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How to become MiCA authorised

A practical map of the EU Markets in Crypto-Assets (MiCA) authorisation path: which regime you fall under, the CASP dossier steps, capital classes, pitfalls seen in applications, and links to official forms and templates. This is information only — not legal, regulatory or compliance advice. Confirm everything with your home NCA and counsel.

1. Pick your path

MiCA is not one licence. Match your activity to the correct Title before drafting policies.

Crypto-asset service provider (CASP)

You provide one or more of the ten services in Art. 3(1)(16) (custody, trading platform, exchange, execution, placing, RTO, advice, portfolio management, transfer) on a professional basis in the EU.

Route: Home-state authorisation under Title V (Arts. 62–63), then passport. Already-regulated firms may use Art. 60 notification for listed services instead of a full new licence — check NCA guidance.

Other crypto-asset offer / admission (Title II)

Utility / “other” tokens offered to the public or admitted to trading (not ART/EMT, not MiFID instruments).

Route: White paper notification (iXBRL from Dec 2025), marketing rules — generally no CASP licence solely for issuing, but platforms listing the token need CASP.

Asset-referenced token (ART) issuer

Token referencing multiple assets / basket (Title III). Authorisation of the issuer + white paper; significant ARTs involve EBA.

E-money token (EMT) issuer

Token referencing a single fiat currency (Title IV). Typically credit institution or e-money institution pathway + white paper. Custody/transfer of EMTs by a CASP can also trigger PSD2 payment-licence issues (dual-licence trap).

Not sure? Use the CASP register and NCASP check, then map services against Art. 3(1)(16). UK FCA rules are separate — MiCA does not authorise UK activity.

2. CASP authorisation — walkthrough

  1. Scope the services

    List exactly which of services (a)–(j) you will provide. Scope drives Annex IV capital class, policies, systems and staffing. Do not apply for services you cannot evidence.

  2. Choose home Member State & build EU substance

    Incorporate (or use) an EU legal entity whose management and head office match the home NCA. “Brass plate” boards without local decision-makers are a frequent refusal theme. Get an LEI early — registers and white papers expect it.

  3. Capitalise to Annex IV + Art. 67

    Hold the higher of the permanent minimum for your class or one quarter of fixed overheads. Funds should be eligible CET1-style own funds, paid up and typically segregated — not founder loans parked in operating cash. See capital table.

  4. Build the Art. 62 dossier

    Content is detailed in Commission Delegated Regulation (EU) 2025/305; forms/procedures in Implementing Regulation (EU) 2025/306. Expect at least: identity & programme of operations (≈3 years), governance & internal controls, fit-and-proper for management and qualifying holders, AML/CFT (incl. Travel Rule / TFR), ICT/DORA resilience, custody/safeguarding where relevant, outsourcing map, complaints, conflicts, and financials/capital proof.

  5. Pre-application (where the NCA runs one)

    Some NCAs (e.g. Central Bank of Ireland) require meetings and a Key Facts Document before the formal file. Follow that NCA’s portal guide — skipping pre-app resets calendars.

  6. File with the home NCA

    Submit via the NCA’s channel using the 2025/306 templates / national portal forms. Keep a completeness tracker mapped to 2025/305 fields.

  7. Completeness → assessment → register

    Statutory clocks under Art. 63: acknowledge receipt, completeness check, then decision. Incomplete files stop the assessment clock. On grant, the NCA notifies ESMA and you appear on the interim CASP register; then passport notifications for other Member States.

3. Capital & services (a–j)

Permanent minimum capital (MiCA Annex IV). Ongoing own funds = higher of that floor or 25% of prior-year fixed overheads (Art. 67). Multiple services → highest class once, not summed.

ClassFloorTypical services
1 €50,000 Execution; placing; reception & transmission; advice; portfolio management; transfer (e, f, g, h, i, j)
2 €125,000 Custody; exchange for funds; exchange for crypto (a, c, d) — plus Class 1 if combined
3 €150,000 Operating a trading platform (b) — plus lower classes if combined

Service labels: a Custody and administration of crypto-assets on behalf of clients · b Operation of a trading platform for crypto-assets · c Exchange of crypto-assets for funds · d Exchange of crypto-assets for other crypto-assets · e Execution of orders for crypto-assets on behalf of clients · f Placing of crypto-assets · g Reception and transmission of orders for crypto-assets on behalf of clients · h Providing advice on crypto-assets · i Providing portfolio management on crypto-assets · j Providing transfer services for crypto-assets on behalf of clients.

4. Common pitfalls

Patterns repeatedly called out by practitioners and NCA feedback (not an exhaustive regulatory list):

  • Template policies that don’t match the model — off-the-shelf AML/ICT manuals that ignore your wallets, chains, or outsourcing get pushed back.
  • No EU substance — non-resident-only boards; decisions taken from a third country while the EU entity is a shell.
  • Weak AML evidence — describing controls without proving staffing, monitoring rules, Travel Rule tooling, and SAR workflows. Art. 63 lets NCAs refuse where management creates serious ML/TF risk.
  • Travel Rule “we’ll buy it later” — NCAs increasingly expect contracted, testable TFR capability in the file, including self-hosted wallet handling.
  • Capital not real / not segregated — own funds mixed with operating cash, or non-CET1 instruments counted as prudential capital.
  • EMT dual-licence trap — custody or transfer of e-money tokens may need MiCA CASP and PSD2 PI/EMI authorisation. Budget the higher capital and dual governance.
  • ICT / DORA as a slide deck — incident, BCP and ICT risk must be operable, not aspirational.
  • Scope inflation — applying for trading-platform or custody without systems, key management or market-abuse surveillance.
  • Pending application ≠ licence — after the Art. 143 grandfathering outer date (1 Jul 2026), unauthorised EU service is out of regime; a filed dossier is not authorisation.
  • Wrong product classification — treating a MiFID financial instrument as a MiCA “other” token, or fractional/series NFTs as out of scope.

5. Templates & official packs by business type

Prefer primary sources. Law-firm checklists are secondary illustrations — always reconcile to the RTS/ITS and your NCA’s portal.

All applicants — Level 1 & Level 2

CASP (exchange, custody, broker, adviser, platform…)

Token issuers — white papers (ART / EMT / other)

  • ITS (EU) 2024/2984 — white paper forms/formats (iXBRL).
  • ESMA MiCA White Paper Taxonomy 2025 — taxonomy package, reporting manual, validation rules.
  • ESMA Excel showcases (voluntary generators): linked from the ESMA MiCA hub — SCWP workbooks for EMT, ART and OTHR tokens. Outputs remain the preparer’s responsibility.
  • EBA ART/EMT policy hub — issuer-side mandates and guidelines.
  • Browse notified papers on this site: White papers.

Already authorised under other EU regimes

  • Review Art. 60 MiCA notification routes for credit institutions, MiFID firms, EMIs, PIs, etc., before assuming a full Art. 62 CASP application is required. Your NCA publishes the notification pack.

6. Statutory clocks (Art. 63 — indicative)

  • ~5 working days — NCA acknowledges receipt.
  • ~25 working days — completeness assessment (clock pauses if the file is incomplete).
  • ~40 working days — assessment to grant or refuse after completeness (extensions possible in complex cases — read Art. 63 and NCA practice).

National pre-application phases sit outside these clocks. Always use your NCA’s published service standards.

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