What Zurich quietly got right

Working here, one develops an appreciation for frameworks that do not announce themselves. The Swiss DLT Act, passed in 2021 and taking staged effect through 2022, did not make international headlines. It created no new regulator. It established no dramatic new category of licensed institution. It was, and remains, a careful amendment to existing Swiss financial law that accommodates DLT-based financial infrastructure without disrupting the rest of the stack.

Four years on, the Swiss framework is arguably the most operationally mature national DLT regime in the world. SIX Digital Exchange has been continuously processing institutional tokenised-bond and tokenised-equity settlement since 2021. Swiss banks routinely hold and custody tokenised assets alongside traditional ones. The stablecoin bench is deep, multi-currency, and supervised proportionately by FINMA under existing category rules.

None of this is glamorous. All of it is durable.

The contrast with frameworks that were more ambitious and less accretive is instructive. MiCA made bigger headlines and has produced more uncertainty. Abu Dhabi's VARA rules are ambitious but less operationally tested. The US is mid-convergence and will probably arrive at a workable framework within two years, but the intervening uncertainty has cost it operational muscle that will take time to rebuild.

Writing from Zürich, it is tempting to overstate the Swiss advantage. We try not to — operational maturity is a slow compounder, not a moat, and competing jurisdictions are catching up. But the Swiss approach of accommodating new infrastructure rather than legislating it into existence has aged unusually well, and it is worth articulating why.

The answer, we think, is that financial infrastructure is plumbing, and plumbing rewards frameworks that make incremental accommodation cheap. Swiss financial law is unusually good at this. It is not an accident that the Association chose to be based here.