Tokenisation in Switzerland vs Singapore: Two Leading Jurisdictions Compared

Switzerland and Singapore have emerged as the two jurisdictions most consistently cited in institutional discussions of regulated tokenisation. Both combine regulatory sophistication with active central bank engagement, deep financial centre expertise, and a pragmatic approach to enabling institutional digital asset activity. Yet the two are not equivalent: each has distinct strengths, different asset class specialisations, and contrasting approaches to international distribution. This analysis provides the definitive comparison for institutional practitioners making jurisdiction decisions.

Singapore’s Tokenisation Landscape

Singapore’s approach to institutional tokenisation has been shaped primarily by the Monetary Authority of Singapore (MAS), which has positioned Singapore as Asia’s leading regulated digital asset jurisdiction through a combination of licensing frameworks, regulatory guidance, and direct market development initiatives.

MAS Project Guardian

Project Guardian is MAS’s flagship institutional tokenisation and DeFi initiative, launched in 2022 as a collaborative framework bringing together MAS, BIS Innovation Hub, and major global financial institutions. Unlike regulatory sandboxes that restrict participants to domestic institutions, Project Guardian explicitly involves global banks as active participants — DBS, JPMorgan Chase, Standard Chartered, HSBC, UBS, Citi, T. Rowe Price, BlackRock, and Invesco have all participated in Project Guardian pilots across different asset classes.

Project Guardian has demonstrated institutional tokenisation across five key asset categories:

Tokenised fixed income: Project Guardian pilots included tokenised bonds settled in wholesale CBDC (MAS’s Project Orchid / SGD wholesale digital token experiments), tokenised government securities as collateral in repo transactions, and tokenised commercial paper.

Tokenised foreign exchange: Project Guardian’s FX pilot demonstrated atomic settlement of multi-currency FX transactions using tokenised currencies, eliminating settlement risk in cross-currency transactions — a significant use case for Singapore’s role as Asia’s largest FX trading centre.

Tokenised funds: the fund tokenisation pilots demonstrated subscription and redemption in tokenised fund units via blockchain, with JPMorgan’s Onyx network and Project Guardian infrastructure used for pilot transactions involving tokenised money market funds.

Tokenised collateral: Project Guardian demonstrated the use of tokenised securities as intraday collateral in repo and securities lending transactions — a use case with significant operational efficiency implications for Singapore’s institutional markets.

Institutional DeFi: Project Guardian explored the use of permissionless DeFi protocols (Aave, Uniswap) adapted for institutional use with KYC-compliant liquidity pools — the most experimentally ambitious of the project’s workstreams.

DBS Digital Exchange (DDEx) and DBS Tokenisation

DBS Group, Singapore’s largest bank, has been the most active domestic institutional tokenisation participant. Through DDEx, DBS operates Singapore’s first digital asset exchange for institutional and accredited investors, providing:

• Spot trading in digital payment tokens (Bitcoin, Ethereum) for institutional clients
• Digital bond issuance and trading (DBS issued a SGD 15m digital bond on DDEx in 2020)
• Security token offerings (STOs) for qualified investors
• Tokenised trade finance instruments for Asian corporate clients

DBS’s tokenisation programme extends beyond DDEx: DBS has tokenised real estate investment trust (REIT) units, structured tokenised notes for private wealth clients, and issued tokenised cash management products. The bank’s ability to deploy tokenisation across wholesale banking, treasury markets, and private banking gives it a scope unmatched by any single Swiss institution.

Temasek-Backed Platforms and Singapore’s VCC Structure

Temasek Holdings, Singapore’s sovereign investment company, has invested in and incubated multiple tokenisation-adjacent platforms:

Partior: a blockchain-based multilateral interbank settlement network co-founded by DBS, JPMorgan, and Temasek, focused on cross-border payment settlement using tokenised commercial bank money.

The Singapore Variable Capital Company (VCC): introduced in 2020, the VCC is a fund vehicle specifically designed for Singapore’s asset management industry, including explicit accommodation for digital asset funds and tokenised fund structures. Several tokenised fund platforms have structured their products as VCCs, providing a clean legal vehicle for tokenised fund unit issuance to professional and institutional investors.

Switzerland’s Tokenisation Landscape: Recap

Switzerland’s tokenisation infrastructure is covered in depth elsewhere on this site; the summary for comparison purposes:

• Legal framework: DLT Act (2021) — permanent legislation, Registerwertrecht concept, DLT trading facility licence
• Primary venue: SIX Digital Exchange (SDX) — FINMA-licenced DLT trading facility and CSD, Project Helvetia CBDC settlement
• Infrastructure providers: Taurus Group (custody and EXPLORER tokenisation platform), Custodigit, Metaco/Ripple
• Platform operators: Tokenestate (real estate funds), Stableton (PE/VC feeder funds), BrickMark (direct real estate tokens), Daura (SME equity)
• Institutional participants: UBS, ZKB, Basler Kantonalbank, Julius Baer, Sygnum, SEBA

Regulatory Framework: MAS Guidance vs Switzerland’s DLT Act

Design Philosophy

Switzerland’s DLT Act took a legislative approach: Parliament enacted permanent amendments to Swiss private law and financial market law, creating new legal categories (Registerwertrecht, DLT-Handelssystem) that exist in statute. Every tokenised security in Switzerland has a clear legal basis in enacted law regardless of what regulators subsequently do.

Singapore’s MAS approach is regulatory guidance-led: rather than enacting a separate tokenisation statute, MAS has issued guidance under existing frameworks, expanded licensing categories (Payment Services Act, Securities and Futures Act), and operated collaborative pilot programmes to demonstrate acceptable practices. This approach is more flexible and faster to iterate but creates more regulatory uncertainty: the rules are in guidance documents that can change, not in statute.

Advantage Switzerland: legislative permanence and legal clarity. A Swiss practitioner can point to a specific article of the Code of Obligations to establish that a Registerwertrecht is legally perfected. A Singapore practitioner relies on guidance documents that may be updated.

Advantage Singapore: regulatory flexibility and innovation pace. MAS has been able to pilot institutional DeFi, cross-border FX, and tokenised collateral use cases under Project Guardian without waiting for parliamentary approval. Switzerland’s legislative approach is slower to extend to new asset classes.

Asset Class Regulation

Switzerland’s DLT Act is strongest for debt securities (bonds, notes) and has a clear framework for equity Registerwertrechte. Fund tokenisation is possible but requires compliance with the existing CISA (Collective Investment Schemes Act) framework, which predates DLT and is not optimally designed for tokenised funds.

Singapore’s framework is strongest for fund tokenisation (VCC structure is purpose-built), tokenised cash management products, and digital payment tokens. The SFA (Securities and Futures Act) covers a broad range of capital market products, and MAS guidance has explicitly addressed tokenised funds, tokenised bonds, and tokenised structured products. Singapore’s fund tokenisation ecosystem is more developed than Switzerland’s.

Asset Class Focus: Where Each Jurisdiction Leads

Switzerland leads in debt securities tokenisation; Singapore leads in fund tokenisation, FX/cash management, and institutional DeFi exploration. The two jurisdictions are complementary rather than directly competitive across most asset classes.

Institutional Participants: Who Is Building in Each Jurisdiction

Switzerland’s Institutional Participants

The Swiss institutional tokenisation ecosystem is characterised by domestic banks at the centre, with international banks participating selectively:

• UBS: the most active Swiss universal bank in tokenisation, with the benchmark CHF 375m digital bond on SDX (2022) and ongoing structured product tokenisation exploration
• Zürcher Kantonalbank (ZKB): cantonal bank that participated in SDX issuances and partnered with Daura for SME equity digitisation
• Julius Baer: private bank with digital asset custody offering and tokenised structured product exploration for HNWI clients
• Sygnum Bank: specialist digital asset bank with FINMA licence for banking and securities dealing; offers tokenisation services for institutional and professional clients
• SEBA Bank: specialist digital asset bank with comparable scope to Sygnum; issued tokenised structured products for institutional clients
• SNB: central bank participant in Project Helvetia; providing wholesale CBDC for SDX settlement in pilot phase

Singapore’s Institutional Participants

Singapore’s institutional tokenisation ecosystem involves global banks to a greater extent than Switzerland’s, reflecting MAS’s design of Project Guardian as a global collaboration:

• DBS: the anchor institutional participant; DDEx operator; tokenised bond issuer; Partior co-founder
• Standard Chartered: Project Guardian participant; tokenised bond programme; digital asset custody expansion via Zodia Markets and Zodia Custody
• HSBC: Project Guardian participant; tokenised gold product (HSBC Orion platform); tokenised trade finance; Asian real estate tokenisation pilot
• JPMorgan: Project Guardian participant via Onyx network; tokenised collateral system (Project Guardian repo pilot with DBS); Partior co-founder
• UBS: participated in Singapore Project Guardian fixed income workstream alongside Switzerland activity — demonstrating dual-jurisdiction engagement
• MAS: active central bank participant in wholesale CBDC pilots via Project Orchid and related experiments

Switzerland’s institutional roster is deeper in cantonal banks and private banks; Singapore’s roster is deeper in global investment banks and Asian universal banks. For issuers targeting Asian institutional distribution, Singapore’s participant network is superior.

Settlement: CBDC Progress in Both Jurisdictions

Project Helvetia (Switzerland)

Project Helvetia is the more advanced of the two in terms of actual live CBDC settlement of tokenised securities transactions. Phase III (2023) demonstrated real SNB wholesale CBDC used to settle real tokenised bond transactions on SDX, with approximately a dozen commercial banks as participating institutions. This is genuine live CBDC settlement — not a simulation — and represents the global frontier in wholesale CBDC application to securities settlement.

The limitation is scope: Project Helvetia is currently limited to Swiss franc-denominated transactions on SDX infrastructure. Cross-border CBDC settlement (settling a USD-denominated tokenised bond with USD CBDC) would require coordination with the Federal Reserve and has not been attempted.

Project Orchid / Project Guardian CBDC Workstreams (Singapore)

Singapore’s wholesale CBDC development has proceeded through Project Orchid, which developed a purpose-bound digital SGD for various use cases, and through Project Guardian’s FX and payments workstreams that involved tokenised commercial bank money (not central bank money) in most pilots.

The Banque de France/MAS project Jura (conducted in 2021) demonstrated cross-border CBDC settlement between EUR wholesale CBDC and CHF wholesale CBDC — the most ambitious cross-border CBDC demonstration globally. This experiment involved the Swiss National Bank alongside the Banque de France and MAS, illustrating the potential for multi-currency CBDC settlement connecting Singapore and Switzerland.

Settlement comparison: Switzerland is ahead on domestic CBDC settlement integration; Singapore is ahead on cross-border CBDC experimentation and multi-currency tokenised payment infrastructure.

Cross-Border Distribution: Where Singapore Leads

Switzerland’s most significant structural disadvantage relative to Singapore in the tokenisation competition is international distribution reach. Swiss tokenised securities face the EU recognition gap: a Swiss Registerwertrecht is not automatically recognised as a MiFID II financial instrument, limiting distribution into EU institutional accounts. Switzerland also has no existing trade agreement framework that provides financial services passporting into major Asian markets.

Singapore’s advantages in cross-border distribution:

• ASEAN-plus network: Singapore’s MAS has bilateral regulatory cooperation agreements with financial regulators across ASEAN, Hong Kong, Japan, Australia, and the EU. MAS-licensed products can reach Asian institutional investors through established regulatory recognition pathways.
• Global bank participation: because Project Guardian involves global banks operating from Singapore, tokenised products structured in Singapore can be distributed through those banks’ global client networks — a distribution reach that SDX cannot match with its current participant roster.
• VCC cross-border: the Singapore VCC can be distributed to professional investors in multiple jurisdictions under applicable private placement exemptions, giving tokenised Singapore funds broader international reach than comparable Swiss collective investment scheme products.

Talent: Financial and Technical Expertise

Singapore’s talent profile: Singapore draws on a broader talent pool than Switzerland by population, with significant inflows of fintech, blockchain, and traditional finance talent from across Southeast Asia, China, India, and Hong Kong. MAS’s regulatory clarity has attracted financial services talent that would previously have gone to Hong Kong, and the city-state’s English-language environment makes it accessible to global talent.

Switzerland’s talent profile: Switzerland’s financial talent pool is deep in traditional banking and asset management (Zurich and Geneva are major private banking and asset management centres), with strong cryptography and computer science capabilities from ETH Zurich and EPFL. The Crypto Valley Zug ecosystem has concentrated blockchain and DLT technical talent. However, Switzerland’s labour market is constrained by immigration complexity and cost of living relative to comparable markets.

Both jurisdictions are net importers of digital asset talent. Switzerland has the cryptography and DLT infrastructure expertise advantage; Singapore has the scale advantage and Asian talent network access.

The Competition for Issuers: Why Each Wins

Singapore wins when:

• The issuer wants Asian investor distribution (especially institutional distribution in Japan, Korea, Hong Kong, Southeast Asia)
• The asset class is fund tokenisation or structured notes for HNWI distribution
• The issuer is a global bank operating from Singapore with existing MAS licensing
• The issuance is in USD or SGD, not CHF
• Cross-border tokenised payments or FX settlement are involved

Switzerland wins when:

• The issuer wants Swiss institutional investor distribution (Pensionskassen, Swiss insurance, cantonal bank treasuries)
• The issuance is in CHF with Swiss DLT Act legal certainty
• CBDC settlement quality is a requirement (Project Helvetia integration)
• The issuer seeks the most legally permanent framework without sunset risk
• The issuer is a European or international bank with existing Swiss operations or FINMA regulatory relationships

Decision Matrix: 10 Criteria for a Structured Product Issuer

The following matrix applies to a hypothetical structured product issuer (e.g., a European bank issuing a principal-protected note linked to a commodity index) choosing between Switzerland and Singapore for tokenised issuance:

Aggregate: Switzerland 71/100, Singapore 76/100 for an Asian-distribution-focused structured product issuer. For a Swiss-distribution-focused issuer, Switzerland would score substantially higher.

Conclusion: Two Different Markets, One Complementary Network

Switzerland and Singapore are not in a zero-sum competition for tokenisation business. They serve overlapping but distinct markets: Switzerland is the pre-eminent jurisdiction for Swiss franc-denominated institutional debt tokenisation with CBDC settlement; Singapore is the pre-eminent Asian hub for institutional tokenisation across asset classes with global bank distribution. The banks that matter most — UBS, Standard Chartered, HSBC, JPMorgan — are active in both, treating Swiss and Singapore tokenisation infrastructure as complementary rather than competing.

The long-term question is whether a cross-border bridge between the two ecosystems — building on Project Jura’s CBDC demonstration — can create a genuinely integrated Swiss-Singapore tokenised securities corridor. If it does, both jurisdictions benefit disproportionately from their early-mover infrastructure investments.

Published by ZUG DLT — Donovan Vanderbilt. zugdlt.com provides independent institutional intelligence on Switzerland’s distributed ledger technology ecosystem.