The reference for crypto-asset service providers under MiCA.

Yes. The asset-referenced token (ART) and e-money token (EMT) titles went live on 30 June 2024. The CASP regime - everything in Titles V and VI - went live on 30 December 2024. We're now operating under it, not preparing for it.

MiCA Article 149 (application dates)

Two clocks. The competent authority has 25 working days to do the completeness check (Article 63(1)) and then 40 working days to decide once the file is complete (Article 63(4)). In practice, getting the file to complete is the slow part - most teams spend three to nine months preparing it, depending on jurisdiction, prior compliance posture, and how clean their custody story is. France, Germany, and Ireland are running longer than the legal clock. Malta and Lithuania have been faster.

MiCA Article 63

It depends on which services you're authorised for. There are three classes, and the requirement is the higher of the class minimum or one quarter of the previous year's fixed overheads.

Class 1 (€50,000): reception/transmission, advice, portfolio management, transfer services.
Class 2 (€125,000): Class 1 services + custody, exchange of crypto for fiat or other crypto, execution of orders, placing.
Class 3 (€150,000): Class 2 + operating a trading platform.

The fixed-overhead test trips up well-funded operators more than the class minimum does.

MiCA Article 67(1) and Annex IV

Do not start with a generic quote request. Prepare a short evidence pack: authorised or planned MiCA services, Article 67 safeguard route, fixed-overhead calculation, custody model, client-asset segregation, outsourcing dependencies, incident history, complaints process, and the Article 75 loss/liability scenarios that could reach the policy. The useful output is a broker-ready diligence packet, not a coverage, placement, or regulatory-acceptance assurance. Start with the CASP insurance evidence pack and the Article 75 custody liability checklist.

MiCA Articles 67 and 75

Article 60 is the lighter "notification" route for firms already authorised in the EU - credit institutions, investment firms, e-money institutions, UCITS management companies, MiFID firms - that want to add crypto-asset services. They notify their existing regulator and can start providing services 40 working days later. Article 62 is the full authorisation route for everyone else. If you're not already an EU-regulated financial entity, Article 62 is your only path.

MiCA Articles 60, 62

No. CASP authorisation passports across all 27 member states. You get authorised in your home member state and notify the others before providing services there. The notification covers which services and which member states, and the host state can object on certain grounds but mostly can't add gold-plating.

MiCA Article 65

Technically yes, but the door is much narrower than firms assume. Article 61 lets a third-country firm serve EU clients only at the client's own exclusive initiative. You can't market, you can't solicit, you can't offer new services or asset classes once the relationship exists, and you have to keep records proving client initiative. ESMA's December 2024 statement signalled that aggressive use of reverse solicitation will be policed - they explicitly warned against treating it as a backdoor.

MiCA Article 61; ESMA statement of 17 December 2024

Article 143 gives a transitional regime: firms providing crypto services under national law before 30 December 2024 can continue under that national framework until they get MiCA authorisation, up to 1 July 2026. Member states could shorten this - France went to 30 June 2026, Germany also shortened. Lithuania chose the full 18 months. You should already have an authorisation plan and a target NCA. If you don't, time is short.

MiCA Article 143

There's no honest universal answer. Each NCA has different posture, timelines, and informal expectations. Speed/rigour are inversely correlated. Malta (MFSA) and Lithuania have been faster but ask different questions. France (AMF) has a strong reputation and a heavy file. Germany (BaFin) is rigorous and slow. Ireland (CBI) is methodical. The Netherlands (AFM) is responsive. Choose where your business, board, and lawyers actually are - passporting handles the rest. Compare them side by side.