# Issuers

### 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. 

{% content-ref url="../listing-requirements" %}
[listing-requirements](https://docs.21x.eu/participant-docs/listing-requirements)
{% endcontent-ref %}

### Frequently Asked Questions

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<summary><strong>1. Who can act as an issuer on 21X?</strong></summary>

Any legal entity that has been successfully onboarded and passed the due diligence criteria of 21X can be an issuer.

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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.

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<summary><strong>2. What does it mean to list an instrument on 21X?</strong></summary>

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.

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<summary><strong>3. Which types of instruments can be issued and listed?</strong></summary>

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.

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<summary><strong>4. Do I need to tokenize the asset before listing?</strong></summary>

No. 21X offers full tokenization services for issuers and can admit existing tokenized assets if they meet the compliance and technical requirements.

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Where necessary, 21X will coordinate with relevant partners along the value chain.

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<summary><strong>5. Does the listing require a prospectus?</strong></summary>

Yes. A prospectus or appropriate exemption documentation must be submitted in accordance with EU law.

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If applicable, your Listing Sponsor will support you in determining the applicable disclosure requirements.

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<summary><strong>6. Is a Listing Sponsor mandatory?</strong></summary>

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.

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<summary><strong>7. What legal jurisdiction applies to instruments listed on 21X?</strong></summary>

21X operates under German and EU law and is authorized under the EU DLT Pilot Regime.

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Financial instruments listed on 21X must comply with MiFID II, the Prospectus Regulation, and applicable EU/EEA member state regulation.

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<summary><strong>8. Which blockchain protocols does 21X support?</strong></summary>

21X currently supports token issuance on public blockchains such as **Polygon** and **Stellar**, with access controlled via smart contract whitelisting.

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Additional network support will be added based on client demand.

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<summary><strong>9. Does 21X hold the tokenholders’ registry?</strong></summary>

Yes. 21X is licensed as an electronic securities registrar with BaFin and can provide DLT-based registry services for issuers natively on-chain.

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Depending on instrument type and jurisdiction, registry and transfer agent services may be provided through regulated partners.

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<summary><strong>10. What token standards are supported on 21X?</strong></summary>

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.

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<summary><strong>11. What is the typical timeline for onboarding and listing?</strong></summary>

The standard onboarding and listing process takes approximately **4–6 weeks**, depending on instrument complexity, documentation quality, and issuer readiness.

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<summary><strong>12. What are the costs associated with issuing and listing?</strong></summary>

Issuers pay onboarding, listing, and variable trading and registry fees.

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Additional fees may apply for tokenization, legal review, or custom features. Please refer to the [ **21X Fee Schedule**](https://21x.eu/regulatory/documents/).

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<summary><strong>13. Do I need to provide KYC/AML information?</strong></summary>

Yes. All issuers are subject to KYC, AML, wallet whitelisting, and sanctions screening during onboarding, including verification of UBOs and key personnel.

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<summary><strong>14. Can I update or modify a listed instrument post-listing?</strong></summary>

Yes, but material changes must be reviewed by the Listing Sponsor, relevant authorities (if applicable), and approved by 21X.

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Technical changes may require smart contract upgrades or token migrations.

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<summary><strong>15. Can I access trading data on listed financial instruments?</strong></summary>

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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<summary><strong>16. How is investor access managed?</strong></summary>

Investor eligibility criteria are defined during admission and disclosed in the prospectus or relevant documentation.

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Access is enforced by 21X through onboarding controls and on-chain whitelisting.

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<summary><strong>17. Can I list the same instrument on other platforms?</strong></summary>

Yes. 21X does not require exclusivity.\
Cross-listings must comply with applicable regulations and be approved by 21X for legal and technical compatibility.

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