In a coordinated effort that underscores the growing significance of digital assets within traditional financial markets, a coalition of leading market participants—including Nasdaq, the Stuttgart Stock Exchange (Börse Stuttgart), and a number of other prominent exchanges and custodians—has formally appealed to European Union regulators to either lift the existing ceiling on tokenisation projects or to substantially increase it. The coalition’s request stems from a mounting body of evidence that the current cap, which was introduced as part of the EU’s pilot regime for tokenised securities, is rapidly becoming a bottleneck for innovative financial products that are already being developed across the continent.
The pilot regime, which was launched under the EU’s Markets in Crypto‑Assets (MiCA) framework, set a provisional maximum value for tokenisation projects at €100 million. This limit was intended as a temporary safeguard while regulators gathered data on market behaviour, investor protection, and systemic risk. However, as the coalition points out, a number of high‑profile initiatives—ranging from tokenised corporate bonds to fractional ownership of real‑estate assets—have already eclipsed this threshold.
In some cases, the total value of assets being tokenised under a single project has approached or even exceeded €500 million, rendering the €100 million ceiling not only impractical but also potentially stifling to further development. Nasdaq, a global leader in exchange technology and market data, highlighted that its own tokenisation platform, which aims to bring a broader spectrum of securities onto blockchain‑based settlement layers, is constrained by the cap. The company noted that the limitation hampers its ability to onboard large‑scale issuers who are looking to raise capital through tokenised instruments.
"Our clients are seeking to unlock liquidity and broaden their investor base by issuing tokenised securities that can be traded 24/7 across borders," a Nasdaq spokesperson explained. "The current €100 million ceiling forces them to either split their offerings into multiple, smaller tranches—complicating compliance and increasing costs—or to abandon tokenisation altogether, which would be a step backward for market innovation." Similarly, Börse Stuttgart, which has positioned itself as a pioneer in the European token market through its subsidiary, the Stuttgart Digital Exchange (SDX), argued that the cap undermines the exchange’s strategy to become a hub for tokenised assets.
The exchange has already facilitated the tokenisation of several mid‑cap German companies, with total issuance values well beyond the pilot limit. "Our experience shows that investors are eager for tokenised securities that reflect the true scale of the underlying companies," said a representative from Börse Stuttgart. "By keeping the cap at €100 million, regulators are effectively limiting the size of projects that can benefit from the efficiencies of blockchain technology, such as faster settlement, reduced custody costs, and enhanced transparency." Beyond the immediate concerns of individual exchanges, the coalition emphasized broader systemic implications. Tokenisation, they argue, holds the promise of democratizing access to capital markets, allowing smaller investors to purchase fractional shares of high‑value assets that were previously out of reach.
This could lead to deeper market participation, greater liquidity, and more resilient capital formation mechanisms. However, the cap threatens to curtail these benefits by restricting the scale at which tokenised securities can be issued and traded.
The coalition’s petition also references several ongoing projects that have already encountered regulatory friction due to the cap. For instance, a cross‑border tokenised bond issuance involving a consortium of European banks was forced to restructure its offering into three separate tranches, each staying below the €100 million limit. This fragmentation not only increased administrative overhead but also introduced complexities in secondary market trading, as each tranche required distinct clearing and settlement arrangements.
In response to these challenges, the coalition proposes two possible pathways for the EU regulators: 1. **Removal of the Cap** – Eliminating the ceiling altogether would allow tokenisation projects to scale organically based on market demand and risk assessments, aligning the regulatory environment with the dynamic nature of blockchain‑based finance. 2.
**Significant Increase of the Cap** – If a complete removal is deemed premature, the coalition suggests raising the limit to at least €500 million, a figure that reflects the current size of many tokenisation initiatives and provides sufficient headroom for future growth. The petition also calls for a clear, transparent timeline for any regulatory adjustments, stressing that prolonged uncertainty could deter investment and slow the adoption of tokenised assets across Europe. The coalition highlighted that other jurisdictions, such as the United States and Singapore, have already adopted more flexible approaches, thereby attracting a wave of innovative projects and positioning themselves as hubs for digital securities. Regulators, for their part, have acknowledged the concerns raised by the coalition.
A spokesperson from the European Commission’s Directorate‑General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) indicated that the pilot regime is under continuous review and that stakeholder feedback is a critical component of the evaluation process. "We appreciate the detailed input from market participants and recognize the importance of striking a balance between fostering innovation and ensuring investor protection," the spokesperson said. "Our aim is to develop a regulatory framework that supports sustainable growth while mitigating systemic risks." The upcoming consultation, scheduled for early next year, will provide a formal platform for the coalition and other interested parties to present their arguments. Industry observers anticipate that the outcome of this consultation could shape the trajectory of Europe’s digital asset market for years to come.
If the EU decides to raise or remove the cap, it could accelerate the rollout of large‑scale tokenisation projects, potentially positioning Europe as a leader in the emerging market for blockchain‑enabled securities. In conclusion, the coalition’s appeal reflects a broader narrative: the intersection of traditional finance and blockchain technology is reaching a critical juncture where regulatory frameworks must evolve to accommodate new forms of capital formation. By addressing the cap on tokenisation projects, EU policymakers have an opportunity to either unlock a wave of innovation that could enhance market efficiency and inclusivity or risk stalling momentum as innovators look to more accommodating jurisdictions.
The next few months will be pivotal in determining whether Europe will seize this chance to lead the tokenisation revolution or watch it pass by.