Marina Lyubimova
Nasdaq and 27 other companies and industry groups have urged the EU Council to reconsider the limit, arguing that it could restrict the market before institutional tokenization reaches scale.
The difference between the current rules and the industry proposal is significant:
- Current EU cap: €6 billion
- Proposed EU cap: €100 billion
- Industry alternative: up to €1.5 trillion
The EU proposal would increase the existing ceiling by more than 16×. However, the €1.5 trillion alternative backed by industry participants would be 15× higher than the proposed €100 billion cap and 250× the current limit.
The group’s preferred option is to remove the aggregate cap entirely. The €1.5 trillion figure is proposed as an alternative if regulators decide that a ceiling must remain.
The concern is scale. Once large bond issues, equities, funds and other securities move onto DLT infrastructure, a €100 billion ceiling could limit how much business regulated platforms can process.
The dispute now centers on whether Europe’s DLT framework should remain a controlled pilot or expand into infrastructure capable of supporting trillion-euro capital markets. For Nasdaq and its allies, €100 billion is not enough.
Marina Lyubimova
