Nasdaq and Boerse Stuttgart lead push to scrap EU tokenisation caps

A coalition of ten securities firms and sixteen fintech associations, including Nasdaq and Boerse Stuttgart, has written to the European Parliament and Council demanding the removal of value caps on tokenised securities traded through the European Union’s distributed ledger technology (DLT) Pilot Regime. The letter represents the most coordinated lobbying effort yet from participants inside the regime, most of whom have found the existing limits incompatible with institutional-scale activity.

The current rules cap the aggregate value of securities listed on a DLT venue at €6 billion, a threshold large incumbents deemed too restrictive when the regime was established, leading them to sit out entirely. The European Commission’s Market Integration and Supervision Package (MISP), launched in December 2025, proposed raising that ceiling to €100 billion and broadening the eligible asset classes beyond stocks, bonds, and funds. The coalition’s letter treats even that revised figure as insufficient, calling instead for the caps to be eliminated altogether. If caps must remain, the signatories request a fallback threshold of €1.5 trillion and ask that the Commission be granted authority to adjust limits without predetermined maximums.

The letter also highlights the competitive gap with the United States, referencing without naming it a no-action letter from the DTCC (Depository Trust and Clearing Corporation) that would permit tokenisation of securities relating to entities worth one hundred times the proposed €100 billion ceiling. A further demand cuts at market structure: any caps that survive the legislative process should apply equally to new DLT venues and to incumbent central securities depositories, preventing asymmetric constraints that favour established players.

The practical stakes are structural. If the MISP proposals pass without the cap being lifted substantially, institutional participants considering a move to DLT rails face a hard ceiling that limits the size of programmes they can run inside the EU. The coalition’s reference to the DTCC baseline appears designed to frame the Commission’s €100 billion proposal as conservative rather than ambitious, and to push policymakers toward a regime closer to regulatory parity with the US.