits, including when it does not.
Our local partner picks the vehicle and the instrument, and identifies who will act as transfer agent for the issuance. That appointment comes two months prior to the issuance, so it comes first.
The legal work and the launch run in parallel. In Luxembourg the pace is set by setting up the vehicle and by the two month notice period for the control agent appointment. Your lawyer starts on day one.
Yes, and it has been settled for years. Four blockchain laws since 2019 recognise DLT for registering, issuing and transferring securities, and the 2024 law extended the framework to equity securities, fund units and physical assets including real estate.
You notify rather than apply. The issuer notifies the regulator at least two months before the control agent starts, and the regulator checks professional experience, internal governance and IT systems.
A role created by the 2024 law. It maintains the issuance account on the blockchain, monitors the ownership chain and reconciles issued against held securities, without holding custody for investors. A bank, investment firm or settlement organisation acts as the reconciling party.
It decouples the issuance record from custody. Securities can be distributed broadly while one party maintains transaction integrity, so the number of intermediaries in a fund drops and so does the cost.
Last updated: 12-08-2026
The information on this page is for general informational purposes only and does not constitute legal, financial, investment, or tax advice.
Tokenizer.Estate provides a platform for real estate tokenization and connects you with licensed local partners, but we do not provide legal or regulatory guidance.
Please consult qualified professionals in your jurisdiction before making any investment or tokenization decisions.