The Crowd Goes Global: Inside the Push to Fix Equity Crowdfunding's Fragmentation Problem

Equity crowdfunding is already crossing borders. The rules aren’t keeping up – and a new alliance of industry veterans thinks that has to change.

From 49 countries on Zoom to one shared problem

When the Global Equity Crowdfunding Alliance (GECA) convened a joint webinar with Crowdfund Insider and the European Digital Finance Association (EDFA), 49 countries dialed in to talk about a single, stubborn challenge: how to turn today’s patchwork of national rules into a genuinely connected global ecosystem for crowdfunding.​

As GECA steering committee lead Andy Field put it, crowdfunding is already global in practice – investors and platforms are operating across borders every day – but still fragmented in regulation, infrastructure and coordination.​

The consequences are concrete:

• Founders who want to raise across borders face multiple regulatory systems, overlapping compliance regimes and incompatible technology standards.​
• Investors struggle to access deals outside their home market.​
• Platforms duplicate costs, and offers that should be global remain stubbornly local – just when capital is urgently needed for SMEs, climate projects, infrastructure and innovation.​

GECA’s answer is deliberately modest and ambitious at the same time: not a lobbying machine for one preferred regime, but a neutral, industry‑led network that brings together platforms, investors, founders, industry associations, regulators, policymakers and tech providers to create practical pathways for cross‑border collaboration.​

This webinar -anchored by moderator Andrew Dix of Crowdfund Insider with contributions from US securities lawyer Robin Sosnow, German policy veteran Karsten Wenzlaff, UK pioneer Bruce Davis, and a second‑half line‑up featuring Konstantin Boyko, Neera Patel, Sherwood “Woodie” Neiss and Benoit Collas – was a high‑level tour of where those pathways might emerge.​

The US: Jobs Act 2.0 and a market “almost there”

To understand where online capital formation is going, the panelists began by looking back. In the United States, Robin Sosnow traced the evolution from the 2012 JOBS Act to today’s mix of exemptions that underpin investment crowdfunding.​

Regulation D was first to change, allowing general solicitation in 2013 and effectively legitimizing online private placements to accredited investors. Regulation A followed in 2015, re‑emerging as “Reg A+” with the ability to raise from retail investors under a two‑tier system that now allows up to 75 million dollars under Tier 2 – a structure increasingly attractive to later‑stage private companies eyeing alternatives to a traditional IPO.​

Then came Regulation Crowdfunding (Reg CF) in 2016, which legalized retail investment crowdfunding but initially capped offerings at 1 million dollars per 12‑month period. The cost of legal, portal and accounting work made that cap hard to justify, and early adoption was modest.​

The real inflection point arrived with 2021 rule changes:

• The Reg CF limit rose to 5 million dollars.​
• “Testing the waters” became permissible.​
• Crowdfunding vehicles (SPVs) were allowed, solving the “messy cap table” concern by pooling investors into a single LLC on the issuer’s cap table.​

Since then, the various JOBS Act exemptions have started to function as a coherent capital stack for private companies, rather than disconnected experiments.​

The SEC continues to refine the rules at a more granular level. Recent compliance and disclosure interpretations clarified, for example, that Reg CF investor limits for retail investors are calculated on a calendar‑year basis, even though issuer offering caps are measured on a rolling 12‑month period. On the Reg A side, the Commission has confirmed that issuers can file draft offering statements confidentially, shielding their initial disclosures and SEC comment correspondence from competitors until they choose to go public.​

Legislatively, the Invest Act currently before the US Senate would raise the threshold at which very small Reg CF issuers must provide reviewed financial statements – moving it from around 100,000 dollars to 250,000 dollars, with scope to increase that to 400,000 dollars over time. That change, Robin argued, will matter for true micro‑offers, even if a deeper fix would also relax the requirement for GAAP‑based financials at the very bottom of the market.​

The more controversial frontier is the accredited investor definition. The policy conversation is shifting from purely wealth‑based criteria toward some form of knowledge‑based certification – potentially unlocking a broader pool of sophisticated investors without lowering standards.​

Through all of this, Dix framed a simple success condition: three stakeholders must win, or the system fails. Platforms must be profitable; issuers must raise the capital they need; investors must see a reasonable path to returns. Technology, he argued, is finally bringing that goal into view – if regulation can keep up.​

Europe: ECSPR’s promise – and a 5 vs 12 million problem

On the other side of the Atlantic, Europe has spent the past decade wrestling with its own fragmentation. When early drafts of the European Crowdfunding Service Providers Regulation (ECSPR) were written ten years ago, some EU member states did not even permit online securities offerings. Others had bespoke frameworks, but cross‑border operations remained painfully complex.​

ECSPR was designed to change that by harmonizing how platforms are licensed, what they may offer, and how they must report. Under the framework:​

• Platforms can intermediate transferable securities (mainly shares) and loans.​
• Issuers can raise up to 5 million euros per year across all platforms, EU‑wide.​
• Instead of hard investor caps, platforms must segment investors as “sophisticated” or “non‑sophisticated” and apply knowledge and appropriateness tests for the latter – an approach borrowed in spirit from the UK.​
• Issuers must provide a six‑page Key Investment Information Sheet (KIIS), the EU’s surprisingly user‑friendly “KIIS” document, which serves as a standardized disclosure across member states.​

In theory, ECSPR created a unified passport for platforms and issuers. In practice, Karsten Wenzlaff noted, fragmentation lingers in subtler ways:

• National regulators interpret and apply the rules differently.​
• Investors still display a strong “home bias” -Spanish investors prefer Spanish platforms and SMEs, even though they could easily back Slovak or German deals.​

The most striking anomaly is the fundraising cap. Under separate prospectus rules, a company can raise up to 12 million euros from the public on its own site without a full prospectus, as long as it stays within the EU Listing Act thresholds and structures the offer correctly. The moment it uses a regulated crowdfunding platform, however, it is constrained to 5 million euros in aggregate across all platforms.​

That inversion – platforms being more constrained than direct offerings – cuts against the original policy intent of using regulated platforms to channel capital to SMEs and scale‑ups. It also feels increasingly out of step with the capital requirements of modern sectors, from AI to deep tech.​

An ECSPR working group led by platforms and associations has already published an 80‑page evaluation report, and the European Commission is formally required under Article 45 of ECSPR to review the regime this year. Wenzlaff and his peers are pushing to align the crowdfunding cap with the 12‑million‑euro threshold used elsewhere in EU capital markets legislation, with an expectation that inflation and market development may eventually push that number higher.​

Secondary markets are another fault line. Today, ECSPR platforms can host bulletin boards, but cannot operate true order‑matching marketplaces. That leaves issuers and investors with limited liquidity and constrains the ability of crowdfunding to feed into a broader private‑markets stack.​

Tokenization could, in theory, help. Wenzlaff sees three immediate use cases:

• Dynamically splitting and routing fees when multiple platforms syndicate a deal, recognizing the additional work done by the “originating” platform.​
• Enabling compliance checks and investment limits to be enforced on‑chain, without platforms having to share raw investor data with competitors.​
• Providing a decentralized, tamper‑resistant channel for post‑investment reporting, ensuring that all investors receive the same information at the same time, regardless of which platform they used.​

But as Benoit Collas of impact‑focused EU platform Enerfip emphasized, none of this is painless. Even within ECSPR, he recounted, a recent cross‑border “deal sharing” arrangement between his platform and a neighbor depended on quirks in the other platform’s national license that allowed them to invest via a specific vehicle; when they tried to replicate that structure elsewhere, regulators simply said no.​

Compliance, in other words, is both bridge and wall: essential for trust and investor protection, but frequently the reason why a promising model works once and then stops.​

The UK: from crowdfunding pioneer to private‑markets testbed

If the US is iterating through Congress and SEC guidance, and the EU is rationalizing 27 national regimes, the UK sits in an interesting third position: a mature crowdfunding market now being wired into a broader private‑capital strategy.

Bruce Davis – co‑founder of Abundance Investment and long‑time head of the UK Crowdfunding Association – reminded the audience that the UK’s regulatory framework has always existed on top of its own securities and markets legislation, and that differences at that base layer now translate into divergent crowdfunding models.​

On the equity and bond side, platforms are regulated to “arrange deals” and promote them to the public, with explicit responsibilities for segmenting customers and assessing whether an investment is appropriate. Peer‑to‑peer loans sit under a separate regime, where it is the activity rather than the instrument that is regulated, reflecting the fact that P2P emerged before regulation caught up.​

Over the last seven years, Davis argued, the UK has shifted away from principles‑based regulation toward product regulation. That shift means supervisors now spend much of their time debating business models with platforms – defining the shape of the product, not just the standards it must meet.​

The upside is that crowdfunding is now seen as part of a broader push to “mobilize private capital,” not an oddity on the fringe. New rules for Public Offer Platforms (POPs) and Private Intermittent Securities and Capital Exchange Systems (Pisces) effectively create a continuum:​

• Traditional crowdfunding rules apply up to 5 million pounds.​
• Above that, POPs enable unlimited offers to the public in the private markets, blurring the line between private and public issuance.​
• Pisces provides a framework for intermittent secondary transactions in private company shares – initially conceived as a solution for VC portfolio liquidity, but now opening cautiously to retail.​

This architecture makes it easier to imagine a company raising growth capital from the crowd and then offering episodic liquidity events without a full listing, all within one coherent regulatory perimeter.​

Secondary markets remain constrained, however. Like their EU counterparts, UK platforms typically operate bulletin boards rather than fully regulated multilateral trading facilities (MTFs). The concern, Davis said, is that importing the full machinery of listed‑market regulation into the crowdfunding context would be prohibitively expensive and inappropriate for smaller tickets.​

A more immediate brake on growth is marketing friction. After successive rounds of rule‑tightening, UK platforms now face complex appropriateness assessments and near‑perfect pass‑rate expectations for retail investors, driving up acquisition costs and pushing many players to cut back on marketing. The FCA has launched a discussion paper to review whether those frictions have overshot, opening the door to potential recalibration.​

On tokenization, the UK has taken a conservative line: if you tokenize an investment asset, you are still carrying on regulated activity; tokenization does not grant you a different regime. That makes tokenization a technology upgrade rather than a regulatory arbitrage – its value must come from efficiency and better user experience, not lighter rules.​

Where the UK really stands out is in tax. The Enterprise Investment Scheme (EIS) and Seed EIS (SEIS) provide generous income‑tax relief on investments into qualifying high‑risk companies (around 30 percent for EIS and 50 percent for SEIS), plus loss relief in certain cases. The Innovative Finance ISA (IFISA) allows investors to hold peer‑to‑peer loans and other qualifying instruments in a tax‑advantaged wrapper, with up to 20,000 pounds in new contributions each year and no tax on income or gains within the envelope.​

Davis called these schemes “the one thing we got right” and vowed that the industry would “defend IFISA till we die,” arguing that they have been a key driver of capital into early‑stage and growth companies and a necessary leveler against the attractions of listed markets and pensions.​

Karsten Wenzlaff, for his part, sees EIS/SEIS as a model Europe should take seriously – not just as a way to boost crowdfunding volumes, but as a bridge that turns retail investors into tomorrow’s angel investors. The political challenge is that taxation remains a national competence within the EU, and Brussels has historically preferred EU‑wide guarantee schemes over pan‑European tax incentives. That may be shifting as member states hunt for ways to mobilize private capital for energy transition, defense and health, but any UK‑style regime would require both technical and political alignment.​

Tokenization, AI and shared infrastructure: tools, not silver bullets

If the first half of the webinar mapped the regulatory terrain, the second half turned to tools: tokenization, AI and shared infrastructure.

Andrew Dix and Sherwood “Woodie” Neiss – author of Investomers and policy expert, were clear that tokenization is no longer hypothetical. US platforms like Republic have already used tokenized securities; firms like Securitize began as enablers and have evolved into marketplaces, and institutions such as Figure have built tokenization stacks from the institutional side. The New York Stock Exchange has announced a tokenized securities exchange, signaling that mainstream market infrastructure is moving in this direction as well.​

For Dix, the promise is straightforward: remove intrinsic frictions, reduce costs, improve security, portability and compliance, and enable new categories of assets to reach investors. In today’s analog private markets, humans push paper through fragmented systems. Tokenization and digital market infrastructure could automate large parts of that process, especially when combined with AI.​

Yet, as platform builder Konstantin Boyko stressed, technology is the easy part. The harder problems begin when you connect code to real‑world money flows, KYC, payment providers, and multiple jurisdictions. Picking a single payment provider is hard enough in one country; building a stack that gracefully spans regions is far harder.​

AI, he argued, could dramatically reduce the burden of drafting and standardizing disclosure documents such as ECSPR’s Key Investment Information Sheet, where lawyers today reinvent the wheel in their own style. That view was echoed across the panel: AI can sit in the background, generating structured, regulator‑aligned templates and freeing human experts to focus on judgment rather than formatting.​

Neiss sees an even broader role. The current US disclosure system is “written by lawyers for lawyers,” he said, and is increasingly unusable for the very retail investors it is supposed to protect. AI could help regulators and platforms converge on shorter, more intelligible, yet still compliant disclosures that meet investors where they are and accommodate cross‑border offerings.​

On shared infrastructure, Dacxi Chain’s Chief Product Officer Neera Patel sketched a future in which neutral networks and common rails underpin syndicated deals across platforms and borders.​

She highlighted three layers:

• Operational efficiency: Issuers launch a deal onto a network and have AI‑infused compliance engines run jurisdiction‑specific checks in parallel, drastically reducing manual legal duplication and accelerating time‑to‑market.​
• Investor experience: A shared, verifiable KYC/identity layer -likely based on verifiable credentials – would allow investors to onboard once and then invest across multiple platforms with minimal friction, reducing drop‑off rates and cutting KYC costs.​
• Transparency and auditability: Blockchain infrastructure provides an immutable record of allocations, payments, disputes and withdrawals, making it easier for platforms and regulators to monitor the life of a deal – especially when it is syndicated across borders.​

Patel was pragmatic about the obstacles. Tax, business‑model economics (e.g., fee split mechanics between platforms), and differing local rules still need human and political negotiation. But those are precisely the topics she believes alliances like GECA should own – creating standards and norms that technology can then codify.​

Secondary markets and the search for real liquidity

If there was one theme that united all jurisdictions, it was the sense that primary issuance is only half the story. Without functioning secondary markets, equity crowdfunding will struggle to fulfill its promise.

In the US, the problem is structural. Primary issuance under Reg CF and Reg A is governed at the federal level. Secondary trading, however, falls under state “blue sky” laws, splintering the market into 50 different regimes.​

Neiss pointed to the “manual exemption” as one partial workaround: issuers who publish standardized information into a national securities manual – an “Edgar‑lite” – can qualify for exemptions in many states. But the complexity of those rules, and the lack of investor demand for smaller names, have constrained activity. Most meaningful secondary trading in the US still takes place in the Reg D space, on venues like Nasdaq Private Market, Forge and EquityZen, or among larger Reg A+ issuers where investor interest is sufficient to justify the overhead.​

Dix did not mince words on the state of US blue sky law: a “Byzantine mess” sustained by state regulators’ desire to preserve their own empires. He argued for a more federalized approach to secondary trading in line with the Clarity Act’s broader effort to update market infrastructure, while acknowledging that current US proposals focus more on digital commodities than tokenized securities.​

In the UK, Pisces is an early attempt to square that circle by allowing controlled, episodic liquidity events without the full weight of listing rules. Davis framed the debate in lifecycle terms: different investors want or need to exit at different points, and the system should be able to recycle capital efficiently rather than locking it up until an IPO that may never come.​

In Europe, stock exchanges are among the fiercest opponents of any move that might erode their monopoly on secondary trading, and that political reality helps explain ECSPR’s conservative stance on matching engines. But Wenzlaff was blunt: if Europe is serious about financing the green and digital transitions, it will need mechanisms that allow capital from the global north to flow into renewable infrastructure projects in Latin America, Africa and parts of Asia, with credible liquidity options along the way.​

Here again, the idea of a shared, decentralized protocol surfaced -not to replace local rules, but to provide a common technical substrate onto which different regulatory wrappers could be mapped.​

Why this matters now

The stakes behind this dense, acronym‑heavy conversation are high. For all the technical debate about thresholds, investor tests and SPVs, the through‑line was clear: the world needs more ways for ordinary and professional investors to fund the companies and projects that will shape the next decade – and those channels need to work across borders.​

The building blocks are already visible:

• US exemptions that now support meaningful retail participation and are edging toward more inclusive definitions of sophistication.​
• A pan‑European license that, once re‑tuned, could allow SMEs to raise up to 12 million euros in a single, cross‑border campaign.​
• A UK ecosystem that has quietly invented a tax and regulatory stack for high‑risk private capital, and is now experimenting with POPs and Pisces as bridges into the listed world.​
• Tokenization and AI tools that can take friction, cost and opacity out of compliance and operations, rather than adding new layers of hype.​

What is missing is coordination – and that, ultimately, is where GECA, EDFA and their partners come in.

As Andy Field closed, the webinar was not intended as an endpoint, but as a starting block. The next step is bringing these conversations into the room: regulators, platforms, academics and technologists meeting face‑to‑face in Malaga this April to move from diagnosis to design.​

Dix’s final message was simple and, in its own way, optimistic: the direction of travel is right, even if the pace is frustrating. Progress will depend on exactly the kind of cross‑jurisdictional, cross‑disciplinary dialogue this webinar represented – because in a world where capital, talent and technology are already global, leaving crowdfunding trapped in national silos is no longer a tenable option.​

Watch the full webinar here: https://www.youtube.com/watch?v=JhvKrySbAr8

GECA: Frequently Asked Questions

What is GECA?
The Global Equity Crowdfunding Alliance (GECA) is a neutral, industry‑led network that brings together platforms, investors, founders, industry associations, regulators, policymakers and technology providers focused on investment crowdfunding.​

Why was GECA created?
GECA was formed because crowdfunding is already global in practice, but fragmented in regulation, infrastructure and coordination, which slows growth and limits cross‑border capital flows.​

What problem is GECA trying to solve?
Today, a business that wants to raise capital across borders faces multiple regulatory systems, overlapping compliance regimes and different technology standards, while investors struggle to access opportunities outside their home market.​

Is GECA a lobbying organization?
No. GECA’s mission is not to promote one regulatory regime over another but to act as a neutral convening layer that fosters dialogue, alignment and practical pathways for cross‑border collaboration.​

Who participates in GECA activities?
Participants include crowdfunding platforms, SME and startup founders, retail and professional investors, national and regional industry bodies, regulators, policymakers and technology providers building market infrastructure.​

What is GECA doing in practice, beyond webinars?
GECA is publishing primary‑research‑based white papers, convening working groups with partners like EDFA, and co‑hosting in‑person events such as the April meetings in Malaga to drive regulatory and technical alignment.​

How does GECA view emerging tech like tokenization and AI?
GECA sees tokenization and AI as tools to reduce cost and friction in compliance, reporting and cross‑border syndication – not as regulatory shortcuts – and is encouraging shared standards and infrastructure in these areas.​

How can I engage with GECA next?
GECA and EDFA are inviting platforms, associations and regulators to the in‑person sessions in Malaga (8–10 April) to continue these conversations through workshops on UX, secondary markets, tokenization and collaboration with academic researchers.​    

Full Details https://www.crowdfunding-research.org/icafr2026

Register https://www.crowdfunding-research.org/pago 

GECA Membership & Participation

Who can join GECA?

GECA welcomes equity crowdfunding platforms, national and regional crowdfunding associations, regulators and policymakers, technology providers, investor associations, researchers and academics.

How do I join GECA?

Visit https://thegeca.org/join to become a GECA member or supporter organization.

What are the benefits of joining GECA?

GECA members gain:

• Access to cross-border dialogue and coordination forums
• Participation in working groups on standards, secondary markets, disclosure templates
• Networking with platforms, regulators, and technology providers globally
• Early access to research, whitepapers, and policy recommendations
• Invitations to GECA events (webinars, workshops, conferences)
• Influence on the development of global crowdfunding infrastructure