MiCA Year One: Fintech Infrastructure Gaps

MiCA Year One Impact on Fintech Crypto-Banking Products

FinHarbor reports surging demand for unified fiat-crypto financial products as companies built on parallel-system architectures struggle to meet regulatory and market requirements

February 18, 2026 – As the first full year of MiCA Year One enforcement draws to a close in Europe, a widening gap has emerged between what customers demand and what most fintech infrastructures can deliver. FinHarbor, a unified banking and crypto infrastructure provider, reports that the market has shifted decisively: companies no longer seek standalone crypto services – they need full-spectrum financial products with crypto built in, not bolted on.

The transition from MiCA's CASP provisions taking effect on December 30, 2024 through the ongoing grandfathering periods extending to July 2026 has forced a reckoning. Companies that built fiat and crypto as two separate systems now face serious infrastructure challenges in meeting compliance requirements while delivering the seamless hybrid products their users expect.

Three Hybrid Products Driving the Strongest Demand

FinHarbor identifies three product types at the center of this shift – all sharing a common principle: the user should never need to know where banking ends and crypto begins.

Unified multi-currency accounts represent the most fundamental change: a single interface where fiat and crypto are simply different asset types. EUR and BTC balances are managed within one user experience, giving customers a seamless neobank interaction—while the underlying infrastructure maintains full regulatory segregation of fiat and crypto assets as required by MiCA and EU banking regulations. The result feels like one account, but architecturally preserves the compliance boundaries that regulators demand.

Zero-balance cards with auto-conversion have become one of the most requested capabilities in the market. The user pays with Visa or Mastercard; the system selects the optimal asset, converts crypto to fiat in milliseconds, and completes the authorization. Yet the vast majority of the industry still relies on prepaid cards or manual pre-conversion – a fundamentally different and far less capable product.

Native on/off-ramp functionality with stablecoin savings embeds fiat-to-crypto conversion as naturally as a transfer between accounts, with unified KYC. Users hold balances in USDC or USDT for instant payments through a familiar banking interface. Outside the EU, yield products on stablecoins are already emerging, though within the EU MiCA explicitly prohibits interest accrual on e-money tokens (Article 45 of Regulation (EU) 2023/1114).

Why Most Architectures Fail

The majority of companies make the same strategic error: they take a banking core, place a crypto module alongside it, and connect the two through APIs. This works as a demo but breaks down in production.

The foundational requirement is a unified ledger – a single balance engine where fiat and crypto are accounted for together. Without it, atomic cross-rail operations such as real-time card payments funded by crypto assets are impossible. Equally critical is a unified compliance layer: one KYC/AML system covering fiat transactions, on-chain transfers, card operations, and OTC trades, producing one risk score per client and one audit trail.

In a hybrid product, a single transaction can touch five systems in 200 milliseconds: blockchain node, FX engine, card processor, AML screening, and ledger. Synchronous API calls between them are a recipe for failure. Event-driven architecture with message queues is the only way to achieve both speed and reliability – particularly for zero-balance cards where Visa and Mastercard require finalization in extremely tight timeframes. The architecture must also abstract payment rails – SEPA, SWIFT, Bitcoin, Ethereum, Tron, and card networks – behind a unified routing interface, so new rails can be added without rewriting the product. Every module should be independently deployable: swapping a KYC provider or custodian must be a configuration change, not a redevelopment project.

“The architectural debt of a 'glued' system manifests as concrete problems: dual balances that drift out of sync, duplicated KYC, two audit trails regulators won't accept. Companies building this way today will be rewriting from scratch within 18 months,” – Ilya Podoynitsyn CEO of FinHarbor notes.

Regulatory Landscape: MiCA as Catalyst

Most jurisdictions still require dual licensing – an EMI or banking license for fiat and a VASP/CASP license for crypto. MiCA has shifted the dynamic in Europe by creating a unified framework that explicitly anticipates interaction with traditional finance. The CASP license under MiCA is not "crypto in a vacuum" – it is part of a regulated financial ecosystem. For well-architected hybrid products, this is an advantage, not a barrier.

"Regulators are not opposed to hybrid products.They are opposed to opacity. A single audit trail, one risk score, one monitoring system across all client operations is what they want to see. They are moving toward a Single Client View across all transaction types," says  Ilya Podoynitsyn CEO of FinHarbor.

The licensing models currently in use range from dual licensing (EMI/bank plus VASP), which remains the most common, to partnership models where a fintech holding one license partners with a holder of the other. Several jurisdictions – including Lithuania, the UAE, and the UK – offer regulatory sandboxes specifically for hybrid models. A few countries are beginning to move toward unified new-type licenses that cover both fiat and crypto within a single product, though this remains rare.

FinHarbor's Approach: Built Unified from Day One

FinHarbor built all components – fiat accounts, crypto wallets, card processing, compliance, and on/off-ramp functionality – as a single platform from the start, with compliance architecture designed around MiCA, FATF guidelines, and EU AML Directives from inception. Clients launching on FinHarbor's infrastructure deliver hybrid financial products without the architectural debt of connecting parallel systems.

“Nearly every team we speak with has built fiat and crypto as two different products and hit a wall trying to scale. The model of 'bank plus crypto' as two separate systems no longer works. We built differently because we saw this convergence coming,” – says Ilya Podoynitsyn, CEO of FinHarbor

About FinHarbor

FinHarbor is a technical platform provider for launching compliant, modular financial products – from wallets and neobanks to crypto ramps and OTC desks. Built on years of real-world fintech experience, the platform covers onboarding, compliance, wallets, transactions, cards, and reporting, delivered with a microservice-based architecture (ISO/PCI DSS-certified), a robust API layer, and on-premise or cloud-ready deployment. FinHarbor supports fiat-only, crypto-native, and hybrid business models across markets in Europe, MENA, and beyond.

Learn more: www.finharbor.com

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