In a coordinated effort that underscores the growing significance of digital assets in mainstream finance, a coalition of leading market participants—including Nasdaq, the Börse Stuttgart, and a range of other exchanges and financial institutions—has formally appealed to European Union regulators to either remove the existing ceiling on tokenised securities or to substantially increase it within the framework of the EU’s ongoing tokenisation pilot programme. The request emerges against a backdrop of rapid innovation in the tokenisation of assets, a process that converts traditional financial instruments such as equities, bonds, and real‑estate holdings into blockchain‑based tokens.
These tokens retain the economic rights of the underlying assets while offering the benefits of distributed ledger technology, such as enhanced transparency, faster settlement, and broader investor accessibility. The EU’s tokenisation pilot, launched in 2023, was designed to test the regulatory, technical, and market‑infrastructure challenges associated with these new forms of securities, initially setting a maximum issuance limit of €1 billion per project to contain risk while the regulatory framework was still being refined.
The coalition’s letter, addressed to the European Commission’s Directorate‑General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA), argues that the €1 billion cap is now an anachronism. Several pilot participants have already reported that their tokenised offerings comfortably exceed the current threshold, with some projects reaching €1.5 billion and even €2 billion in tokenised capital.
These figures, the coalition contends, are not outliers but rather indicative of the genuine market demand for larger‑scale tokenised issuances that can rival traditional capital‑raising mechanisms. "The present ceiling hampers the ability of issuers to fully exploit the efficiencies and investor‑reach that tokenisation promises," the letter states.
"By limiting the size of tokenised offerings, the EU risks stifling innovation and ceding competitive advantage to jurisdictions with more permissive frameworks, such as the United States and certain Asian markets, where larger tokenised deals are already commonplace." In addition to the quantitative argument, the coalition highlights qualitative benefits that become more pronounced as tokenised issuances scale up. Larger token pools improve liquidity by attracting a broader base of institutional and retail participants, which in turn reduces bid‑ask spreads and enhances price discovery. Moreover, sizable tokenised projects provide richer data sets for regulators and market participants, facilitating more robust risk‑management models and compliance monitoring tools. The coalition suggests that a higher cap—or its complete removal—would allow the EU to gather valuable insights into how large‑scale tokenisation functions in practice, thereby informing a more nuanced and future‑proof regulatory approach.
The letter also points to the operational readiness of the EU’s market infrastructure. Several European clearinghouses, custodians, and digital‑asset service providers have already upgraded their systems to handle high‑volume token transactions, including real‑time settlement and cross‑border processing. These upgrades, the coalition argues, demonstrate that the technical capacity to support larger tokenised deals already exists, and that the regulatory ceiling is the primary bottleneck.
From a policy perspective, the coalition urges the Commission to consider a tiered cap system that aligns with the maturity of the issuer and the underlying asset class. For example, a higher limit could be granted to issuers with a proven track record in traditional securities markets, while newer entrants could retain a more modest ceiling until they demonstrate compliance and operational robustness.
Such a calibrated approach would preserve investor protection objectives while still unlocking the growth potential of tokenised finance. The appeal arrives at a critical juncture for the EU’s digital finance agenda.
The European Commission’s recent Digital Finance Package, which includes the Markets in Crypto‑Assets (MiCA) regulation, signals a strong commitment to fostering a competitive yet secure environment for crypto‑related services. However, critics have warned that overly restrictive measures could undermine the EU’s ambition to become a global hub for fintech innovation. By addressing the cap issue, the Commission would send a clear signal that it is willing to adapt its regulatory parameters in response to market realities.
Industry analysts have largely welcomed the coalition’s move, noting that a higher cap could catalyse a wave of new tokenised projects across sectors such as green finance, infrastructure, and even intellectual‑property rights. "We are seeing a clear appetite from issuers who want to tap into the efficiencies of blockchain while still accessing deep pools of capital," says Maria Kovacs, a senior analyst at EuroFinTech Research. "Removing or raising the cap would not only align the regulatory environment with market demand but also accelerate the development of ancillary services—like token custody, compliance tooling, and secondary‑market platforms—that are essential for a vibrant token ecosystem." In response, the European Commission has indicated that it will review the coalition’s recommendations as part of its broader assessment of the pilot programme, scheduled for completion by the end of 2027. While no immediate policy change has been announced, the Commission’s willingness to engage with stakeholders suggests that a revision of the cap is a distinct possibility.
In summary, Nasdaq, Börse Stuttgart, and their allied partners are urging EU regulators to reconsider the €1 billion limit imposed on tokenised securities within the pilot scheme. Their argument rests on concrete evidence that current projects already exceed the cap, on the operational readiness of market infrastructure, and on the broader strategic goal of positioning the EU as a leader in digital finance. By potentially raising or eliminating the ceiling, the EU could unlock greater liquidity, foster innovation, and gather critical data to shape a forward‑looking regulatory framework that balances investor protection with the transformative potential of tokenisation.