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The French and Italian authorities make proposals for a more competitive “Pilot Regime” in Europe

AI Analysis

Executive Summary

The French (AMF) and Italian (Consob) financial authorities have jointly proposed amendments to the EU's DLT Pilot Regime to increase its competitiveness and attract market participants. The Pilot Regime, which became operational in March 2023, has underperformed with only three authorized infrastructures and minimal live trading activity, prompting regulators to recommend structural changes including greater proportionality, expanded eligible instruments, and raised activity thresholds.

What Changed

The proposed amendments address the Pilot Regime's limited uptake by introducing the following regulatory modifications: Scope Expansion - Expand eligible financial instruments from current restrictions to all financial assets - Remove categorical limitations that previously restricted participation Activity Thresholds - Raise activity thresholds from €6 billion to €100 billion - Introduce greater proportionality based on project scale, allowing smaller players simplified requirements Operational Flexibility - Remove time limits on authorizations, providing greater certainty for long-term investment - Introduce simplified compliance requirements for smaller market infrastructures Regulatory Framework - Maintain investor protection and market integrity safeguards while reducing unnecess

What You Need To Do

  • *For Market Infrastructure Operators
  • *Reassess Business Cases
  • *Prepare Applications
  • *Monitor Commission Decisions
  • *Compliance Documentation
  • *For Asset Managers and Issuers

Key Dates

March 24, 2026 - ESMA report deadline to European Commission on Pilot Regime functioning and recommendations DEADLINE
June 30, 2026 - End of MiCA transitional period; full crypto-asset regime implementation
Q2 2026 - Expected European Commission report to Parliament and Council with recommendations on Pilot Regime extension, amendment, or permanent conversion
April 9, 2025 - AMF and Consob formal proposals submitted
Mid-2022 - Original DLT Pilot Regime legislation enacted
March 2023 - Pilot Regime became operational

Compliance Impact

Urgency: HIGH

Who is Affected

Market Infrastructure OperatorsFinancial Instrument Issuersbased issuance and tokenization of securitiesAsset Management Companiesbased settlementExisting Pilot Regime ParticipantsProspective ApplicantsRegulatory Authorities

Summary

Market infrastructures Innovation Europe & international Cooperation Other professionals Market Infrastructures Journalists Investment management companies The French and Italian authorities make proposals for a more competitive...

Relevant Firm Types

Asset ManagerBroker DealerFintech
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