Since 1 February 2021, Swiss law has allowed the introduction of ledger-based securities recorded on a blockchain. This is the legal basis for tokenising the shares of a company limited by shares (SA). The Federal Council brought this part of the law on distributed ledger technology (DLT) into force on 11 December 2020. Such projects remain regulated: for the Swiss Financial Market Supervisory Authority (FINMA), a token representing a share is a security.
This page is part of our blockchain and tokenisation section. It answers a single question: how a Swiss SME turns its shares into tokens, and what makes the cost vary.
What has Swiss law allowed since 2021?
In September 2020, Parliament adopted the Federal Act on the Adaptation of Federal Law to Developments in Distributed Ledger Technology. The text of the Federal DLT Act is a single enactment: it amends several federal laws at once.
The Federal Council brought it into force in two stages. On 1 February 2021, it brought into force the amendments to the Code of Obligations (CO), the Federal Intermediated Securities Act and the Federal Act on Private International Law. These are what allow the introduction of ledger-based securities recorded on a blockchain. Its press release of 11 December 2020 announced the other provisions for 1 August 2021.
Before this reform, FINMA pointed to uncertainty under civil law. In its guidelines of 16 February 2018 on token-based fundraising (initial coin offerings, ICOs), it questioned whether the rights attached to a token could be transferred and enforced. In its view, clarity in civil law would be "a decisive condition" for the lasting growth of blockchain in Switzerland.
Is a tokenised share a security?
Yes, as a rule. FINMA classifies tokens according to their economic function and their transferability. It distinguishes three types, with hybrid forms possible: payment tokens, utility tokens and asset tokens.
A token that represents a stake in a company or a right to dividends is an asset token. From an economic perspective, FINMA regards it as a share, a bond or a derivative financial instrument. It therefore treats it as a security, with the consequences that entails for its trading.
This classification brings disclosure obligations. According to FINMA, it generally entails obligations under the Code of Obligations, for example the obligation to draw up a prospectus. Anti-money laundering rules come on top of this: FINMA considers this risk to be high when assets circulate anonymously on a decentralised system.
These guidelines date from 2018, before the DLT Act. They set out the supervisory authority's reading grid, not the civil-law regime for ledger-based securities.
What are the steps to tokenise the shares of an SA?
The official sources consulted outline a process in five stages. They do not detail the company-law formalities, such as amending the articles of association or registering the ledger-based securities: these requirements are set out in the Code of Obligations.
- Classify the token. Its function and transferability determine the applicable regime, according to FINMA's grid.
- Prepare investor information. An asset token generally entails obligations under the CO, such as a prospectus.
- Take anti-money laundering rules into account. The law imposes due diligence obligations on financial intermediaries, such as identifying beneficial owners.
- Choose the infrastructure. Trading, custody and settlement of tokens according to common rules fall to an authorised operator.
- Find a financial partner. Few Swiss institutions offered share tokenisation in the third quarter of 2026.
How do you choose a platform for tokenised shares?
A platform that circulates DLT-based securities may need authorisation from FINMA. This status of DLT trading facility is governed by the Financial Market Infrastructure Act (FinMIA), in chapter 4a, art. 73a et seq.
Authorisation is required as soon as one of these three activities is carried out:
- multilateral and professional trading of DLT-based securities, open to retail clients;
- custody of these securities according to common rules and procedures;
- clearing and settlement of transactions according to common rules and procedures.
The operator must be a legal entity under Swiss law, with its registered office and effective management in Switzerland. FINMA grants the authorisation and publishes guidelines for the application. A project can be presented to it before filing, at fintech@finma.ch.
For the issuing SME, a first check is to verify the platform's status. The FINMA website has an "Authorised institutions" section.
The token's legal model matters as much as the platform. Abroad, some products are certificates. At Coinbase, each token represents a certificate issued by a dedicated entity, and the shares remain with the broker Alpaca. Dividends are reinvested after fees, and the token does not necessarily confer the same rights as the share, notably voting rights. Our article on tokenised shares according to Token Terminal describes this market, valued at 3.9 billion dollars on 12 October 2026.
Other ranges target listed securities. Backed Finance's xStocks range launched with some sixty US-listed stocks and exchange-traded index funds (ETFs), as our analysis of tokenisation on Solana points out.
How much does it cost to tokenise the shares of an SA?
The official sources consulted do not put a figure on the cost of tokenising shares. They do, however, make it possible to identify what determines it. The bill depends above all on the role the SME chooses to play: issuing its tokens or operating a platform itself.
| Item | What determines it | Figure in the sources |
|---|---|---|
| Token classification | Economic function and transferability of the token | None |
| Investor information | CO obligations, generally a prospectus | None |
| Authorised platform | Services chosen: trading, custody, settlement | No pricing |
| Anti-money laundering | Due diligence obligations, identification of beneficial owners | None |
| Own authorisation, if the SME operates the platform | Fees, review by an audit firm, complexity of the application | Amounts not stated |
The heaviest scenario is that of a company that itself operates a DLT trading facility. FINMA then requires a review by an audit firm for any authorisation of this kind. The procedure is subject to fees, governed by the ordinance on fees. Its duration depends on the complexity of the project and on the quality and completeness of the application.
An SME that uses an existing platform does not bear this burden. Its cost depends on the services chosen and on the information to be provided to investors. A quote that separates issuance, custody and trading helps compare offers.
Do Swiss banks offer share tokenisation?
Still rarely. The Swiss Blockchain Survey 2026 by the University of St. Gallen (HSG) surveyed 25 institutions in Switzerland and Liechtenstein in the third quarter of 2026. Only 8% offer the tokenisation of shares or fund units, 12% are planning it and 80% have no plans.
The obstacles are mainly commercial. 63% of institutions cite a lack of strategic priority or business model, 58% weak client interest. Regulatory or compliance requirements follow, at 46%. The sample is small: one institution weighs 4 points. Our report on the Swiss Blockchain Survey 2026 gives the details.
The large universal banks, such as UBS, have bet on tokenised bonds, structured products and money market funds. For an SME, the Swiss banking offer for share tokenisation therefore remains narrow.
Key figures
- 11 December 2020: the Federal Council partially brings the DLT Act into force.
- 1 February 2021: entry into force of ledger-based securities recorded on a blockchain (CO, intermediated securities, private international law).
- 3 types of tokens distinguished by FINMA in its guidelines of 16 February 2018: payment, utility, asset.
- 3 activities trigger the DLT trading facility authorisation: trading, custody, settlement.
- 8% of the 25 institutions surveyed offer the tokenisation of shares or fund units (third quarter of 2026).
- 3.9 billion dollars: capitalisation of the tokenised shares tracked by Token Terminal as of 12 October 2026.
What we do not know yet
- The total cost of share tokenisation for an SME: none of the sources consulted puts a figure on it, nor on platform pricing.
- The amount of FINMA's fees for a DLT trading facility authorisation: its page refers to the ordinance on fees without giving a figure.
- The number of Swiss SAs that have already issued ledger-based securities: the sources consulted do not give it.
- Switzerland's share of the 3.9 billion dollars in tokenised shares: the source does not break it down.
This information describes a legal framework and does not constitute an investment recommendation.
