Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
Get in Touch
T: +44 20 3695 9251
E: info@grtconsult.com
71-75 Shelton Street Covent Garden, London, WC2H 9JQ
The Markets in Crypto-Assets Regulation (MiCA – Regulation (EU) 2023/1114) is now fully in force across the European Union. For operational staff – compliance officers, operations managers, middle-office teams, risk and legal support – this is no longer a theoretical exercise. It is a day-to-day reality that affects client onboarding, capital planning, governance, transaction reporting, custody, and cross-border service delivery.
This practical guide is written for the people who actually have to implement MiCA. It maps the different business types, sets out the exact steps to become an authorised Crypto-Asset Service Provider (CASP), and highlights the operational actions that matter most.
MiCA replaces fragmented national regimes with a single EU-wide passport. Authorisation as a CASP allows you to serve clients across all 27 Member States (plus EEA). Failure to obtain or maintain authorisation means you cannot provide regulated crypto-asset services in the Union after the transitional period (which ended at the latest on 1 July 2026).
Operational consequences include:
Different activities trigger different obligations. Use the table below as a quick reference for gap analysis and resource planning.
| Business Type / Activity | Core Obligations | Capital / Prudential | Authorisation Route | Key Sources |
|---|---|---|---|---|
| Issuer / Offeror of other crypto-assets (utility tokens etc.) – Title II | White paper notification, fair communications, liability for content, 14-day withdrawal right in most cases | No MiCA-specific own-funds floor | White-paper notification only (no prior authorisation for the offer) | EUR-Lex consolidated text Arts 4–15; ESMA Interim Register |
| Issuer of Asset-Referenced Tokens (ARTs) – Title III | Authorisation, approved white paper, segregated reserve of assets, redemption rights, recovery & redemption plans, governance | Higher of €350 000, 2 % of average reserve, or 25 % fixed overheads | Prior authorisation by home NCA (or credit-institution route) | EUR-Lex Arts 16–47 |
| Issuer of E-Money Tokens (EMTs) – Title IV | Restricted mainly to credit institutions & EMIs; par redemption at any time free of charge; reserve rules | Similar prudential logic to ARTs | Authorisation as CI or EMI + MiCA overlay | EUR-Lex Arts 48–58 |
| CASP Class 1 (reception & transmission, execution, placing, advice, portfolio management, transfer) | Honesty, client information, governance, conflicts, complaints, AML/CFT, DORA | Higher of €50 000 or 25 % fixed overheads | Full CASP authorisation or Art 60 notification | EUR-Lex Arts 59–85 + Annex IV |
| CASP Class 2 (Class 1 + custody & administration + exchange for funds or other crypto-assets) | All Class 1 + client-asset segregation & liability | Higher of €125 000 or 25 % fixed overheads | Same as Class 1 | EUR-Lex Annex IV; ESMA Q&A 2343 |
| CASP Class 3 (Class 2 + operation of a trading platform) | All Class 2 + platform operating rules and market-abuse detection | Higher of €150 000 or 25 % fixed overheads | Same as Class 1 | EUR-Lex Annex IV |
| Existing financial entities (credit institutions, MiFID firms, EMIs, etc.) | ||||
| Notification rather than full new authorisation for overlapping services | Existing regime + MiCA overlay where higher | Art 60 notification (≥ 40 working days) | EUR-Lex Art 60 |
Operational tip: Capital is calculated on the highest class of services you are authorised for. Always take the higher of the Annex IV floor or one-quarter of the preceding year’s fixed overheads (projected figures for new firms).
Operational teams should treat this as a project plan with clear owners, deadlines and evidence packs.
2025/305)5Assemble the application packageProgramme of operations, organisational chart, internal controls, capital evidence, personal questionnaires, ICT description, etc.Art 62 + RTS 2025/3056Submit to home NCAUse the national portal; incomplete files restart the clockNational NCA portals7NCA assessmentCompleteness check (~25 working days); decision within 40 working days of a complete applicationArt 638Passport & go liveSingle authorisation valid across the Union; notify home NCA of cross-border activityArt 659Ongoing complianceContinuous capital, reporting, incident notification (DORA), updates to ESMA registerArts 66–85; ESMA Interim Register
| Step | Action | What operational staff must deliver | Official reference |
|---|---|---|---|
| 1 | Map the 10 crypto-asset services | Exact list of services you will provide (determines Class 1/2/3) | Art 3(1)(16) |
| 2 | Establish EU substance | Legal entity with registered office and place of effective management in the EU; at least one director resident in the EU | Art 59; ESMA Supervisory Briefing |
| 3 | Secure capital | Permanent minimum own funds (or qualifying insurance) in place before application | Art 67 + Annex IV |
| 4 | Build governance & policies | Fit-and-proper for management body and qualifying shareholders; policies for AML/CFT, conflicts, complaints, business continuity, outsourcing, client-asset segregation, ICT/DORA | RTS on CASP authorisation (Delegated Reg. |
Typical elapsed time from first NCA contact to authorisation is 3–9 months depending on completeness and jurisdiction.
GRT Consulting supports operational teams with:
Contact us for a focused readiness review or full authorisation support: T: +44 20 3695 9251 E: info@grtconsult.com Web: grtconsult.com
Sources
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