ON THE RECORD
By Dec 2028 — raw neural data will be classified as GDPR Article 9 special category.
By Q3 2027 — MiCA Title VI will trigger a 30%+ reduction in licensed EU CASPs.
By Q4 2027 — a major EU neurotech firm will face a retroactive Article 9 enforcement action.
By 2028 — a national court of appeal will rule on an autonomous AI agent as contractual party.
By Q4 2027 — a tokenised US Treasury product will face a cascade redemption event.
01 / 05
A small firm in Amsterdam.

We advise founders, capital allocators, and operators building in industries that move faster than the law.

We litigate when those frontiers produce conflict, and for clients in any sector who need adversarial competence rather than process management.

Two practices, one instinct: read the situation faster than the other side does — and act on it.

— The Navabi method

Frontier industries we know intimately.

We pick our sectors deliberately. Each one operates ahead of its regulatory framework — and rewards the firms that read the future correctly.

01
DeFi protocols
Lending · DEXs · oracles · settlement
Where MiCA, DORA and securities law are still being drawn.
02
Stablecoins & e-money
EMI · MiCA Title III & IV · cross-border
Licensing, reserve architecture, and redemption mechanics.
03
Autonomous AI agents
Contract personality · liability · AI Act
No framework exists. Founders need one before their first enterprise deal.
04
Neurotechnology & BCI
Consumer EEG · BCI · GDPR Article 9
Brain data is the next sensitive category. The regime is being written now.
05
Carbon credits
VCM · CRCF · Article 6 · ETS
Climate finance with securities-like exposure and no settled jurisprudence.
06
Psychedelics
MDMA · psilocybin therapy · EMA
Therapeutic-grade compounds in pre-approval clinical infrastructure.
07
Cannabis
Wietexperiment · medicinal · EU export
The Dutch experiment is producing the first lawful supply chain.
08
Space & satellite
Wrva · ESA · data licensing
Dutch sector with growing commercial activity and unsettled liability rules.
09
Nuclear · SMR & fusion
Small modular reactors · ITER · fuel cycle
First commercial deployment cycle in a generation. Permitting precedent is being set.
10
Quantum compliance
Post-quantum crypto · NIS2 · DORA
Migration is now mandatory for critical infrastructure. Few firms have a plan.
11
DAO governance
Token-voting · multisig · disputes
Where on-chain governance produces off-chain litigation.
+
Adjacent frontier
By inquiry
If you are operating somewhere the law has not arrived, we may already be watching.

What we do, in plain language.

01 · Advisory Forward-looking
Advisory.

Forward-looking counsel for founders, fund managers, and capital allocators.

  • Regulatory architecture for emerging-technology products
  • Fund structuring, tokenisation, and digital asset deal counsel
  • Frontier-zone fundraising — term sheets, side letters, KYC infrastructure
  • M&A and joint ventures in regulated emerging industries
  • Pre-emptive regulatory strategy — what the law will say in three years
02 · Litigation Adversarial
Litigation & disputes.

When another party has made a problem out of you, we make it our problem.

  • Commercial litigation and complex civil procedure
  • Regulatory enforcement defence
  • Contract disputes and breach of fiduciary claims
  • Tuchtzaken and professional liability
  • Crypto, DeFi, and digital asset disputes
  • Cross-border enforcement and asset recovery
03 · Counsel Ongoing
Counsel.

On retainer. For when you need us to already know you.

  • Ongoing legal counsel — monthly retainer, not hourly billing
  • Board observer seats and corporate governance advisory
  • Standing review of contracts, term sheets, and policies
  • First call when something breaks: regulators, counterparties, journalists
  • Compliance program design and internal investigations support
  • Continuous monitoring of regulatory developments in your sector
  • Direct access without intake — we already know the file

An ongoing series on frontier law.

The legal terrain that opens when technology moves faster than the regulatory system designed to constrain it.

Essay No. 01May 2026

Brain data is the new genetic data — and it has no lawyer.

Every European neurotech company funded in 2026 is being valued on a regulatory premise that will not survive 2028. Founders know this. Their lawyers know this. Their investors are pretending not to.

Read

Regulatory developments we are tracking.

Updated continuously. A live record of what the law is becoming.

StatusJurisdiction · FileSummaryDate
Imminent
EU Parliament Neurotechnology Ethics Panel

Recommendations expected this quarter. We expect a recommendation to amend GDPR Article 9 to include neural data as a special category.

Q4 2026
Active
MiCA Title VI implementation deadline

CASPs operating in the EU without authorisation after 30 December 2024 are exposed to enforcement. DNB and AFM have begun first-wave investigations.

Jul 2026
Active
Connecticut CTDPA neural data provisions

First US state to expressly treat neural data as sensitive personal information. Companies with US-facing neurotech products need a compliant pathway today.

1 Jul 2026
Watching
MIND Act (S. 2925) — Federal US

Management of Individuals' Neural Data Act has cleared committee. Even if it does not pass, the FTC study it mandates will produce enforcement signal within eighteen months.

Pending
Watching
DORA — DeFi protocol perimeter

ESMA's January 2026 guidance left undefined whether DeFi protocols providing oracle, lending, or settlement services to regulated entities fall within DORA.

2026–2027
Watching
EU AI Act — General-purpose AI obligations

Compliance obligations for GPAI providers under Article 53 entered force August 2025. Enforcement guidance is still being written.

Aug 2025+

One conversation. Scope confirmed in 48h.

For founders, funds and operators with a matter in motion. We respond within 24 hours.

Book a 30-min discovery call
Navabi · Amsterdam, Nederland · navabi.nl