Digital Operational Resilience in Crypto and Decentralised Finance
Jannik WoxholthDirk Zetzsche
First view: [Sep 2026 Online] Sing JLS 1-30
Several regulators have taken steps to strengthen operational resilience of crypto and Decentralised Finance (“DeFi”) systems. We inquire into the effectiveness of such policy approaches against the background of the EU’s Digital Operational Resilience Act (“DORA”). To further legitimate cybersecurity and national security concerns, DORA relies on a risk management pyramid with financial institutions at the top and ICT service providers below. Using DeFi lending and internationally launched stablecoins as examples, we show that both centralised crypto and DeFi systems are rooted in cooperation and decentralisation. By mandating hierarchical risk management in its pursuit of resilience, DORA-style legislation undermines crypto’s ambition of achieving the same goal through horizontal financial infrastructures, potentially sacrificing groundbreaking innovations for incremental gains. Taking the EU Markets in Crypto-assets Regulation (“MiCA”) as a regulatory blueprint, we reconcile the policy paradigms of DORA and crypto and propose policy steps that ensure cyber resilience in crypto networks.