Semaine 52
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Last week, the European Commission proposed a set of measures designed to lay the foundations for a future European capital market built on blockchain. At its core is a major overhaul of the Pilot Regime, the EU framework that lets financial institutions trade and settle tokenized securities under regulatory supervision.
Why it matters
The Pilot was meant to serve as Europe’s real-market testbed for blockchain, but it drew only six participants. The reasons were structural: a €6 billion aggregate cap on all instruments admitted to a DLT system, size limits that excluded funds above €500 million, and the regime’s temporary nature, which discouraged long-term investment. As a result, activity remained minimal despite rising interest in tokenization.
The Commission now wants the Pilot Regime to operate without a predefined end date, transforming what was originally a time-limited experiment into a stable, long-term framework.
“Removing that uncertainty now gives us much greater confidence to build the ecosystem we need around our platform,” explained Dirk Kruwinnus, CPO at Seturion, Boerse Stuttgart’s recently unveiled settlement platform for tokenized assets, as the group is currently undergoing approval under the Pilot Regime.
A three-tier regulatory structure
To broaden participation, the Commission also proposes to replace the current one-size-fits-all setup with a three-tier model. Such a reform would open the regime to both major institutions and smaller players and CASPs like crypto exchanges, who were previously barred from applying.
Under the new tiers, annual volumes could rise to €10-100 billion. The previous restrictions on listing debt, equities and funds would disappear, and participants could settle using tokenized deposits or MiCA-regulated stablecoins, a pragmatic bridge while a CBDC remains distant.
Supervision by ESMA
Supervision of most Pilot participants would also shift from national regulators to ESMA, the EU’s financial regulator. The move is intended to harmonize oversight and ensure consistent application across member states.
Crucially, the Pilot is not the only path forward. The package also proposes targeted amendments to the rulebook for traditional CSDs like Euroclear and Clearstream.
These changes would let them perform atomic settlement without involving a clearing house, removing a longstanding barrier to adopting DLT within traditional infrastructure. In practice, this creates a parallel route to DLT adoption for major incumbents, without requiring them to join the Pilot Regime.
The proposal now moves to Parliament and Council for separate reviews before trilogue negotiations. Under favourable political conditions, the new framework could enter into force in under two years.
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