The Luxembourg Stock Exchange ("LuxSE") March 2026 update to its Rules & Regulations (the "R&R") introduces two key changes. First, securities listed on the Euro MTF Specialist Securities Segment ("EM3S") may now be admitted to listing before being recorded in a central securities depository ("CSD"), allowing issuers to list first and migrate to CSD infrastructure only once an on-venue trade occurs. Second, the rulebook now incorporates definitions drawn from the EU's DLT Pilot Regime (Regulation (EU) 2022/858), covering distributed ledger technology ("DLT"), DLT multilateral trading facilities and DLT settlement systems. These changes took effect on 2 March 2026.
These two developments are examined in turn below.
LuxSE's new pre-CSD admission pathway: a flexible route to market for EM3S issuers
EM3S securities can come to market without first being recorded in a central securities depository ("CSD") or a DLT settlement system/trading and settlement system ("DLT SS/TSS"). This is a meaningful departure from conventional listing mechanics, where CSD registration is a prerequisite to admission.
Under this new pathway:
- securities may be held in dematerialised form in a system maintained by the issuer, in dematerialised form in a system maintained by a third party (e.g. a registrar), or in book-entry form in a CSD (the traditional option) - meaning that, at the point of admission, securities need not be within the CSD infrastructure at all;
- trading on EM3S can commence without CSD involvement from day one; and
- where a trade actually takes place on the venue, the securities must be migrated into a CSD before the intended settlement date.
This sequencing - admit first, register later - ensures that settlement integrity is preserved once a transaction occurs, without forcing instruments into conventional post-trade infrastructure from inception.
Issuers and their advisers should be aware that updated EM3S application forms and letters of undertaking now need to be used to reflect this new option, with the final submission required at least three business days before the targeted listing date. Once an on-venue trade is executed, LuxSE will notify the issuer, who must promptly set the CSD recording process in motion, meet the associated costs, and confirm completion to LuxSE together with revised issuance documentation and a published notice. Non-compliance will be treated as a breach of the R&R and will result in the cancellation of the relevant trade and the delisting of the securities concerned.
T+2 settlement carve-out and new DLT Pilot Regime definitions in the LuxSE Rules & Regulations
The R&R revision also tidies up the settlement mechanics: the standard T+2 settlement window is now expressly disapplied for the first trade in EM3S securities that takes place before those securities have been recorded in a CSD or DLT SS/TSS, reflecting the practical reality of the new admission process.
On the definitional side, LuxSE has taken the opportunity to incorporate the vocabulary of the EU's DLT Pilot Regime (Regulation (EU) 2022/858) into the R&R, with new entries covering distributed ledger technology itself, DLT multilateral trading facilities and DLT settlement systems. Whilst these definitions do not in themselves create new obligations, they lay the groundwork for the R&R to evolve in step with the wider regulatory landscape around tokenised securities.
This version of the R&R supersedes the version dated March 2025. Together, the pre-CSD admission pathway and the incorporation of DLT Pilot Regime definitions reflect LuxSE's continued adaptation of its listing framework to meet the changing expectations of market participants who require more flexible, technology-neutral pathways to listing and settlement, whilst safeguarding the integrity of its trading and settlement infrastructure.
The updated R&R are available on the LuxSE website.
Share on
