DORA, MiCA & the Infrastructure Pivot
DORA, MiCA & the Compliance Moat
The most significant structural shift in European fintech is the move from consumer-facing applications to infrastructure. Companies like Adyen, Stripe (with its expanding European footprint), and emerging players in banking-as-a-service are building the plumbing that non-financial companies use to embed financial services into their products.
B2B payments represent the largest underdigitised opportunity. While consumer payments have been transformed by real-time rails and mobile wallets, business-to-business cross-border payments remain slow, expensive, and opaque. European infrastructure players, operating within the SEPA framework and evolving ISO 20022 messaging standards, are well-positioned to capture this value.
From Consumer Neobanks to Infrastructure Champions
| Company | HQ | Category | Differentiation |
|---|---|---|---|
| Adyen | Netherlands | Payments platform | Unified commerce, enterprise-grade |
| Klarna | Sweden | Consumer payments | BNPL pivot to full banking |
| Revolut | UK | Neobank | 45M+ customers, UK banking licence |
| SumUp | UK/Germany | SME payments | Point-of-sale, merchant acquiring |
| Banking Circle | Luxembourg | BaaS infrastructure | Payments bank for fintechs |
| Mambu | Germany | Core banking SaaS | Cloud-native banking platform |
| Thought Machine | UK | Core banking | Vault, next-gen ledger technology |
The ECB's digital euro project could reshape retail payments infrastructure across the eurozone, creating both opportunities and threats for existing fintech rails.
The successor to PSD2 will expand open banking mandates and could extend open finance to insurance, pensions, and investment products.
First enforcement actions under DORA in 2026 will set precedents for ICT risk management requirements and third-party oversight.