Nasdaq-led coalition urges EU to scrap €100B DLT Pilot cap or lift it to €500B
A Sept. 7 draft letter to the EU Council and Parliament ECON argues the ceiling would block scaling and tilt liquidity toward US venues.
A coalition of market-structure and tokenization groups is pressing EU lawmakers to remove a proposed €100 billion ceiling on tokenized instruments admitted to DLT infrastructure, or raise it sharply if a cap remains. The Sept. 7 draft letter frames the limit as a near-term capacity constraint that could push issuance and liquidity toward US rails.
The latest push to rewrite the European Union’s Distributed Ledger Technology (DLT) Pilot Regime is coming from a coalition that includes Nasdaq, Boerse Stuttgart Group, Securitize, the European Ethereum Institute and Axiology, which in a draft letter dated Sept. 7 urged lawmakers to delete a proposed €100 billion cap on tokenized financial instruments admitted to DLT infrastructure.
The letter was addressed to members of the EU Council and the European Parliament’s Economic and Monetary Affairs Committee (ECON). If lawmakers insist on keeping a ceiling, the coalition asked that it be lifted to at least €500 billion, describing that level as a baseline rather than an aspirational target.
That posture is a step beyond the industry’s earlier “raise the limit” lobbying. The European Commission has already proposed expanding the regime’s current €6 billion limit to as much as €100 billion as part of its Market Integration and Supervision Package, but the coalition’s new ask is effectively that €100 billion is still too small to be a workable scaling threshold.
Why the Cap Design Matters: ‘Admitted Market Value’ vs Trading Volume
The mechanical detail doing most of the work is how the threshold is measured. The coalition argued the DLT Pilot Regime limits apply to the market value of financial instruments admitted to DLT infrastructure, not to trading volume, which makes the ceiling a hard capacity constraint even if secondary-market turnover on the venue is modest.
In practice, a market-value-based cap can force platforms and issuers into rationing decisions. A venue can hit the ceiling simply by admitting large, high-market-cap instruments, even if those instruments trade lightly on the DLT venue, and that can turn the cap into a gating factor for listings and issuance rather than a risk-control tied to activity.
The coalition also claimed the proposed €100 billion ceiling is already below the scale of some existing European projects, saying certain initiatives “already reach 350 billion euro in scale” and plan further growth. The projects were not identified in the provided text, but the point is straightforward: if the ceiling is below what the market is already building toward, the cap stops being a sandbox parameter and starts functioning like a structural limit.
There is also a sizing mismatch worth keeping in view for traders watching tokenized securities supply. Onchain real-world assets remain small in aggregate by crypto standards: distributed RWA totals about $39.15 billion excluding stablecoins, with US Treasury debt the largest category at roughly $15.8 billion, according to RWA.xyz. The coalition’s argument is that the DLT Pilot Regime is meant to cover tokenized financial instruments like stocks and bonds, where admitted market value can scale far faster than today’s RWA totals.
US Comparison and the Liquidity-Migration Argument as Brussels Rewrites the Regime
The coalition’s competitiveness framing leans heavily on a US comparison, writing that “a dominant settlement platform is enabled to tokenise US equities and other assets without volume caps,” and arguing that setup could cover as much as €150 trillion in assets. The letter does not name the platform in the provided text, leaving a key reference point unresolved even as it anchors the migration risk.
The timing matters because the DLT Pilot Regime, in force since 2023, is explicitly a test environment that grants exemptions from certain EU financial rules so firms can trial blockchain-based trading and settlement for instruments such as stocks and bonds. Brussels is now revisiting the regime through the European Commission’s Market Integration and Supervision Package, including the proposal to raise the overall limit from €6 billion up to €100 billion.
Industry pressure has been building through 2026. In April, a group of 39 financial firms and industry groups, including Nasdaq and Boerse Stuttgart, urged EU policymakers to fast-track changes and raise the overall limit to between €100 billion and €150 billion, while also seeking broader asset eligibility and removal of time limits on licenses. In February, tokenization and market infrastructure firms including Securitize, 21X and Boerse Stuttgart warned that existing asset limits, volume caps and time-limited licenses were preventing regulated onchain markets from scaling in Europe, and that liquidity could migrate to US markets without faster changes.
The next signals are procedural and political rather than technical. Traders should watch whether the EU Council and the European Parliament’s ECON committee indicate support for removing the cap entirely versus adopting a higher ceiling, and whether the Commission’s package ultimately preserves the “market value admitted” mechanic or shifts to a different measurement.
Another open thread is the coalition’s own fallback number. The body text of the draft letter describes a €500 billion baseline if a cap remains, but the public framing around the letter includes a reference to a “€1.5 trillion” baseline that is not supported elsewhere in the provided excerpt. Clarification from signatories or lawmakers on what number is actually being proposed would reduce the risk of markets trading the wrong headline.
My Take: This Is a Market-Structure Fight Over Where Tokenized Securities Scale First
The filing is being read as a simple “raise the cap” request, but the procedural detail points to something sharper: the coalition is explicitly asking to delete the cap, and only treating €500 billion as a fallback. That escalation matters because it implies the Commission’s €6 billion to €100 billion proposal is being treated as a political compromise, not a scaling threshold the market thinks it can live with.
The threshold that matters is whether lawmakers keep the cap tied to admitted market value, because that design turns the limit into a capacity constraint that shapes where issuers list and where liquidity forms. If the revisions land on a higher ceiling or remove the cap entirely while keeping licensing workable, tokenized securities in Europe stop being a pilot-sized experiment and start looking like a venue-selection problem for real issuance.
