In a coordinated effort that underscores the growing momentum behind digital asset innovation across Europe, a diverse group of market participants—including Nasdaq, the Stuttgart Stock Exchange (Börse Stuttgart), and a number of other prominent financial institutions—has formally appealed to the European Union to either remove the present ceiling on tokenised assets or to increase it substantially within the framework of the EU’s ongoing tokenisation pilot. This coalition argues that the current cap, set at a relatively modest level, hampers the development of promising projects that are already demonstrating the ability to exceed the limit, thereby stifling the broader ambition of creating a vibrant, interoperable market for tokenised securities and other digital representations of real‑world assets. The request was submitted to the European Commission and the European Parliament as part of a broader dialogue on how best to integrate tokenisation into the existing financial regulatory architecture.
The signatories contend that the pilot, which was launched to test the feasibility of issuing, trading, and settling tokenised assets under a harmonised set of rules, should be allowed to operate without an artificial ceiling that does not reflect the actual scale and potential of the projects currently in development. They point to several ongoing initiatives across the continent—ranging from tokenised corporate bonds and equity shares to real‑estate and infrastructure assets—that have already reached or are projected to surpass the current limit of €1 billion in aggregate value. According to the coalition’s statement, the existing cap was originally intended as a precautionary measure, designed to limit exposure while regulators gathered data on market behaviour, investor protection issues, and operational risks.
However, the signatories argue that the landscape has evolved rapidly. Advances in blockchain technology, improvements in custodial solutions, and the emergence of robust compliance frameworks have collectively reduced many of the risks that initially justified a low threshold. Moreover, the coalition highlights that the cap creates a competitive disadvantage for European issuers when compared with jurisdictions such as the United States or Singapore, where regulators have adopted more flexible approaches, allowing larger tokenised offerings to proceed unhindered. Nasdaq, as one of the world’s leading exchange operators, brings a wealth of experience in managing large‑scale securities listings and has been actively exploring how its technology can be adapted for tokenised instruments.
In its contribution to the letter, Nasdaq emphasised that its own pilot projects have already attracted interest from issuers seeking to raise capital in the range of several hundred million euros, and that a higher cap would unlock the ability to support multi‑billion‑euro offerings, thereby attracting a broader set of participants and fostering deeper liquidity. The Stuttgart Stock Exchange, which has a long history of supporting innovative trading mechanisms, echoed these points, noting that its own tokenisation platform, which focuses on small‑ and medium‑sized enterprises, is quickly reaching the current limit and would benefit from a more generous ceiling to accommodate growth. Beyond the immediate financial considerations, the coalition also stresses the strategic importance of tokenisation for the EU’s wider economic objectives. Tokenised assets can enhance market accessibility by lowering entry barriers for both issuers and investors, improve transparency through immutable ledger records, and increase settlement efficiency by reducing reliance on legacy clearing and settlement infrastructures.
These benefits align with the EU’s Digital Finance Strategy, which aims to foster a competitive, innovative, and resilient financial ecosystem. By lifting the cap, the EU would send a clear signal to the market that it is committed to nurturing the nascent tokenisation sector, encouraging further investment, research, and development.
The coalition’s request is not merely a demand for regulatory leniency; it is accompanied by a set of concrete proposals to ensure that any increase in the cap is matched by robust oversight mechanisms. Among these proposals are: (1) enhanced reporting requirements for tokenised issuers, including periodic disclosures of underlying asset performance and token holder composition; (2) mandatory adoption of internationally recognised security token standards to promote interoperability; (3) strengthened anti‑money‑laundering (AML) and know‑your‑customer (KYC) procedures tailored to the digital nature of tokenised securities; and (4) the establishment of a supervisory sandbox that allows regulators to monitor high‑value tokenised offerings in real time, thereby mitigating systemic risk while still permitting innovation.
Critics of the current cap argue that it inadvertently creates a two‑tier market, where only smaller projects can participate, limiting the diversity of assets and potentially concentrating risk among a narrow set of participants. By contrast, a higher or removed cap would enable a broader spectrum of issuers—from start‑ups to large corporations—to experiment with tokenisation, generating a richer data set for regulators to analyse and refine their policies. This, in turn, would accelerate the development of best practices and industry standards, benefiting the entire ecosystem.
In response, some regulators have expressed cautious optimism. They acknowledge that the pilot has yielded valuable insights into operational challenges, such as cross‑border settlement timing, investor onboarding, and the integration of tokenised assets into existing portfolio management systems. Yet, they also emphasize the need to balance innovation with investor protection, particularly given the nascent nature of many tokenised products and the potential for market volatility. The coalition’s appeal arrives at a pivotal moment, as the EU prepares to finalize its MiCA (Markets in Crypto‑Assets) framework, which will set the long‑term regulatory foundation for crypto‑related activities, including tokenised securities.
A decision to raise or eliminate the cap within the pilot could serve as a practical complement to MiCA, offering real‑world evidence on how larger‑scale tokenised offerings perform under a regulated environment. It would also provide a testing ground for the supervisory tools and compliance measures that MiCA envisages. In summary, Nasdaq, Börse Stuttgart, and their fellow signatories are urging the European Union to reconsider the current tokenisation cap imposed on its pilot program.
They argue that the limit is now out of step with market realities, hampers the growth of promising projects, and puts the EU at a competitive disadvantage. By proposing a higher ceiling—or its complete removal—paired with strengthened oversight, the coalition seeks to unlock the full potential of tokenised assets, align regulatory practice with technological progress, and support the EU’s broader digital finance ambitions.
The outcome of this request will likely shape the trajectory of tokenisation in Europe for years to come, influencing both the scale of future offerings and the regulatory approach adopted across the continent.