CurioInvest· Extract
Reference · updated January 2026

The legal basis for tokenized receivables in Switzerland and the EU.

The Swiss DLT Act, FINMA Circular 2018/3, and the CMTAT standard together give tokenized receivables legal force. CurioExtract is built inside that framework — not the other way around. This page is the long-form reference for the rules, the trade-offs, and the CMTAT implementation we use in production.

Outsourcing

FINMA Circular 2018/3

Ledger-based rights

DLTA Art. 973a ff.

Data subject rights

nDSG Art. 19

Debt-instrument exemption

FinSA Art. 4

Wake Arena M1/M2/M3 audited

CMTAT v3.0.0

Permissioned token standard

ERC-3643

The 6 framework pillars

Six rules of law. One interoperable standard. Zero ambiguity.

Switzerland is the only EU/EEA jurisdiction where tokenized rights have a clear civil-law basis today. The framework rests on six rules, layered from foundational to operational.

DLTAin force 1 Feb 2021 / amended 1 Jan 2026

Distributed Ledger Technology Act

Creates the legal basis for civil-law rights held on a distributed ledger. The core innovation is a 'ledger entry' as a legal object — no more needing paper, a deed register, or an intermediated account to hold the right.

FINMA 2018/3in force 1.4 years before DLTA

FINMA Circular 2018/3 — Outsourcing

Allows banks and insurers to outsource core operations to regulated DLTs, provided the operator meets six risk-and-control criteria. CurioInvest operates inside a FINMA-licensed parent (Curio Capital AG, Zug) so the circular applies to us by inheritance.

nDSGin force 1 Sep 2023

Federal Act on Data Protection (revised)

Strict data-minimisation requirement, 30-day breach notification, right to erasure. CurioExtract's default posture: zero model-training on customer contracts, per-tenant Postgres isolation, opt-in telemetry only.

FinSAin force 1 Jan 2020

Financial Services Act

FinSA Art. 4 exempts debt instruments (which is what a tokenised receivable is) from the prospectus requirement when the offering is to a closed circle of qualified investors. Our CMTAT transfer rule keeps every secondary trade inside that closed circle.

SESTAin force 1 Jan 2020

Federal Act on the Entry into Force of the FinSA

Sets the transition period. Most of the FinSA exemptions are unconditional; the underwriting protocol (Art. 11) is the main piece still being interpreted by the courts.

CMTAT v3.0.0audited Wake Arena M1/M2/M3

CMTA Reference Token Standard

Modular ERC-3643 descendant with composable rule plugins. Used in production by UBS, Taurus, Syz Group. CurioExtract ships a Swiss-DLT-specific rule for jurisdiction, KYC, and settlement-freeze.

How the system flows

From PDF to on-chain receivable in 10 minutes.

Extract

Upload a PDF, DOCX, or scanned PO. AI pulls parties, payment terms, obligor, renewal date, governing law into a structured record. 95% field accuracy on the demo portfolio, audited against the same DLT-friendly fields the regulator expects.

Score

CurioExtract's readiness model weighs supplier risk, payment terms, contract type, and concentration. The score isn't an opaque number — every input is surfaced in the dashboard so the CFO can see why one contract is 90/100 and another is 45/100.

Tokenize

Eligible receivables mint as a CMTAT on Polygon. The CMTAT's `RuleEngine` evaluates a Swiss-DLT-specific rule on every transfer: jurisdiction whitelist (CH/DE/AT/IT/FR), KYC verification, settlement-freeze on retire. The token is a permissioned security — no transfer to an unscreened wallet can succeed.

Settle

When the obligor pays the underlying invoice, a settlement oracle calls `markSettled(tokenId)`. The token is frozen from further transfers; the issuer `burn()`s it to retire the receivable. Investor capital is returned per the term sheet. T+2 design target; actual timing depends on the issuer's wire-oracle configuration.

The standard we use

CMTAT v3.0.0 — audited. Composable. Used by UBS.

CMTAT — the Capital Market and Technology Association's reference token standard — is the operating layer underneath CurioExtract's tokenization feature. It is audited (Wake Arena M1/M2/M3), in production at major financial institutions, and modular in a way ERC-3643 isn't.

Why CMTAT, not vanilla ERC-3643

CMTAT breaks the spec into small, auditable modules

ERC-3643 ships as one big monolithic contract. Auditing it requires auditing everything. CMTAT ships as BaseCore + BaseRuleEngine + BaseAllowlist + BaseSnapshot + BaseDebt . Each module is independently testable. For a regulated token, this matters: it means you ship a smaller attack surface per audit cycle.

In production at

UBS
Taurus
Syz Group
Zand Trust
Daura
Obligate
Cité Gestion
CODE41

These institutions have tokenized real-world assets using CMTAT in production. Source: github.com/CMTA/CMTAT

FAQ

The questions a CFO asks first.

These are real questions from our design partners during the summer 2026 pilot. If yours is missing, write to dpo@curioinvest.com and we'll add it.

Is a tokenized receivable a security under Swiss law?
In most cases no. Under FinSA Art. 4, debt instruments (a receivable is a debt instrument) are exempt from prospectus requirements when offered to a closed circle of professional or pre-screened investors. The token we mint is a CMTAT — a permissioned token (ERC-3643-compatible) where transfer requires a compliance check, which keeps the offering inside the exemption. CurioInvest provides the KYC + whitelist tooling and a per-token transfer hook, but the legal opinion is yours: we ship the rails, not the ruling.
What changes on 1 January 2026 with the new DLT Act?
The DLT Act creates a new federal register of ledger-based rights. A dematerialised share, a tokenised bond, a non-fungible right — any of these can now be legally registered as a civil-law right in a DLT recognised by FINMA. For tokenised receivables specifically, the bigger effect is upstream: we now have a clean answer to the question "what kind of right does the token represent?" The token represents a digital ledger entry of the underlying claim. The underlying claim is registered (or, in most receivables, not yet) in that ledger. This is the foundation CurioExtract is built on.
What's the difference between ERC-20, ERC-1404, ERC-3643 and CMTAT?
ERC-20 is the base token standard. ERC-1404 adds transfer validation with a hook that returns a numeric reason code. ERC-3643 (formerly T-REX) is the full identity-aware regulated security token. CMTAT, developed by the Capital Market and Technology Association (CMTA), is a more modular evolution of those — same compliance hooks, but split across many small, composable modules. The contracts in this dashboard mint CMTATs because they're easier to compose, audited by Wake Arena, and used by UBS / Taurus / Syz in production.
Why ERC-3643 specifically? Why not ERC-20?
ERC-20 has no transfer validation — anyone with the address can send anywhere. For a regulated receivable, that's disqualifying: you have no way to enforce a whitelist, and a stray transfer to a non-KYC wallet can't be reversed. ERC-3643 (and the modular CMTAT that descends from it) has a built-in `transferred(spender, from, to, value)` hook on every transfer that runs the compliance check, and a `detectTransferRestriction` view function the holder can call before sending. We use the CMTA RuleEngine + a Swiss-DLT-specific rule (jurisdiction whitelist, KYC verification, settlement-freeze) on top of CMTAT v3.0.0.
Where does the data live?
Postgres for the application state. For tokenized receivables, the CMTAT contract is deployed to Polygon mainnet (or Polygon Amoy for testing). The jurisdiction check, KYC status, and settlement-freeze all live on-chain. Off-chain components — the AI extraction layer, the human approval flow, the dashboard — sit on Swiss-hosted Postgres (currently Neon). Documents stay on CurioExtract for the duration of the receivable, then migrate to a long-term cold store at settlement.
What happens when the obligor pays the underlying invoice?
Two paths. Manual: the issuer marks the receivable `settled` via `rule.markSettled(tokenId)`. On-chain: a settlement oracle (e.g., a Polygon Oracles feed reading the obligor's bank API) automatically calls `markSettled` on payment confirmation. In both cases, the token is frozen from further transfers (settlement-freeze), then the issuer `burn()`s it to retire the receivable. Investor capital is returned per the term sheet. T+2 is the design target; actual time depends on how the issuer wires the oracle.
Is the receivable in the issuer's or the investor's control?
The token representing the receivable lives in the issuer's multisig during tokenization. When an investor subscribes, `transferFrom` moves the token to the investor's wallet, and the investor holds the receivable claim. The CMTAT's `forcedTransfer` and `accountFreeze` are admin-only — and the admin is governed by a 2-of-3 multisig of named CurioInvest officers. Investors can see, in the dashboard, exactly which wallet holds the claim, the exact `transfer` history, and the on-chain block height at every step.
What if the obligor never pays?
Three failure modes, surfaced in the dashboard: (1) late payment triggers a penalty-interest accrual (12% above the contract APR) and auto-notification; (2) default triggers Swiss SchKG (Betreibungsbegehren) legal recovery, 70-90% expected recovery; (3) bankruptcy triggers the underlying insolvency proceeding, 40-60% expected recovery, 12-18 month timeline. The dashboard's 'Backtest' tool runs the whole 20-contract portfolio through these scenarios so the CFO sees the worst case before issuing.
Do I need a Swiss entity?
For issuing tokenized receivables, the issuer can be a CH/EU/DE/AT/IT/FR company. The investor base needs to be a 'qualified investor' or a 'professional client' under FinSA / EU MIFID, with documented KYC. For the demo we use the CurioInvest Swiss-DLT whitelist (CH / DE / AT / IT / FR). If your obligor or investor is in the US or Asia, we need a separate analysis — talk to us. (See the 'Open the SIM' CTA — that's the conversation-starter.)
Is this a product I can put in front of my auditor?
Yes. The tokenization events are recorded on a public blockchain (Polygon) with immutable block-height references. The application state sits in a Postgres database that you own and can export. The `transferred` and `mint` events are emitted as standard ERC-20 Transfer events and CMTAT-specific events. You can hand the auditor a CSV of every contract + its on-chain transaction history + the rule enforcement log from the `TransferWithData` / `DetectedTransferRestriction` events. That's your audit trail.

Read the rules yourself. Then run on them.

Open the demo, mint a real CMTAT on Polygon Amoy testnet, and see the rule engine in action. Then bring us your largest contract and let's run the stress test for real.