In recent weeks, a coalition of major financial market participants—including Nasdaq, Germany’s Boerse Stuttgart, and a host of other exchanges and industry groups—has formally appealed to European Union regulators to either remove the existing ceiling on tokenised assets in the EU’s experimental tokenisation framework or to raise it substantially. Their request stems from growing concerns that the present cap, which limits the total value of assets that can be tokenised under the pilot scheme, is already being outstripped by several high‑profile projects operating within the bloc.
The tokenisation pilot, launched by the European Commission as part of its broader digital finance strategy, was designed to provide a sandbox environment where issuers could test the issuance, trading, and settlement of digital tokens representing real‑world assets such as equities, bonds, real estate, and commodities. The pilot’s original parameters set a maximum aggregate value of €1 billion for all tokenised securities issued under the programme.
While this figure was intended to be a cautious starting point, market participants argue that it now acts as a bottleneck, stifling innovation and preventing the EU from fully capitalising on the efficiencies and liquidity benefits that tokenisation promises. Nasdaq, a global leader in exchange technology and market infrastructure, highlighted that several of its own pilot projects in Europe have already approached, and in some cases exceeded, the €1 billion threshold. In a statement, Nasdaq’s European chief said, “Our experience shows that the demand for tokenised securities is far greater than the current limit allows.
By capping the total value, the EU is inadvertently discouraging issuers who could otherwise unlock new sources of capital for businesses across the continent.” Similarly, Boerse Stuttgart, which has been at the forefront of digital asset trading in Germany, underscored that its tokenised bond platform has attracted institutional interest amounting to well over €500 million in just a few months. The exchange’s CEO added, “When you combine the volume we are seeing with the activity on other participating platforms, it becomes clear that the €1 billion cap is no longer fit for purpose. We risk leaving Europe behind as other jurisdictions, such as the United States and Singapore, move swiftly to accommodate larger tokenisation markets.” The coalition’s letter to the European Commission cites concrete examples of projects that have already breached the cap. One such initiative involves a tokenised infrastructure fund that aims to raise €750 million to finance green energy projects across the EU.
Another project, a tokenised real‑estate investment trust (REIT), has secured commitments totalling €400 million for the acquisition of commercial properties in major European cities. Together, these two undertakings alone exceed the current limit, illustrating the practical challenges that market participants face.
Beyond the immediate financial figures, the coalition argues that the cap hampers the broader strategic objectives of the EU’s digital finance agenda. Tokenisation is expected to enhance market transparency, reduce settlement times, lower transaction costs, and broaden access to capital for small and medium‑sized enterprises (SMEs). By restricting the scale at which these benefits can be realised, the EU may miss out on a wave of investment that could drive economic growth, foster innovation, and support the transition to a more sustainable economy. In response, the European Commission’s Directorate‑General for Financial Stability, Financial Services and Capital Markets Union (DG FISMA) has indicated that it is reviewing the feedback from the pilot participants.
A senior official from DG FISMA told industry observers that the Commission is “open to adjusting the parameters of the pilot, including the aggregate cap, if evidence shows that the current limit is constraining market development and does not align with the overarching goals of the Digital Finance Package.” The coalition’s appeal also touches on regulatory certainty. Market participants contend that a clear, predictable framework—whether it involves raising the cap or removing it altogether—will encourage more issuers to experiment with tokenised securities, thereby generating valuable data that can inform future legislation. They note that other jurisdictions have already taken steps to provide such certainty. For instance, the United Kingdom’s Financial Conduct Authority (FCA) has introduced a flexible tokenisation sandbox with no explicit aggregate cap, while the Monetary Authority of Singapore (MAS) has adopted a risk‑based approach that allows larger volumes of tokenised assets to be tested.
If the EU decides to maintain the current ceiling, the coalition warns that it could see a migration of tokenisation activity to these more permissive environments, potentially resulting in a loss of competitive advantage for European financial markets. Conversely, raising or eliminating the cap would signal a strong commitment to fostering digital innovation and could attract a wave of new issuers, investors, and technology providers to the region.
In conclusion, the request from Nasdaq, Boerse Stuttgart, and their allied partners reflects a growing consensus that the tokenisation pilot’s original design needs to evolve in step with market realities. By reconsidering the €1 billion limit—whether by raising it to a level that accommodates existing demand or by removing it entirely—the European Union has the opportunity to cement its position as a leader in the emerging digital asset economy, unlock new sources of capital for businesses, and deliver on the promise of a more efficient, inclusive, and sustainable financial system.