Real-World Asset Tokenisation in Zug: How Switzerland Is Digitising Bonds, Real Estate, and Private Equity

Defining Real-World Asset Tokenisation

Real-world asset (RWA) tokenisation is the process of representing ownership interests in tangible or traditional financial assets — bonds, equity, real estate, infrastructure, commodities, fund units — as digital tokens on a blockchain. Unlike cryptocurrencies, which are native digital assets, tokenised RWAs are digital representations of rights that exist in the physical or legal world.

The tokenisation thesis has three components:

Legal equivalence: The digital token must be legally equivalent to the underlying asset right — not a contractual approximation, not a warehouse receipt, but a statutory security. Switzerland’s Federal Act on Distributed Ledger Technology (DLT Act), effective February 1, 2021, achieved this through the creation of the Registerwertrecht (DLT security) — a securities category that exists only on-chain but has the full legal character of a traditional security under the Code of Obligations.

Operational efficiency: Tokenised assets settle faster (T+0 vs T+2), automate corporate actions through smart contracts, enable fractionalisation (lower minimum investment sizes), and reduce the intermediary layers between issuer and investor.

Market access: Tokenisation enables assets that are structurally illiquid — private equity, infrastructure debt, commercial real estate — to be traded on secondary markets, accessing global institutional capital that traditional private market structures cannot reach.

Switzerland has moved furthest from theory to practice because it is the only jurisdiction with all three components operational simultaneously: statutory legal equivalence (DLT Act), FINMA-licensed institutional infrastructure (Sygnum Bank, AMINA Bank), and a regulated secondary market (SIX Digital Exchange).

The Legal Foundation: Registerwertrechte

The DLT Act’s creation of the Registerwertrecht (register-based right, or DLT security) is the sine qua non of Swiss RWA tokenisation. The mechanism is technically elegant and legally precise.

A Registerwertrecht is a security that:

1. Is entered in a distributed electronic register (a blockchain or equivalent DLT)
2. Gives all parties to the register access to the registered information
3. Is technically protected against modification by unauthorised parties

Once a right is issued as a Registerwertrecht, the blockchain entry IS the security. The holder of the on-chain token holds the legal right. Transfer of the token constitutes legal transfer of the right. Pledge of the token constitutes a valid pledge under Swiss law. Redemption on-chain extinguishes the right with full legal effect.

This is fundamentally different from the contractual tokenisation approaches used in jurisdictions without DLT securities law. In many jurisdictions, a “tokenised bond” is actually a contractual claim against the issuer that is tracked using a token — the token is evidence of the claim, not the claim itself. Swiss Registerwertrechte are the claim. The distinction matters enormously for insolvency treatment, transfer mechanics, and collateral enforceability.

The DLT Act also provides statutory insolvency segregation for custodied crypto assets: client tokens held by a FINMA-licensed custodian are segregated from the custodian’s insolvency estate, providing statutory client protection that contractual structures cannot replicate.

Three RWA Structures Under Swiss Law

Swiss practitioners and regulators have identified three primary structures for tokenising real-world assets, each with distinct regulatory treatment under FINMA’s framework:

Structure 1: DLT Security (Registerwertrecht)

The purest form of Swiss RWA tokenisation. The asset right — bond, equity, fund unit — is issued directly as a Registerwertrecht under the DLT Act. No underlying paper instrument exists; the on-chain record is the primary and only instrument.

FINMA classification: An asset token (Anlage-Token) — representing rights in assets or cashflows and functionally equivalent to an equity or debt instrument. Subject to Swiss securities law.

Regulatory requirements: Issuers of DLT securities need a FINMA-licensed counterparty (Sygnum, AMINA, or SDX) to issue and custody the instruments. The securities themselves require compliance with Swiss FinSA (prospectus requirements for public offerings) and FinMIA (trading facility requirements for secondary market access).

Who uses it: Sygnum’s tokenised equity and bond products; SDX-listed tokenised bonds from Swiss issuers including UBS and Julius Baer.

Structure 2: Tokenised Fund Unit

Collective investment scheme units can be issued as DLT securities under the DLT Act’s framework. Tokenised fund units are structurally similar to traditional CISA-regulated fund units but with on-chain settlement.

FINMA classification: Collective investment scheme units — regulated under the Collective Investment Schemes Act (CISA) regardless of whether they are DLT-based. The CISA framework applies; the DLT Act provides the technical mechanism for on-chain issuance.

Regulatory requirements: The fund itself requires FINMA authorisation as a collective investment scheme. The fund manager requires FINMA authorisation as an asset manager of collective investment schemes. DLT mechanics require an approved custodian (typically Sygnum or AMINA).

Who uses it: Sygnum’s tokenised fund products; institutional fund managers working with Swiss digital asset banks to offer DLT-settled fund units.

Structure 3: Payment Token Representation

Some RWA tokenisation structures use a payment token to represent claims rather than creating Registerwertrechte — typically because the underlying asset is a commodity or currency equivalent (such as a gold-backed token or a stablecoin pegged to a traditional asset).

FINMA classification: Payment tokens, if the primary function is payment or value transfer. However, if the token gives holders claims on the issuer (redemption rights, yield), FINMA may re-classify it as an asset token with banking act implications.

Regulatory complexity: Payment token RWA structures are the most legally complex because they sit at the boundary of FINMA’s token classification framework. The distinction between a payment token and an asset token depends on the specific rights conferred — a detail that requires precise legal structuring.

Landmark Transactions

SIX Digital Exchange: Swiss Bond Tokenisation at Scale

SDX has established itself as the primary venue for Swiss institutional bond tokenisation. Notable transactions include:

SIX Group bond (2020): SIX Group itself issued a digital bond on SDX — the first institutional bond issued and settled natively on a regulated blockchain securities exchange.

UBS tokenised bond: UBS, Switzerland’s largest bank, issued a tokenised bond on SDX, settling in a combination of SDX’s infrastructure and digital Swiss franc (d-CHF) — a wholesale CBDC tested by the Swiss National Bank (SNB) for Project Helvetia.

Julius Baer: Julius Baer’s participation in SDX-listed instruments demonstrates that Swiss private banking’s tier-one institutions are direct participants in the DLT securities market, not merely observers.

The SNB’s Project Helvetia experiments with wholesale CBDC settlement for SDX-listed instruments is particularly significant: it means that DLT securities on SDX can be settled in central bank money — the gold standard for institutional settlement — not just commercial bank deposits or stablecoins.

Sygnum: Tokenised Shares and Private Equity

Sygnum has built the most institutionally comprehensive tokenisation platform in the Crypto Valley ecosystem. Notable milestones include:

Tokenised shares in blockchain companies: Sygnum has issued tokenised equity in blockchain ecosystem companies, enabling its institutional client base to access private company exposure in DLT security form through its banking infrastructure.

$50 million Bitcoin-backed syndicated loan (August 2024): While not a tokenised RWA per se, this landmark transaction demonstrated Sygnum’s ability to structure institutional lending products using digital assets as collateral within FINMA’s regulatory framework — establishing crypto assets as recognised collateral in Swiss banking.

B2B platform tokenisation: Sygnum’s B2B platform, which serves 20+ Swiss banks, enables those institutions to offer tokenised securities products to their own clients — significantly expanding the distribution of Swiss DLT securities beyond Sygnum’s direct client base.

Helvetia III: The Wholesale CBDC Connection

The SNB’s Project Helvetia Phase III (2024) explored the operational integration of wholesale digital Swiss francs (w-CHF) into SDX’s settlement infrastructure. Unlike retail CBDCs (which involve central bank accounts for individuals), wholesale CBDC is issued to financial institutions for interbank and securities settlement.

Project Helvetia III demonstrated live settlement of tokenised bonds on SDX using w-CHF issued by the SNB. This is the most advanced integration of central bank money with DLT securities settlement infrastructure demonstrated anywhere in the world — and it positions Switzerland as the first jurisdiction to operationally link its central bank with its regulated blockchain exchange.

Institutional Adoption: Global Signals Amplifying Swiss Leadership

Switzerland’s RWA tokenisation infrastructure exists within a global trend toward institutional adoption that amplifies its significance:

BlackRock BUIDL Fund: In March 2024, BlackRock — the world’s largest asset manager with $10 trillion in AUM — launched the BlackRock USD Institutional Digital Liquidity Fund (BUIDL) on Ethereum. BUIDL is a tokenised money market fund that invests in US Treasury bills and repo agreements. Within months of launch, BUIDL exceeded $500 million in AUM, making it the largest tokenised fund in existence. BlackRock’s participation sends an unambiguous signal: institutional asset management is moving toward tokenised structures.

UBS tokenised money market fund: UBS partnered with tokenisation infrastructure providers to offer a tokenised money market fund on Ethereum — a direct institutional-grade competitor to BlackRock BUIDL and a further signal of tier-one bank participation.

Franklin Templeton BENJI: Franklin Templeton’s BENJI fund — a tokenised US Government money market fund operating on multiple chains — preceded BUIDL and has been used by Franklin as a proof-of-concept for the operational efficiency of tokenised fund settlement.

These global developments validate the tokenisation infrastructure Switzerland has been building since 2021. Swiss institutions are not ahead of the curve in isolation — they are positioned to serve the global institutional RWA market as the regulatory and infrastructure leader.

The Companies Building Swiss RWA Infrastructure

Tokenestate

Tokenestate is a Zug-based tokenisation platform focusing on real estate and private equity. The company structures tokenised real estate products using Swiss law, leveraging the DLT Act’s framework for property-linked DLT securities. Tokenestate’s approach addresses one of Swiss real estate tokenisation’s persistent challenges: integrating blockchain-based ownership records with cantonal land registries that remain paper-based.

Obligate

Obligate is a Swiss-based on-chain bond issuance platform building infrastructure for DeFi-native corporate debt. Obligate’s model uses blockchain-based bond issuance to connect institutional borrowers (typically established companies seeking working capital) with on-chain liquidity providers. The company has positioned itself at the intersection of traditional Swiss corporate finance and DeFi capital pools.

Incore Bank

Incore Bank (previously InCore Bank) is a Swiss B2B bank providing white-label banking services to financial intermediaries. Incore has developed tokenisation capabilities enabling its financial intermediary clients to offer DLT security products to their own end clients — broadening the distribution of Swiss tokenised assets through the traditional intermediary banking structure.

Aktionariat

Aktionariat is a Zug-based startup providing tokenisation infrastructure specifically for SMEs — enabling small and medium-sized Swiss companies to issue tokenised equity to employees, investors, and secondary market participants without the complexity and cost of traditional capital market processes. Aktionariat’s model addresses the long tail of private company tokenisation: not the $100M+ private equity funds that Sygnum serves, but the CHF 2-50 million equity rounds of Swiss growth companies.

FINMA’s Classification Impact on RWA Structures

FINMA’s token classification framework — payment tokens, utility tokens, asset tokens — has direct consequences for every RWA tokenisation structure. The critical determination is whether a token constitutes an asset token (and therefore a security) or a payment token (and therefore potentially subject only to AML regulation).

For most RWA tokenisation structures, the answer is clear: a tokenised bond, equity stake, or fund unit confers rights on the holder that are economically equivalent to securities — cash flows, redemption rights, governance participation. FINMA classifies these as asset tokens, triggering Swiss securities law compliance requirements.

The banking act implications are most acute for tokenised money market funds and stablecoin-adjacent structures: if an issuer accepts the equivalent of deposits (e.g., investors subscribe to a tokenised fund that invests in cash equivalents) without a Swiss banking licence, this may constitute regulated deposit-taking. The Swiss RWA ecosystem has navigated this by channeling issuance through FINMA-licensed banks (Sygnum, AMINA) or under the specific CISA framework for regulated funds.

2025–2030 Market Size Projections

Market participants and research organisations have offered substantial projections for the RWA tokenisation market:

• Boston Consulting Group (BCG): Projected the global tokenised asset market at $16 trillion by 2030 — representing approximately 10% of global GDP
• BlackRock CEO Larry Fink: Stated in public remarks that “every asset will eventually be tokenised”
• McKinsey: More conservative projection of $2 trillion in tokenised assets by 2030, with bonds and funds as the primary asset classes

Switzerland’s share of this market is not determined by geography but by regulatory infrastructure. Swiss institutions — Sygnum, AMINA, SDX, and the expanding network of FINMA-licensed intermediaries — are positioned to provide the issuance, custody, and trading infrastructure for a significant share of the global institutional market, regardless of where the underlying assets are located.

The key differentiator: Swiss Registerwertrechte have statutory legal certainty in multiple jurisdictions’ conflict-of-law frameworks. An investor holding a Swiss DLT security can rely on Swiss law for enforcement, regardless of their jurisdiction of residence. This legal portability makes Swiss RWA structures attractive for cross-border institutional transactions in ways that jurisdiction-specific tokenisation frameworks cannot replicate.

Frequently Asked Questions

What is a real-world asset (RWA) in the context of blockchain? A real-world asset (RWA) is a traditional financial or physical asset — such as a bond, equity stake, real estate interest, or fund unit — whose ownership or economic rights are represented as a digital token on a blockchain. In Switzerland, the most legally robust RWA tokenisation uses the DLT Act’s Registerwertrecht structure, which creates a statutory security that exists only on-chain but has full legal equivalence to a traditional instrument.

How does Switzerland’s DLT Act enable RWA tokenisation? The Swiss DLT Act (effective February 1, 2021) created the Registerwertrecht — a new legal category of security that exists as an entry on a distributed electronic register. This statutory foundation means Swiss tokenised securities are not contractual approximations but true legal securities. The Act also provides statutory insolvency segregation for custodied crypto assets, strengthening client protection for DLT security holders.

Which Swiss banks can issue tokenised RWAs? Sygnum Bank AG (FINMA banking and securities dealer licence since 2019) and AMINA Bank AG (also FINMA-licensed since 2019) are the two Swiss banks authorised to issue, custody, and trade DLT securities within FINMA’s regulatory framework. SIX Digital Exchange (SDX), which holds the world’s first DLT trading facility licence, provides the regulated secondary market for DLT securities.

What types of assets are being tokenised in Switzerland today? As of 2025, Swiss institutional tokenisation is most active in: corporate bonds (SDX-listed instruments from UBS, Julius Baer, and others), private equity (Sygnum’s tokenisation platform), and fund units (tokenised collective investment scheme units with intraday settlement). Real estate tokenisation is developing but faces structural challenges around cantonal land registry integration.

How does Swiss RWA tokenisation compare to EU and US approaches? Switzerland’s DLT Act provides permanent statutory rights for DLT securities — unlike the EU’s DLT Pilot Regime (a temporary sandbox) or US securities law (which has not specifically adapted for on-chain securities). Switzerland’s combination of statutory framework, FINMA-licensed banks, and a live regulated exchange (SDX) makes it the most operationally complete RWA tokenisation jurisdiction globally.

Internal Links

• The Swiss DLT Act: How Switzerland Legalised Tokenised Securities
• Tokenisation in Switzerland: Real-World Assets on Blockchain
• Sygnum Bank: The World’s First Regulated Digital Asset Bank
• AMINA Bank AG: From SEBA to Switzerland’s Second Digital Asset Bank
• FINMA Crypto Banking Framework: How Switzerland Licences Digital Asset Banks
• Encyclopedia: DLT Securities