ESMA launched a Call for Evidence on 15 January 2027-deadline terms asking whether tokenised collateral can be used safely and effectively by EU central counterparties, with stakeholder contributions due by 15 January 2027 and an assessment of responses planned for the first quarter of 2027.

The call targets the collateral lifecycle itself: how tokenisation may affect the transfer, management, protection and use of collateral posted to CCPs. ESMA frames tokenisation as moving from testing to real-world use, with collateral mobilisation the most relevant clearing application.

What does ESMA want to know?

The evidence request examines several tokenisation models:

• "Digital twins" — tokenised versions of assets held in traditional infrastructures
• Assets issued directly on distributed ledger technology (DLT)
• Hybrid arrangements and their interaction with tokenised cash and other settlement assets

ESMA asks how these models would operate in practice, particularly in the event of a clearing member default. Specific questions include whether CCPs could access, transfer and convert tokenised collateral into liquidity when needed, and how client protection, segregation and settlement finality could be ensured where DLT interacts with traditional market infrastructures. The regulator also wants views on whether and how tokenising already eligible collateral changes its risk profile.

What did ESMA's leadership say?

Verena Ross, Chair of ESMA, said: "Tokenisation has the potential to make Europe's financial markets more efficient, integrated and innovative. As it moves from experimentation to the mainstream, we must create the conditions for tokenised markets to operate safely and at scale across borders, with legal certainty, interoperable infrastructures and appropriate supervision."

Klaus Löber, Chair of ESMA's CCP Supervisory Committee, set the supervisory boundary. "Tokenisation can support more efficient collateral mobilisation and contribute to the further integration of EU post-trade markets. At the same time, it is key that the fundamental safeguards applicable to CCP collateral remain unchanged," Löber said. "Collateral must be of high quality, legally enforceable, highly liquid, and easily operationally available, including in stressed conditions and following a clearing member default."

Löber added that the call aims to establish "how tokenised arrangements work in practice and whether the existing framework can accommodate them safely and effectively."

Mandate versus proposal

Nothing in the call changes CCP collateral rules today. This is an evidence-gathering step, not a consultation on draft technical standards and not a rule amendment. Responses will be published after the consultation closes unless respondents request otherwise.

For clearing members and their clients, the workflow implications are downstream but concrete. If tokenised collateral gains CCP eligibility, margin operations would face new questions: DLT-wallet access at default, conversion paths to cash under stress, and segregation models where tokens sit on ledgers that interact with CSDs and custodians rather than replacing them. The digital-twin model implies parallel legal claims over one asset; the native-issuance model implies new legal frameworks altogether. ESMA's focus on settlement finality signals that interoperability with existing infrastructures, not replacement, is the operative scenario.

What comes next

ESMA will assess feedback in Q1 2027. Based on that assessment and its wider tokenisation work, the authority will determine "the most appropriate course of action, including any regulatory or supervisory convergence action within its remit" — language that leaves open anything from no action to guidance or rule changes for CCP collateral frameworks.

desks running clearing and financing operations have until 15 January 2027 to document where tokenised collateral would help or complicate default management, segregation and liquidity conversion.