Twenty-seven signatories ask Brussels to take the cap off tokenized markets

What happened

Twenty-seven firms and trade associations wrote to the Council of the European Union and to the European Parliament's Committee on Economic and Monetary Affairs on 7 September 2026, asking the co-legislators to remove or greatly raise the ceiling on the value of financial instruments that may be admitted to trading on distributed ledger market infrastructure. The document is three pages, is headed 'Industry recommendation on larger scale volumes within the DLTPR under the MISP', and is published by the European Digital Finance Association, one of the signatories, on its own site. Its subject is the revision of the DLT Pilot Regime inside the European Commission's Market Integration and Supervision Package. The letter welcomes the package, calls the revision 'a unique opportunity to establish the European Union as the leading jurisdiction for regulated tokenised financial markets', and says the Commission's proposal to raise the cap 'from EUR 6 billion to up to EUR 100 billion represents an important step forward'. It then says the figure is too small: 'given rapid market developments, especially in the US, it proves insufficient, considering current capital market volumes (some existing European projects already hold a volume reaching EUR350 billion and plan for further growth)'. It makes the point that the measure is the wrong one: 'It is important to note that the thresholds are based on market capitalization, not trading volume. While EUR100 billion may seem a substantial figure, it is relatively modest in the context of global equity markets.' The recommendation comes in two options. The first, which the letter labels 'The bold move Europe deserves', is to 'remove the cap on the total value of financial instruments admitted to trading on DLT infrastructure for the regular regime'. The second, 'The move Europe requires to not fall behind', is that if thresholds 'remain politically necessary, they must be set at a level that gives operators and investors confidence for significant scaling up', and states the number: 'We believe a threshold of EUR 1,500 billion as some policymakers are currently suggesting would be an appropriate baseline.' The comparison offered is to the United States: 'currently in the US a dominant settlement platform is enabled to tokenise US equities and other assets without volume caps which could amount to 150 trillion or 100 times the threshold we suggest'. The letter does not name the platform. It asks that any power given to the Commission to raise thresholds not be 'subject to predetermined maximum caps', on the reasoning that 'fixed ceilings would reduce regulatory certainty for market participants making long-term investment decisions'. Its second recommendation is about equal treatment, and it is the sharpest passage in the document: the signatories 'strongly oppose the introduction of differentiated threshold mechanisms, such as EUR 100 billion threshold (with a possible increase up to EUR 250 billion) for DLT market infrastructures while a more generous threshold of EUR 500 billion (with a possible increase up to EUR 1 trillion) would apply for CSDs designated under the SFD', because it 'would create unlevel business and investment opportunities and hinder the scaling of new providers of market infrastructures'. The principle it invokes is 'Same business, same risks, sames rules'. The signature block is two pages of marks rather than a typed list, and this desk extracted and read each of the twenty-seven. They are: 21X, Axiology, Boerse Stuttgart Group, Nasdaq, Securitize, STX by Bit2Me, dowgo, Lise, Cashlink, ClearDil, NYALA, ADAN, the European Digital Finance Association, the European Ethereum Institute, the Coalition for Tokenized Markets, the Crypto Council for Innovation, the Bundesverband fuer elektronische Wertpapiere, France FinTech, Digital Invest Germany, the Czech Fintech Association, ItaliaFintech, rofintech, the Asociacion Espanola de Fintech e Insurtech, the Swedish FinTech Association, the Holland FinTech Association, Nederland Crowdfunding and Alastria. Only the Spanish association appears in the document's text layer as well as in the images. The reports and the letter do not agree. Cointelegraph, which published on 10 September, reports that the coalition asked lawmakers to remove the cap 'or raise it to at least 500 billion euro' and that 'the 500 billion euro threshold should serve as a baseline if lawmakers decide to retain a cap'; the letter names EUR 1,500 billion as the baseline, and the EUR 500 billion figure in the document is the threshold the signatories say should not be reserved for designated central securities depositories. That outlet's own url for the piece says 15t. Crypto Briefing reports that the industry wants 'between EUR 150 billion and EUR 1.5 trillion, or no caps at all'. Ledger Insights, whose account is behind a subscription beyond its opening, describes the letter as backed by ten securities firms and sixteen fintech associations, which is twenty-six.

Why it matters

The number to watch in this document is not the cap, it is the second recommendation. A single ceiling that applies to everyone is a policy choice about how fast Europe wants tokenized issuance to grow, and reasonable people can argue about where it sits. Two ceilings, one of EUR 100bn for DLT market infrastructures and one of EUR 500bn for designated central securities depositories, is something else: it is an industrial policy that says the incumbent settlement layer may tokenize five times as much as a new venue may, and it does so at exactly the moment when the incumbents have started tokenizing. The signatories are an unusual coalition for that reason. Nasdaq and Boerse Stuttgart are not startups complaining about a regime designed for startups; they are exchange groups that would be operating DLT infrastructure under the pilot regime rather than as designated depositories, which puts them on the same side of the line as the tokenization platforms. The second thing worth saying is that the letter is right about the measure, and it is a point that generalises beyond Europe. A cap on the market capitalisation of instruments admitted to a DLT venue is a cap on what may exist there, not on what may trade there, and it binds hardest on exactly the asset the pilot regime was meant to test: a large, liquid, ordinary security. EUR 100bn will accommodate a great many bond issues and no meaningful fraction of a European equity market, so the regime can be used to prove that tokenized settlement works on instruments nobody was worried about and cannot be used to prove it on the ones that matter. That is a design that guarantees an inconclusive pilot. Third, the US comparison is doing real work even though the letter leaves the platform unnamed. The obvious referent is the American depository, which this corpus has covered as it has moved into tokenized collateral, and the asymmetry the letter describes is real in kind if not in the precise figure: the American arrangement proceeds by an existing infrastructure extending its own service under its existing permissions, while the European one proceeds by a time-limited exemption with a quantitative ceiling. Those are different regulatory philosophies and they produce different scales, and a signatory list containing both an American exchange group and a Spanish fintech association is evidence that the difference is now legible to people on both sides of it. What the letter does not do is give any of its own numbers a source. The EUR 350bn of existing European projects is asserted and unattributed, and it is the single figure on which the claim that EUR 100bn is insufficient rests.

What is not settled

Which European projects already hold EUR 350bn is not stated, and no signatory is identified with the figure, so the letter's central empirical claim cannot be checked from the document. The desk did not open the Commission's Market Integration and Supervision Package proposal itself, so the differentiated thresholds the second recommendation opposes, EUR 100bn rising to EUR 250bn for DLT market infrastructures against EUR 500bn rising to EUR 1 trillion for designated depositories, are described here as the signatories describe them rather than as the proposal states them. The 150 trillion figure attributed to the American settlement platform is given without a unit basis or a source and the platform is not named. Whether the recommendation has been formally transmitted, and to whom, is not clear: the publishing association describes itself as having signed it, while one report calls it a draft letter. The signature block is images rather than text and was read as images, so the count of twenty-seven is this desk's own reading of the marks on the page rather than a published total, and the two reports that give a count disagree with it and with each other. Nothing in the document says what the Council's or the Parliament's position is, and neither institution has published one that this desk found. And the letter says nothing about the exit threshold under the current regime, about how a venue approaching a cap would be required to behave, or about what happens to instruments already admitted if a ceiling is reached, which are the operational questions a ceiling of any size raises.