Europe's Tokenisation Rulebook Is Taking Shape. Where Does the Netherlands Stand?

A practitioner's guide to the regulatory landscape for tokenised securities in Europe — what's live, what's coming, and what Dutch wealth managers need to understand now.

The rulebook nobody expected to arrive this fast

If you had asked a room of European compliance officers in early 2023 whether they expected a comprehensive regulatory framework for tokenised securities to be operational within two years, most would have been sceptical. Regulation in financial services moves slowly, deliberately, and with extensive consultation periods. Digital assets, the thinking went, were no exception.

They were wrong. As of early 2025, Europe has a live, enforceable regulatory architecture for digital assets and tokenised securities that is more advanced than any other major jurisdiction in the world — including the United States. MiCA became fully applicable on 30 December 2024. The DLT Pilot Regime has authorised its first operators. Over seventy crypto-asset service provider licenses have been issued across the European Economic Area. And in December 2025, the European Commission proposed the most ambitious expansion yet: a Market Integration Package that would raise the DLT Pilot Regime's threshold from €6 billion to €100 billion and open eligibility to all MiFID II financial instruments.

All of it already in force. All of it shaping the operating environment your firm sits in today.

Most Dutch wealth managers know MiCA exists. Fewer have a clear picture of what it actually means for their products, their partners, and their competitive position relative to firms in Luxembourg or Frankfurt. That gap between awareness and understanding is where the risk lives.

Three pillars, one architecture

The European approach to tokenised finance rests on three regulatory pillars that work together. Understanding how they connect is essential for any wealth manager evaluating tokenisation opportunities.

MiCA (Markets in Crypto-Assets Regulation) is the broadest pillar. It creates a harmonised licensing framework for crypto-asset service providers across the EU, with a single authorisation that passports across all member states. MiCA covers crypto-asset issuance, trading, custody, exchange, portfolio management, and advisory services. For wealth managers, MiCA's significance lies in the infrastructure it enables: the custodians, platforms, and service providers your firm will need to work with for tokenised products are now operating under consistent European rules.

The DLT Pilot Regime is the more specialised pillar — and arguably the more consequential one for tokenised securities. It creates a regulatory sandbox, now on track to become permanent, that allows authorised market infrastructures to trade, clear, and settle financial instruments on distributed ledger technology. Effectively, it is the only legal tool today that enables both a security token offering and a genuine secondary market for tokenised financial instruments in Europe. Without the Pilot Regime, tokenised bonds, fund shares, and structured products remain trapped in primary issuance with no regulated secondary trading venue.

National securities law forms the third pillar. Each jurisdiction — the Netherlands, Luxembourg, Germany, France — has its own legal treatment of tokenised securities under existing financial regulation. A token representing a bond or a fund unit does not escape prospectus requirements, conduct rules, or investor protection frameworks simply because it lives on a blockchain. This is the layer where jurisdiction-specific expertise matters most, and where many firms underestimate the complexity.

MiCA is live — and implementation is uneven

MiCA's full application date of 30 December 2024 was a milestone. The reality on the ground, though, is more nuanced than the headline suggests. Each member state needed complementary national legislation: a designated competent authority, defined sanctions, and grandfathering periods for existing operators. Some countries moved fast. Others are still catching up. The result is a patchwork.

Germany leads the pack with approximately 21 CASP licenses issued by BaFin, benefiting from years of pre-existing crypto regulation and a shortened grandfathering period. Major licensees include Commerzbank, N26, Trade Republic, and BitGo.

The Netherlands followed closely. The AFM was among the first European regulators to issue MiCA authorisations, granting licenses to MoonPay, BitStaete, and Hidden Road on the very first day of full application. Around fourteen licenses have been issued to date. The Dutch grandfathering period is among the shortest in Europe at six months, which signals the AFM's intent: get compliant or get out.

France has issued approximately six licenses through a simplified fast-track procedure, leveraging the PACTE Act framework that pre-dates MiCA. The French grandfathering period extends to the full eighteen months, giving existing operators more runway — at the cost of a longer stretch of competitive ambiguity.

Luxembourg and Malta have each authorised around six providers, while several member states — Poland, Belgium, Portugal — are still working through legislative or implementation delays.

For Dutch wealth managers, the practical implication is clear: your local regulatory environment is among the most advanced in Europe. The AFM is active, capable, and applying MiCA with characteristic Dutch directness. That is an advantage — and it also means the window for preparation is shorter than in jurisdictions with longer transition periods.

The DLT Pilot Regime: small numbers, big implications

The numbers are modest: by late 2025, only four entities had been authorised under the DLT Pilot Regime across the entire EU. CSD Prague on R3 Corda. 21X in Frankfurt on Polygon. 360X AG as a multilateral trading facility. And Securitize in Spain on Avalanche.

The trajectory, however, tells a different story. 21X, the first fully blockchain-based exchange for tokenised securities, launched primary markets in May 2025 and secondary markets in September 2025 — settling trades via smart contracts in approximately two seconds versus the traditional two-day cycle. By year-end it had executed a €500 million debt issue, signed over thirty exchange participant agreements, and claimed one hundred financial instruments in its pipeline. Settlement uses Circle's MiCA-authorised USDC stablecoin, creating a direct bridge between the two regulatory frameworks.

ESMA's comprehensive review, published in June 2025, identified the constraints holding the regime back: restrictive thresholds, limited interoperability with traditional infrastructure, no access to central bank money for settlement, and the uncertainty created by the regime's temporary status. ESMA recommended making it permanent.

The Commission's December 2025 response went dramatically further than expected. The proposed Market Integration Package would raise the aggregate threshold from €6 billion to €100 billion, open eligibility to all MiFID II financial instruments, drop product-specific market cap restrictions, allow MiCA-authorised CASPs to operate DLT infrastructures, and permit settlement using regulated e-money tokens.

If these proposals become law, the DLT Pilot Regime stops being a cautious experiment and becomes the legal foundation for a parallel European securities market running on blockchain.

This matters for wealth managers because it determines where your future products will be traded and settled. If you are considering tokenised structured products, fund shares, or bonds, the infrastructure you will depend on is being built inside this regime right now.

Four countries, four strategies: where the Netherlands fits

The competition between European jurisdictions to lead tokenised finance is real, and each country is pursuing a distinct strategy. Understanding these differences is essential for Dutch firms evaluating where to domicile tokenised products — or which partners to work with.

Luxembourg: the fund powerhouse. With over €6 trillion in fund assets and four successive "Blockchain Laws" enacted between 2019 and 2025, Luxembourg has built Europe's most comprehensive legal architecture for fund tokenisation. The CSSF already permits fund registers on DLT. Franklin Templeton received CSSF approval in October 2024 for the first fully tokenised UCITS in Europe — a US Government Money Fund on a public blockchain. If your firm is considering tokenised fund structures, Luxembourg is the most proven jurisdiction.

Germany: the securities pioneer. The eWpG (Electronic Securities Act) has permitted bearer bonds and fund units on DLT since 2021. The tokenised securities market grew from €31 million to €615 million in the second half of 2024 alone. NRW.BANK issued a €100 million blockchain bond on Polygon in July 2025 — one of Europe's largest public-sector digital bond issuances. Germany hosts two of the four DLT Pilot Regime operators and has committed to a €2 billion Web3 investment strategy.

France: the regulatory architect. France's PACTE Act of 2019 created the template that became MiCA. The AMF and ACPR have been among the most proactive European regulators, including a pioneering joint consultation on smart contract certification published in February 2025. France's strength is regulatory sophistication and a deep bench of specialised legal expertise.

The Netherlands: the pragmatic early mover. The AFM's approach is characteristically Dutch: technology-neutral, efficient, and no-nonsense. Tokens qualifying as financial instruments face the same prospectus and conduct requirements as their traditional equivalents. The DNB supervises e-money token issuers, with Quantoz launching MiCA-compliant euro and dollar stablecoins under Dutch supervision. The short grandfathering period reflects a regulator that expects the market to move quickly.

The honest assessment: the Netherlands is well-positioned on MiCA licensing and regulatory readiness, yet it has not matched Luxembourg's fund tokenisation infrastructure or Germany's electronic securities framework. The regulatory foundation is solid. Whether the Dutch market will build on it with the same speed as its neighbours remains an open question — and one that individual firms can influence by moving early.

The challenges nobody is solving fast enough

For all the progress, several structural issues remain unresolved — and they are the ones most likely to determine which firms succeed and which get stuck.

Secondary market liquidity. European bond tokenisation reached €1.7 billion by October 2025, which is real growth but remains thin compared to traditional markets. A tokenised product without a liquid secondary market is functionally illiquid — which limits its attractiveness to institutional investors and high-net-worth clients alike.

Settlement without central bank money. The absence of a digital euro or other central bank digital currency for DLT settlement is a structural gap. The Commission's proposal to allow settlement using regulated stablecoins is a pragmatic workaround, though it carries different risk characteristics than settling in risk-free central bank money.

Euro stablecoin sovereignty. Dollar-backed stablecoins currently represent roughly 90% of market capitalisation in Europe, according to a joint EBA and ESMA report from January 2025. If tokenised securities settle predominantly in dollar-denominated instruments, European capital markets acquire a dollar dependency that has profound strategic implications.

Interoperability between old and new infrastructure. Most wealth managers operate through traditional custodians, CSDs, and transfer agents. Tokenised securities need to connect to these existing systems or replace them entirely — and both paths are complex.

Legal certainty around custody and insolvency. If a custodian holding tokenised assets goes bankrupt, what happens to the tokens? The answer varies by member state and is not fully tested in European courts. This uncertainty makes institutional investors cautious, and until it is resolved by either legislation or case law, it will remain a drag on adoption.

What's coming next

The regulatory trajectory for the next twelve to eighteen months is unusually visible. Three developments will shape the landscape:

The Market Integration Package will move through the European legislative process through 2026. If adopted in its current form, it represents a step-change: a hundred-fold increase in DLT Pilot thresholds, ESMA-level supervision for CASPs, and technology-neutral settlement rules. Political will appears strong, though the legislative timeline remains uncertain.

AIFMD II transposition is due by 16 April 2026. It does not contain specific tokenisation provisions, though it modernises the framework under which alternative investment funds operate — including tokenised fund structures. Wealth managers with AIF exposure should ensure their compliance teams understand the implications.

ESMA's UCITS Eligible Assets review has confirmed that tokenised financial instruments — bonds, shares — qualify as transferable securities and pose no eligibility issue for UCITS. Direct crypto-asset investment remains ineligible. This is important because it means tokenised government bonds or corporate bonds can enter UCITS portfolios under existing rules, without requiring any new legislative action.

What this means for your firm

The European regulatory framework for tokenised securities is operational, expanding, and accelerating faster than most market participants anticipated.

The firms that will benefit most from this transition are the ones investing now in understanding the regulatory landscape — with enough depth to make real product and infrastructure decisions. Which of your existing products could be tokenised under current regulation? Which jurisdictions offer the best fit for different product types? Which infrastructure partners actually operate under the right licenses? Which regulatory developments will shift the calculus over the next twelve months?

Equally important: knowing what you do not need to do yet. Some products should stay traditional. Some routes are not feasible. Plenty of platforms claiming end-to-end solutions fall short on closer inspection. Structured, independent analysis is how you separate the real opportunities from the noise.

The regulatory environment for tokenised securities is moving. Understanding it well enough to act — and well enough to know when not to — may be the most consequential investment your firm makes this year.