���������

DORA compliance is now live. Find out how ��������� can help you optimise your compliance processes:��DORA Compliance Software: What to Look For and Why It Matters

The near-simultaneous entries into force of the Markets in Crypto-Assets Regulation (MiCA) on December 30, 2024 and the Digital Operational Resilience Act (DORA) on January 17, 2025 created significant compliance pressures across the industry, with regulatory activity spiking across Europe. This regulatory convergence offers critical insights for payment service providers (PSPs) and financial institutions preparing for the next wave of major EU relevant legislation; in particular, the Payment Services Directive 3 (PSD3) and Payment Services Regulation (PSR), which are currently advancing through trilogue negotiations.

As ���ĺ�������’s Horizon Scanning data reveals, regulatory activity intensified dramatically in the lead up to the entry into force of MiCA and DORA, coupled with sustained high activity levels post-implementation, which demonstrates that EU financial regulation operates in waves of concentrated impact rather than steady streams.

For companies already managing ongoing deadlines across the globe, understanding these patterns is crucial for resource allocation, system preparation and strategic planning for major EU legislation coming down the line, in particular PSD3/PSR, which are on the horizon.��

The Bigger Picture

Regulatory updates related to MiCA and DORA from Aug 2024 to Aug 2025

‍

Over the preceding 12 months, the number of regulatory updates published on ��������� PC Horizon Scanning regarding MiCA and DORA peaked in December 2024, as MiCA came into effect on December 30, 2024, with DORA following shortly after on January 17, 2025.

In the four months leading up to the implementation dates, the total number of updates rose from 12 to 71, a nearly fivefold increase, with actionable updates increasing from 1 to 22, which are updates that indicate a regulatory change is taking place and action needs to be taken. Even after the implementation dates passed, regulatory updates remained high for the three months following as member states scrambled to make the necessary changes to comply. Although this wave died back as the significant deadlines passed, it is indicative of the kind of spike that can be expected around the entry into force of new EU legislation, especially when more than one is coming at the same time.

European regulatory landscape - Aug 2024 to Aug 2025

‍

Then it must be remembered that regulatory developments at both the EU and jurisdictional levels continued in parallel. Preparation for MiCA and DORA had to be managed alongside other regulatory demands, adding extra pressure on regulatory and compliance teams. Although the implementation of MiCA and DORA clearly drove a surge in updates in the lead-up to their effective dates, the broader European regulatory landscape remained consistently demanding. Each month more than 100 updates were released in Q3 2024, and at least half of these each month were actionable or indicative (which means consideration needed to be taken as action could be coming). DORA and MiCA updates made up just under half of the actionable updates in December, meaning there was still a lot of activity occurring across the region at the time of year where typically demand tapers off, as seen in the previous two years.

Why should you care?

The data highlights how regulatory impact and the amount of relevant regulatory updates being released increase leading up to and following the implementation of major EU legislation for a sustained period of time, particularly when there are more than one concurrently.

This would suggest that around the as-yet-to-be-defined implementation of the next big piece of EU legislation in the payments industry, PSD3/PSR, that the industry could expect to see up to as much as a fivefold increase in regulatory activity for a significant amount of time. MiCA and DORA were direct regulations rather than directives, which means there wasn’t the added complexity of transposition at member states, and activity could be even higher with draft laws, consultations and additional guidance or interpretation expected.��

PSPs should, therefore, do what they can to be prepared:

• Keep up to date with the legislative process: being aware as early as possible will mean a company can be in the best position to know what is coming and avoid unexpected hurdles.��
• Ensure resourcing and preparedness: look at resourcing and ensure the right people are ready and prepared to do what they need to do to ensure compliance, while also keeping up with ongoing obligations under existing regulations. This could mean ensuring that systems, policies and technology are ready to act when needed. Building capacity early reduces the risk of costly, last-minute remediation.��
• Conduct a gap analysis: look at how your company is set up to deal with this new legislation, alongside other overlapping or parallel regulation, such as DORA, with operational resilience expected to be a key component of PSD3/PSR. A clear gap analysis provides a roadmap for investment and prioritisation before deadlines hit.��

Next steps

Negotiations on PSD3/PSR are currently underway under the Danish presidency of the Council, with the expectation that the trilogues will be completed by the end of the presidency in December 2025 and a final version of the legislative package agreed upon.

‍

Want to know more?

‍Book a demo so a member of the team can show you how ���ĺ�������'s Horizon Scanning can help your business stay ahead of pressing topics like this, and more.