In a coordinated move that underscores the growing momentum behind digital asset innovation in Europe, a coalition of leading market participants—including Nasdaq, the Stuttgart Stock Exchange (Boerse Stuttgart), and several other prominent exchanges and fintech firms—has formally requested that the European Union revisit the limits set for its ongoing tokenisation trial. The coalition argues that the current cap, which restricts the value of tokenised assets to a relatively modest threshold, is hindering the development of promising projects that are already operating at scales well beyond the permitted maximum.
The request arrives at a pivotal moment for the EU’s broader regulatory framework for crypto‑assets, most notably the Markets in Crypto‑Assets Regulation (MiCA), which seeks to provide a harmonised set of rules for digital assets across member states. Under the pilot scheme launched last year, participants were allowed to issue tokenised securities and other financial instruments, but only up to a ceiling of €100,000 per token.
While the intention behind the ceiling was to mitigate risk while the regulatory environment was still being fine‑tuned, market actors now contend that the limit is overly conservative for a market that is rapidly maturing. "We recognise the EU’s commitment to fostering innovation while protecting investors," said a spokesperson for Nasdaq. "However, the €100,000 cap is no longer proportionate to the scale of projects that are emerging across the continent.
Many of these initiatives involve tokenised real‑estate portfolios, infrastructure financing, and even fractional ownership of high‑value assets such as art and patents. These projects routinely exceed the current limit, and the cap is effectively stifling their ability to raise capital and demonstrate the full potential of tokenisation." Similarly, Boerse Stuttgart highlighted concrete examples where the cap has forced issuers to either split offerings into multiple smaller tokens—complicating the investor experience—or abandon tokenisation altogether in favour of traditional financing routes. "The administrative overhead and investor confusion caused by fragmenting a single asset into dozens of sub‑tokens outweigh any perceived safety benefit of the cap," the exchange noted in its joint statement.
The coalition’s letter to the European Commission outlines three primary arguments for raising or removing the cap: 1. **Market Realities:** Several pilot participants have already issued tokenised securities whose underlying value far exceeds €100,000. For instance, a German renewable‑energy project tokenised a share of a wind‑farm valued at €5 million, but was forced to cap each token at €100,000, resulting in a fragmented ownership structure that deterred institutional investors.
2. **Investor Demand:** Surveys conducted among qualified investors indicate a strong appetite for larger‑ticket tokenised assets, particularly from asset managers seeking efficient, blockchain‑based ways to diversify portfolios. 3.
**Regulatory Alignment:** Other jurisdictions, such as the United Kingdom and Singapore, have adopted more flexible thresholds, allowing tokenised assets to reach millions of euros without additional licensing burdens. Aligning the EU’s cap with these international standards would help maintain competitiveness. In response, EU officials have acknowledged the concerns but caution that any adjustment must be balanced against the overarching goal of consumer protection. A senior representative from the European Commission’s Directorate‑General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) remarked, "We are closely monitoring the pilot’s outcomes and the feedback from market participants.
While the cap was introduced as a precautionary measure, we are open to calibrating it based on empirical evidence and risk assessments." The debate also touches on broader themes within the EU’s digital finance agenda. Tokenisation—transforming physical or traditional financial assets into digital tokens on a blockchain—promises increased liquidity, fractional ownership, and streamlined settlement processes. Proponents argue that a higher cap would unlock these benefits for larger, traditionally illiquid assets such as commercial real estate, infrastructure projects, and even small‑ and medium‑sized enterprise equity. Critics, however, warn that lifting the cap without accompanying safeguards could expose retail investors to heightened volatility and fraud risk.
To address this, the coalition has suggested a tiered approach: maintaining the current cap for retail‑focused offerings while allowing higher thresholds for qualified or institutional investors under stricter disclosure requirements. The request also aligns with ongoing discussions about the future of MiCA. As the regulation moves towards final implementation, policymakers are expected to fine‑tune provisions related to token‑service providers, stablecoins, and the classification of asset‑referenced tokens.
Adjusting the pilot’s cap could serve as a practical test case for how the EU might handle larger‑scale tokenised securities once MiCA is fully in force. Stakeholders outside the immediate coalition have weighed in as well. Several European venture capital firms have expressed that a higher cap would make tokenised fundraising more attractive, potentially funneling capital into innovative sectors such as green technology and digital health. Meanwhile, consumer‑rights groups remain vigilant, emphasizing the need for clear risk warnings and robust investor education.
In summary, the coalition’s appeal to the EU reflects a maturing ecosystem that is beginning to outgrow the precautionary parameters set at the pilot’s inception. By urging a reassessment of the €100,000 ceiling, Nasdaq, Boerse Stuttgart, and their partners are not only seeking to remove a practical obstacle but also to signal that the European market is ready for a more expansive, yet responsibly regulated, tokenisation landscape. The outcome of this dialogue will likely influence the trajectory of digital asset adoption across the continent, shaping how future financial instruments are created, traded, and overseen within the EU’s regulatory framework.