In recent weeks, a coalition of major financial market participants—including Nasdaq, Germany’s Boerse Stuttgart, and a host of other exchanges and tokenisation platforms—has formally appealed to the European Union to either eliminate the current ceiling on tokenised assets or at least raise it substantially. Their joint statement underscores a growing consensus that the existing limit, which caps the total value of assets that can be issued in a tokenised form under the EU’s pilot framework, is no longer fit for purpose in a rapidly evolving digital‑finance landscape. The coalition’s concerns are rooted in practical experience. Several high‑profile European projects that have already moved forward with tokenisation have found themselves constrained by the cap, which was originally set at a relatively modest €100 million per issuer for the pilot phase.
These projects include a cross‑border securities issuance platform that aims to streamline the trading of corporate bonds, a green‑finance initiative that tokenises renewable‑energy assets, and a real‑estate fund that seeks to fractionalise property ownership for retail investors. In each case, the participants have reported that the ceiling limits their ability to scale, to attract a broader investor base, and to fully demonstrate the efficiency gains that tokenisation promises. Nasdaq, a global market operator with a long history of pioneering new trading technologies, highlighted how the cap hampers its ambition to bring a suite of tokenised securities to European markets.
"Our pilot programmes have shown that tokenisation can dramatically reduce settlement times, cut transaction costs, and increase market transparency," said a Nasdaq spokesperson. "But the current €100 million threshold means that many issuers—especially mid‑size companies that could benefit most from a digitised capital‑raising process—are forced to either stay under the limit or abandon the tokenisation route altogether. This is a missed opportunity for both issuers and investors." Boerse Stuttgart, Europe’s leading exchange for digital assets, echoed these sentiments. The exchange has been at the forefront of integrating blockchain‑based securities into its trading infrastructure.
Its chief operating officer explained that the cap not only restricts the volume of assets that can be tokenised but also creates an uneven playing field. "Large institutional investors are looking for sizeable, liquid tokenised instruments, yet the cap fragments the market into many small, illiquid offerings," she noted. "By raising or removing the cap, the EU would enable the creation of deeper, more liquid markets that can attract the kind of capital needed for large‑scale projects, from infrastructure to sustainable energy." Beyond the immediate commercial implications, the coalition argues that the cap runs counter to the EU’s broader strategic goals. The European Commission has repeatedly emphasised the importance of fostering innovation in fintech, promoting sustainable finance, and positioning Europe as a leader in the digital economy.
Tokenisation, by converting real‑world assets into blockchain‑based tokens, aligns with these objectives by enhancing transparency, improving access to capital, and supporting the development of new financial products such as tokenised bonds, asset‑backed tokens, and digital securities. Critics of the current framework point out that the cap was originally intended as a safeguard—to limit exposure while regulators gathered data on how tokenised assets behave in a regulated market.
However, the coalition contends that the pilot phase has now yielded sufficient evidence to justify a recalibration of the limits. Over the past twelve months, the EU’s supervisory authorities have collected extensive data on transaction volumes, market participants, and compliance outcomes. This data, according to the coalition, demonstrates that tokenised markets can operate safely under appropriate AML/KYC and investor‑protection regimes, without the need for a restrictive financial ceiling. The coalition’s petition also includes concrete proposals for how the EU might adjust the framework.
First, they suggest moving from a fixed monetary cap to a tiered system based on issuer size and risk profile, allowing larger issuers to access higher limits while maintaining safeguards for smaller, less‑experienced participants. Second, they propose introducing a dynamic cap that can be adjusted annually based on market growth metrics, such as total tokenised issuance volume and liquidity measures. Finally, the coalition recommends that the EU provide clear guidance on the regulatory treatment of tokenised assets across different asset classes, thereby reducing legal uncertainty and encouraging cross‑border participation. If the EU were to adopt these recommendations, the potential impact could be significant.
A higher or removed cap would likely spur a wave of new tokenised offerings, ranging from corporate equities and debt instruments to tokenised commodities and real‑estate assets. This, in turn, could attract a broader spectrum of investors, including retail participants who are increasingly comfortable with digital assets, as well as institutional funds seeking diversified exposure to tokenised markets.
Moreover, raising the cap could accelerate the development of secondary markets for tokenised securities. With larger issuances, liquidity providers would have more incentive to create market‑making services, price discovery mechanisms, and custodial solutions tailored to tokenised assets.
This would address one of the key criticisms of early tokenisation pilots—the lack of robust secondary market infrastructure. In summary, Nasdaq, Boerse Stuttgart, and their allied partners are making a compelling case that the EU’s tokenisation cap, while well‑intentioned at the outset, now stands in the way of the continent’s ambition to lead in digital finance.
By lifting or substantially increasing the limit, the EU would not only unlock the full potential of tokenisation for issuers and investors but also reinforce its commitment to innovation, sustainability, and market competitiveness. The coalition’s request is a clear signal that the industry is ready to move beyond the pilot phase and into a mature, scalable ecosystem where tokenised assets can play a central role in Europe’s financial future.