Abstract
The Intelligence Economy Institute's response to the Eurosystem's Appia public consultation, submitted to the European Central Bank on tokenised financial market infrastructure. It addresses the high-level principles governing Appia, the design of a shared network layer, European strategic autonomy, common standards, the settlement of central bank money across one or several networks, the governance of Eurosystem core services, and the conduct of the Appia investigation — framed around monetary primacy, ontology-driven control, and strategic autonomy, and drawing on TKNFRA's work on the INTERLOCC settlement protocol and euro monetary sovereignty.
Executive summary
This document is the Intelligence Economy Institute's feedback on the Eurosystem's Appia roadmap, submitted to the European Central Bank's public consultation on tokenised financial market infrastructure. The response works through the high-level principles governing Appia, the design of a shared network layer, European strategic autonomy, common standards, the settlement of central bank money across one or several networks, the governance of Eurosystem core services, and the conduct of the Appia investigation.
The strategic framing rests on three ideas:
- Monetary primacy at the architecture level, not only in policy. In a tokenised environment the decisive question is whether central bank money remains operationally central in settlement, collateral and liquidity routing — not merely legally relevant — given the risk of functional substitution by dollar-linked stablecoins.
- Neutrality of infrastructure rules, not of sovereignty outcomes. A European tokenised ecosystem should stay open to participation and innovation while embedding strategic autonomy as a design objective, rather than being indifferent to dependence on non-European infrastructures, governance centres, or liquidity anchors.
- Interoperability through semantic discipline. Connecting ledgers at the transport level is not enough; assets, obligations, compliance states and settlement-finality conditions must share a machine-readable model — the role of ontology-driven control.
The analysis draws on TKNFRA's work on ontology-driven control and the INTERLOCC settlement protocol, and on a broader reading of euro monetary sovereignty, digital monetary substitution, and euro-native liquidity infrastructure.