
Why a bank takes a year to adopt an onchain product
Brian Butler, Polygon Labs
Moment at 25:55Episode 4 · TradFi Goes Onchain: Who's Building the New Financial System?
Digital asset infrastructure for banks is the engineering layer between a bank's existing channel and the regulated crypto rails it rents: in-app trading and custody under a MiCA Article 60 notification, staking with per-customer reward records, credit against pledged crypto marked continuously, and euro stablecoin balances distributed from a licensed issuer, delivered inside the bank's own governance.

Reviewed by Diego Torres, Offer Owner at ProtofireLast reviewed: October 2026
Under MiCA, a credit institution can provide crypto-asset services on the authorisation it already holds: Article 60 gives banks a notification path, 40 working days, with a completeness check rather than a merits approval. So for most banks the licensing question is settled, and what remains is engineering.
Digital asset infrastructure for banks is the layer between the channel a bank already runs (its app, its core ledger, its controls) and the crypto rails it rents (custody technology, execution venues, validator operators). In practice it means order and position records reconciled per customer, key governance a risk committee approves, per-customer staking reward records, and compliance wiring that produces its own evidence.
Protofire builds that layer. We are an engineering firm with 250+ projects shipped since 2016 across 60+ networks and 95+ protocols, and the custody, attestation, and on-chain operations underneath a bank-grade product are systems we have built and operated in production.
The bank's channel and authorisation sit on top, rented rails below, and the engineered layer between them is where the product lives.
We build for four bank profiles. A retail or universal bank adding spot crypto trading and custody inside the app its customers already log into, on the banking authorisation it already holds. A central institution or group IT provider serving a network of legally independent member banks, building the capability once and activating it bank by bank.
A private bank or broker extending crypto custody it operates today with staking and Lombard-style credit against pledged crypto. And a bank that needs euro stablecoin balances in its product, distributed from a licensed issuer rather than issued in-house. The common thread is that the authorisation, the customer relationship, and the channel already exist; the digital-asset layer has to be engineered into them.
Brokers that operate under a CASP authorisation rather than a banking licence are covered on the CASPs and crypto exchanges page.
Less than most bank boards assume, and the details are specific. For trading and custody, MiCA Article 60 lets a credit institution notify its regulator at least 40 working days before providing crypto-asset services; the authority checks within 20 working days that the notification is complete (Article 60(8)), and the text sets no approval decision, though ESMA Q&A 2088 says the notification must still fit national banking rules.
Staking is not a listed crypto-asset service, but a Commission answer published by ESMA as Q&A 2067 (20 June 2024) treats staking-as-a-service as ancillary to custody, so custody obligations follow it, and Article 75(8) keeps the institution liable for client crypto-asset losses attributable to it. The lending itself sits outside MiCA scope as the rules stand in 2026 (Recital 94); MiCA gives no passport for it, so the loan runs on the bank's existing credit permissions under each country's credit and consumer-protection rules.
And a euro e-money token can be put in the product by contracting a licensed issuer, though distributing and custodying a third-party EMT is itself a crypto-asset service, and Article 50 bars passing any holding-linked yield to the client. On top of all of it sit DORA and the recast Transfer of Funds Regulation.
The regulation decides which products may exist. What it does not supply is the operational half: consent flows, per-customer records, segregation, and evidence.
We build the engineered layer, and we operate it after launch. For in-app crypto trading and custody, crypto-as-a-service integration connects the rail a bank chooses, or its own custody stack, to the app and the core banking system.
Where a bank's counterparties settle on Canton, Canton Network development covers the Daml applications, validator nodes and links to EVM chains. Where a bank needs transactions hidden from the public but open to its supervisor, our onchain privacy guide compares who holds the disclosure key on Canton, private ledgers, FHE tokens and shielded pools.
For custody, Safe multisig deployment and Fireblocks integration put key governance under policies a risk committee approves; we deployed Safe on 120+ EVM networks, where it secures $2B+. For the compliance chain, compliance integration wires KYC, screening, and Travel Rule data flows into the bank's existing stack.
For staking, we run validator infrastructure and build the per-customer reward attribution the rented stack does not produce: operators report per validator, while the bank's statements and tax reporting need rewards attributed per customer in its own core. For credit against crypto collateral, white-label lending provides the collateral marking and liquidation machinery on a hardened base. Proof-of-reserve infrastructure publishes reserve balances continuously, oracle integration prices collateral on manipulation-resistant feeds, and managed on-chain operations keeps the whole stack watched 24/7.
For the bank's own money on chain, a tokenized deposits platform issues a deposit token that is minted and burned against the core ledger. Before any of it faces customers, smart-contract audit hardens what will hold client assets.
Our blueprint library documents digital-asset architectures already running at regulated institutions: the regime that permits each one, named institutions operating it, and which layers a bank owns, rents, or has us build. Six are drawn for banks:
Add spot crypto trading and custody inside your existing app, on the authorisation you already hold.
Build crypto trading once centrally, then switch it on bank by bank across your network.
Add staking on top of the custody you already run, with a per-customer reward record built in.
Lend fiat or stablecoins against pledged crypto, marked and margined continuously.
Add a euro stablecoin to your product on a licensed issuer's rails, with no issuance licence of your own.
Answer defined on-chain threats in seconds from a pre-agreed matrix, bounded by limits you set.
Protofire is an engineering-led blockchain firm with 250+ projects shipped since 2016, across 60+ networks and 95+ protocols, with zero vulnerabilities across delivered projects. We deployed Safe, the audited multisig custody and key-governance layer a risk committee signs off, on 120+ EVM networks, where it secures $2B+.
We are a core contributor to Chainlink and built and operated enterprise-scale proof-of-reserve infrastructure covering billions in reserves on-chain, the reserve-assurance layer an auditor stands behind. We built the DEX core and subgraph for Swarm Markets, a BaFin-licensed DEX at launch where only KYC-verified wallets can trade tokenized real-world assets, so engineering for a regulated, KYC-gated venue is work we have shipped, and we maintain Solhint, the Solidity linter used by over a million developers.
The custody half and the evidence half of a bank's digital-asset stack are both systems we have built and operated in production. What DORA asks of each onchain provider a bank contracts with, from custody software and validators to RPC and engineering firms, is set out in our DORA third-party risk guide.
“The bank keeps the customer, the app, and the authorisation; the custody technology, venues, and validators are rented; the layer in between is what has to be engineered: the integration, the per-customer records, and the controls.”
We built and operated real-time proof-of-reserve infrastructure at enterprise scale, covering billions in reserves, the reserve-assurance layer a bank's auditor stands behind.
We deployed audited Safe contracts on 120+ EVM networks as institutional-grade custody, with separated operator and risk roles so no single key can move client assets.
We built the DEX core and subgraph for Swarm Markets, a BaFin-licensed DEX at launch for tokenized real-world assets where only KYC-verified wallets can trade; Swarm holds the license and runs its own KYC and permissioning.

Brian Butler, Polygon Labs
Moment at 25:55Episode 4 · TradFi Goes Onchain: Who's Building the New Financial System?

Rado Patus, Protofire
Moment at 14:25Episode 5 · TradFi Goes Onchain, Part 2: From Pilots to Market Infrastructure
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