The French and Italian authorities make proposals for a more competitive “Pilot Regime” in Europe
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
Suggested Considerations
- *For Market Infrastructure Operators:
- *Reassess Business Cases: Evaluate viability under revised €100 billion thresholds and expanded instrument eligibility
- *Prepare Applications: Organizations previously excluded by €6 billion threshold should prepare authorization applications under new proportionality framework
- *Monitor Commission Decisions: Track European Commission's response to ESMA report (expected Q2 2026) for final regulatory direction
- *Compliance Documentation: Prepare operational and technical documentation demonstrating alignment with revised requirements
- *For Asset Managers and Issuers:
Key Dates
Compliance Impact
Urgency: HIGH
Who is Affected
References
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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...