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ESMA Seeks Evidence That Tokenized Collateral Can Be Liquidated During Market Stress

The European Securities and Markets Authority has launched a consultation to determine whether existing EU rules adequately protect clearinghouses' ability to access and convert tokenized collateral to cash when members default.
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ESMA Seeks Evidence That Tokenized Collateral Can Be Liquidated During Market Stress

The European Securities and Markets Authority (ESMA) published a call for evidence on Friday seeking industry feedback on tokenized collateral, specifically requesting proof that clearinghouses can access and liquidate such assets during periods of market stress.

ESMA Chair Verena Ross stated that the authority aims to "create the conditions for tokenized markets to operate safely and at scale across borders, with legal certainty, interoperable infrastructures and appropriate supervision."

Tokenized collateral is already being used in live European clearing operations as financial institutions seek faster access to securities to meet margin requirements. ESMA's review will help determine whether current EU regulations ensure clearinghouses can access and liquidate tokenized collateral when a member defaults.

Current Implementation and Regulatory Focus

In July 2025, Eurex Clearing introduced a collateral service based on distributed ledger technology. JPMorgan executed the first live transaction for Dutch pension investor PGGM, moving securities from another custody location.

The consultation covers tokenized representations of assets held in traditional financial infrastructure as well as assets issued directly on distributed ledgers. It also examines how these models interact with stablecoins, central bank money, and tokenized deposits.

Liquidity and Ownership Questions

ESMA raised concerns that even assets considered liquid in traditional form may face additional risks when tokenized, including delays caused by redemption procedures or restrictions on transfers. The authority also sought clarity on whether token transfers properly confer ownership or enforceable rights over the underlying assets.

The consultation follows the Eurosystem's September launch of Pontes, a system allowing financial institutions to settle tokenized asset transactions using central bank money. ESMA indicated that Pontes could support tokenized collateral arrangements by connecting blockchain-based infrastructure with existing settlement systems.

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