The DLT Pilot reform, and the road to Pontes

On 9 October 2026 EU finance ministers agreed the key elements of the Council's position on the market integration and supervision package. Most of the coverage is about ESMA getting new supervisory powers. One part of the package matters more to anyone building tokenised markets: the DLT Pilot Regime, the EU's sandbox for trading and settling securities on a distributed ledger, is about to get much bigger.

The Council's compromise raises the main ceiling from €6 billion to €300 billion, lets crypto-asset trading platforms in, and creates new tiers for smaller operators and for single post-trade services. Read it next to the eligibility rules for Pontes, the Eurosystem's DLT settlement bridge that went live on 21 September, and there's a second story. The reform could become the route by which a new class of operator reaches settlement in central bank money.

This is still a negotiating position, not law. Here is what it says, what it would change, and what it would take to build against.

What the DLT Pilot Regime is#

The DLT Pilot Regime, Regulation (EU) 2022/858, has applied since March 2023. It lets market infrastructures run on a distributed ledger with targeted exemptions from MiFID II, MiFIR and the CSD Regulation. Those rules were written for databases, accounts and intermediaries. They do not map cleanly onto a shared ledger.

It created three kinds of DLT market infrastructure:

Type	What it does	Replaces
DLT MTF	Trading of DLT financial instruments	A multilateral trading facility
DLT SS	Settlement and recording of DLT financial instruments	A securities settlement system run by a CSD
DLT TSS	Trading and settlement on one platform	Both of the above, combined

The exemptions came with tight limits. Shares were capped at €500 million in issuer market capitalisation, bonds at €1 billion in issue size, and only shares, bonds and UCITS units qualified. The total market value of DLT financial instruments on an infrastructure could not exceed €6 billion. Permissions lasted at most six years.

Why almost nobody used it#

ESMA's review under Article 14, published in June 2025, found that only three DLT market infrastructures had been authorised by its May 2025 cut-off:

CSD Prague, a DLT settlement system since 11 October 2024
21X AG, a DLT trading and settlement system since 3 December 2024
360X AG, a DLT MTF since 29 April 2025

ESMA reported minimal live trading. It named the frictions: thresholds that keep out established issuers and larger institutions, a six-year sunset that makes investment hard to justify, no interoperability, and no access to central bank money. Its recommendations were to raise the thresholds and make the regime permanent.

The first of the three is in Prague. CSD Prague runs its DLT settlement system on R3 Corda Enterprise, supervised by the Czech National Bank. If you work in CEE, this regime isn't something happening somewhere else.

What the Commission proposed#

The Commission's proposal of 4 December 2025 took ESMA's diagnosis and went further:

All financial instruments become eligible, not just shares, bonds and UCITS. The asset-specific caps go.
A €100 billion ceiling per infrastructure replaces the €6 billion one.
CASPs can participate, provided they meet the sectoral rules for the activity they choose.
A simplified regime for operators up to €10 billion, with lighter obligations.
Unbundled CSD services. Investment firms, regulated markets, credit institutions, CSDs and CASPs could offer a single CSD function on its own, such as DLT notary or central maintenance, without becoming a full CSD.
Settlement schemes. Credit institutions acting as DLT account keepers with access to central bank money could jointly run a new kind of infrastructure under ESMA supervision.
No time limit. Permissions would no longer expire.

Separately, the CSD Regulation amendments in the same package would let certain tokenised assets settle the cash leg, not just central bank money.

What the Council changed#

The Council kept the structure and turned up the numbers. Its compromise text, put to ministers on 5 October, sets out these thresholds:

	Today	Commission, Dec 2025	Council, Oct 2026
Main ceiling	€6bn	€100bn	€300bn, with €500bn possible by delegated act
Simplified regime	None	Up to €10bn	€10bn
Unbundled services	None	Introduced	€50bn
Headroom over threshold	None	—	Temporary room to operate at up to 125%
CASP trading platforms	Not eligible	Eligible	Eligible

The Council text also removes the ability of Member States to set different thresholds at national, project or group level, so one EU-wide framework applies.

On supervision, the Council departs from the Commission in a way that matters to CEE firms. The Commission wanted every CASP authorised and supervised by ESMA. The Council would move only the most significant cross-border CASPs to ESMA immediately. The rest stay with their national authority.

The Pontes connection#

Pontes lets transactions on market DLT platforms settle in central bank money through TARGET. It has two roles. A market participant is any entity with access to T2, which in practice means banks. A market DLT operator runs the platform where the asset side lives and contracts with its national central bank.

The eligibility criteria the ECB published in January 2026 list who can be a DLT operator:

CSDs authorised under the CSD Regulation
Operators of a DLT SS or DLT TSS authorised under the DLT Pilot Regime
Overseen payment system operators in the EU or EEA
CCPs authorised under EMIR
Banks, investment firms, market operators and other licensed financial institutions, if they are subject to market-infrastructure supervision or pass a case-by-case assessment by their central bank

A MiCA-licensed CASP is not on that list as such. Its route today would be the case-by-case assessment, which is discretionary. A CASP that holds a DLT settlement or trading-and-settlement permission under the Pilot would fall into a named category instead.

That is our reading, and the caveats are real:

It depends on the final text. This is the Council's position only. Negotiations with the Parliament can start once it adopts its own.
Only settlement counts. Pontes names DLT SS and DLT TSS operators. A CASP running a DLT MTF alone would not qualify. Whether an unbundled notary or maintenance service qualifies is not answered by the published criteria.
Your participants still need T2. The operator runs the platform. The counterparties who settle the cash leg must be T2 participants, which a CASP is not.
Pontes is euro-only for now. Its planned multi-currency step covers currencies settled in T2, which leaves out the koruna, the zloty and the forint.

Even with those caveats, the regulatory path for a crypto platform and the Eurosystem's settlement path now point at the same place.

Where it breaks in practice#

Moving from a MiCA licence to a DLT Pilot permission is not a paperwork upgrade. A CASP trading platform is built for crypto-assets under MiCA. A DLT TSS handles financial instruments under the rules that normally apply to CSDs and trading venues. The gap between the two is mostly engineering.

Settlement finality. A DLT SS has to say when a transfer is final and prove it holds in insolvency. ESMA noted that CSD Prague operates under an exemption from the CSDR's finality article. Pontes makes the cash leg final once it completes in T2. Your ledger's asset leg has to agree with both.
The conditional lock. As a Pontes operator you have to hold the asset leg until the Eurosystem confirms the cash leg, then release or revert it. That is new logic on your ledger, and certification tests it.
Instrument lifecycle. Securities have corporate actions, record dates, coupon payments and registers of holders. Crypto-asset platforms usually have none of these. An ERC-3643 or T-REX class token can enforce transfer rules, but the lifecycle around it has to be built.
Two rulebooks at once. A CASP inside the Pilot would run MiCA obligations for its crypto business and Pilot obligations for its securities business, often on shared infrastructure. Segregation of assets, books and controls has to be designed, not assumed.
Thresholds are now a monitoring problem. With tiers at €10 billion, €50 billion and €300 billion, and temporary headroom to 125%, you need a live measure of aggregate market value and a plan for moving between tiers.
DORA, again. A Pontes connection and a Pilot infrastructure are both ICT risk items. The register of information, incident classification and resilience testing apply to both.

The CEE angle#

Three things make this more relevant in Prague than the coverage suggests.

First, one of the three authorised DLT market infrastructures is already here and supervised by the CNB. The regulator has done this once.

Second, the CNB has a large CASP population. When MiCA's transition ended on 1 July 2026, it had assessed 251 applications and granted licences to 11 entities. Under the Council's approach, most of those firms would not be significant enough for ESMA and would stay with the CNB. A Czech CASP looking at the Pilot would deal with a familiar supervisor.

Third, the currency question cuts both ways. A koruna-denominated DLT market gets nothing from Pontes today. A Czech platform serving euro issuance gets a route to central bank money settlement that didn't exist two years ago.

What to do now#

Nothing here is final, but the shape is clear enough to plan against.

Decide which role you want. Trading venue, settlement system, combined, or a single unbundled service. Pontes eligibility and your build both depend on that choice.
Map the gap from MiCA to the Pilot. List what your platform does today for crypto-assets, and what a DLT SS or TSS would have to do for financial instruments. The difference is your programme.
Design the ledger for conditional settlement now. Whether or not you connect to Pontes first, a lock-and-release model is what wholesale DvP expects.
Track the trilogue. The thresholds, the CASP route and the unbundled-service rules can all still move. Re-read the primary texts when the Parliament adopts its position.

How we help#

We don't run a venue or sell a platform, so we can give the same advice to a CASP, a bank or a CSD.

Pontes/EBSI Readiness Sprint. Fixed fee, two to four weeks. Which route fits you, DLT operator or participant, under which regime. A gap map from your current stack to a DLT SS or TSS and to Pontes certification. A target architecture for finality, the conditional lock and reconciliation, with a cost on the build.
Tokenization Stack Assessment. For teams connecting an ERC-3643 or T-REX class engine to KYC, custody, transfer agency and core banking, measured against what a Pilot infrastructure would need for the instrument lifecycle.
CASP Compliance Stack Audit. For CASPs weighing the Pilot, what MiCA and DORA require of the stack you run today, so the new business sits on a sound base.

We have shipped on these rails before: an EU-Commission-backed bonds-on-DLT delivery on EBSI and Hyperledger Besu, and the risk layer underneath tokenized assets at RWArmor. For the mechanics of the bridge itself, see our note on connecting to Pontes. For the issuer side, see the ECB as buyer.

If the Pilot or Pontes is on your 2027 plan, start with a fixed-scope verdict. See the readiness sprints, or write to us at info@prodevel.com.