In recent weeks, a coalition of leading financial market participants, including Nasdaq, the Börse Stuttgart, and a number of other prominent exchanges and industry groups, has formally appealed to the European Union to either remove the existing ceiling on tokenised assets in the EU’s experimental framework or, at the very least, raise it to a level that reflects the rapid growth and evolving complexity of the market. This request emerges against a backdrop of accelerating interest in digital assets, blockchain‑based securities, and the broader tokenisation of real‑world assets, which together promise to reshape capital markets by increasing liquidity, broadening investor access, and lowering transaction costs. The current regulatory sandbox for tokenisation, introduced under the EU’s Markets in Crypto‑Assets (MiCA) regime, sets a maximum aggregate value of €100 million for tokenised projects that can participate in the pilot.
While the cap was originally intended as a cautious safeguard—allowing regulators to observe market dynamics on a manageable scale—participants argue that it now acts as a bottleneck that stifles innovation and prevents many viable projects from testing their solutions in a real‑world environment. In their joint statement, the coalition highlights several ongoing European initiatives that have already exceeded the €100 million threshold, underscoring the mismatch between the regulatory limit and market reality. Among the projects cited are a cross‑border tokenised bond issuance platform being piloted by a consortium of banks in the Eurozone, a tokenised real‑estate fund that has attracted commitments well above the cap, and a series of tokenised commodity trading schemes that are already generating substantial trading volumes on secondary markets.
These examples illustrate that the tokenisation ecosystem is no longer confined to niche experiments; it is moving toward mainstream adoption, with institutional investors showing keen interest in diversified, blockchain‑enabled assets. The coalition’s argument rests on three core premises. First, the cap is technically outdated.
When the sandbox was designed, the tokenisation market was in its infancy, and a modest ceiling was reasonable to limit exposure. Today, however, the market’s scale and sophistication have expanded dramatically, making the €100 million limit appear arbitrary and restrictive. Second, the cap hampers the EU’s strategic ambition to become a global leader in digital finance. Competitors such as the United States, Singapore, and Switzerland have already adopted more flexible frameworks that allow larger tokenised projects to operate, thereby attracting capital, talent, and innovation.
By maintaining a low ceiling, the EU risks losing market share to these jurisdictions. Third, the coalition points out that a higher or removed cap would not diminish regulatory oversight.
Instead, it would enable regulators to gather data from a broader set of participants, improving the quality of supervision and informing future policy decisions. In response, EU policymakers have acknowledged the concerns and indicated that they are reviewing the sandbox parameters. The European Commission’s Directorate‑General for Financial Stability, Financial Services and Capital Markets Union (DG‑FIN) has scheduled a series of consultations with industry stakeholders to assess whether the current limits remain appropriate. While some officials stress the importance of maintaining prudential safeguards, others recognize that an overly restrictive cap could undermine the very objectives of the sandbox, which are to foster innovation while ensuring investor protection.
The coalition’s request also touches on broader regulatory themes, such as the need for proportionality in oversight, the balance between innovation and risk, and the importance of regulatory certainty for market participants. By advocating for a cap increase—or its removal altogether—the coalition seeks to create a more level playing field where both small‑scale pilots and larger, more ambitious projects can coexist, share best practices, and contribute to a robust, resilient digital asset ecosystem.
If the EU decides to raise the cap, several potential outcomes could follow. Larger tokenised issuances would be able to test end‑to‑end processes, from issuance and settlement to secondary market trading and custody, under real‑world conditions. This would generate valuable data on market liquidity, price discovery mechanisms, and operational risk, which could then be used to refine regulatory standards.
Moreover, a higher ceiling would likely attract additional participants, including asset managers, pension funds, and sovereign wealth funds, all of whom are watching the regulatory landscape closely before committing capital to tokenised assets. Conversely, if the cap remains unchanged, some projects may seek to relocate their pilot activities to more permissive jurisdictions, potentially leading to a fragmentation of the European market. Such a scenario could dilute the EU’s ability to set global standards for tokenisation and diminish the continent’s influence in shaping the future of digital finance. In summary, Nasdaq, the Börse Stuttgart, and their allied partners are urging the European Union to reconsider the current €100 million limit imposed on tokenisation pilots.
Their appeal is grounded in concrete examples of projects that have already outgrown the cap, a strategic desire to keep the EU competitive on the global stage, and a belief that a higher limit would enhance, rather than compromise, regulatory oversight. As discussions continue, the outcome of this debate will likely shape the trajectory of tokenised finance in Europe for years to come, influencing everything from capital market structures to investor access and the overall pace of digital transformation in the financial sector.