What features must your multi-currency super crypto app have to comply with MiCA in 2026?

The regulatory environment in the EU is going to be dramatically different starting from 2026. Just having a great-looking crypto app with super-fast swaps won’t be enough to launch your application in the EU. Under the new regulations of MiCA and DORA, compliance will be integrated into a single "converged environment."
Legal status and technical architecture can no longer be treated separately but must coexist within the same environment. (You can no longer assume that technical security controls, such as KYC and wallet, will provide you with a legal entity under the new regulations.)
To develop your multi-currency super crypto app within the updated legal order, you will face new requirements that include having a physical office (headquarters) located in an EU country (the provision of "cloud-only" corporate structures for CASP is prohibited by regulators) with local employees who are appointed as directors.
Along with having a physical presence in the EU, handling digital assets will necessitate using secure infrastructure like Multi-Party Computation (MPC)-based wallets to provide proof of segregated custody of digital currency and user assets.
The integration of stablecoins introduces additional complexity. Your architecture must separate systems for E-Money Tokens (EMTs) from Asset-Referenced Tokens (ARTs). Non-Euro ARTs will be subjected to strict daily transaction limits.
In tandem with this, cyber resilience is at the forefront of DORA. An organization should be prepared to undertake advanced threat-led penetration testing to prove its system is capable of surviving a data breach without crashing.