A coalition of market operators, including Nasdaq (NASDAQ: NDAQ) and Börse Stuttgart Group, has urged European Union lawmakers to revisit and strengthen proposed updates to the bloc’s distributed ledger technology framework. The group argues that current and planned restrictions, particularly an aggregate activity limit of €100 billion, remain too tight to support competitive tokenized markets.
The appeal comes as the European Commission’s Market Integration and Supervision Package seeks to overhaul the DLT Pilot Regime introduced in 2023.
That original sandbox limited eligible instruments to smaller shares, bonds and certain funds, imposed an overall cap of €6 billion (rising to a €9 billion trigger for an exit plan), and set six-year license terms.
The Commission’s December 2025 proposals would expand eligible assets to all MiFID II financial instruments, scrap product-specific size limits and lift the overall cap to €100 billion while making the regime permanent.
Industry participants say even those changes fall short of what is needed to match developments elsewhere.
In a joint letter coordinated with the French digital-asset association Adan and signed by 39 organizations, the firms asked officials to detach the DLT amendments from the wider legislative package and treat them as a standalone “quick fix.”
They contend that bundling the changes with politically complex market-integration measures could delay implementation until 2030 or later. In that interval, they warn, activity and liquidity could shift to jurisdictions moving faster on tokenization.
The signatories specifically requested that the aggregate cap be raised further, to at least €150 billion—roughly one percent of the European equity market—so platforms can handle institutional-scale volumes rather than remain confined to experimental sizes.
They also called for the complete removal of remaining asset-class restrictions and the six-year license sunset so operators can plan long-term infrastructure investments.
These adjustments, they stressed, would not weaken investor-protection rules already applied under MiFID II.
The timing reflects accelerating competition.
US venues such as Nasdaq and the New York Stock Exchange have outlined plans for around-the-clock trading of tokenized securities, while the Depository Trust & Clearing Corporation received regulatory clearance to pursue large-scale tokenized settlement.
European operators fear that without comparable scale, issuers and investors will simply list and settle elsewhere.
Börse Stuttgart’s Seturion platform, which Nasdaq’s European venues plan to connect for tokenized structured products, is among the infrastructures already operating under the existing pilot and would benefit from higher limits.
Supporters of a higher cap argue that tokenization can reduce settlement risk, cut costs and support 24/7 markets only if platforms can attract meaningful liquidity.
Critics of further relaxation counter that larger thresholds could introduce new operational and systemic risks before supervisors have sufficient experience.
The Commission has so far presented the €100 billion figure as a balanced increase that still contains overall exposure.
The letter emphasizes that Europe once led in providing regulatory clarity for digital assets but now risks repeating past patterns of fragmented capital markets. By acting quickly on a limited set of technical changes, the coalition says, policymakers can keep tokenized activity inside the euro area rather than watching it migrate.