Author: Liang Yu
Editor: Zhao Yidan
The global market for the tokenization of real-world assets (RWA) is experiencing an unprecedented phase of rapid growth. According to predictions from the Head Leopard Research Institute, by 2029, the global RWA market is expected to exceed $2.4 trillion, with real estate and fixed income products being the main drivers of this growth. Against this backdrop, different jurisdictions have adopted varying regulatory strategies, showing a clear trend of differentiation: the "strong regulation, safety first" model represented by the United States, the United Kingdom, and Japan, and the "innovation-oriented, pilot-first" model represented by Singapore, the UAE, and South Korea.
Switzerland, with its long-standing financial tradition, stable political environment, and flexible and pragmatic regulatory philosophy, exhibits a unique "gradual compliance" characteristic in the RWA field. In contrast to the EU's approach of establishing unified standards through MiCA and the fragmented enforcement relied upon by the United States, Switzerland has adopted a balanced and gradual development strategy. This strategy ensures the stability of the financial system while providing sufficient growth space for innovation, making it an ideal case study for researching the digital transformation of traditional financial bastions. However, Switzerland still lags behind traditional financial centers like the United States in terms of market depth and capital scale, and the cross-border acceptance of its legal framework remains to be tested.
The RWA Research Institute is honorably releasing a series of in-depth research reports titled "Global RWA Compliance Landscape Overview." This series aims to study the regulatory legal policies, major regional projects, protocol technology construction, and architectural design of cryptocurrencies in major regulatory countries/regions such as the United States, Hong Kong, Singapore, Dubai in the UAE, Thailand, and Germany, attempting to provide readers with profound and comprehensive insights.
This is the fourth article in our series.
Chapter 1: The Evolution of Legislative Concepts: How Switzerland Balances Innovation and Compliance in the RWA Field
Global digital financial regulation is undergoing a fundamental shift in core concepts, with legislative bodies gradually transitioning from the initial principle of technological neutrality to a proactive regulatory framework that empowers new technologies legally. In this transition, Switzerland, with its long-standing financial tradition and flexible and pragmatic regulatory philosophy, demonstrates a unique gradual compliance characteristic in the tokenization of real-world assets, contrasting sharply with the EU's path of establishing unified standards through MiCA, providing an ideal case study for the digital transformation of traditional financial bastions.
1. Legislative Background: Constraints of Traditional Regulations and the Demand for Innovation
When distributed ledger technology (DLT) and crypto assets emerged, the existing legal framework was not prepared for them. The EU's financial services legislation was initially not designed for DLT or digital assets, leading to existing legal provisions that could hinder or restrict the use of DLT in the issuance, trading, and settlement of financial instruments. Most crypto assets previously fell outside the scope of EU financial services legislation, posing challenges in investor protection, market integrity, and financial stability.
Regulatory agencies recognized the need for dual action: on one hand, to fill regulatory gaps and address emerging risks, and on the other hand, to seize the efficiency enhancement opportunities brought by DLT technology. The International Organization of Securities Commissions pointed out the cross-border nature of crypto asset market activities, the risks of regulatory arbitrage, and the significant harm risks faced by retail investors, highlighting the urgent need for more consistent regulation and oversight.
In contrast, Switzerland adopted a more gradual legislative strategy. Since 2016, the Swiss Federal Government has deliberately implemented progressive policies to promote the development of the blockchain and digital asset industry. This strategic approach has made Switzerland a preferred destination for innovative enterprises in this field, characterized by a structured legal framework that allows cryptocurrencies to be used as legal means of payment.
2. Adherence to and Development of the Principle of Technological Neutrality
Technological neutrality has long been a principle of financial services legislation. When formulating a new framework for DLT and crypto assets, Switzerland is committed to maintaining an open attitude towards technological choices while embracing innovation.
The design of the Swiss DLT bill embodies the principle of technological neutrality, introducing neutral wording that avoids mentioning specific types of DLT and requiring operators of DLT market infrastructure to comply with all applicable requirements regardless of the technology used. The principle of equal risk for similar activities further reinforces this idea, with regulatory focus on the activities and risks generated by crypto asset service providers rather than the underlying technology itself.
However, the principle of technological neutrality also has limitations, as regulatory agencies acknowledge that different DLT technologies may present different risks and regulatory requirements. The Hong Kong Securities and Futures Commission noted that issuing bearer tokens on public non-permissioned networks could lead to higher cybersecurity and money laundering risks, necessitating stricter risk prevention and management measures.
3. The Practice of the Legal Empowerment Concept
Legal empowerment is reflected in providing a clear legal path and necessary flexibility for the innovation of DLT and crypto assets through proactive regulatory intervention. Switzerland has put this concept into practice with the implementation of the Distributed Ledger Technology Act in 2021, making it one of the first countries globally to provide a comprehensive legal framework for DLT.
The Swiss DLT Act introduces a new legal category of "non-physical registered securities," formally recognizing the legal enforceability of blockchain-based securities. According to the definition in the act, non-physical registered securities refer to rights and claims electronically registered on DLT, possessing the same legal functions and levels of protection as transferable securities. Asset tokens, utility tokens, hybrid tokens, and stablecoins can all be issued in the form of these non-physical registered securities.
Compared to the EU's DLT financial instruments and Hong Kong's tokenized securities concepts, Switzerland's non-physical registered securities represent a more thorough legal innovation. However, this new legal category faces challenges in practice. How other jurisdictions recognize and apply Switzerland's non-physical registered securities in cross-border investments still requires further judicial clarification and international coordination.
4. Differences in Legislative Paths Between Switzerland and the EU
Switzerland's legislative path in the RWA field presents an interesting contrast to that of the EU. The EU constructs unified standards through the Markets in Crypto-Assets Regulation (MiCA), while Switzerland adopts a balanced and gradual development strategy. This strategy ensures the stability of the financial system while providing sufficient growth space for innovation.
As the EU's MiCA serves as the first comprehensive cryptocurrency regulation in the EU, it provides a legal framework for crypto assets that were previously not covered by traditional laws, requiring token issuers and crypto asset service providers to obtain authorization to provide services in the EU. In contrast, Switzerland gradually incorporates DLT and crypto assets into its existing regulatory framework through the revision and improvement of its current legal system, reflecting its gradual regulatory philosophy.
Notably, in June 2025, the EU and Switzerland reached an agreement to modernize their cooperation framework, marking an important step towards a closer cooperative relationship in various fields, including financial regulation. This development helps Switzerland maintain its regulatory characteristics while achieving legal coordination with the EU.
5. The Forward-looking and Flexible Nature of Swiss Legislation
Swiss legislative bodies demonstrate a profound understanding of the balance between financial innovation and financial stability. Their legislative philosophy is not to solve all problems with a single comprehensive law but to construct a framework of fundamental principles that reserves space for future technological developments and market changes. This flexibility allows Switzerland to remain agile in the rapidly changing digital asset field.
The creation of a new type of license for DLT trading systems represents another significant innovation in the Swiss regulatory framework. This type of license allows for integrated services of trading, clearing, settlement, and asset custody for DLT securities without the need to apply for multiple additional licenses. This model breaks the traditional financial practice of separating functions for risk management and competitive reasons.
In terms of regulatory flexibility, Switzerland's model and the EU's DLT pilot system each have their unique characteristics. The EU system provides a temporary exemption mechanism that allows DLT market infrastructure to be exempt from certain traditional requirements under specific conditions, but must comply with compensatory measures. Switzerland, on the other hand, directly grants legal status to integrated services through the new type of license, reflecting a more thorough regulatory innovation.
As the EU's MiCA regulation comes into full effect in 2025, Switzerland is actively adjusting its framework to maintain compatibility with the EU. This coordination facilitates Swiss RWA projects entering a broader European market, and with its unique gradual compliance regulatory framework, Switzerland provides an ideal case study for the digital transformation of traditional financial bastions.
Chapter 2: Building the Legal Foundation for the RWA Digital Property System
Switzerland's legal breakthroughs in the RWA field are primarily reflected in the implementation of the Distributed Ledger Technology Act in 2021. This act positions Switzerland among the first countries globally to provide a comprehensive legal framework for distributed ledger technology, but its innovativeness needs to be objectively assessed in the context of global regulatory innovation.
1. Establishing the Legal Status of Blockchain-based Securities
The core challenge faced by digital assets in legal terms is how to achieve legal certainty and transferability similar to traditional securities and real estate, especially in the face of the "principle of property law" commonly found in civil law systems.
The Swiss DLT Act introduces the new legal category of "non-physical registered securities," formally recognizing the legal enforceability of blockchain-based securities. According to the act's definition, non-physical registered securities refer to rights and claims electronically registered on DLT, possessing the same legal functions and levels of protection as transferable securities. Asset tokens, utility tokens, hybrid tokens, and stablecoins can all be issued in the form of these "non-physical registered securities."
Compared to the EU's "DLT financial instruments" and Hong Kong's "tokenized securities" concepts, Switzerland's "non-physical registered securities" represent a more thorough legal innovation. However, this new legal category faces challenges in practice. How other jurisdictions recognize and apply Switzerland's "non-physical registered securities" in cross-border investments still requires further judicial clarification and international coordination. This means that an RWA token fully compliant in Switzerland may face uncertainty regarding its legal effectiveness in cross-border scenarios.
2. Innovation of the New Type of License for DLT Trading Systems
The creation of a new type of license for DLT trading systems represents another significant innovation in the regulatory framework. This type of license allows for integrated services of trading, clearing, settlement, and asset custody for DLT securities without the need to apply for multiple additional licenses. This model breaks the traditional financial practice of separating functions for risk management and competitive reasons.
Similar to the EU's DLT pilot system, Switzerland's DLT trading system license reflects the advantages of business integration. It allows investment companies/market operators or central securities depositories to simultaneously provide trading and settlement services to achieve the efficiency improvements brought by DLT. However, this license requires the operating entity to have its headquarters located in Switzerland, which poses certain entry and operational costs for multinational projects wishing to operate in a light-asset model.
In terms of regulatory flexibility, Switzerland's model and the EU's DLT pilot system each have their unique characteristics. The EU system provides a temporary exemption mechanism that allows DLT market infrastructure to be exempt from certain traditional requirements under specific conditions, but must comply with compensatory measures. Switzerland, on the other hand, directly grants legal status to integrated services through the new type of license, reflecting a more thorough regulatory innovation.
3. The Fundamental Support Role of the Financial Market Infrastructure Act
In constructing the regulatory framework, the Financial Market Infrastructure Act, implemented in 2016, serves as a higher law that provides foundational support for the stability and order of the Swiss financial market. This law aims to regulate the organization and operation of financial market infrastructures (FMIs) such as securities exchanges, central counterparties, central securities depositories, trade repositories, and payment systems to ensure the stability and efficiency of the financial market.
The reporting obligations stipulated by the law have also been adjusted accordingly. According to Article 39, transactions involving securities authorized for trading on Swiss trading venues must be reported to the relevant Swiss trading venue. Participants in DLT trading systems, as new trading venues, are still required to fulfill this reporting obligation. Additionally, transactions in derivatives must be reported to a FINMA (Swiss Financial Market Supervisory Authority) authorized or recognized trade repository as stipulated in Article 104.
In practice, Swiss RWA projects typically use special purpose vehicles (SPVs) as legal entities to achieve effective isolation between real assets and token issuers, ensuring bankruptcy protection for the assets. Token holders indirectly hold ownership or rights to the underlying assets through the SPV, a structure that has received explicit recognition from FINMA. The exercise of investor rights is achieved through a combination of smart contracts and traditional legal documents, leveraging the automation advantages of blockchain technology while ensuring legal enforceability.
Chapter 3: Regulatory Landscape and Compliance Framework
The Swiss Financial Market Supervisory Authority (FINMA) is known for its strict yet pragmatic regulatory style, which reflects an organic combination of the "same risk, same rules" principle and the proportionality principle. This regulatory philosophy allows Switzerland to maintain financial stability while providing appropriate development space for innovation.
1. FINMA's Regulatory Philosophy and Practice
FINMA's regulatory philosophy emphasizes a risk-based and flexible approach while maintaining financial stability and investor protection. Although the term "same risk, same rules" is not directly used in the documentation, FINMA's regulatory approach achieves risk-neutral and outcome-consistent regulatory goals through the practice of the "proportionality principle" and "risk-based" methods.
In terms of prudential regulation, FINMA categorizes financial market participants into different regulatory categories based on their size, importance, and risk profile. Larger, systemically important institutions face stricter regulatory requirements, including higher capital adequacy ratios, liquidity standards, and risk management requirements. In contrast, smaller, lower-risk institutions are subject to simplified regulatory standards, effectively balancing the dual goals of risk prevention and innovation promotion.
However, in the realm of conduct regulation, FINMA adheres to the principle of equal treatment, providing no regulatory exemptions. Whether it is anti-money laundering regulations, customer protection in financial services, or market conduct norms in securities trading, these requirements apply regardless of the size of the financial institution. All institutions across regulatory categories must equally comply with the same conduct standards to ensure the overall integrity of the financial market.
2. Sandbox Regulation and Case Communication Mechanism
FINMA adopts a flexible and innovative regulatory approach in the fintech and DLT sectors, supporting industry development through regulatory dialogue and case-specific authorization mechanisms. Although Switzerland does not have a formally named "regulatory sandbox" project like the UK, its DLT Act and specific authorization systems serve a similar purpose.
The specific authorization category for FinTech established by FINMA and the specially introduced DLT trading system license provide clear access paths for innovative enterprises. Since 2015, FINMA has begun issuing licenses to blockchain and DLT companies, demonstrating a forward-looking regulatory stance.
The regulatory dialogue mechanism is an important feature of FINMA's regulatory practice. Its regulatory work includes ongoing communication with regulated entities, employing various forms of dialogue covering a range of business topics. Enforcement actions are viewed as the final step in the regulatory process, initiated only when regular inquiries, ethical persuasion, or negotiated dialogue fail to resolve issues.
3. Token Classification and Regulatory Applicability Framework
In terms of determining the nature of securities, FINMA continues to follow the token classification framework established in its 2017 "Initial Coin Offering Regulatory Guidelines," which has been incorporated into the Swiss federal legal system. According to this framework, crypto assets are divided into three categories—payment tokens represent the intrinsic value of the blockchain, such as Bitcoin; utility tokens represent rights to goods or services; and asset tokens represent financial assets like stocks and bonds, which must comply with securities law.
FINMA also acknowledges the existence of hybrid tokens and adheres to a case-by-case analysis principle to assess the economic functions and actual uses of each token, ensuring the accuracy and effectiveness of regulation. This classification framework provides clear guidance for the compliance pathways of RWA projects, enabling project parties to determine applicable regulatory requirements based on the economic substance of the tokens.
Chapter 4: Anti-Money Laundering Compliance and Financial Crime Prevention
Switzerland's Anti-Money Laundering Law applies comprehensively to RWA businesses, and the DLT Act explicitly includes DLT trading systems within its regulatory scope. In this tokenization process, DLT trading systems, custodial wallet providers, and stablecoin issuers are all clearly identified as financial intermediaries and must strictly comply with anti-money laundering legal provisions.
1. Identification and Obligations of Financial Intermediaries
Switzerland's DLT Act establishes the anti-money laundering obligations of DLT trading systems by amending existing federal laws, thereby confirming their status as financial intermediaries within the RWA ecosystem. As new trading venues, DLT trading systems are formally regarded as financial intermediaries and must adhere to the obligations set forth in the Anti-Money Laundering Law.
Similarly, custodial wallet providers that transfer payment tokens or other DLT financial instruments at the direction of clients are considered financial intermediaries providing payment transaction services and must be regulated by FINMA and fulfill due diligence obligations. Stablecoin issuers, due to their payment mechanisms and potential money laundering risks, are also regarded as financial intermediaries under the Anti-Money Laundering Law.
The Swiss Financial Market Supervisory Authority adopts a stance of not providing any regulatory exemptions in the realm of conduct regulation. This means that regardless of the size of the RWA project's operating entity, regulations regarding anti-money laundering, investor protection, market conduct, and cross-border services will be implemented equally, meeting the highest regulatory standards.
2. Core Compliance Obligations and Due Diligence
Financial intermediaries such as DLT trading systems must execute strict due diligence and disclosure requirements in the RWA field. Core compliance obligations include rigorous customer identity verification and beneficial ownership verification, which must be validated through legally binding documents to confirm the identity of contracting parties and accurately identify the ultimate beneficial owners of assets.
For customer relationships involving politically exposed persons or clients from high-risk countries, enhanced due diligence procedures must be implemented. FINMA has previously mandated that banks exercise "extra caution" when dealing with politically exposed persons as clients, and this standard equally applies to financial intermediaries in the RWA sector.
When there is suspicion of money laundering activities in business relationships, suspicious transaction reports must be submitted immediately to the Federal Police's Anti-Money Laundering Reporting Office. Furthermore, DLT trading systems, as trading venues or broker-dealers, must report transactions involving securities authorized for trading on Swiss trading venues to the relevant Swiss trading venue in accordance with Article 39 of the Financial Market Infrastructure Act.
3. Special Risks of DLT Technology and Regulatory Responses
Swiss regulatory authorities recognize the challenges posed by the inherent characteristics of DLT technology to anti-money laundering efforts. The primary risk associated with crypto assets arises from the decentralized and anonymous nature of blockchain technology. If transactions are conducted outside of financial intermediaries, regulators will be unable to ascertain the true identities of the parties involved in the transactions.
Blockchain technology enhances the liquidity and speed of asset transactions while also increasing the speed and breadth of risk transmission. To address these challenges, the Swiss government is committed to enhancing transparency and plans to establish a federal registry requiring business entities and trusts established in Switzerland to disclose their beneficial owners, thereby improving transparency and closing legal loopholes.
Chapter 5: Market Practices and Innovative Applications
Tokenized bonds represent the most mature area of the Swiss RWA market, having achieved successful practices in multiple state governments. These cases are not only notable for their issuance scale but also demonstrate Switzerland's leading position in terms of technological application and regulatory collaboration.
Among them, the digital bond issued by the World Bank in Switzerland is a landmark case. This bond is the largest Swiss franc bond issued by the World Bank since 2009. Its innovation lies in being the world's first digital bond settled using wholesale central bank digital currency (wCBDC). The bond was issued on the SIX Digital Exchange (SDX) distributed ledger technology platform and settled using the wCBDC under the Swiss National Bank's "Helvetia III" project, achieving a deep integration of traditional financial market infrastructure with blockchain technology.
Additionally, the first digital bond issued by the digital asset trading platform (SIX Digital Exchange, SDX) under the Swiss Stock Exchange is also highly representative. As the world's first purely digital bond issued in a fully regulated environment, it received multiple oversubscriptions, attracting a wide range of Swiss institutional investors, fully demonstrating the feasibility and appeal of DLT technology in core capital markets.
The active participation of traditional financial institutions further drives market development. According to a report by the International Business Daily on July 11, 2025, a tokenized bond transaction worth 120 million Swiss francs was settled on the digital asset trading platform (SIX Digital Exchange, SDX) under the Swiss Stock Exchange, with the funding side being the wholesale central bank digital currency tested and issued by the Swiss National Bank. This marks the entry of wholesale CBDC into the practical stage in the core financial scenario of securities transaction settlement.
These cases indicate that Switzerland's tokenized bond ecosystem has surpassed the experimental stage, forming a complete closed loop that encompasses issuance, trading on regulated DLT platforms like SDX, and settlement using wCBDC. This model, driven by leading financial institutions and regulatory bodies, provides a replicable practical example for the global RWA market.
1. Market Practices of Tokenized Bonds
These tokenized bonds adopt a typical issuance structure—state governments act as issuers, issuing tokens representing bond rights through special purpose vehicles (SPVs), allowing investors to enjoy interest income and principal repayment rights by purchasing tokens. This model demonstrates significant advantages, including lower issuance costs, faster settlement speeds, and higher transparency.
However, tokenized bonds are not unique to Switzerland. The Hong Kong government has issued 80 billion Hong Kong dollars in tokenized green bonds; Singapore, under the "Project Guardian" framework, has also successfully trialed tokenized bonds with institutions such as JPMorgan and DBS Bank. These cases indicate that multiple financial centers globally are making substantial progress in this field, with Switzerland's advantage lying in the completeness of its legal framework and the early initiation of market practices.
The traditional settlement cycle has been shortened from T+2 to T+1, and even real-time settlement has been achieved, significantly enhancing market efficiency. For institutional investors seeking a high degree of legal assurance, this arrangement provides additional security, fully showcasing the market confidence brought by the Swiss legal framework. However, it is important to note that the liquidity and scale of the Swiss tokenized bond market still have a considerable gap compared to traditional bond markets.
2. Innovations in Real Estate and Luxury Goods Tokenization
Significant progress has also been made in the field of real estate tokenization, with the Swiss legal framework supporting both direct property tokenization and fund share tokenization models. Real estate tokenization platforms leverage executable ledger-based securities to achieve precise ownership records and compliant transactions.
However, its level of development still lags behind that of the UAE (Dubai). The Dubai Virtual Assets Regulatory Authority has promoted the direct integration of real estate tokenization platforms with the land registry system, achieving a deeper level of on-chain rights confirmation. Switzerland relies more on the parallel operation of traditional property registration systems and blockchain records in real estate tokenization, indicating room for improvement in the depth of technological integration.
Innovative cases have also emerged in the tokenization of luxury goods and alternative assets. The Swiss compliant blockchain ecosystem Swisstronik has collaborated with luxury jewelry brand Van der Bauwede and the Swiss Diamond Lab to launch a synthetic diamond tokenization project. This project builds a verifiable, efficient, and fully compliant Web3 luxury goods market, where the source, size, and ownership details of each diamond are securely stored on the blockchain, ensuring complete traceability and authenticity.
Token holders have the right to exchange their tokens for physical diamonds once the product is completed, and they can also trade on specialized diamond-backed token exchanges. The entire process strictly adheres to anti-money laundering and know-your-customer regulations, demonstrating the innovative application potential of Swiss RWA technology in non-traditional asset classes.
Chapter 6: Tax Treatment Guidelines
Switzerland provides clear and defined tax treatment rules for RWA investments, which vary based on the type of investor, offering stable expectations for market participants.
1. Tax Treatment for Individual Investors
Individual investors typically enjoy tax-exempt capital gains when holding and selling cryptocurrencies, including tokens representing RWAs. This creates an attractive investment environment, but this benefit comes with important prerequisites and limitations.
Firstly, it mainly applies to crypto assets considered personal wealth. Frequent trading activities that may be deemed commercial could have different tax treatments. Secondly, as noted in a report by Galaxy Securities, "heavy tax burdens can raise the cost of capital migration and suppress long-term allocation willingness," while a friendly tax regime is key to attracting capital. However, with the increasing global standards for tax transparency, whether Switzerland's tax exemption policy will face international coordination pressure and adjustments in the future is a potential risk that investors need to consider.
Switzerland has also established clear rules for specific tax scenarios. For wealth tax, cryptocurrencies, including RWA tokens, must be included in the wealth tax calculation if their total asset value exceeds the personal exemption threshold on December 31 each year. Regarding income tax, income from RWA tokens, such as rent and interest, must be reported as taxable income. The applicability of stamp duty depends on the specific transaction structure; generally, token issuance may involve stamp duty, while secondary market transactions are usually exempt.
2. Tax Considerations for International Investors
International investors enjoy a relatively friendly tax environment in Switzerland. Non-residents typically only need to pay taxes on Swiss-source income, and many RWA investments may be considered foreign-source income. Additionally, Switzerland's extensive network of tax treaties provides extra protection against double taxation, enhancing international investors' confidence in participating in the Swiss RWA market.
However, for corporations and cross-border investors, Switzerland's tax environment may present more complex challenges. As global tax transparency requirements increase, how Switzerland's tax policies align with international tax treaties remains an issue that needs further resolution in the future. Particularly in the context of the EU's ongoing push for tax transparency standards, Switzerland's capital gains tax exemption policy may face external pressure.
Chapter 7: Challenges and Future Outlook
As the Swiss RWA ecosystem progresses, it also faces multiple challenges. These challenges arise both from the adaptability of the traditional legal system and from new issues brought about by technological development, requiring careful handling in future development.
1. Complexity of Legal Coordination and Technological Implementation
The complexity of legal coordination constitutes a primary challenge. Although the federal DLT Act provides a unified framework, there are still differences among states in property law, particularly in real estate registration and judicial procedures. This legal decentralization under the federal system poses obstacles to nationwide unified RWA practices, especially in areas like real estate that are strictly regulated by state law, necessitating more coordination efforts.
Technological risks are also significant, especially in the field of RWA tokenization. Technical issues such as smart contract vulnerabilities, oracle manipulation, and private key management errors may threaten the security of tokens. The Swiss regulatory system requires platforms to implement strict technical security measures, including auditing and verifying smart contracts to ensure they undergo security reviews before deployment. However, these measures increase compliance costs for projects, posing a considerable burden for startups.
2. Balancing Privacy Protection and Digital Identity
The balance between privacy and compliance is another important issue. Notably, in 2025, Switzerland narrowly approved the national electronic identity system (e-ID) by 50.4% in a referendum, marking a certain balance in Switzerland's long-standing debate over privacy protection and digital identity verification.
While this system emphasizes privacy protection and data minimization principles, it remains controversial, particularly regarding how to ensure seamless integration of this system with KYC processes in the RWA field, avoiding potential conflicts between technology and privacy protection. The Swiss government plans to launch this system in the summer of 2026, expecting it to provide a more efficient and secure identity verification mechanism for the RWA field.
In 2021, Switzerland rejected a proposal for an electronic identity operated by a private company with 64% of the votes against it, reflecting the public's deep concern for privacy protection. The new system approved in 2025 represents a core shift in that the core identity infrastructure will be entirely government-operated. This system is expected to be launched in the summer of 2026, potentially providing a more efficient and secure identity verification solution for KYC processes in the RWA field, but its narrow approval margin itself reflects Swiss society's concerns about data privacy and centralized management.
3. Future Innovation Catalysts and Development Pathways
Looking ahead, several innovation catalysts are driving the evolution of the Swiss RWA ecosystem. The national electronic identity system is expected to be launched in 2026, emphasizing privacy protection and data minimization principles, which could greatly simplify the onboarding process for investors in the RWA field.
The development of programmable currencies and central bank digital currencies (CBDCs) is also noteworthy. The Swiss National Bank continues to test the settlement functions of wholesale CBDCs, and traditional financial market infrastructures like SIX have collaborated with the Swiss National Bank to explore technological options for central bank digital currencies. The combination of wholesale CBDCs and RWA tokens can achieve true atomic settlement, further reducing counterparty risk and enhancing overall efficiency in financial markets.
Aligning with international standards is another important trend. With the EU's MiCA regulation set to take full effect in 2025, Switzerland is actively adjusting its framework to maintain compatibility with the EU. This coordination will help Swiss RWA projects enter broader European markets, but the subtle differences between the two frameworks may still lead to additional compliance costs, requiring Switzerland to continue its efforts to maintain its competitive advantage in the European market.
Chapter 8: Conclusion and Insights
The relative success of the Swiss RWA ecosystem is built on three solid pillars. A clear and forward-looking legal framework serves as the primary pillar, with the DLT Act providing legal recognition for blockchain-based securities, addressing the fundamental legal barriers to tokenization. A pragmatic and collaborative regulatory approach constitutes the second pillar, with FINMA's principle of "same risk, same rules" and sandbox mechanisms providing space for innovation while ensuring financial stability. Institutional-level market infrastructure is the third pillar, with the active participation of traditional financial institutions like SIX Digital Exchange providing immediate credibility and liquidity support for the RWA market.
The Swiss model demonstrates that financial innovation and financial stability are not a zero-sum game. Its incremental legislative strategy—first clarifying the applicability of existing laws, then making targeted amendments—provides a replicable development pathway for other countries. Additionally, the Swiss experience indicates that the integration of traditional financial infrastructure with blockchain technology is more feasible than complete replacement, a pragmatic attitude that other markets should consider.
However, the Swiss model is not the only solution. It lags behind the U.S. in market depth and global capital attractiveness, and it faces competition from emerging centers like Singapore and the UAE in regulatory clarity and tax friendliness. While the innovative nature of its legal framework is commendable, its cross-border acceptance remains to be tested, which is a limitation that cannot be ignored in the context of globalization.
For project parties and investors considering entering the Swiss RWA ecosystem, we offer the following recommendations. Project parties should communicate early with FINMA to clarify regulatory expectations, choose the appropriate license type based on the substance of their business, and fully leverage Switzerland's network of bilateral treaties to optimize cross-border business structures. At the same time, they should carefully assess the effectiveness of the Swiss legal framework in cross-border scenarios, monitor the future stability of its tax regime, and prepare for the complexities of federal and state laws.
Investors should focus on the legal structure behind the tokens rather than just the technical features, deeply understand the tax implications of different RWA products, and effectively utilize the additional protections provided by Swiss law to exercise their investor rights. When choosing the Swiss market, they should not only leverage its advantages but also objectively recognize the current state of its market size and liquidity, as well as the potential risks that may arise during technological implementation.
In summary, Switzerland, with its unique financial tradition, pragmatic regulatory attitude, and forward-looking legal framework, provides a high-quality and credible experimental environment for the global development of RWA. However, it also faces intense international competition and internal challenges, and its ability to continue leading the global market will depend on its capacity to evolve continuously in a rapidly changing global landscape, setting a benchmark for innovation in the global digital asset field.
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