LUXEMBOURG Trends and Developments Contributed by: Álvaro Garrido Mesa and Agustina Torino Martínez, Legal Node
expertise has allowed Luxembourg to move beyond facilitating innovation into a stage of digital asset nor - malisation within traditional financial markets, with both regulated crypto-asset activities and tokenised financial instruments developing within clearly deline - ated legal regimes, and with further integration of large players into the digital assets arena foreseen for 2026. Since the adoption of the first Luxembourg blockchain law in 2019, Luxembourg has positioned itself as a beacon for digital assets projects involving the use of DLT in finance, having now adopted four block - chain laws centred on the facilitation of digitalisation of financial instruments through the use of DLT, and deserving its reputation as a stable jurisdiction for the tokenisation of financial instruments. Luxembourg has shown its unwavering support for private digital assets entrepreneurs over time, and the country itself has been a pioneer in the field. In June 2025, the Luxembourg State Treasury issued EUR50 million of digital treasury certificates (certificats de trésorerie digitaux) via blockchain, with defined matu - rity, issuance price and admission to trading, consti - tuting one of the first sovereign DLT-based debt issu - ances in the EU. The 2026 Regulatory Landscape The applicable Luxembourg legal framework for digital assets and related services is clear and predictable. MiCA MiCA functions as the primary framework governing both the issuance of crypto-assets and the provision of crypto-asset services. MiCA is now fully applicable and operates as a digital assets rulebook, levelling the playing field across the EU. The practical effect is a clear delineation between authorised and non- authorised activity, reinforcing legal certainty within regulated financial services and contributing to the institutionalisation of the crypto-asset sector. DORA DORA complements the digital assets framework by establishing harmonised obligations concern - ing digital resilience. Its requirements relating to ICT risk management, incident response, resilience test - ing and third-party oversight apply uniformly across
banks, investment firms, CASPs and certain crypto- asset issuers. As a result, operational resilience is no longer treated as a peripheral compliance obligation but as an integral component of governance and risk management. Blockchain Law IV Within the EU-wide legal framework, Luxembourg stands out as the most advanced legal system for DLT-enabled securities, having approved Blockchain Law IV. Adopted in 2024, the law established the legal framework for integrating DLT into the dematerialised securities regime by expressly enabling the use of DLT for the crediting/recording of dematerialised securities within a legally recognised account-based architec - ture, without displacing existing concepts of owner - ship, custody or settlement. Blockchain Law IV did not create a parallel regime for tokenised financial instruments, but rather embed - ded tokenisation within existing securities law rules. Dematerialised securities issued or recorded on DLT remain governed by an account-based model cen - tred on securities issuance accounts and securities accounts, ensuring continuity with traditional market practice while, in respect of non-listed securities, ena - bling the recording of such securities directly within or through DLT and dispensing with the need for central account keepers and settlement organisations. This approach allows tokenisation to scale within solid legal structures. A defining element of this new framework is the Con - trol Agent role, introducing an alternative infrastructure and reducing reliance on traditional intermediaries. Appointed from among authorised credit institutions or investment firms and subject to CSSF authorisa - tion, the Control Agent is responsible for (among other things) overseeing the securities issuance account held through or within DLT. By concentrating oversight in a regulated entity, the new infrastructure enables on-chain issuance and life cycle management while maintaining supervisory comfort and investor protec - tion. In July 2025, Investre became the first entity to obtain authorisation as a Control Agent from the CSSF under Blockchain Law IV, with more Control Agent authorisations expected to be granted in 2026.
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