EU Finance Ministers Push DLT Pilot Cap to €300bn as ECB Pushes Back

The Council of the European Union agreed on 10 October 2025 its negotiating position on the Market Integration and Supervision Package (MISP), choosing to raise the per-infrastructure cap on the DLT (Distributed Ledger Technology) Pilot Regime dramatically beyond what the European Commission had proposed. Where the Commission suggested lifting the current €6 billion limit to €100 billion, EU finance ministers have landed on €300 billion, with a further escalation to €500 billion possible through a Commission delegated act.

European Central Bank President Christine Lagarde has objected to the €300 billion figure, warning the European Parliament to revisit it on the grounds that DLT structures risk fragmenting markets rather than integrating them, and may not prove interoperable with existing infrastructure. That concern appears to reference the access and linkage obligations embedded in the Central Securities Depositories Regulation (CSDR), from which DLT Pilot Regime operators currently benefit from selective exemptions. Exchanges including Nasdaq and Boerse Stuttgart had lobbied for the caps to be removed entirely, so the Council’s position lands between industry ambition and Commission caution, while drawing ECB resistance from above.

On a parallel track, the Council also revised the Commission’s proposed €10 billion cap for DLT-based settlement schemes run by consortia of banks, which would function as a decentralised central securities depository (CSD). Ministers raised that figure to €50 billion, matching the floor suggested by the Association for Financial Markets in Europe (AFME). For crypto, the Council’s position reserves EU-level ESMA supervision only for significant crypto asset service providers (CASPs), leaving smaller CASPs under national oversight, though the criteria defining significance have not yet been made public.