An ERIR platform is the system through which the entity responsible for registration and record-keeping records ownership of transferable securities represented by distributed ledger technology, under Spain's Law 6/2023 (LMVSI). Unknown Gravity builds these platforms for issuers and entities that take on the ERIR role in Spain.
An ERIR (the entity responsible for registering and recording securities represented by distributed ledger technology, Arts. 7 and 8 of Law 6/2023) platform is the technological infrastructure with which an entity responsible for the administration of the recording and registration of securities represented through distributed ledger technology (DLT) systems, known as the ERIR, performs its role in a safe, traceable and compliant manner (Art. 8 of Spanish Law 6/2023 (LMVSI), BOE-A-2023-7053). Its main function is to record, control and monitor tokenized issuances and all associated events: holdings, transfers, restrictions, corporate events and audit evidence.
It is an institutional platform that combines distributed registration, regulatory back-office, eligibility control and reporting, designed to support continuous monitoring, segregation of duties and operational compliance by design (compliance-by-design). At Unknown Gravity we built it with a legal-first approach, aligning law, process and technology.
01 / What is an ERIR Platform and what is it for?
It is the central system an ERIR uses to perform its functions: recording issuances and holdings, controlling how tokens move and supervising compliance with the rules of each issuance. Eligibility comes before technology: that entity, even where it is the issuer itself, must be authorized to provide custody and administration of financial instruments on behalf of clients, which in practice means an investment firm or a credit institution. The platform does not replace that authorization (Arts. 8(4) and 126(a) LMVSI, BOE-A-2023-7053).
It acts as the single source of operational truth, connecting the distributed registry with internal processes, validations, evidence and reporting. The blockchain provides immutability; the platform adds control, context and accountability.
Registry versus operations
Operations apply rules, permissions and validations before an event takes place. The registry leaves a traceable record and must preserve the integrity and immutability of the issuance: that is a duty of the responsible entity, not an absolute guarantee of the system (Art. 8 LMVSI, BOE-A-2023-7053).
Institutional role of the ERIR
The platform is designed to reflect the functional responsibility of the ERIR: controlled decisions, verifiable evidence and continuous oversight.
02 / Distributed Record and Book of Holders
The core of the platform is the registry: who is the owner, since when, under what conditions and how has that position changed over time.
Book of Tokenized Holders
- Positions by token, series and issuance
- Complete and reconstructable history by date
- Evidence of the origin and destination of each change
Integrity and immutability
- Hashes and cross-references
- On-chain/off-chain reconciliation
- Preventing operational inconsistencies
The issuance document
The register rests on the issuance document: it identifies the entity responsible for the recording and registration, sets out the content of the securities and describes how the system works and is governed. The platform keeps it, versions it and makes it available to holders and to the public, as the law requires (Art. 7 LMVSI, BOE-A-2023-7053).
03 / Transfer Control and Eligibility
In ERIR environments a transfer is not free by default: it must comply with clear, documented rules, and the system has to guarantee the integrity and immutability of the issuance and identify the holders at all times (Arts. 6(5) and 8 LMVSI, BOE-A-2023-7053).
Eligibility Rules
- Whitelists and authorized profiles
- Restrictions by token type, jurisdiction, or state
- Temporary windows and operating limits
Locks, freezes and recoveries
- Preventive or corrective freezing
- Recovery under procedure
- Reverses controlled with evidence
04 / Governance, Roles and Oversight
An ERIR Platform should reflect the segregation of duties and the principles of good governance.
Advanced roles and permissions
- Operator, Supervisor, Compliance, Auditor
- Two-step approvals (four-eyes)
- Critical actions with reinforced authorization
Operational risk is minimized and institutional accountability is reinforced.
Decision traceability
- Immutable action logs
- Versioning configurations
- Evidences associated with each decision
Not only is the event recorded, but Why and who authorized it.
05 / Auditing, Reporting and Evidence
An ERIR needs prove your operation, not just execute it.
Regulatory reporting
- Reports by issuance, period and holder
- Structured exportables
- Full traceability
Internal and external auditing
- Evidences of processes
- Decision history
- Preparing for supervision
This content is for information purposes. It is not legal, tax or investment advice and does not replace consulting a professional. Regulation on tokenization and crypto-assets keeps evolving: check the current version of the rules cited on BOE and EUR-Lex.
FAQ
Frequently asked questions
Is this platform mandatory for an ERIR?
There is no “official software”, but without a platform of this type it is unfeasible consistently perform the functions of registration, control and supervision.
Can it adapt to different types of tokens and assets?
Yes, technically: the platform works with per-issuance rules and configurations, and it serves tokenized securities, RWA or energy projects. One distinction matters: the ERIR figure exists only for transferable securities represented in distributed ledger systems. A consumer token under MiCA has no ERIR, although it may still need registration and operational controls (Art. 8(4) LMVSI, BOE-A-2023-7053).
Does it work only with public blockchain?
No. It can be designed on public, permissioned or hybrid blockchain, prioritizing control, costs and regulatory requirements.