When I recently reviewed the regulatory materials for @Dusk , I found that what needs to be separated most isn’t the technical and compliance aspects, but three states that are often confused with one another: a counterpart already holds a license, a project is currently applying for a new license, and a certain entity has already been approved to operate a DLT market infrastructure. All three can be written into a roadmap, but they cannot simultaneously be treated as business capabilities that are already in place.
NPEX does indeed have Dusk and NPEX publicly stated plans to apply for the EU DLT Pilot Regime in the Netherlands AFM’s MTF registration. However, AFM and ESMA rules are very clear: DLT MTF, DLT SS, and DLT TSS all require specific permissions for the operating entity; ESMA will also publish the approved infrastructure and the duration of the permissions. On the other hand, 21X’s public materials explicitly state that it obtained the DLT‑TSS license in 2024, while industry materials related to NPEX still use wording such as “is applying.”
This creates a discrepancy in the wording that is worth checking. Some of Dusk’s current documents describe the mainnet as being able to support compliance CSD functions under a DLT‑TSS license. But based on that sentence alone, you cannot determine whether the license belongs to Dusk, NPEX, or is referring to a future target. Licenses do not automatically “transfer” just because there is a technical cooperation arrangement. Trading, custody, settlement, and issuance may also be handled by different legal entities.
So when I look at the progress of the RWA for #dusk , I would put the document status before the cooperation announcement: who the approved entity is, what the license type and term are, which assets are permitted, who bears responsibility for investor protection and final registration, and when the first real transaction will occur. Whether $DUSK forms a network demand also has to wait until the regulated processes actually generate settlement and gas, rather than first writing the application as revenue.
Dusk’s regulatory pathway has a real basis for cooperation, but the closer you get to traditional finance, the less ambiguity the wording can have. Whether the technology can run is one question; who is allowed to operate is another. Only by treating the two sets of answers separately can you avoid replacing licensing facts with grand narratives.
NPEX does indeed have Dusk and NPEX publicly stated plans to apply for the EU DLT Pilot Regime in the Netherlands AFM’s MTF registration. However, AFM and ESMA rules are very clear: DLT MTF, DLT SS, and DLT TSS all require specific permissions for the operating entity; ESMA will also publish the approved infrastructure and the duration of the permissions. On the other hand, 21X’s public materials explicitly state that it obtained the DLT‑TSS license in 2024, while industry materials related to NPEX still use wording such as “is applying.”
This creates a discrepancy in the wording that is worth checking. Some of Dusk’s current documents describe the mainnet as being able to support compliance CSD functions under a DLT‑TSS license. But based on that sentence alone, you cannot determine whether the license belongs to Dusk, NPEX, or is referring to a future target. Licenses do not automatically “transfer” just because there is a technical cooperation arrangement. Trading, custody, settlement, and issuance may also be handled by different legal entities.
So when I look at the progress of the RWA for #dusk , I would put the document status before the cooperation announcement: who the approved entity is, what the license type and term are, which assets are permitted, who bears responsibility for investor protection and final registration, and when the first real transaction will occur. Whether $DUSK forms a network demand also has to wait until the regulated processes actually generate settlement and gas, rather than first writing the application as revenue.
Dusk’s regulatory pathway has a real basis for cooperation, but the closer you get to traditional finance, the less ambiguity the wording can have. Whether the technology can run is one question; who is allowed to operate is another. Only by treating the two sets of answers separately can you avoid replacing licensing facts with grand narratives.
