In recent weeks, a coalition of leading financial market participants—including Nasdaq, the Stuttgart Stock Exchange (Börse Stuttgart), and a number of other prominent institutions—has formally appealed to European Union policymakers to either remove the existing ceiling on tokenised assets or substantially increase it within the framework of the EU’s tokenisation pilot programme. This request stems from growing concerns that the current cap, which limits the total value of assets that can be tokenised under the pilot, is far too restrictive for the ambitions of the market and for the scale of projects already underway across the continent. The tokenisation pilot, launched by the European Commission as part of its broader digital finance strategy, aims to test the feasibility, security, and regulatory adequacy of issuing and trading digital representations of real‑world assets on distributed ledger technology (DLT) platforms.
By allowing participants to experiment with tokenised securities, real estate, commodities, and other asset classes, the pilot is intended to lay the groundwork for a more efficient, transparent, and inclusive financial ecosystem in Europe. However, the pilot’s design includes a monetary ceiling that limits the aggregate value of tokenised assets that can be issued under its auspices. While the exact figure has not been publicly disclosed, insiders indicate that it is measured in the low‑hundreds of millions of euros—a modest amount compared to the billions of euros that many market participants anticipate deploying. Nasdaq, a global leader in exchange services and market infrastructure, has been vocal about the limitations imposed by the current cap.
In a joint statement released by the coalition, Nasdaq highlighted that several of its European partners are already preparing tokenisation projects that would exceed the pilot’s ceiling. "We see a robust appetite among issuers, investors, and technology providers for tokenised solutions that can unlock liquidity, reduce settlement times, and lower transaction costs," the statement read. "The existing limit not only hampers the scale of these initiatives but also sends a mixed signal to the market about the EU’s commitment to fostering innovation in digital finance." The Stuttgart Stock Exchange, which has been actively exploring tokenised bonds and other fixed‑income instruments, echoed these concerns.
Representatives from Börse Stuttgart noted that their pilot projects, which involve tokenising sovereign and corporate bonds with a combined face value well beyond the current cap, are already encountering regulatory bottlenecks. "Our goal is to demonstrate that tokenised bonds can provide faster settlement, greater accessibility for retail investors, and enhanced transparency," said a senior executive at the exchange. "But the artificial ceiling forces us to either truncate our offerings or seek alternative jurisdictions, which defeats the purpose of a unified European approach." Beyond Nasdaq and Stuttgart, the coalition includes a range of fintech firms, asset managers, and custodians who are all aligned in their assessment that the cap is misaligned with market realities.
Several of these participants have already launched proof‑of‑concepts that involve tokenising assets worth several hundred million euros each. For instance, a leading European asset manager is in the final stages of a project that tokenises a portfolio of renewable energy assets, with an estimated market value of €350 million.
Under the current pilot rules, only a fraction of that portfolio could be tokenised, limiting the project's ability to showcase the full benefits of digital securities. The coalition’s appeal to the EU is grounded in both practical and strategic arguments. Practically, a higher cap—or the removal of the cap altogether—would enable participants to test tokenisation at a scale that reflects real‑world market conditions, thereby providing regulators with richer data on risk, liquidity, and operational resilience. Strategically, the EU risks falling behind other jurisdictions, such as the United States, Singapore, and Switzerland, which have adopted more permissive frameworks for digital asset experimentation.
These regions are already attracting a wave of issuers looking to leverage tokenisation to access global capital, and a restrictive EU cap could divert that activity away from Europe. In addition to the immediate concerns about scale, the coalition also raised broader policy considerations. They argued that the cap could inadvertently create a fragmented market, where only smaller, less complex tokenised assets are permitted, while larger, institutional‑grade projects are forced to seek alternative regulatory sandboxes or to operate outside the EU altogether. This fragmentation could undermine the EU’s ambition to become a leader in digital finance and could limit the development of ancillary services—such as custodial solutions, compliance tools, and DLT infrastructure—that depend on a vibrant tokenisation ecosystem.
To address these issues, the coalition proposed several concrete steps for the European Commission and the European Securities and Markets Authority (ESMA). First, they suggested an immediate review of the pilot’s monetary ceiling, with a view to either raising it to a level that accommodates multi‑billion‑euro projects or removing it entirely to allow unrestricted experimentation.
Second, they recommended the establishment of a transparent, data‑driven framework for assessing the impact of larger tokenisation volumes on market stability, including stress‑testing scenarios and liquidity analyses. Third, they called for enhanced coordination between national regulators and EU‑level bodies to ensure that any changes to the cap are harmonised across member states, thereby preventing regulatory arbitrage.
The coalition also underscored the importance of maintaining investor protection while expanding the pilot. They emphasized that robust KYC/AML procedures, clear disclosure standards, and reliable custody arrangements must remain central pillars of any tokenisation framework, regardless of the size of the assets involved. By coupling a higher cap with strong safeguards, the EU can demonstrate that it is capable of fostering innovation without compromising market integrity.
In response to the coalition’s letter, an EU spokesperson acknowledged receipt of the concerns and indicated that the Commission is reviewing the pilot’s parameters in light of feedback from market participants. "We appreciate the constructive input from industry stakeholders and are committed to ensuring that the tokenisation pilot reflects both the ambition and the practical needs of the European financial sector," the spokesperson said. "Our goal is to strike the right balance between encouraging innovation and preserving the stability and confidence of the market." As the dialogue continues, many observers anticipate that the EU will adjust the pilot’s framework before the current testing phase concludes later this year.
Should the cap be raised or removed, it could unlock a new wave of tokenisation projects across Europe, ranging from tokenised real estate and infrastructure assets to digital representations of intellectual property and carbon credits. Such developments would not only enhance market efficiency but also align with the EU’s broader sustainability and digital transformation objectives.
In summary, Nasdaq, the Stuttgart Stock Exchange, and a coalition of allied firms are urging the European Union to reconsider the monetary ceiling that limits the tokenisation pilot. Their argument rests on the premise that the present cap is too low to accommodate existing projects that already exceed it, and that a higher—or nonexistent—cap would better serve the goals of market innovation, competitiveness, and investor protection.
The outcome of this request will likely shape the trajectory of digital asset adoption in Europe for years to come.