In a coordinated effort that underscores the growing importance of digital assets in traditional finance, several prominent market participants—including Nasdaq, Boerse Stuttgart, and a number of other exchanges and custodians—have formally requested that the European Union revisit the regulatory ceiling that governs the tokenisation of assets in its pilot programme. The coalition’s joint statement, released earlier this week, argues that the existing cap on the total value of assets that can be tokenised under the EU’s experimental framework is insufficient for the scale of projects already underway and for the ambitions of future initiatives that aim to bring greater liquidity, transparency, and efficiency to capital markets. The tokenisation pilot, which was launched by the European Commission as part of its broader digital finance strategy, allows authorised market infrastructures to issue token‑based representations of real‑world assets—such as equities, bonds, real‑estate parcels, or even commodities—on a distributed ledger. Participants in the experiment must adhere to a maximum aggregate value for all tokenised securities they issue, a limit that was initially set at a modest €2 billion.
The coalition of firms contends that this ceiling, while perhaps appropriate when the pilot was first conceived, now acts as a bottleneck that hampers the development of larger‑scale projects and prevents the EU from fully showcasing the potential of blockchain‑enabled finance. "We have witnessed a rapid evolution in the tokenisation landscape over the past twelve months," said a spokesperson for Nasdaq, one of the leading proponents of the request. "Several of our European partners are already piloting tokenised securities that, taken together, exceed the current cap. Maintaining the status quo would force them to either truncate their offerings or abandon promising use cases altogether.
A higher ceiling—or the removal of the cap entirely—would provide the regulatory certainty needed to attract further investment and to scale these innovative solutions across the continent." Boerse Stuttgart echoed these sentiments, highlighting specific projects that have already pushed the boundaries of the existing limit. The German exchange pointed to a tokenised bond issuance that, once fully subscribed, would represent a value of roughly €1.5 billion on its own. When combined with other tokenised equity and real‑estate offerings currently in the pipeline, the total exposure easily surpasses the €2 billion threshold. "Our experience demonstrates that the market demand for tokenised assets is far larger than the current regulatory framework allows," the exchange noted.
"We are prepared to comply with all AML, KYC, and investor protection requirements, but we need a framework that reflects the reality of market activity." Beyond the immediate concerns of individual participants, the coalition argues that the cap undermines the EU’s strategic objectives in the digital finance arena. The European Commission has repeatedly signalled its desire to position Europe as a leader in the development of secure, interoperable tokenisation standards, and to encourage cross‑border investment flows through the use of distributed ledger technology.
A restrictive ceiling, they claim, sends a contradictory message to both domestic innovators and international competitors, potentially diverting capital to jurisdictions with more permissive regulatory environments, such as the United States or Singapore. The request also touches on broader policy considerations, including investor protection, market integrity, and systemic risk.
The coalition acknowledges that any increase in the cap must be accompanied by robust supervisory mechanisms, enhanced reporting obligations, and clear guidelines on the custody of tokenised assets. To that end, they propose a phased approach: initially raising the limit to €5 billion, followed by periodic reviews tied to measurable market metrics such as the number of active tokenised securities, the volume of secondary market trading, and the incidence of operational incidents.
In addition to the quantitative arguments, the coalition provides qualitative evidence of the benefits that a higher cap could unlock. Tokenisation can dramatically reduce settlement times—from days to minutes—by eliminating the need for multiple intermediaries and by leveraging smart contracts that automatically enforce contractual terms. It can also broaden access to capital for smaller issuers, who can fractionalise their assets and reach a global pool of investors without the prohibitive costs associated with traditional underwriting processes. Moreover, the immutable audit trail inherent to blockchain technology enhances transparency, making it easier for regulators to monitor compliance and for investors to verify ownership.
Critics of the proposal caution that a sudden expansion of the cap could expose the market to speculative bubbles or to operational risks associated with nascent technology. They stress the importance of maintaining a balanced regulatory stance that protects investors while still fostering innovation. In response, the coalition emphasises that the pilot framework already includes stringent safeguards, such as mandatory token‑issuer licensing, real‑time transaction monitoring, and mandatory disclosure of underlying asset information. The European Commission has indicated that it will review the coalition’s submission as part of its ongoing assessment of the tokenisation pilot, which is scheduled to conclude in late 2027.
Stakeholders are expected to submit detailed feedback during a public consultation period that will run through the autumn. The outcome of this review could shape the future of digital securities across the EU, influencing everything from the design of the forthcoming Markets in Crypto‑Assets (MiCA) regulation to the development of cross‑border settlement infrastructures.
In summary, Nasdaq, Boerse Stuttgart, and their allied partners are urging EU regulators to either lift the current €2 billion ceiling on tokenised assets or to replace it with a more flexible, tiered system that can accommodate the rapid growth of the market. Their argument rests on concrete examples of projects already exceeding the limit, on the strategic importance of maintaining Europe’s competitive edge in digital finance, and on a commitment to uphold investor protection while unlocking the efficiency gains that tokenisation promises. The forthcoming regulatory decision will be closely watched by industry participants worldwide, as it will signal the EU’s willingness to adapt its rules to the evolving landscape of blockchain‑based financial services.