The short answer
The useful onboarding file explains who the company is, what it does and why the expected payments make sense. It should distinguish company treasury from client activity and support the narrative with traceable records. Provider-specific requests and applicable law take precedence over this editorial checklist.
Source-linked facts below are distinct from our suggested workflows. Examples are hypothetical; this is not individual legal, tax or investment advice.
- 01Identity
- 02Activity
- 03Money trail
- 04Review file
Make the opening explanation concrete
Write a plain-language account of the company’s products, customers and revenue. State whether it handles assets for other people and whether it provides services that require permission. Link that explanation to contracts and the relevant scope assessment. Avoid a pitch deck that explains market ambition but not the transaction the bank will see.
A reviewer should be able to identify the expected payer, the conversion counterparty and the reason for the bank credit. Use one worked transaction as a guide through the evidence file. If the model is not operating yet, label the example as a forecast or hypothetical scenario rather than inventing historical activity.
Tie ownership records to decision rights
Keep current incorporation and ownership records with an explanation of the people authorised to instruct the account. Distinguish legal ownership from operational access to wallets and from governance rights in an associated protocol. Where a structure is complex, a diagram should simplify the view without hiding intermediate entities.
The exact documents requested depend on the institution and jurisdiction. Confirm certification, translation and recency requirements before commissioning documents. This site does not prescribe a universal beneficial-ownership threshold or guarantee that a particular document format will be accepted.
Explain the money and the asset path
For expected receipts, connect the commercial purpose, origin record, wallet event, conversion and bank payout. Explain whether the bank will see the company’s name, a service provider’s name or another entity as the sender. If the provider uses pooled accounts, retain its documentation linking the payout to the company.
Use dates and references that the finance team can reconcile. A blockchain explorer is one evidence source, not the full commercial explanation. Sensitive identity records and secret credentials should not be embedded in broad-access working spreadsheets. Private keys and recovery phrases must not be sent as ordinary onboarding documents.
Provide a permission file where the activity requires it
Identify the regulated services actually performed and the legal basis for them. Check current authorisation or the relevant permitted route and cross-border scope. ESMA’s register and the applicable competent authority are primary reference points for MiCA status. [EUR-Lex] [ESMA]
A legacy registration, an application in progress and a granted authorisation are different states. The EU-wide maximum transition ended on 1 July 2026. Do not present a historical registration as equivalent to current permission without verifying the legal basis. [ESMA]
Answer technical questions at the right level
A bank may need to understand custody, signing authority, transaction monitoring and how suspicious or unsupported activity is handled. Explain the actual process and the evidence it produces. Do not claim that a vendor tool eliminates all risk or that a monitoring dashboard is a substitute for review and escalation.
The travel-rule process should identify how the relevant provider gathers and transmits the required information, including self-hosted-address treatment where applicable. Keep that separate from any broader monitoring and sanctions process. Different controls can operate on the same transfer for different reasons. [EUR-Lex] [EBA]
Submit a versioned and navigable pack
Use a contents page with document names, versions, owners and a short statement of relevance. Answer a request by pointing to the exact item, not by forwarding the same large archive repeatedly. Where an answer is not available, say so and state the next step rather than implying completeness.
After onboarding, preserve the submitted version. It provides the baseline against which changes in activity and volumes can be understood. An approval is not a permanent exemption from further questions. EBA guidance on de-risking recognises risk-management decisions and the need for individual consideration; it is not an account-opening guarantee. [EBA]
Working checklist
Ticks record your work, not an approval or compliance score. Progress stays in this browser where storage is available.
Method, assumptions and limits
Regulatory facts are linked to primary sources. Suggested workflows are our editorial synthesis; examples and fee scenarios are hypothetical. The mechanical illustration is a conceptual navigation aid, not a prescribed legal funds flow.
This is a dated research edition, not an automatically updated register or live price feed. Check the applicable entity, service, jurisdiction and source version before using the material.
Read the methodologyQAnswers
Questions before you set out.
01Is there a universal onboarding pack?
No. Use the actual provider’s document requirements and applicable legal framework.
02Can a forecast be used?
Yes as a clearly labelled planning record, not as fabricated evidence of completed business.
03Does a completed pack guarantee approval?
No. The institution makes its own decision.
04Should the pack contain recovery phrases?
No. Do not include private keys or recovery phrases in an onboarding file.
Sources & scope
Research snapshot: 12 November 2026. The dated rule, its scope and the legal entity matter. Open the primary source before acting.
- EUR-Lex: Regulation (EU) 2023/1114 — Markets in Crypto-AssetsEU legislation
- ESMA: MiCA implementation and the central registerRegulator register and guidance
- ESMA: Statement on the end of transitional periods under MiCA, 17 April 2026Supervisory statement
- EUR-Lex: Regulation (EU) 2023/1113 — information accompanying transfersEU legislation
- EBA: Travel Rule Guidelines — information accompanying transfersRegulator guidance
- EBA: Guidelines challenging unwarranted de-riskingRegulator guidance