EU Consults on Including DeFi Lending in MiCA

The consultation's core difficulty is structural: MiCA assumes an identifiable service provider, but vault designs disperse control and risk management, leaving no obvious entity to license or supervise. That gap matters most for DeFi lending protocols and the borrowers and depositors using them, since a definition of "actual control" would determine who carries compliance obligations. Whether the EU settles on a narrow, function-based test or a broader one that captures vault curators and governance arrangements is the open question to watch when the consultation closes.