Nasdaq, Boerse Stuttgart urge EU to adjust tokenization trial caps

Two of the world’s most prominent exchange operators are telling Brussels the same thing: your tokenization sandbox is too small, and the grown-ups are leaving the playground.

Nasdaq and the Boerse Stuttgart Group, along with other financial market stakeholders, have formally asked EU lawmakers to either scrap or dramatically increase the caps on tokenized securities imposed by the bloc’s DLT Pilot Regime. Their argument is blunt: at current limits, Europe cannot compete with the United States for institutional-scale digital asset issuance.

The cap problem, explained

The DLT Pilot Regime launched in 2023 as a regulatory sandbox where exchanges and settlement systems could experiment with distributed ledger technology for trading traditional securities in tokenized form. The regime currently caps the aggregate market value of all tokenized securities at €6 billion, with an exit threshold of €9 billion. It also restricts participation to smaller securities and bonds under MiFID II rules.

The European Commission recognized the constraint and proposed raising the ceiling to €100 billion as part of a December 2025 revision, along with expanding the list of eligible assets under MiFID II rules.

In a letter sent in September 2026, the coalition of exchanges and market participants asked for something considerably more ambitious: raise the caps to between €150 billion and €1.5 trillion, or eliminate them entirely. The gap between the Commission’s proposed €100 billion and the industry’s ask of up to €1.5 trillion tells you how far apart the two sides are on what “institutional scale” actually means.

The US threat looming over Brussels

The letter’s most pointed argument centers on transatlantic competition. The US market already allows tokenization at scales roughly 100 times larger than what Europe’s current framework permits, according to the stakeholders. The DTCC, America’s central clearing and settlement backbone, has taken a notably more expansive approach to tokenized settlements, enabled by regulatory no-action letters that give firms breathing room to innovate without constant enforcement risk.

Nasdaq and Boerse Stuttgart aren’t just writing letters

The two exchange operators are backing their lobbying with operational commitments. In March 2026, Nasdaq formed a partnership with Boerse Stuttgart’s Seturion platform, a move designed to broaden the range of tokenized products available to European investors and create more flexible settlement pathways.

Seturion, Boerse Stuttgart’s dedicated digital securities infrastructure, gives Nasdaq a foothold in the European DLT market without building from scratch. For Boerse Stuttgart, the tie-up brings Nasdaq’s global distribution network and technology stack to a platform that’s been purpose-built for tokenized instruments under EU regulation.

If the EU chooses to maintain the current trajectory, with the Commission’s €100 billion proposal as the ceiling, the gap with US capabilities will narrow only slightly. Institutional participants have made clear they view that number as inadequate for serious capital markets activity.

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