How Europe can match the US in the tokenised economy

In September 2020, the European Commission published its Digital Finance Package, including the DLT Pilot Regime (DLT PR) and Markets in Crypto Assets Regulation (MiCA). This ushered in innovation and digital transformation in financial markets while safeguarding financial stability and investor protection.

A regulatory sandbox was introduced to enable testing of DLT-based issuance, trading and settlement with the benefit of key regulatory relief and exemptions.

MiCA brought in a blueprint for crypto asset oversight, including stablecoins. 

At the same time, in the US, where there was only regulation by enforcement, some leading firms were investing and expanding their market share. 

The new Trump administration has introduced rules and regulations to support a DLT-based financial ecosystem. In 2025, a paper ‘Strengthening American Leadership in Digital Financial Technology’, charted a new course. 

This, and the legislative proposals such as the GENIUS and CLARITY Acts, supported a pro-innovation, technology-neutral framework that protected individual rights – including self-custody; access to public blockchains; a rejection of central bank digital currency on the grounds of the risks it posed to privacy and individual rights; and a conscious policy to promote the dollar through dollar-backed stablecoins. 

Collaboration and contrast

The pro-digital policy of the US administration also forced collaboration between the country’s main regulatory authorities, such as the SEC and the CFTC. The result has been a wave of rulemaking by both agencies.

The CLARITY Act, which regulates market infrastructure, encountered disagreement over stablecoin yield on trading platforms. Traditional banks oppose allowing crypto platforms to pay passive rewards simply for holding stablecoins, fearing it would cause deposit outflows. Major crypto-trading platforms argue that restricting such rewards woud undermine incentives, platform growth, and the competitiveness of digital asset services.

The US GENIUS Act is a near duplicate of MiCA rules on stablecoins with similar rules on licensing/authorisation of issuers, reserve backing with high-quality assets and consumer protection safeguards with the ability to redeem stablecoins at par.

Yet while Europe has led on regulation, US-issued and dollar-denominated stablecoins dominate the global market.

As of early 2026, the total stablecoin market cap stood around $310bn (€264bn), with dollar-pegged stablecoins accounting for approximately 99% of supply. By contrast, euro-denominated stablecoins total only about $1.1bn (roughly 0.35% of supply), and their trading volumes represent a tiny fraction of dollar-based activity.

Digital asset-based economy

According to data from RWA.xyz, which tracks tokenised real-world assets (RWAs) on public blockchains, the global on-chain market for RWAs – Treasuries, private credit, funds and commodities – is $24-26bn, with tokenised US Treasuries alone accounting for $9-11bn, making these the single largest category. The comparable figure in the EU is under €500m.

US spot bitcoin ETFs alone represent $87bn in AUM. Total US-listed crypto ETPs/digital-asset treasuries exceed $180-220bn. By contrast, the entire EU crypto ETP market is around $12.5bn.

Europe needs speed and vision and an urgent reboot of the continent’s regulatory framework to avoid opening a structural gap with the US. 

Some jurisdictions are already making progress. Examples include Luxembourg’s Blockchain Law, the German Electronics Act and Italy’s Fintech Decree. Recent clarifications by the CSSF allowing UCITS funds to hold stablecoins for settlement purposes, or to indirectly invest up to 10% of their net asset value in crypto-assets, were welcomed.

At European level, the Market Integration Package currently under review reopens DLT PR and MiCA as well as traditional financial frameworks such as Central Securities Depositories Regulation and the Settlement Finality directive

To the extent that the package provides legal certainty and a signal that Europe is open for business, adoption of the DLT part of the package should be expedited.

Susan Yavari is deputy director, capital markets and digital, at the European Fund & Asset Management Association