Forty Firms Including Nasdaq and Börse Stuttgart Demand EU Scrap or Radically Raise €100bn DLT Cap
Forty Firms Including Nasdaq and Börse Stuttgart Demand EU Scrap or Radically Raise €100bn DLT Cap #
A coalition of around 40 financial and technology firms, including Nasdaq, Börse Stuttgart Group, Danske Bank, LBBW and Union Investment, has written to members of the European Parliament and Council urging a fundamental rethink of the proposed volume ceiling in the EU’s revised Distributed Ledger Technology (DLT) Pilot Regime.
The joint letter, sent on 21 April, argues that the European Commission’s plan to raise the cap on tokenised securities from its current €6 billion per platform to €100 billion falls well short of what is needed to enable large-scale adoption of blockchain-based market infrastructure. The signatories’ preferred outcome is to remove any overall cap entirely under the regular regime. If EU lawmakers insist on retaining a threshold, the group says €1.5 trillion should be the baseline, accompanied by a mechanism that would allow the Commission to increase it dynamically as markets mature.
The letter also warns against applying lower thresholds to DLT market infrastructure operators than to incumbent central securities depositories, arguing that such an asymmetry would hand a structural competitive advantage to established players.
Axiology CEO Marius Jurgilas said a €100 billion ceiling “may look generous on paper, but for market infrastructure it could quickly become a brake on investment and scale,” adding that the EU now has an opportunity to give regulated DLT markets the headroom to compete globally on equal terms.
Beyond the cap, the coalition is pushing for several other changes: expanding eligibility to cover all MiFID II financial instruments rather than the current narrower list, dropping asset-class-specific sub-limits, and abolishing expiry dates on DLT licences to make the regime permanent rather than a time-limited pilot.
The group is also calling on legislators to decouple the DLT Pilot Regime from the much broader Market Integration and Supervision Package (MISP), an omnibus bundle of around 18 financial laws that the Commission announced in December 2025. Because the DLT updates are embedded in that wider package, industry participants fear they could be delayed or diluted during the complex trilogue process. In February 2026, nine existing DLT Pilot licensees and pending applicants made a similar separation request; the new letter broadens that push to include major traditional finance institutions and numerous fintech trade associations across EU member states.
Signatories warn that legislative delays carry a competitive cost. The US has moved quickly to develop its own framework for tokenised securities, and firms already active in that market face little incentive to engage with an EU pilot that imposes tighter constraints. The UK’s Digital Securities Sandbox has also attracted a string of major institutions, including Euroclear, LSEG and HSBC, that have not yet engaged with the EU regime.
Whether the Commission will agree to decouple the DLT provisions from MISP remains uncertain. EU officials have previously signalled a preference for passing the full package together.
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