The VI3NNA Declaration for 2026 was published this week. Summarizing the high-level, behind-closed-doors digital asset policy discussions from the inaugural VI3NNA Congress, the document lays out a blueprint for Europe’s regulatory and infrastructure prospects under MiCA.
While the report covers extensive ground across liquidity, taxation, and market structures, two specific recommendations regarding the Travel Rule and KYC/KYB compliance caught our eye. They call for direct feedback from the trenches—and as infrastructure providers navigating these frameworks daily, we have some thoughts.
Recommendation #1: A Single EU Onboarding and Reporting Portal
The Proposal: Build a single EU onboarding and reporting portal. The EU should develop one portal where CASPs perform KYC/AML, submit Travel-Rule data and file DAC8 tax reports, linked to eIDAS 2.0 / EUDI wallets. This is a compliance layer and shared infrastructure — explicitly not a single Level-0 settlement infrastructure “to chain them all,” and not a new regulatory tier. A practitioners’ note applies: a portal spanning KYC/AML, DAC8 reporting and MiCAR authorisation will involve multiple authorities with different mandates — financial supervisors, financial intelligence units and tax administrations. Governance arrangements must therefore assign clear ownership, delineate data-access rights between authorities and include strong data-protection safeguards from the outset. The European Commission, ESMA/EBA and AMLA should jointly design these arrangements as part of the portal’s technical specification, before deployment rather than after.
A Centralized Wolf in Web3 Clothing?
At first glance, this proposal reads like asking for a state-owned compliance vendor. Proposing a government-managed, singular system to handle KYC/AML verification for market participants across the entire Union would be remarkably… centralised. It is certainly not in the bingo card for proposals coming from a dedicated Web3 policy forum.
This setup feels fundamentally antithetical to the core tenets of decentralized architecture, European privacy considerations, and the basic principles of a free-market economy – where the state typically only steps in as a direct service provider within highly strategic domains, or where the market simply fails.
Putting Privacy at the Core: eIDAS 2.0 and EUDI Wallets
However, if you look past the initial shock value, the explicit integration with EUDI wallets (standing for European Union Digital Identity) provides ground for careful optimism.
If this portal’s underlying architecture is predicated on user-managed, privately provided digital identity infrastructure rather than a state-run honey pot of incredibly sensitive payments data, the narrative shifts. Most Payment Service Providers (PSPs) and CASPs haven’t fully understood this yet, but user authentication in Europe is due for a massive overhaul over the next five years via eIDAS 2.0. This is a rare area where decentralisation and the EU’s strict approach to data protection might actually align – provided the Union-wide compliance layer is engineered with privacy-by-design at its core.
A Better Precedent: Look to Traditional Finance
As for using a single pan-European portal exclusively for Travel Rule data exchange? While technically achievable and practically effective, the current global adoption rate of digital currency payments simply does not yet merit dedicating notable resources to a centralised message exchange layer.
Regardless, we should look to a well-functioning precedent already active in traditional European banking. Under SEPA, instant payments execute smoothly across borders utilizing the Verification of Payee (VOP) mandate. This verification is performed against the Directory Service maintained by the European Payments Council (EPC). If Europe eventually requires a unified payment data validation layer as the digital asset market matures, the EPC is already uniquely positioned to absorb and execute this function.
Recommendation #2: Mandating a Common Standard for Travel Rule Interoperability
The Proposal: Travel-Rule messages today go unanswered because neither providers nor their regulators require interoperability across networks. The EU should mandate common data-exchange standards (e.g. TRISA, IVMS 101) so transfers can be individually identified across providers; the cross-border payments use case is the real opportunity being lost.
The Reality: It’s Not a Tech Problem, It’s a Trust Problem
While this recommendation is far less controversial than a centralized onboarding hub, it is also unfortunately far less effectual.
The data exchange bottlenecks occurring between various Travel Rule providers today are not stuck behind a missing technical standard or an uninvented protocol. The industry already possesses the necessary standards. The real friction comes down to a basic lack of management will.
At CryptoSwift, we have always maintained an open ecosystem stance regarding interoperability. Our orchestration layer routinely integrates with peer compliance systems running on different protocols. These connections don’t happen when a data exchange standard is decreed; they happen when two Travel Rule service providers decide to build the bridge.
When will the rest of the industry follow suit? When supervisors and national regulators actively step up the enforcement of the Travel Rule across the board. They just haven’t gotten around to it yet.
The Path Forward
We owe a round of applause to Oliver Schmitt and his team at the VI3NNA Congress for facilitating these critical, high-stakes policy debates. Shaping European regulations that simultaneously protect users while fostering a thriving digital asset ecosystem is an incredibly delicate balancing act, and bringing these discussions into the open is exactly what market participants need.