Can Europe’s private markets ever be truly pan-European?

The EU has allowed cross-border crowdinvesting since years. In practice, however, the market has barely moved. Today you will learn why that is and what has changed so that it can now be common.

Since November 2021, a crowdinvesting platform licensed in one EU country has had the legal option to offer its investments to investors in any other member state. The European Crowdfunding Service Providers Regulation (ECSPR) replaced a patchwork of national regulations with a single license and passport: once authorized in a country, operating throughout the whole Union is possible.

But ask a retail investor in Madrid, Milan, or Amsterdam today, almost five years later, how many of the offerings on the platform they use emerged from a different country. For most, the honest answer is: none.

The framework, which was intended to create a single European market for private-market investments, has been in place for years, yet the market still behaves like a series of coexisting national markets. The question this article raises is simple: Why is this the case, and is anything suggesting a pan-European private market can become reality?

The gap between what the regulation allows and what the market does

The regulations allow for a great deal of flexibility. Any platform authorized under the ECSPR can offer its services throughout the EU by notifying its home supervisory authority. In practice, however, cross-border distribution is the exception rather than the rule. ESMA’s latest market report, published in December 2025 and covering the year 2024, backs this up with figures.

• As of the end of 2024, 229 authorized providers were listed in the ESMA register.
• Across the EU, 181 active providers raised more than 4.25bn EUR over the course of the year.
• Of this amount, only about 8% was raised across borders, and just 5.8% came from investors in other EU or EEA countries.
• Providers in several member states, including Poland, Portugal, Romania, and Slovakia, raised funds exclusively from domestic investors 

What stands in the way?

The legal possibility to conduct cross-border business is essentially unrestricted, so the obstacles are structural in nature, not regulatory.

For an issuer, distribution involves a series of negotiations. To even reach investors in another country and then convince them to invest, the issuer relies on the market access of a local platform and must meet its requirements for onboarding and reporting. Given the scale of a typical crowdinvesting funding round, the effort involved isn’t worth it across multiple countries. One or two markets might make sense; an entire continent, however, does not.

Cross-border incentives are limited for platforms too. Building a genuine investor base in another country from scratch is time-consuming and costly. Local trust, language, marketing, and payment habits require years of understanding, and a strong domestic market almost always offers a better return on investment than a limited presence in several foreign markets. The result? Issuers and platforms stay local and the single EU capital market remains purely theoretical.

None of this is a shortcoming of the ECSPR. The regulation has removed the legal barriers. What it could not eliminate, however, are the operating costs of cross-border investments. 

What changes with a shared distribution layer

If you put the two challenges side-by-side, you will notice the same underlying problem but from two sides of the coin. An issuer cannot efficiently reach every investors in every country on their own and an investment platform cannot cost-effectively build an audience in every country on their own. 

Viewed this way, the answer to the problem becomes obvious. If a single platform cannot penetrate every country on their own, then the goal is not to send the issuer to each country, but to connect the existing platforms with one another, so that the same project can be financed simultaneously across multiple markets.

That is the idea behind co-listing. A security is issued once on a regulated infrastructure that handles the issuance, custody, and registration of holders. From there, it can be listed simultaneously on multiple platforms in multiple countries. Each platform retains its own investors, its own brand, and its own front end, while the issuance and custody take place behind the scenes. NYALA already offers this model.

The key change concerns the distribution channels. Today, whether an investment opportunity finds investors or not, depends mostly from which country the issuance is launched. With a shared distribution layer, this limitation is removed.

Distribution can take place simultaneously across multiple platforms in different jurisdictions, so that a transaction launched on a platform in one country can simultaneously reach investors on other platforms in other countries without the issuer having to negotiate each market separately. Distribution is no longer dependent on geography but is driven by investor demand.

How this works in practice

Co-listing is not a new idea. Platforms have attempted cross-border distribution before without it taking hold. The difference now is that NYALA has solved several previous challenges by tokenizing the financial security and facilitating sharing investment project data. It would be premature to speak of a long track record of securities traded cross-border in this manner,  what is already in place, however, are the fundamentals.

The cross-border mechanism on which the model is based, has been in use for years: more than 70 cross-border projects and approximately 70m EUR that NYALA has already processed, demonstrate that capital can flow between countries when the system is supported at the operational level (data provided by NYALA).

In practice, a jointly listed capital raising would look like this:

1. An issuer brings a security to the market once.
2. Three platforms, for example, a German, a French and a Spanish, each offer it to their own investors in their own language and under their own brand, on identical terms.
3. Investors subscribe through the platform they already trust and each platform earns a commission fee.
4. The issuer conducts a single capital raise and reaches three investor groups instead of just one.

What will change if this becomes the new standard?

Let’s return to the original question. If cross-border and cross-platform distribution is no longer the exception but the rule, the European crowdinvesting market, with a volume of 4.25bn EUR, will no longer behave like twenty-one national markets, but as a single market.

 An investor in Lisbon discovers attractive offers from Lithuania. An issuer in Tallinn raises capital from four countries without having to negotiate with four investment platforms. The “long tail” of smaller markets, those sixteen EU countries that currently account for less than one-fifth of the total EU volume, gains access to demand that it cannot generate on its own.

This is a bigger change than any single product. It is the evolution into a pan-European capital market and it is the difference between a single market on paper and a single market in practice.

For readers who’d like to explore this further, there are two concrete starting points.

If you operate a platform: The integration is designed to be used independently and can be accessed for free. You can review the API documentation and the integration overview [Link to co-listing page] before speaking with anyone. Once you feel ready to dive deeper, feel free to contact NYALA’s representative Carlos Ficola (c.ficola@nyala.de)

If you’re an investor: Co-listing projects appear on the crowdfunding platforms that offer them, and they will be listed on that platform’s profile in the CrowdSpace directory as they go live.