Issuers
Issuers create DLT Financial Instruments and seek their admission to trading on the 21X DLT-TSS.
Definition
An Issuer is a legal entity that issues or proposes to issue DLT Financial Instruments and whose instruments are admitted to trading or traded on the 21X DLT-TSS (or for which a request for admission has been made).
Responsibilities
Prepare and provide the documentation required for admission to trading.
Ensure required disclosures (e.g., prospectus or information document) are prepared and made available where applicable.
Ensure information submitted is accurate, complete, and not misleading.
Comply with ongoing legal, regulatory, and disclosure obligations once admitted.
Coordinate with a Listing Sponsor for the admission process (where applicable).
Requirements
Enter into the Engagement Agreement with 21X for support in the admission-to-trading process.
Provide required corporate, legal, and financial information and supporting documents for the admission process.
Ensure the instrument meets the eligibility framework and limitations applicable under the Rulebook and DLT Pilot Regime context.
A detailed list of admission requirements for Issuers of tokenized financial instruments can be found below.
Listing requirementsFrequently Asked Questions
1. Who can act as an issuer on 21X?
Any legal entity that has been successfully onboarded and passed the due diligence criteria of 21X can be an issuer.
21X further provides issuance, tokenization, and lifecycle management services for asset managers who want to issue their products with 21X and coordinates with partners where necessary.
2. What does it mean to list an instrument on 21X?
Listing on 21X means making a tokenized financial instrument available for primary issuance and/or secondary trading on the regulated DLT Trading and Settlement System (DLT TSS).
The instrument must meet the listing criteria and requires a dedicated Listing Sponsor, unless the issuer has been explicitly approved by 21X to act as a self-sponsored entity based on its regulatory status and internal structuring expertise.
3. Which types of instruments can be issued and listed?
Issuers may list tokenized financial instruments such as:
Equity instruments (shares, certificates)
Debt instruments (bonds, notes)
Fund units (money market funds, exchange traded funds, mutual funds)
All instruments must qualify as financial instruments under MiFID II.
4. Do I need to tokenize the asset before listing?
No. 21X offers full tokenization services for issuers and can admit existing tokenized assets if they meet the compliance and technical requirements.
Where necessary, 21X will coordinate with relevant partners along the value chain.
5. Does the listing require a prospectus?
Yes. A prospectus or appropriate exemption documentation must be submitted in accordance with EU law.
If applicable, your Listing Sponsor will support you in determining the applicable disclosure requirements.
6. Is a Listing Sponsor mandatory?
Yes. All listings on 21X require engagement with a licensed Listing Sponsor to ensure regulatory alignment and market readiness, unless the issuer has been explicitly approved by 21X to act as a self-sponsored entity.
7. What legal jurisdiction applies to instruments listed on 21X?
21X operates under German and EU law and is authorized under the EU DLT Pilot Regime.
Financial instruments listed on 21X must comply with MiFID II, the Prospectus Regulation, and applicable EU/EEA member state regulation.
8. Which blockchain protocols does 21X support?
21X currently supports token issuance on public blockchains such as Polygon and Stellar, with access controlled via smart contract whitelisting.
Additional network support will be added based on client demand.
9. Does 21X hold the tokenholders’ registry?
Yes. 21X is licensed as an electronic securities registrar with BaFin and can provide DLT-based registry services for issuers natively on-chain.
Depending on instrument type and jurisdiction, registry and transfer agent services may be provided through regulated partners.
10. What token standards are supported on 21X?
21X currently supports:
Polygon (ERC-20 compatible)
Stellar (SEP-41 compatible)
Issuers may tokenize with 21X or use their own audited token standards that meet 21X requirements.
11. What is the typical timeline for onboarding and listing?
The standard onboarding and listing process takes approximately 4–6 weeks, depending on instrument complexity, documentation quality, and issuer readiness.
12. What are the costs associated with issuing and listing?
Issuers pay onboarding, listing, and variable trading and registry fees.
Additional fees may apply for tokenization, legal review, or custom features. Please refer to the 21X Fee Schedule.
13. Do I need to provide KYC/AML information?
Yes. All issuers are subject to KYC, AML, wallet whitelisting, and sanctions screening during onboarding, including verification of UBOs and key personnel.
14. Can I update or modify a listed instrument post-listing?
Yes, but material changes must be reviewed by the Listing Sponsor, relevant authorities (if applicable), and approved by 21X.
Technical changes may require smart contract upgrades or token migrations.
15. Can I access trading data on listed financial instruments?
Yes. Issuers can access post-trade and registry data via secure APIs. 21X also supports on-chain price oracles in collaboration with Chainlink.
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