In recent weeks, a coalition of major market participants—including Nasdaq, the Stuttgart Stock Exchange (Boerse Stuttgart), and a number of other leading institutions—has formally appealed to European Union regulators to either lift the current ceiling on tokenised assets or to raise it substantially within the framework of the EU’s tokenisation pilot programme. The request stems from growing concerns that the existing cap, which limits the amount of value that can be placed into tokenised securities during the trial, is far too restrictive for the scale of activity that market actors are already witnessing across the continent. The coalition’s statement underscores a key tension at the heart of the EU’s effort to foster a vibrant digital‑asset ecosystem: on the one hand, policymakers are eager to experiment with blockchain‑based securities and to test how tokenisation can streamline issuance, settlement, and custody processes; on the other hand, they have imposed a relatively modest monetary ceiling—initially set at €100 million per issuer—to contain risk while the regulatory framework is still being refined.
According to the signatories, that limit does not reflect the realities of today’s market, where several high‑profile projects have already reached, or are projected to exceed, that threshold. Nasdaq, a global leader in exchange technology and market infrastructure, highlighted that its own tokenisation initiatives in Europe have attracted significant investor interest, with pilot issuances quickly approaching the cap. The exchange argued that the artificial ceiling not only hampers the ability of issuers to raise capital efficiently but also discourages innovative fintech firms from experimenting with token‑based securities models under the EU umbrella.
"We see a clear mismatch between the ambition of the EU’s digital finance strategy and the practical constraints imposed by the current cap," a Nasdaq spokesperson said. "If the goal is to position Europe as a world‑class hub for tokenised finance, the regulatory parameters need to be aligned with market demand." Similarly, Boerse Stuttgart, which has been at the forefront of integrating blockchain technology into its trading platforms, pointed out that its own tokenised bond and equity offerings have already generated demand that outstrips the €100 million limit.
The exchange noted that several of its pilot projects have secured commitments from institutional investors that collectively exceed the cap, meaning that the projects would have to be artificially split or curtailed to stay within the regulatory bounds. "Fragmenting issuances undermines the very efficiencies that tokenisation promises—speed, transparency, and reduced transaction costs," the Stuttgart exchange’s chief digital officer explained. Other participants in the coalition, including several asset managers, custodians, and technology providers, echoed these concerns. They cited concrete examples: a German fintech firm that tokenised a €150 million corporate bond, a French investment platform that launched a tokenised share offering worth €120 million, and a cross‑border consortium that is preparing a €200 million tokenised infrastructure fund.
All of these initiatives, they argued, would either have to be scaled back or halted entirely if the cap remains unchanged. Beyond the immediate financial implications, the coalition warned that an overly restrictive cap could have broader strategic consequences for the EU’s competitiveness. The global race to become the leading jurisdiction for digital asset innovation is intensifying, with the United States, Singapore, and several Asian economies already offering more permissive regimes for tokenised securities.
If Europe continues to impose low ceilings, innovators may look to those jurisdictions for a more supportive environment, potentially resulting in a loss of talent, investment, and technological know‑how. The coalition’s appeal is not merely a request for a higher number; it is also a call for a more flexible, risk‑adjusted approach to regulation. They propose that the EU consider a tiered cap system, where issuers with robust compliance frameworks, audited custodial solutions, and proven market demand could qualify for higher limits. Such a system would preserve the regulator’s ability to manage systemic risk while allowing the market to scale organically.
Additionally, the coalition suggested that the EU introduce a fast‑track review process for projects that demonstrate strong governance and investor protection measures, thereby reducing administrative bottlenecks. In response, EU officials have acknowledged the feedback and indicated that they are reviewing the pilot’s parameters. A spokesperson from the European Commission’s Directorate‑General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) said that the Commission is aware of the “rapid evolution of tokenised finance” and is committed to ensuring that the pilot remains both safe and conducive to innovation. The spokesperson added that any adjustment to the cap would be based on a thorough risk assessment, taking into account market liquidity, investor protection, and the overall stability of the financial system.
The debate is expected to continue over the coming weeks, with a formal consultation scheduled later this month. Stakeholders from across the financial ecosystem—including banks, asset managers, fintech startups, and consumer groups—are invited to submit their perspectives on how best to balance innovation with prudential oversight.
The outcome of this consultation could shape not only the tokenisation pilot but also the broader regulatory architecture for digital assets in Europe for years to come. In summary, Nasdaq, Boerse Stuttgart, and a coalition of other market participants are urging the European Union to either remove the current €100 million cap on tokenised assets within the pilot programme or to raise it to a level that reflects actual market activity and future growth potential. They argue that the present limit is too low, citing multiple ongoing projects that have already surpassed it, and warn that maintaining such a restrictive ceiling could hinder Europe’s ambition to become a leading hub for tokenisation and digital finance. The conversation now moves to the EU’s regulators, who must weigh the benefits of a more expansive cap against the need to safeguard financial stability and protect investors.