Solus Partners Releases Report On Web3 Neobanks, Mapping Infrastructure, Licensing, And Regulatory Risks

Research and advisory agency Solus Partners has launched a brand new report titled “The Compliance Infrastructure Stack,”providing an in depth evaluation of how Web3 neobanks assemble regulatory moats and handle infrastructure dependencies. 

The report emphasizes that the defensibility of a Web3 neobank is decided not by its consumer interface or token incentives, however by what number of layers of its infrastructure stack it owns versus rents, and whether or not it holds the licenses required to function these layers independently.

The research highlights the rise of stablecoin-native neobanks, which permit customers to carry dollar-pegged belongings, spend by way of Visa or Mastercard, earn yield, and transfer funds throughout borders at near-zero price. While the market stays in its early levels—with Web3 neobanks representing lower than 0.2% of the $143–195 billion world neobank alternative—the infrastructure choices made at present will decide which platforms survive regulatory scrutiny. Unlike most present protection that focuses on product options or consumer progress, this report takes a bottom-up strategy, reverse-engineering the infrastructure stacks of a number of platforms to reply essential questions, akin to Who owns their infrastructure versus renting it? Where are the hidden single factors of failure? Which platforms maintain the required licenses to function independently below tightening laws?

The solutions are more and more related because the Web3 neobank sector enters a regulatory part transition. The full enforcement of MiCA in December 2024 would require CASP authorization for any platform providing crypto change, custody, or switch companies within the EU, with transitional intervals expiring between mid-2025 and mid-2027. Platforms that fail to acquire authorization threat both ceasing EU operations or going through penalties of as much as 12.5% of annual turnover.

Market Overview And Platform Taxonomy

The report begins with an evaluation of market sizing, platform taxonomy, and the stablecoin infrastructure panorama.The world neobank market reached an estimated $143–195 billion in 2024 and is projected to develop to $210–261 billion in 2025, with long-term forecasts indicating a 40–49% CAGR by way of the early 2030s. Approximately 350 million customers worldwide are projected to make use of neobank companies by 2025, with Europe accounting for 37–41% of income. Latin America’s neobank consumer base doubled from 85 million in 2022 to 170 million by 2024, pushed primarily by Nubank, whereas U.S. digital-only financial institution customers reached 39 million, a 22% year-over-year improve.

While no main analysis agency tracks Web3 neobanks as a standalone market, CoinGecko’s neobank token class tracked 21 tasks with a mixed market capitalization of $2.7 billion in early 2026.

The platform taxonomy categorizes neobanks into Web2, hybrid, and Web3-native fashions, highlighting their strategy to account administration, custody, and blockchain integration. Notable tasks embrace Chime, Monzo, N26, Revolut, Nubank, Cash App, Gnosis Pay, Fiat24, and Holyheld. The report additional examines key market dynamics shaping Web3 neobanks by way of 2025 and 2026, masking stablecoin settlement, crypto card volumes, and institutional financial institution entry.

Regulatory Landscape

The report offers a forward-looking regulatory evaluation for the upcoming 12 months, highlighting how MiCA enforcement and associated measures will impression Web3 neobank operations. Regulatory readiness, license acquisition, and compliance methods are examined for every platform, displaying which firms are positioned to outlive and thrive as guidelines tighten.

Six-Layer Infrastructure Anatomy

A significant contribution of the report is its six-layer infrastructure framework, which analyzes vendor landscapes, pricing, and build-vs-buy choices at every layer. Every Web3 neobank assembles a stack comprising:

• Card Issuance – Crypto-native principals like Rain and Reap maintain direct Visa or Mastercard memberships, whereas conventional BIN sponsors akin to Monavate, Unlimit, and Marqeta intermediate between card networks and fintech applications. Costs range extensively, with in-house builds taking 12–24 months and $2–10M+, whereas shopping for takes 3–6 months for $100–500K.
• KYC/AML – Identity verification, transaction monitoring, and FATF Travel Rule compliance are managed by way of distributors akin to Sumsub, Jumio, Onfido, Chainalysis, TRM Labs, and Notabene. Costs vary from $1–2.50 per verification, with annual analytics subscriptions exceeding $50K. Most platforms buy these companies reasonably than constructing in-house.
• Custody – Crypto safekeeping varies between third-party custodial (Fireblocks, BitGo, Copper), MPC/TSS semi-custodial options (Dfns, Fordefi), and self-custodial wallets. Self-custody is the best owned ratio amongst layers, with compliance influenced by MiCA Art. 75 and Recital 83.
• Fiat On/Off-Ramp – Platforms combine with suppliers like Transak, MoonPay, Ramp Network, and Onramper, or function in-house EMIs akin to Fiat24 and Deblock. Transaction prices vary from 0.25%–5%, with internalization requiring $350K–1M+ capital.
• Core Banking Ledger – Account state and transaction administration could also be dealt with by way of BaaS suppliers (Column-Unit, Treasury Prime) or on-chain options (GP, Fiat24). Costs embrace SaaS charges ($100K+/yr) or minimal fuel charges ($0.001–0.01 per transaction).
• Blockchain Settlement / Chain Selection – Platforms select L1 and L2 chains akin to Gnosis Chain, Arbitrum, Base, and Solana, supporting multi-chain operations, account abstraction (ERC-4337), and fuel abstraction. Transaction prices range from $0.00025 on Solana to $0.02 on Base.

Platform Profiles And Cross-Platform Analysis

The report contains detailed profiles of 19 platforms, reverse-engineering their infrastructure stacks, licensing standing, and regulatory runway below MiCA and associated 2026–2027 guidelines. Companies analyzed embrace Gnosis Pay, Fiat24, Ether.Fi Cash, Kast, Wirex, Deblock, Tria, Tuyo, IN1, CYPHER, Avici, Allscale, Holyheld, Nexo, Minipay, Reap, Rain, Nordark, and Stakestone.

A cross-platform evaluation examines license clustering, infrastructure focus, and regulatory divergence, highlighting potential dangers akin to vendor dependency and gaps in CASP authorization. The report identifies strategic build-vs-buy inflection factors that would decide the long-term survival of those neobanks.

The full report is out there here. Contributors embrace Rektonomist, Frigg, Brey, Temmy, and Defizard.

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