Shaping Europe’s tokenised future: ABBL responds to the ECB’s Appia consultation

The European Central Bank’s Appia initiative represents an important step in exploring how financial markets could operate within a future tokenised environment.

As Europe moves progressively from experimentation towards more concrete design considerations, discussions are increasingly focusing on how tokenised market infrastructures could be structured in practice, while preserving financial stability, interoperability and innovation.

In its response to the ECB consultation, the ABBL welcomes the overall direction of the initiative and supports the objective of maintaining central bank money as the anchor of a future tokenised financial ecosystem within the existing two-tier monetary system.

At the same time, the ABBL underlines that the future framework should maintain an appropriate balance between public oversight, market-driven innovation and interoperability.

Central bank money as the anchor of the ecosystem

The ABBL supports the high-level principles presented in the consultation, notably the focus on integration, innovation and the preservation of central bank money at the core of the ecosystem.

At the same time, the Association highlights the important role already played by market participants in developing DLT-based infrastructures and services.

In this context, the ABBL encourages an approach in which the Eurosystem acts as an enabler and anchor of trust, while allowing interoperable market infrastructures and private-sector initiatives to continue developing around it.

The response also stresses the importance of avoiding unintended crowding out of existing market innovation.

Interoperability as a core requirement

A central theme throughout the ABBL response is the importance of interoperability.

Rather than converging on a single infrastructure, the Association supports an ecosystem where multiple networks can coexist and interoperate effectively under harmonised conditions.

This approach would help reduce fragmentation while also avoiding excessive concentration risks and preserving room for innovation.

The ABBL notably underlines that:

• interoperability should be treated as a core requirement from the outset,
• common standards will be essential to support scalability,
• and central bank money settlement should remain available across multiple eligible DLT networks.

The response also highlights the importance of preserving the convertibility between commercial bank money and central bank money in wholesale markets.

Balancing innovation, resilience and strategic autonomy

The consultation also raises broader questions around governance, resilience and Europe’s strategic autonomy.

On this point, the ABBL notes that autonomy should not be viewed solely through a legal lens, but also from a technological and operational perspective, including areas such as cloud infrastructure, software dependencies and operational governance.

The response therefore emphasises the importance of ensuring that critical infrastructures are:

• governed and operated within Europe,
• aligned with European regulatory frameworks,
• while remaining connected to global financial markets and infrastructures.

At the same time, the Association underlines that maintaining openness and international interoperability remains essential given the global nature of financial markets.

The role of standardisation and governance

The ABBL also highlights the importance of standardisation in avoiding fragmentation within a future tokenised ecosystem.

Priority areas identified include:

• asset representation,
• messaging standards,
• and participant identification and authorisation mechanisms.

The response stresses that standardisation efforts should be developed through close cooperation between public authorities and industry participants, combining public oversight with practical market expertise.

Governance arrangements will also play an important role, particularly regarding transparency, participation rules and access conditions.

A practical and market-driven approach

Finally, the ABBL underlines the importance of a practical and evidence-based implementation approach.

In particular, the response highlights that interoperability challenges are best addressed through real-world testing and experimentation, while building on existing infrastructures, market expertise and operational experience