Digital assets and Distributed Ledger Technologies: Building a common framework for financial operations

This article is part of a three-part series:

• The first article delves into how the Societe Generale group and in particular SGSS have organised themselves to face these transformations, highlighting the actions taken and the most significant achievements.

• This second publication focuses on operational workflows and infrastructures, essential elements for the creation of a common framework.

• The third article examines the state of the art of the main regulatory requirement and market trends shaping the near future.

Toward a common reference framework

The development of a digital financial ecosystem depends on common standards and infrastructures, shaped by leading associations in the financial sector and supranational bodies with the aim of outlining a unified framework for integrating digital assets.

Key initiatives include:

• The Basel Committee, integrating crypto assets into prudential requirements. The Basel Committee, in line with the approach of the European Supervisory Authorities (ESAs) and the European Central Bank, has launched a dialogue with the market to integrate the challenges presented by crypto-assets and DLTs into the standards of prudential requirements. The focus is on the need to comply with capital requirements and to carry out the activities related to the correct classification of digital assets in group 1 or 2, which are fundamental for prudential calculations. These obligations concern both crypto bank issuers and banks that intend to offer related services. The technological factor of the issue therefore assumes a weight that must be appropriately evaluated and balanced by the related business opportunities. It should be noted that BASEL, fully grasping the innovative scope of the phenomenon, will continue the dialogue with players, ready to review and reconsider elements of prudential requirements, especially regarding custody of crypto assets.

• The Association of National Numbering Agencies (ANNA) adapting ISIN codes for digital assets. ANNA established an internal task force in 2019 with the aim of understanding how to support the industry in effectively capitalising on the potential improvements associated with the use of new technologies. Based on the outcome of this task force, the decision to make the ISIN codes independent from the technology of issuance and circulation of the asset was subsequently made: this choice has been formalized in the guidelines published in June 2023 and later updated.

• SWIFT plays a key role in shaping network, communication standards and infrastructure. Alongside important initiatives to update its infrastructure, the introduction few years ago of the optional field 36D in its message’s standard, which allows to manage the typical number of digits necessary for quantities of crypto assets, was the first relevant step.

With specific refence to the Basel’s standards, there are two elements to which it is useful to draw attention:

1. Central Bank Digital Currency (CBDC) is excluded from the perimeter, reducing at least two cost lines in the business plans of the initiatives.

2. Liquidity and volatility of crypto assets: these characteristics add elements of risk compared to traditional assets, influencing categorisation under prudential requirements, to the point of determining, in extreme cases, non-eligibility as collateral in repo and securities lending transactions.

Focus on Italy: A constructive regulatory dialogue

In Italy, the dialogue has been carried out for some time by SGSS with the Bank of Italy, Consob and the industry associations (ABI, ASSOGESTIONI, AMF ITALIA). Since 2024, by virtue of the introduction of the digital circulation regime provided for by the "Fintech Decree"¹, the comparison has become even more relevant. In fact, the decree provides a first level regulatory framework, but not sufficient to be able to operate in the new digital ecosystem. In fact, upgrades of the second-level regulations are necessary, for example in post-trading or in the role of the custodian bank.  The discussion with the institutions, once again, is crucial to move to act skillfully, serenity and decision in the new scenarios of opportunities for customers.

A key reference for Italian intermediaries is represented by the Bank of Italy's Communications of June 2022 and July 2024², which emphasize internal skills, understanding and appropriate management of new risk elements within corporate structures, in order to be able to adequately explore DLT technology, and, in particular, use cases related to payments in EMT-qualified digital currencies pursuant to MiCAR (Markets in Crypto-Assets Regulation)³.

With specific reference to the value chain of Investment Funds, the discussion and collaboration with Assogestioni led to the drafting of an important document: the "Guide on Italian Digital Funds". It provides asset management companies and their interlocutors with a solid guideline through the regulatory framework and market practices, useful for launching digital crypto and DLT initiatives in the Investment Fund industry.

In May 2025, the European Fund and Asset Managers Associations (EFAMA) published the study "Tokenisation, a Buy-Side Practitioner's Guide". It is an analysis of the regulations in force in the main European countries and the United Kingdom, thus offering a summary framework of great utility for operators.

Enabling secure and efficient integration

The adoption of common standards and the development of adequate infrastructures remain, in a nutshell, two fundamental elements to ensure efficiency and security in the new financial ecosystem. Only a shared framework will allow full integration between operators and promote market growth.

Oscar Maffioletti, Deputy General Manager Staff, Societe Generale Securities Services

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