ICMA responds to Eurosystem consultation on Appia Roadmap
22 April 2026 The International Capital Market Association (ICMA) yesterday submitted its response to the Eurosystem’s feedback questionnaire on the approach set out in the roadmap for Appia, the strategic initiative to shape the development of a European tokenised financial ecosystem (the “Appia roadmap”).
ICMA’s response reflects the views of a subset of its DLT Bonds Working Group, which includes issuers, banks, investors, market infrastructures and law firms across the value chain of international debt capital markets.
ICMA’s consultation response builds on ICMA’s engagement with the Eurosystem through the ECB New Technologies for Wholesale settlement Contact Group (NTW-CG), which ICMA has been a member of since its inception.
Key points:
- ICMA members welcome the opportunity to provide feedback on the Appia roadmap. Facilitating settlement of DLT transactions in central bank money is of critical importance in order to foster the development of DLT-based capital markets and unlock the wider benefits of tokenisation, as highlighted in ICMA’s previous response to a Eurosystem questionnaire in June 2022.
- While ICMA members are, in principle, supportive of the proposed high-level principles governing Appia, we emphasise (i) the importance of the principle of legal certainty; (ii) international interoperability being integral to market access and integration; and (iii) suggest the inclusion of interoperability, standardisation and proportionality as additional principles.
- The proposed technologically neutral network layer should be built through a market-led, collaborative approach, building on existing traditional and DLT-native standards (for example, ICMA's Bond Data Taxonomy).
- ICMA members believe that the Eurosystem has a critical role to play as an enabler for the EU’s tokenised financial ecosystem, by issuing a wholesale CBDC, driving the adoption of standards and establishing rules for market participants.
- While some ICMA members note the necessity to reduce reliance on non-European providers for critical infrastructure to ensure strategic autonomy, it is equally important to acknowledge that maintaining interoperability between Appia and the global financial system is crucial to avoid fragmentation.
- ICMA members emphasise that any common standards, rules and practices to shape the tokenised financial ecosystem must be built on existing industry standards and initiatives. These common standards are critical to facilitate interoperability and enable scaling within the industry, both within the EU’s tokenised financial system and with third countries.
- Allowing multiple interoperable networks to operate under a common set of harmonised standards is generally the preferred approach from ICMA members’ perspective, instead of a single network operated by the Eurosystem. This model would support competition, reduce concentration risks, and encourage market-led innovation, while also allowing the Eurosystem to maintain safety and compatibility through a strong regulatory and standard-setting role.
ICMA’s detailed response can be found here.
