What the DLT Pilot Regime means for tokenized property
Europe’s framework for on-chain securities does not tokenize buildings directly. It tokenizes the securities that own them, and that distinction shapes every serious property token.
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- The DLT Pilot Regime, in force since 23 March 2023, lets licensed infrastructures trade and settle tokenized shares, bonds and fund units. It does not cover property itself.
- A tokenized property in the EU is therefore usually a security: shares or notes of a company that owns the asset, issued as tokens to verified holders.
- Proposals from December 2025 would raise the cap from €6bn to €100bn, open the regime to all financial instruments and remove time limits. They are not yet law.
What the regime is
The DLT Pilot Regime (Regulation (EU) 2022/858) is the EU’s framework for trading and settling financial instruments on distributed ledgers. It creates three kinds of licence: a DLT multilateral trading facility, a DLT settlement system, and a combined trading and settlement system. Licensed operators get targeted exemptions from rules written for traditional markets.
It was designed as a pilot, with tight limits. Under the current rules, shares must come from issuers worth less than about €500 million, bond issues must be below about €1 billion, and each infrastructure can hold no more than about €6 billion of tokenized instruments in total.
Where property fits
The regime covers financial instruments, not physical assets. A token that gives its holder a share of a building’s rental income or value will generally be treated as a security under EU rules. So the practical structure looks like this: the property sits in a dedicated company, that company issues shares or notes, and those are represented as tokens on a permissioned ledger with verified holders.
This is why serious property tokenization in Europe looks more like a small, digital securities issue than a crypto launch. The legal work sits in the structure and the documentation. The blockchain handles issuance, record-keeping and settlement.
The Portuguese angle
Portugal implemented the regime through Decree-Law 66/2023, and the securities regulator, the CMVM, grants and revokes licences for DLT trading and settlement systems. Law 69/2025, enacted on 22 December 2025, brought the EU’s crypto-asset rules (MiCA) into Portuguese law and set out the CMVM’s role there too.
Combined with an active property market and international buyers, that gives Portugal a clear point of contact for tokenized property, even if the first property-backed issues are still to come.
What would change
In December 2025 the European Commission proposed a broad update as part of its market integration package. The cap per infrastructure would rise from €6 billion to €100 billion, the asset-specific limits would go, every type of financial instrument would become eligible, and licences would no longer be time-limited. Most changes would apply 12 months after the law takes effect, and the proposals still need agreement from the European Parliament and the Council.
Settlement is moving in parallel. The Eurosystem has said it is working to allow DLT transactions to settle in central bank money. If both arrive, tokenized property could move from a pilot to a market.
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What we’re watching
- Negotiations on the December 2025 proposals in the Parliament and the Council.
- The first property-backed issues on licensed DLT infrastructures in the EU.
- Progress on settlement in central bank money for DLT transactions.
- CMVM guidance on tokenized instruments in Portugal.
Sources
For general information only. Not investment, financial, legal or tax advice, and not an offer or solicitation. Figures are taken from the sources listed on the date of publication and may change. See our privacy policy and information notice.
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