ByAUJay
In 2026, your dApp’s biggest blocker isn’t code—it’s the crush of new obligations (DAC8/CARF, 1099-DA, MiCA/PSD2 overlap, DORA, FATF Travel Rule) colliding with real-world product flows. This playbook shows how 7Block Labs turns those requirements into modular, testable components that ship on time and protect margin.
“Compliance‑in‑a‑Box”: Modular RegTech Solutions for 2026 dApps
Target audience: Heads of Compliance/MLROs, Tax Ops leads, Payments/Wallet PMs, Enterprise Procurement, and Legal/Regulatory Engineering teams at EU/UK CASPs, U.S. custodial brokers, and fintechs embedding stablecoins. Required RFP keywords to include and validate in discovery: MiCA RTS/ITS, EBA EMT “No‑Action” timeline to 2 Mar 2026, PSD2/PSR-SCA, FATF R.15/R.16 Travel Rule + IVMS101/TRISA/TRP, DAC8/CARF mapping, IRS Form 1099‑DA (gross proceeds 2025; basis 2026), DORA Article 19 “4/24/72” incident reporting, W3C VCDM 2.0, OpenID4VCI 1.0, SD‑JWT VC, EUDI Wallet acceptance.
Hook — The headache you feel this quarter
- Your EU wallet feature ships “send/receive stablecoins,” which immediately triggers PSD2 payment‑service scope for EMT transfers after March 2, 2026, even if you already hold a MiCA CASP license. Expect SCA, fraud reporting, and cumulative prudential requirements across MiCA+PSD2. (eba.europa.eu)
- Your U.S. custodial rails must begin digital‑asset broker reporting on 1099‑DA—gross proceeds from January 1, 2025 and basis on certain transactions from January 1, 2026—plus transitional relief nuances. If your data pipeline can’t compute covered vs noncovered basis and optional stablecoin/NFT aggregation, you’ll miss filing windows. (irs.gov)
- Your EU tax transparency needs DAC8/CARF fields by January 1, 2026: identity capture and transaction reporting to national authorities with cross‑member‑state exchange. Wait on transposition and you’ll still be late. (taxation-customs.ec.europa.eu)
- Your ops team is unprepared for DORA’s incident reporting clock: initial within 4 hours of “major” classification (and no later than 24 hours from awareness), 72‑hour intermediate, 1‑month final—plus oversight on critical ICT third‑party providers. (eba.europa.eu)
- Your AML toolkit must deliver pre‑transaction Travel Rule data with interoperable IVMS101 and counterparty discovery—because jurisdictions accelerating in 2025–2026 leave no room for “sunrise” excuses. (fatf-gafi.org)
- Marketing can’t “just launch”: UK FCA’s crypto promotions “back‑end” rules require appropriateness checks, personalized risk warnings, and a 24‑hour cooling‑off period with tech enforcement patterns—updated February 2026. (fca.org.uk)
Agitate — What missed compliance really costs
- Missed PSD2 by Mar 2, 2026: your EMT “send/receive” flips to read‑only for EEA users; payments partners de‑risk you; pipeline revenue stalls during re‑architecture. Regulators have already signaled the scope and transition end‑date. (eba.europa.eu)
- Late 1099‑DA: costly remediation and payee statements reissue; backup withholding missteps; audit exposures when basis computations are absent or misapplied. The final regulations phase in and expect precision. (irs.gov)
- DAC8 on Jan 1, 2026: if you didn’t capture identity/transaction fields at T0, you can’t reconstruct compliant reports by Q3 2027; penalties follow national law. The clock starts with your 2026 ledger. (taxation-customs.ec.europa.eu)
- DORA violations: failure to meet “4/24/72” deadlines and critical ICT oversight expectations can trigger supervisory actions precisely when you need incident exemptions to keep trading. (eba.europa.eu)
- Travel Rule shortfalls: compliant VASPs increasingly block withdrawals/receipts when counterparties don’t respond or can’t exchange IVMS101 payloads; interoperability is a procurement “must have,” not a roadmap item. (fatf-gafi.org)
Solve — 7Block Labs’ modular “Compliance‑in‑a‑Box” architecture
We ship composable building blocks you can slot into existing services. No vendor lock‑in; we integrate with your KYC/AML stack, custodial providers, and message buses.
- Identity, permissions, and Travel Rule (pre‑transaction)
- Protocols and standards we implement:
- W3C Verifiable Credentials Data Model v2.0 for credential semantics. (w3.org)
- OpenID for Verifiable Credential Issuance 1.0 (Final, Sept 16, 2025) for issuer and wallet flows; support for authorization code and pre‑authorized code issuance. (openid.net)
- SD‑JWT‑based VCs for selective disclosure; predicate proofs for “over 18,” “KYC‑passed,” “accredited investor,” without leaking raw PII. (ietf.org)
- FATF R.15/INR.15 and R.16 (Travel Rule) alignment; jurisdictional best practices from the June 2025 update and “Travel Rule Supervision” guidance. (fatf-gafi.org)
- TRISA/TRP interoperability and IVMS101 schema; counterparty discovery via VASP directories and certificate authorities. (trisa.io)
- Implementation pattern:
- Off‑chain VC issuance from your KYC provider; wallet holds SD‑JWT VC.
- Pre‑tx checks call our Travel Rule broker: resolve beneficiary VASP, exchange IVMS101, and block or allow based on policy.
- Optional on‑chain proof verification for access‑controlled methods (Solidity: EIP‑712 typed verification + succinct ZK proof verifier for minimal gas).
- Business impact: reduce counterparty friction (fewer blocked transfers), cut PII handling liability, and enable reusable KYC across business lines.
Relevant 7Block Labs offerings: smart contract development, cross‑chain solutions development, security audit services, blockchain integration.
- EU payments + stablecoins: MiCA/PSD2 interplay hardening
- Product controls we build:
- Feature gates by residency and token type (EMT vs other assets).
- SCA enforcement on custodial wallets that function as “payment accounts”; fraud telemetry and reporting workflow. (eba.europa.eu)
- PSD2 authorization runway: streamlined dossier reusing MiCA artifacts per EBA “No‑Action” guidance, with go‑live deadline controls for Mar 2, 2026. (eba.europa.eu)
- Non‑scope safe harbors: classify exchange of crypto↔funds or crypto↔crypto (own‑account) out of PSD2 per EBA clarification to avoid over‑compliance. (morganlewis.com)
- Operational guardrails:
- ESMA alignment for non‑MiCA‑compliant ARTs/EMTs; wind‑down/segmentation playbooks. (esma.europa.eu)
Relevant 7Block Labs offerings: blockchain development services, blockchain integration, defi development services.
- U.S. tax reporting: 1099‑DA reference pipeline
- Data contracts:
- Transaction canonicalization with cost‑basis lots; covered vs noncovered handling; optional aggregate reporting for qualifying stablecoins/NFTs where permitted. (irs.gov)
- Transitional relief flags and backup withholding posture per 2025 guidance; broker scoping for custodial platforms, hosted wallets, kiosks, and PDAPs. (irs.gov)
- Tooling:
- Lot‑matching engine library, Form 1099‑DA generator, payee statement service; audit trail views for IR exam readiness.
Relevant 7Block Labs offerings: asset management platform development, custom web3 development services.
- EU tax transparency: DAC8/CARF adapter
- Scope and timing baked in:
- Data capture for EU residents from Jan 1, 2026; reporting to national authorities with cross‑border AEOI; alignment to CARF schema. (taxation-customs.ec.europa.eu)
- Compliance dashboards with “readiness by jurisdiction” and transposition watch (because national rules may finalize late). (nybacs.com)
Relevant 7Block Labs offerings: asset tokenization, token development services.
- DORA operational resilience pack
- What we implement:
- Incident classification rubric wired to Article 19 and the adopted RTS/ITS—automated timers for “4h initial / 72h intermediate / 1‑month final,” and customer notification workflows. (eba.europa.eu)
- Third‑party risk registers and exit plans for cloud, custody, and analytics under the ESAs’ oversight framework for critical ICT providers. (eiopa.europa.eu)
- Evidence retention, playbook drills, and reporting templates synced to your NCA’s portal usage.
Relevant 7Block Labs offerings: security audit services, blockchain integration.
- UK crypto promotions “back‑end” kit
- Technical controls:
- 24‑hour cooling‑off sequencing, client categorization, personalized risk warnings, and appropriateness testing APIs, per FCA findings (updated Feb 6, 2026). (fca.org.uk)
Relevant 7Block Labs offerings: dApp development, web3 development services.
- ZK compliance patterns (production‑ready, not POCs)
- We combine VCDM 2.0 + OpenID4VCI + SD‑JWT VC to deliver:
- zk‑KYC/zk‑KYB predicates (“KYC passed at provider X within 365 days,” “legal entity verified,” “over 18 in EEA”) with unlinkable presentations.
- On‑chain gating: lightweight Solidity verifiers for proof validity; EIP‑712 signed attestations for off‑chain verifications to minimize gas. (w3.org)
- Why now:
- EUDI Wallet adoption targets by 2026 mean relying parties will increasingly accept VC‑based proofs; our adapters make your verifiers “wallet‑ready.” (consilium.europa.eu)
Relevant 7Block Labs offerings: custom blockchain development services, blockchain integration.
Practical examples you can ship this quarter
- EU CASP adding EMT “send/receive”
Goal: launch euro‑denominated EMT transfers without a forced freeze in 2026.
- Architecture quick‑wins:
- Add a “payments‑scope feature flag” driven by token metadata and residency.
- Implement SCA for custodial wallets treated as payment accounts; integrate fraud reporting feeds. (eba.europa.eu)
- Introduce a PSD2 authorization track aligned to EBA’s June 10, 2025 No‑Action letter; reuse MiCA docs and controls; enforce “no later than Mar 2, 2026” cutover. (eba.europa.eu)
- Apply ESMA guidance: restrict non‑MiCA‑compliant stablecoins for EU retail; maintain controlled wind‑down paths (sell‑only/convert‑only). (esma.europa.eu)
- KPIs to track:
- % EU users SCA‑enrolled; fraud‑rate delta post‑SCA; EMT transaction success rate; “scope‑creep blockers” (features that would unintentionally trigger PSD2).
- U.S. custodial dApp preparing 1099‑DA and DAC8 exposure
Goal: be filing‑ready for 2026 (basis) and flip on DAC8 collection for EU users Jan 1, 2026.
- Build steps:
- Normalize trades, transfers, and corporate actions to a single lot ledger; compute basis with covered/noncovered handling; emit 1099‑DA (2025 proceeds; 2026 basis). (irs.gov)
- Introduce EU residency detection + DAC8 identity capture at onboarding; map to CARF fields and stage reporting for 2026 transactions. (taxation-customs.ec.europa.eu)
- KPIs to track:
- Basis coverage %, reconciliation exceptions per 10k trades, on‑time payee statements; DAC8 field completeness rate; CARF schema validation pass %.
Emerging best practices we’re standardizing into the kit
- Travel Rule interoperability ≥95% deliverability by supporting TRISA/TRP and IVMS101, with counterparty discovery via directories and certificate authorities. Fat‑fingering a VASP or sending PII to an unverified host is a reportable event—don’t let it happen. (trisa.io)
- Privacy‑first KYC with SD‑JWT VCs—verifiers see only proofs, not signatures or raw attributes (reduces PII handling risk and cross‑service linkage). (w3.org)
- EUDI Wallet readiness in verifier APIs—accept VC presentations that will become mandatory in many EU contexts by 2026. (consilium.europa.eu)
- DORA “4/24/72” timers as code—pipelines open tickets, pre‑fill RTS/ITS templates, and escalate on weekends/holidays per NCA specifics. (eba.europa.eu)
- MiCA RTS/ITS alignment for business continuity, transparency, and data standards—so audits don’t become rewrites. (esma.europa.eu)
- Sanctions and mixer‑risk overlays—OFAC guidance and FinCEN’s CVC mixing rulemaking inform our pre‑tx screening and risk scoring; we keep these out of your hot path with async policy engines. (ofac.treasury.gov)
Prove — GTM metrics we commit to with your team
We scope success with measurable, regulator‑anchored outcomes:
- Time‑to‑compliance: PSD2 payments‑scope go/no‑go governance live in ≤6 weeks; SCA enrollment ≥85% of eligible EEA users before Mar 2, 2026. (eba.europa.eu)
- Tax‑reporting readiness: 1099‑DA proceeds (2025) + basis (2026) dry‑run with <0.5% reconciliation exceptions across 100k+ trades; payee statement generation SLA with audit trails. (irs.gov)
- DAC8 collection: EU residency detection precision ≥99%; CARF schema validation pass on first run for 2026 dataset. (taxation-customs.ec.europa.eu)
- Travel Rule operations: ≥95% message deliverability to known VASPs; pre‑tx block on non‑responsive counterparties under configurable thresholds. (fatf-gafi.org)
- DORA incident compliance: automated clocks and templates ensuring initial submission within 4 hours of “major” classification and 24 hours of awareness; intermediate at 72h; final within 1 month. (eba.europa.eu)
How we engage (methodology, not marketing)
- Week 1–2: Regulatory gap scan (MiCA RTS/ITS, EBA EMT scope, PSD2 controls, FATF R.15/R.16 status, DAC8 capture, 1099‑DA data lineage, DORA readiness). We align on “must‑ship” clauses tied to exact dates: Jan 1, 2026 (DAC8 capture begins), Mar 2, 2026 (PSD2 EMT transfer scope from EBA No‑Action letter), rolling 2025–2026 for FATF Travel Rule enforcement, and DORA live now. (taxation-customs.ec.europa.eu)
- Week 3–5: Drop‑in modules to your stack (OIDC4VCI issuer, Travel Rule broker, basis engine, DAC8 mapper, DORA reporters).
- Week 6–8: UAT with policy fixtures, regulator‑style evidence packs, and tabletop exercises (incident, promotions approver flows, sanctions/mixer anomaly drills).
Why this is pragmatic for Procurement
- “No platform rewrites.” We connect to your existing KYC, AML TM, custody, CI/CD, and data lakes.
- “Evidence first.” Everything we ship includes mapped controls to RTS/ITS clauses, NCA portal templates, and test artifacts.
- “Standards, not proprietary APIs.” W3C VCDM 2.0, OpenID4VCI 1.0, IVMS101, TRISA/TRP, CARF/DAC8, 1099‑DA schemas. (w3.org)
What to budget and plan for (non‑negotiables in 2026)
- EU: DAC8 user/data capture from Jan 1, 2026; EUDI Wallet support emerging in onboarding; DORA clocks in production; oversight on critical ICT vendors. (taxation-customs.ec.europa.eu)
- UK: Live crypto promotions “back‑end” stack—cooling‑off, risk warnings, appropriateness—monitored and A/B‑tested to minimize conversion loss. (fca.org.uk)
- US: 1099‑DA with basis from Jan 1, 2026; confirm broker scoping (custodial/hosted wallets/kiosks/PDAPs) and apply transitional relief where applicable. (irs.gov)
- Global AML: Travel Rule interoperability and counterparty discovery; mixer‑risk reporting posture. (fatf-gafi.org)
Where to use us first
- Add our Travel Rule broker and VC issuer to cut false blocks and PII sprawl.
- Turn on our 1099‑DA/DAC8 adapters before Q2 data freezes.
- Wire DORA “4/24/72” timers and incident templates into your alerting.
Explore: custom blockchain development services, blockchain integration, security audit services, web3 development services, dApp development.
Final word
If you recognize your stack in the headaches above, it’s because regulators moved from position papers to precise, time‑boxed controls. We translate those into code and evidence you can ship.
Call to action: If you are (a) serving EU users with stablecoin transfers, or (b) a U.S. custodial broker that must file 1099‑DA with basis from January 1, 2026, reply “Compliance‑in‑a‑Box” and book our 50‑minute blueprint review for Thursday, February 12, 2026. We’ll bring a draft architecture for your PSD2/MiCA+DAC8/1099‑DA+DORA posture and leave you with a build plan tied to your next sprint.
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