INTERVIEW: Can Europe’s Crypto Rules Keep Up With Programmable Finance?

In this interview with Impact Newswire, Ludovico Rossi, CRO and co-founder of Barcelona-based tokenization firm Brickken, discusses the next phase of financial tokenization and how programmable assets, blockchain and AI agents could reshape financial markets. He explores the regulatory challenges around automated transactions, who should be accountable when smart contracts or AI agents control assets, and why machine-readable permissions could become essential to building trusted institutional markets on-chain.

Europe is moving from experimenting with tokenized financial assets to building the infrastructure that could support them at scale. At the centre of that transition is a question that goes beyond whether a bond, fund or loan can be represented as a digital token: who controls a programmable financial asset, who can instruct it to move, and who is ultimately responsible when something goes wrong?

The timing is significant. On Aug. 19, the Eurosystem selected 61 financial-market stakeholders and public-sector institutions for the Appia contact group, which will help shape the Eurosystem’s longer-term approach to a tokenized financial ecosystem while also advising on the operation and evolution of Pontes. The group begins work in September.

Pontes, meanwhile, is scheduled to launch on Sept. 21, 2026. The system will connect market-based distributed-ledger technology (DLT) platforms with the Eurosystem’s TARGET Services, allowing tokenized wholesale transactions to settle in central bank money. Clearstream is participating in end-to-end testing ahead of the launch, including delivery-versus-payment settlement.

That represents a significant shift from the early experimental phase. In 2024, the Eurosystem conducted more than 50 trials and experiments involving 64 participants across nine jurisdictions, with more than €1.6 billion in real transactions settled in central bank money. The experiments covered securities and payment use cases and were intended to test whether DLT could be connected to existing central-bank settlement infrastructure.

The ECB is now effectively building the public settlement layer for a market that it expects to become increasingly programmable. Its broader Appia initiative is intended to develop a blueprint for an integrated European tokenized financial ecosystem by 2028, while Pontes provides the immediate infrastructure for settling DLT-based transactions in central bank money. The ECB argues that central bank money provides the trusted settlement anchor needed for tokenized markets to grow without becoming fragmented across incompatible private networks.

The potential market is substantial, even though tokenisation remains relatively small today. McKinsey estimates that the market capitalization of tokenized financial assets could reach about $2 trillion by 2030, excluding cryptocurrencies and stablecoins, with a bullish scenario of roughly $4 trillion. The firm identifies cash and deposits, bonds, funds, loans and securitisation among the asset classes most likely to drive adoption.

Government bonds illustrate both the opportunity and the challenge. The Bank for International Settlements said in 2025 that tokenized government bonds had reached only about $8 billion in issuance, but found that tokenised bonds could have lower bid-ask spreads than conventional bonds while maintaining comparable issuance costs. The BIS said wider adoption would depend heavily on resolving regulatory and infrastructure issues.

As these markets develop, programmability becomes as important as tokenisation itself. Unlike a conventional electronic security, a tokenized asset can have rules governing how it can be transferred embedded into the infrastructure. Smart contracts can automatically execute transactions when predefined conditions are met. The BIS describes this as the ability to integrate the asset, its transfer rules and transaction logic on a programmable platform. This could automate everything from delivery-versus-payment to collateral management and other conditional financial transactions.

That creates a regulatory problem that is harder than simply deciding whether an asset is a security, crypto-asset or financial instrument.

Consider a tokenized fund or DeFi lending vault. A traditional financial product generally has identifiable intermediaries: an issuer, asset manager, custodian, broker or other regulated entity. In a programmable environment, however, control can be distributed between smart contracts, developers, governance mechanisms, wallets, service providers and users. A transaction could be triggered automatically without an individual making a conventional discretionary decision at the point of execution.

The EU is now examining precisely these gaps as part of its review of the Markets in Crypto-Assets Regulation (MiCA). The European Commission’s targeted consultation, launched on May 20, asks whether MiCA remains fit for purpose following its initial implementation and changing market conditions. The consultation covers areas not fully addressed by the original framework, including decentralised finance, crypto-lending, staking and NFTs, and has a deadline of Sept. 30, 2026.

MiCA itself represents Europe’s attempt to establish a harmonised regulatory framework for crypto-assets and related services that fall outside existing financial-services legislation. But the emergence of increasingly automated and decentralised financial products is testing the assumptions underlying traditional regulation: that there is a clearly identifiable intermediary, that control can be attributed to a legal entity and that responsibility can be assigned to a specific point in the financial chain.

The issue becomes even more complicated with AI agents.

An AI agent could eventually operate within a predefined investment, treasury or collateral mandate, monitoring markets and initiating transactions when specified conditions are met. In such a model, the agent may not legally own or control the underlying assets, but it could have authority to instruct transactions. That creates a new layer of questions: Who granted the authority? What were the limits? Could the agent exceed them? Who is responsible for an unauthorised transaction? And how can regulators reconstruct the chain of decisions after the fact?

This is where the debate around machine-readable permissions becomes important. Instead of regulation existing solely as text interpreted by humans, some rules could potentially be encoded into the infrastructure itself: which assets an agent can access, how much it can transact, what counterparties it can interact with, what conditions must be met and when its authority must automatically expire or be revoked.

The broader financial system is already moving in this direction. The ECB says tokenisation can combine issuance, trading, settlement, custody and servicing more closely, while smart contracts can enable new forms of programmable financial transactions. The BIS similarly argues that tokenisation could integrate messaging, reconciliation and asset transfer into a single programmable process, potentially reducing manual intervention and settlement risks.

But greater programmability also creates new risks. The BIS has warned that tokenisation remains small in scale and that many of its promised benefits remain unproven. It highlights potential trade-offs including increased operational complexity, liquidity pressures and regulatory uncertainty.

Europe therefore faces a potentially awkward race: its central bank is actively building the infrastructure for tokenized markets at the same time that its regulators are reassessing the rules governing parts of the crypto and DeFi ecosystem.

That makes the next phase of regulation less about whether an asset is “crypto” and more about how control is exercised over programmable financial infrastructure.

Ludovico Rossi, CRO and co-founder of Brickken, has been working at the infrastructure level on standards including ERC-7943, focused on compliant tokenized assets, and ERC-8226, which addresses delegated transaction authority for agents with defined limits. He spoke with Faustine Ngila.

Here is the full interview:

1. Europe is moving ahead with tokenized securities infrastructure while regulators are still debating DeFi rules. Is regulation at risk of falling behind the technology? 

There is a risk, though it sits less in regulators moving too slowly and more in how quickly the financial structures themselves are changing. You see it clearly once a regulated asset starts interacting with programmable infrastructure. 

A tokenized fund unit might move into a vault, get pledged as collateral or be allocated through software, and suddenly you need to know who authorised that activity, what mandate they were operating under and who is responsible if something goes wrong. That answer has to travel with the asset itself, not live in a system somewhere behind it. 

Europe has already shown that tokenized securities can operate within regulated markets. The next step is ensuring permissions, ownership rules and investor restrictions remain enforceable as those assets move across platforms and smart contracts. That clarity is what institutions need to use this infrastructure with confidence. 

2. As tokenized funds, collateral and credit become programmable, should regulators focus less on what an asset is and more on who can control it and under what conditions? 

Both matter. A tokenized fund unit is still a fund unit, but programmability introduces a much more detailed question around control. 

You can now define who can move an asset, under what conditions, whether that authority can be delegated and when it can be revoked. Once collateral, credit and fund positions start interacting across different systems, those details stop being a background checkbox and start being the condition that decides whether the transaction can execute at all. 

Regulators need to be able to establish who had permission, what they were authorised to do and where responsibility sits if something happens outside the scope of that mandate. That becomes even more important as execution becomes automated. 

3. Could DeFi lending vaults become the first major test of how European regulators assign responsibility when financial decisions are distributed across smart contracts, protocols and multiple participants? 

Yes, because lending vaults are where composability stops being just a technical property and starts being a real transfer of credit risk. One party might design the strategy, another

provides the infrastructure, a smart contract executes the rules and multiple participants provide capital, and if the strategy fails, real money is lost, not just a position on a ledger. 

Financial regulation still depends on identifying who is responsible for a decision, and that principle doesn’t disappear because execution is distributed. 

If Europe can recognise that structure while still making accountability clear, lending vaults could provide a useful model for a much wider range of programmable financial products. 

4. What happens to regulatory accountability when AI agents begin managing tokenized assets, executing transactions and reallocating capital within predefined mandates? 

Accountability still has to lead back to a person or institution. An AI agent may execute transactions or reallocate capital, but there still needs to be someone behind it who has defined what it is allowed to do. 

The mandate becomes critical here. Who authorised the agent, which assets can it access, how much discretion does it have and who can intervene if something goes wrong? 

That mandate needs to do two things, in the right order. It has to be checked automatically the moment the agent tries to act, so anything outside its authority is stopped before it settles rather than flagged afterwards. Only then does it need to leave a record showing what the agent was authorised to do at that moment. The instinct across the industry is often to build the record first and treat the check as optional. It should be the reverse. The record only has value for transactions that already passed the check. As more capital is managed this way, getting that sequence right will matter enormously. 

5. Could AI-managed financial systems require a new regulatory framework based on machine-readable permissions, transaction limits, monitoring and the ability to revoke an agent’s authority? 

We do not necessarily need an entirely new regulatory framework, because concepts like authority, supervision and accountability already exist in finance. The challenge is making them work when the actor executing the transaction is software rather than a person. 

If an AI agent can manage capital, the system needs to know which assets it can access, what transactions it can execute, what limits apply and when that authority can be revoked, and that information has to be something the software itself can act on, not just something written down for a compliance file. 

This is an evolution of existing regulation, not a replacement of it. The concepts do not change. What changes is that they have to move from policy documents into the systems that execute the transactions.

6. If a tokenized asset is controlled by a smart contract rather than a single identifiable institution, who should be legally responsible when something goes wrong? 

A smart contract cannot carry legal responsibility, so you still have to look at the people and institutions that authorised the activity and had some ability to control it. 

The difficult cases are where that control is split. One party might write the contract, another defines the strategy and someone else has the authority to pause execution. Regulators will need to look at who actually had the power to decide when something happened. 

Responsibility should follow control, authority and the ability to intervene, which is why those roles need to be clear from the beginning. 

7. Europe is trying to build a regulated tokenisation market while also expanding central-bank settlement infrastructure. What regulatory changes are needed to ensure MiCA does not become a bottleneck for institutional adoption? 

Europe needs a cleaner regulatory perimeter so institutions know which framework applies as an asset moves through different parts of the market. This is not abstract. The European Commission’s own consultation on reviewing MiCA, which closes for comments on 31 August 2026, raises exactly this question: should assets that qualify as financial instruments stay under MiFID and the Prospectus Regulation, or should they fall under MiCA instead. That a foundational scope question like this is still open more than three years after MiCA entered into force shows how much of the perimeter is unresolved. 

A tokenized security may sit within securities law, be held through digital custody infrastructure and eventually settle through DLT infrastructure connected to central bank money. That entire journey needs to make regulatory sense. 

Greater consistency around custody, settlement, transfer restrictions and programmable compliance would help, alongside a clearer path from the DLT Pilot Regime into permanent market structure. Institutions can work with strict regulation. What is much harder to manage is uncertainty over which rules apply. 

8. As financial markets become increasingly programmable, what should Europe’s regulatory framework look like to ensure innovation can scale while accountability, investor protection and control remain enforceable?

Regulation needs to become capable of operating at the same level as the infrastructure itself. If assets are programmable, some of the rules governing them also need to be understood and enforced by the systems they move through. 

Institutions should be able to define who can access an asset, what they can do with it, what limits apply and when that authority can be revoked, have the system stop anything that falls outside those limits, and keep a clear record of what happened. 

The principles themselves are already familiar. The next step for Europe is translating them into rules that can actually travel with assets and work inside programmable markets.

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