Karsten Wenzlaff, Advisor
August 26th, 2025
Karsten Wenzlaff is a Crowdfunding and Fintech Expert from Germany. He is Secretary-General of Digit[...]
Brussels Faces Pressure to Fix Europe’s DLT Pilot
Apr 21, 2026 | NCFA Insight | Capital Markets And Funding
EDFA Tells Brussels What Tokenized Securities Need To Scale
On December 4, 2025, the European Commission published its market infrastructure reform package, including proposed changes to the DLT Pilot Regime. On March 19, 2026, the European Digital Finance Association (EDFA) sent a formal letter to the European Commission about the DLT Pilot Regime and MiCAR. It is addressed to Commissioner Maria Luís Albuquerque and DG FISMA Director-General John Berrigan.
EDFA writes on behalf of its members and the undersigned companies. The core point is that the pilot works for testing, but it does not work for scale. Firms are already trying to build tokenized issuance, trading, registry, custody, and settlement in Europe. The problem is that the current DLT Pilot rules keep those activities small, separate, and hard to repeat.
What EDFA Is Asking For
- Broader scope. The letter backs earlier application of changes that would extend the DLT Pilot to more, or all, financial instruments and remove product-specific thresholds. It also supports replacing the current instrument-by-instrument limits with a single overall threshold. The reason is practical. Firms will not invest for the long term if issuance caps stay low and the usable asset set stays narrow.
See: The SEC’s New Crypto Playbook Faces Its First Test
- Interoperability standards. The letter calls for mandatory interoperability between DLT infrastructures and regulated markets and central securities depositories, and asks the Commission to task ESMA with developing technical standards for cross-border connectivity. Without that, tokenized venues remain isolated pools. Liquidity fragments. Secondary trading stays thin.
- The Commission to fix the registry and notary gap. The EDFA letter explains that the EU framework opens these roles beyond traditional central securities depositories, but still leaves out firms already operating under national DLT registrar regimes. EDFA points to Germany’s eWpG (electronic securities act, June 2021) system and similar setups in Luxembourg and Italy. It wants those firms to be recognized at the EU level, allowing them to keep operating under their current approvals, and assessed fairly against EU standards. They allso says the rules should match what these firms actually do, instead of forcing them to meet the full requirements designed for large central depositories.
- Legal clarity on settlement. The letter asks for explicit recognition of tokenized commercial bank money and MiCA-regulated e-money tokens as eligible settlement mechanisms inside DLT infrastructures. This is a major point because if settlement assets aren't clearly recognized, companies can issue on-chain but still struggle to build active trading and repeat liquidity.
The Gap Between Pilot And Market
The issue is structural. The DLT Pilot allows firms to test tokenized issuance, trading, and settlement in controlled conditions. But it doesn't allow those activities to operate at scale. Issuance happens, but it stays small. Trading exists, but liquidity doesn't build. Infrastructure is in place, but it doesn't connect cleanly to the rest of the market. Until those limits are addressed, tokenized securities remain confined to pilot activity instead of forming a market where deals can regularly happen at meaningful scale.
If Brussels makes these changes, firms can issue larger deals and do it more than once. Tokenized platforms can connect to exchanges, custodians, and settlement systems instead of running separately. Companies already licensed at the national level can keep operating instead of being pushed out. And with clear settlement rules, those deals can actually trade and attract real liquidity.
See: Tokenization Finds Scale In Collateral And Cash
If Brussels does not act, the likely outcome is also clear. Europe will keep producing tokenized deals as part of the DLT pilot, but the market will remain shallow and less commercially important. Operators will keep building, but they will be outwardly looking at jurisdictions that allow larger, cleaner, and more continuous activity.
Are We There Yet?
The DLT Pilot was designed for controlled testing, and has done that. The question now is whether the framework evolves to support real market activity. If it doesn’t, tokenized securities will stay limited to small, controlled use cases. If it does, they can develop into a market with real issuance, trading, and liquidity.
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