The short answer
MiCA distinguishes crypto-asset services and issuer regimes. An own-treasury conversion is not automatically the provision of a service to clients. For in-scope services, check the applicable authorisation or Article 60 route and the precise legal entity. The general transitional end date of 1 July 2026 has passed. [EUR-Lex] [ESMA]
Source-linked facts below are distinct from our suggested workflows. Examples are hypothetical; this is not individual legal, tax or investment advice.
- 01Activity
- 02Entity
- 03Application
- 04Ongoing controls
Map activities rather than adopting a label
List custody, exchange, transfer, execution, platform operation, advice and any other actual activity before using an umbrella label such as crypto platform. Mark who the clients are, where the service is provided and whether the company controls assets or keys. Review MiCA’s definitions and scope with a qualified specialist. [EUR-Lex]
One product can contain several activities, each with different controls and contractual relationships. Conversely, a company that accepts tokens for its own commercial invoices does not become a CASP solely by doing so. The operating facts must determine the analysis. Document exclusions and assumptions instead of treating them as invisible design choices.
Identify the route to permission
Article 59 sets the general framework for providing crypto-asset services in the Union. Article 60 provides a route for specified already-regulated entities, subject to its conditions and the relevant services. It is not an unrestricted permission for every financial group company. [EUR-Lex]
Record the applicant or notified entity, home authority, services, locations and any cross-border arrangement. A national legacy registration and a MiCA authorisation are not the same evidence. The transition was not a permanent alternative to the new framework. Check the current register entry and any restrictions, rather than relying on a launch announcement. [ESMA] [CSSF]
Build the application around operating evidence
Article 62 sets out the application information. The file should be assembled around the actual proposed business: governance, programme of operations, prudential safeguards, controls, technology and service-specific arrangements. Refer to the source and the competent authority’s current forms; this page is not an official template. [ESMA]
An effective internal document index records the owner, version, evidence location and review status of each component. Written policies are only one layer. Identify the systems and people that will implement them, how exceptions are recorded and what demonstrates that the arrangements can operate at the proposed scale.
Test the boundaries with counterparties
A CASP authorisation is not a substitute for understanding the bank, payment institution, custodian or technology provider in the route. Document the role of each external party and what happens if it becomes unavailable. Be precise about which entity holds client assets and how the customer agreement explains the arrangement.
Do not treat outsourcing as a way to make regulatory responsibility disappear. MiCA contains conditions on outsourcing, and DORA addresses operational resilience for the entities within its scope. The appropriate control set depends on the service and entity rather than the visual simplicity of a funds-flow diagram. [EUR-Lex] [EUR-Lex]
Treat the transition as history, not a runway
This research edition is dated 12 November 2026. ESMA’s statement identified 1 July 2026 as the end of the EU-wide maximum transition and explained expectations for orderly wind-down and client migration. Some national transitions ended earlier. [ESMA]
A procurement or onboarding checklist still describing a legacy registration as sufficient because MiCA is coming should therefore be reviewed. Check the provider’s current legal position, not only the date it started operating. This page does not maintain a live authorisation feed and cannot certify any particular firm.
Maintain an authorisation evidence record
Keep the current register result alongside the contract and service description. Record the date checked, source address, reference, scope and any inconsistency. Revisit the file when the contracting entity, product or geography changes. An old screenshot is not permanent proof of present status.
Where uncertainty remains, route it to the competent authority or appropriate adviser rather than marking the item as approved. A good operating record makes unanswered questions visible. It does not turn a completed spreadsheet into legal assurance.
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 every Web3 company a CASP?
No. Assess the activities actually performed against the legal definitions and scope.
02Can a firm still rely on the general transition?
The maximum MiCA transitional date of 1 July 2026 has passed. Verify current permission and any applicable legal basis.
03Does MiCA authorisation cover banking?
No. A crypto-service permission is not a bank licence.
04Is there one application document for all services?
No. Article 62 and the applicable authority materials govern the required information; service-specific requirements matter.
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 Article 62 — CASP applicationInteractive legal rulebook
- 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) 2022/2554 — Digital Operational ResilienceEU legislation