EU digital asset regulation tracker
What is in force, what is in progress, and who actually holds an authorisation — dated per item, with a named source for each, and a month-by-month archive at its own URLs. Updated monthly, including the months when nothing changed.
What changed this month?
Nothing entered into force in July 2026. The two files that will change obligations are both still in progress: the proposed reform of the DLT Pilot Regime, which would widen the entities eligible to operate a DLT market infrastructure, and the Commission’s market integration package, which reopens the UCITS and AIFM Directives, MiFID and MiFIR, EMIR, CSDR and the cross-border fund distribution rules with tokenisation in scope.
That is worth stating plainly rather than filling the section. A tracker that reports movement every month is not tracking, it is publishing. The last substantive months were June 2026, when ESMA’s chair addressed fund tokenisation and possible UCITS and AIFMD barriers and the Commission’s pilot-regime reform was reported, and December 2025, when the market integration package landed.
Dated record, newest first
July 2026
2026-07 archive →Nothing was added to the in-force set in July 2026. Two files remain in progress: the proposed reform of the DLT Pilot Regime, and the Commission’s market integration package. Both are at negotiation stage and neither changes any obligation today.
Source: COSIMO Digital monitoring of EU Official Journal and Commission publications.
June 2026
2026-06 archive →In a published speech on priorities for European asset management, ESMA’s chair stated that DLT and fund tokenisation are beginning to reshape market practices, that ESMA is engaging with national competent authorities to build supervisory knowledge from real-life cases, and that part of that work concerns whether regulatory barriers to fund tokenisation exist, including in the UCITS and AIFMD regimes. Investor understanding of the rights attached to holdings was emphasised.
Source: ESMA, speech by the Chair, 12 June 2026.
Practitioner analysis of the Commission’s reform proposal records that MiCA-authorised crypto-asset service providers, and operators of organised trading facilities, would be added to the entities eligible to apply for permission to operate a DLT trading venue or DLT trading and settlement system, subject to the relevant MiFID II, MiFIR and CSDR requirements.
Source: European Commission proposal to reform Regulation (EU) 2022/858, 2026, as reported by practitioners.
March 2026
2026-03 archive →The Central Bank of Ireland published a discussion paper on tokenisation, giving managers and service providers a stated Irish supervisory view to engage with. A discussion paper is not a rule and creates no obligation.
Source: Central Bank of Ireland, discussion paper on tokenisation, March 2026.
Under the Regulation, ESMA was to report to the Commission on the results of the pilot regime by March 2026, following its earlier report on the regime’s functioning. The report feeds the decision on whether elements of the regime become permanent.
Source: Regulation (EU) 2022/858; ESMA Article 14 report, June 2025.
January 2026
2026-01 archive →The register records three authorised infrastructures with their permission types, competent authorities, start dates and the specific CSDR and MiFID II exemptions granted to each: CSD Prague, 21X AG and 360X AG.
Source: ESMA, register of authorised DLT market infrastructures, January 2026.
December 2025
2025-12 archive →The Commission released a market integration package addressing cross-border barriers to fund distribution, supervision, market infrastructure, the consolidated tape and tokenisation, reopening the UCITS and AIFM Directives, MiFID and MiFIR, EMIR, CSDR and the Cross-Border Distribution of Funds Regulation. EFAMA supported most measures while cautioning against additional ESMA supervisory reviews for large asset managers.
Source: European Commission market integration package, December 2025; EFAMA response, 4 December 2025.
Following BNP Paribas Asset Management’s tokenised money market fund shares in May 2025, Amundi issued its first tokenised fund share, adding to the set of live European tokenised fund cases supervisors are examining.
Source: Industry timeline of tokenised fund issuances, Investment Association; issuer statements.
June 2025
2025-06 archive →ESMA’s Article 14 report records the authorised infrastructures and states that the limited number of operational DLT market infrastructures and the recency of the first authorisations mean its considerations are early and high-level.
Source: ESMA, report on the functioning and review of the DLT Pilot Regime under Article 14, June 2025.
The guide sets out the register-keeping models in use for tokenised funds, including registers maintained by the asset manager, by a depositary or distributor, or by a specialised authorised entity, and the direct versus intermediated holding models for investors.
Source: EFAMA, "Tokenisation: A Buy-Side Practitioner’s Guide", June 2025.
Each month above has its own page with the same items and sources, so it can be cited directly: July 2026, June 2026, March 2026, January 2026, December 2025, June 2025.
What is in force right now?
Six things govern EU digital assets today. MiCA has been fully applicable since 30 December 2024. MiFID II governs anything that is a financial instrument. CSDR governs settlement and central registration. The DLT Pilot Regime has been in application since 23 March 2023. ESMA’s December 2024 guidelines control classification. And national law decides whether a ledger can be the legal register.
| Instrument | In force since | What it governs today |
|---|---|---|
| Regulation (EU) 2023/1114 (MiCA) | Fully applicable 30 December 2024 | ARTs, EMTs, other crypto-assets and crypto-asset services. Excludes financial instruments by Article 2(4). |
| Directive 2014/65/EU (MiFID II) | In force | Financial instruments, investment firms, venues, investor protection. The regime for tokenized securities. |
| Regulation (EU) 909/2014 (CSDR) | In force | CSD authorisation, book-entry form, settlement discipline. |
| Regulation (EU) 2022/858 (DLT Pilot Regime) | 23 March 2023 | DLT MTF, SS and TSS permissions with targeted exemptions. Three infrastructures authorised. |
| ESMA guidelines on qualifying crypto-assets as financial instruments | December 2024 | The controlling document for classification questions. |
| National register law (German eWpG, French 2017 decree, Luxembourg law of 15 March 2023 and others) | Various | Whether and how a distributed ledger can be the legal register of a security. |
What is not in force, despite frequent claims to the contrary: any EU tokenization licence, any MiCA authorisation covering tokenized securities, and any harmonised EU rule recognising an on-chain register. Those three absences explain most of the structuring work a European issuance actually requires.
What is coming, and when?
Four items, none of them yet law. The DLT Pilot Regime reform is the closest to a decision. The market integration package is the largest in scope. ESMA’s fund tokenisation work is the most likely to produce practical guidance. And MiCA transitional periods for pre-existing national regimes continue to run down member state by member state.
| Item | Stage | What would change | Watch |
|---|---|---|---|
| DLT Pilot Regime reform | Commission proposal, in negotiation | MiCA-authorised CASPs and OTF operators become eligible to operate DLT trading venues and DLT TSSs | Whether volume caps are raised and whether elements become permanent |
| Market integration package | Proposed, December 2025 | Reopens UCITS, AIFMD, MiFID and MiFIR, EMIR, CSDR and cross-border fund distribution, with tokenisation in scope | Whether register recognition is addressed at EU level |
| ESMA fund tokenisation work | Supervisory engagement, ongoing | Possible guidance on depositary and transfer-agency obligations against a tokenized register | ESMA statements and national authority discussion papers |
| MiCA transitional run-off | Ongoing by member state | Firms without CASP authorisation cease in-scope EU services | National register updates |
Our planning assumption, stated so it can be disagreed with: no new EU regime for tokenized securities arrives before 2028, the pilot-regime reform passes in some form, and register recognition remains national for the medium term. Structures built on current law will not need to be rebuilt; structures built on anticipated law may.
Who is authorised, and where?
Roughly 210 firms hold MiCA authorisation, out of approximately 1,200 that were operating under pre-MiCA national regimes — about one in six. Three DLT market infrastructures hold permissions under the pilot regime. Those two numbers are the most useful summary of the European market’s real capacity.
| Operator | Type | Jurisdiction | Authority | Permission from |
|---|---|---|---|---|
| CSD Prague | DLT Settlement System | Czech Republic | Czech National Bank | 11 October 2024 |
| 21X AG | DLT Trading and Settlement System | Germany | BaFin | 3 December 2024 |
| 360X AG | DLT Multilateral Trading Facility | Germany | BaFin | 29 April 2025 |
Where to check anything on this page yourself: ESMA for EU-level registers and the DLT infrastructure register, and the national competent authority for firm-level authorisations — the Central Bank of Ireland, BaFin, the CSSF and their counterparts. An authorisation exists when it appears on a register.
For completeness on our own group, on the same basis we would want from any firm named in a tracker: Black Manta Capital Partners is BaFin-licensed and operates under MiFID II for the regulated issuance and placement of tokenized securities, and is live. Fortuna is registered as a Virtual Asset Service Provider with the Central Bank of Ireland (register ref C459043, under s.106A of the Criminal Justice (Money Laundering and Terrorist Financing) Acts), with MiCA CASP authorisation in process and not yet effective. We hold no DLT market infrastructure permission.
What does this mean for issuers and allocators?
For issuers: current law is sufficient to issue tokenized securities in Europe today, and waiting for the reforms delays revenue without reducing work. The critical path is classification, domicile and register recognition, a MiFID II firm to issue and place, and a depositary that has done it before. None of those four is affected by anything in the pipeline.
For allocators: the diligence questions are unchanged by the pipeline too, and the most useful ones are register accountability, transfer-restriction enforcement, custody authorisation and the cash leg. Where a structure relies on a pending authorisation, treat it as pending — a licence in process is an application under assessment, not a permission.
For both: check registers rather than decks, and prefer sources with dates. The reason this tracker exists in this form — per-item dates, named sources, a crawlable month archive — is that most public summaries of EU digital asset regulation are undated, and an undated regulatory summary is worse than none.
Read next: the EU regulatory stack for tokenized securities, what the DLT Pilot Regime permits and who holds a licence, or what a MiCA CASP authorisation requires.
The standing framework behind every item in this tracker.
The file with the most movement this year.
What the one-in-six authorisation rate actually involves.
- EU Official Journal: Regulation (EU) 2023/1114 (MiCA); Directive 2014/65/EU (MiFID II); Regulation (EU) 909/2014 (CSDR); Regulation (EU) 2022/858 (DLT Pilot Regime).
- ESMA: register of authorised DLT market infrastructures, January 2026; Article 14 report on the DLT Pilot Regime, June 2025; guidelines on qualifying crypto-assets as financial instruments, December 2024; speech by the Chair, 12 June 2026.
- European Commission: market integration package, December 2025; proposal to reform the DLT Pilot Regime, 2026 (as reported by practitioners).
- Central Bank of Ireland: discussion paper on tokenisation, March 2026. EFAMA: tokenisation policy work and buy-side practitioner’s guide.
- MiCA authorisation counts: COSIMO Digital analysis of regulator registers and market data, 2026.
- Structured source data for this page: /learn/eu-digital-asset-regulation-tracker/tracker.json.
- COSIMO Digital regulatory authorisations, described as of 28 July 2026. Pending authorisations are not effective until granted.
This page is for informational purposes only. Nothing in it is an offer to sell, or a solicitation of an offer to buy, any security, and nothing here is investment, legal, tax, or financial advice. Regulatory authorisations are described as of the date stated; pending authorisations are not effective until granted.
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