2026-09-08

On 7 September 2026, EDFA joined a broad alliance of European firms and associations in an industry recommendation addressed to Members of the Council and to Members of the ECON Committee, on volume thresholds for the DLT Pilot Regime within the Market Integration and Supervision Package.

The revision of the regime is an opportunity to establish the European Union as the leading jurisdiction for regulated tokenised financial markets. Raising the cap from EUR 6 billion to up to EUR 100 billion is a step forward, but it does not match the scale of the market. The thresholds apply to market capitalisation rather than trading volume, and some existing European projects already hold volumes reaching EUR 350 billion.

The recommendation asks co-legislators to remove the cap under the regular regime, sets out what an appropriate threshold would look like if one is retained, and opposes applying stricter limits to DLT market infrastructures than to CSDs designated under the SFD. The full text and the list of signatories are below.