In recent weeks, a coalition of prominent financial market participants—including Nasdaq, the Stuttgart Stock Exchange (Börse Stuttgart), and a number of other leading exchanges and technology firms—has formally appealed to the European Union to either remove the existing ceiling on tokenisation projects or to raise it substantially. This request comes as part of the broader EU‑wide tokenisation trial, a sandbox‑style initiative designed to test the regulatory framework for digital assets, security tokens, and other forms of blockchain‑based securities.
The coalition argues that the current cap, which limits the total value of tokenised assets that can be issued under the pilot, is too restrictive and hampers the ability of innovators to demonstrate the full potential of tokenisation in real‑world market conditions. The tokenisation trial was launched by the European Commission and the European Securities and Markets Authority (ESMA) as a way to explore how distributed ledger technology (DLT) can be integrated into existing financial market infrastructures.
The pilot allows eligible participants to issue tokenised securities, such as equity, debt, or fund shares, on a blockchain platform while operating under a temporary, proportionate regulatory regime. The intention is to gather data on market efficiency, investor protection, and systemic risk, ultimately informing future legislation that could make tokenised assets a mainstream component of European capital markets. However, the coalition’s joint statement highlights a key limitation: the trial imposes a hard cap on the aggregate value of tokenised assets that can be issued.
According to the signatories, this ceiling is set at a level that is already being exceeded by several ongoing projects across the continent. For instance, a number of large‑scale tokenisation initiatives in Germany, France, and the Nordics have already reached or surpassed the limit, forcing participants to either halt further issuance or seek exemptions that add administrative complexity. "The current cap does not reflect the market appetite for tokenised securities nor the scale at which these projects can operate safely," the statement reads. "By constraining the total issuance value, the pilot risks delivering an incomplete picture of the technology’s benefits, such as increased liquidity, fractional ownership, and reduced settlement times.
We therefore request that the EU either remove the cap entirely or raise it to a level that accommodates the genuine size of the projects already underway." Nasdaq, a global leader in exchange services and market technology, has been particularly vocal about the need for a more flexible framework. In its view, the ability to issue larger volumes of tokenised securities is essential for testing the scalability of settlement systems, assessing the robustness of custody solutions, and evaluating cross‑border interoperability. Similarly, Börse Stuttgart, which has been pioneering tokenised bond offerings and digital asset trading in Germany, stresses that a higher limit would enable the exchange to showcase how tokenisation can complement traditional market structures and attract a broader investor base.
Beyond the immediate practical concerns, the coalition argues that the cap undermines the strategic objectives of the EU’s digital finance agenda. The European Commission has repeatedly emphasized the importance of fostering innovation in financial services, positioning Europe as a leader in the development of sustainable, inclusive, and technology‑driven markets. By imposing an artificial ceiling, the pilot could inadvertently signal a lack of confidence in the technology, discouraging investment and slowing down the adoption curve. The request also touches on the competitive dynamics between Europe and other major financial hubs such as the United States and Singapore, where regulatory sandboxes for tokenised assets have been more permissive.
In those jurisdictions, projects have been able to issue tokenised securities worth billions of euros, generating valuable data on market impact and investor behavior. European participants fear that a restrictive cap could push innovators to seek more favourable environments abroad, resulting in a loss of talent, capital, and technological expertise for the EU. In response to the coalition’s appeal, EU officials have indicated that they will review the pilot’s parameters as part of the ongoing evaluation process.
A spokesperson for the European Commission noted that the regulator is aware of the concerns raised and that any adjustments would be made in line with the overarching goal of ensuring market integrity while fostering innovation. The regulator also emphasized that the cap was originally intended as a precautionary measure to monitor systemic risk during the early stages of the experiment. Nevertheless, the coalition remains firm in its position, urging a swift amendment to the cap so that the trial can continue to generate meaningful insights. They propose a tiered approach, where the limit could be increased incrementally based on predefined milestones, such as the successful completion of settlement tests, the implementation of robust anti‑money‑laundering controls, and the demonstration of effective investor protection mechanisms.
If the EU decides to raise or remove the cap, the potential benefits are significant. A higher issuance ceiling would allow participants to test larger, more complex tokenisation structures, including multi‑asset baskets, hybrid securities, and cross‑border offerings. It would also enable a broader range of issuers—such as mid‑size corporations, infrastructure projects, and even public sector entities—to experiment with tokenised financing, thereby expanding the data set available to regulators. Moreover, a more permissive environment could accelerate the development of ancillary services, such as token custody, decentralized finance (DeFi) integration, and real‑time compliance monitoring.
These services are essential for creating a full ecosystem that supports tokenised assets throughout their lifecycle, from issuance to secondary market trading and eventual redemption. In summary, the coalition of Nasdaq, Börse Stuttgart, and other market participants is urging the European Union to reconsider the restrictive issuance cap imposed on the tokenisation trial.
Their argument rests on the premise that the current limit is already being outstripped by active projects, that it hampers the ability to gather comprehensive data, and that it could place Europe at a competitive disadvantage globally. By either removing the cap or raising it to a more realistic level, the EU would not only facilitate a more thorough assessment of tokenisation’s benefits but also reinforce its commitment to leading the world in innovative, digital financial markets.