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CASP application evidence pack checklist

A practical checklist for EU CASP teams turning MiCA authorisation material, Article 67 prudential-safeguard decisions, and Article 75 custody risk into a coherent evidence pack.

Informational only. Not legal, regulatory, brokerage, underwriting, or insurance advice.

Why this page exists

Article 62 application material is broad: identity, governance, programme of operations, controls, custody arrangements where relevant, complaints, outsourcing, ICT and operational risk, and service-specific procedures. CASPs need a clear, source-backed way to assemble evidence before asking a competent authority, broker, counsel, or internal risk owner to react.

Mintara Labs can help prepare the application narrative, evidence inventory, and risk-transfer questions. That does not make Mintara Labs a broker, insurer, underwriter, law firm, or regulated adviser.

Evidence pack structure

1. Authorisation scope

Services requested, target member state, passporting plan, client segments, operating entities, and the boundaries between crypto-asset services, custody, transfer, exchange, trading platform, advice, or portfolio management.

2. Governance and ownership

Management body, fit-and-proper evidence, ownership and group structure, decision rights, conflicts management, and board-level risk ownership.

3. Programme of operations

Business model, commercial policy, client onboarding, service flow, outsourced functions, critical vendors, continuity planning, and operational resilience assumptions.

4. Article 67 prudential-safeguard narrative

Article 67 own-funds calculation, fixed-overhead basis, whether insurance or a comparable guarantee is being evaluated, and how the selected path maps to the firm’s actual risk profile.

5. Custody and client-asset controls

Wallet model, key-control procedures, segregation of client crypto-assets and funds, access recovery, reconciliation, incident response, and the Article 75 loss scenarios the firm can evidence.

6. Insurance-market questions

Professional indemnity, cyber, crime, custody liability, D&O, exclusions, retroactive dates, deductibles, claims history, and the exact question being asked of brokers or insurers.

Source-backed hooks to cite internally

FAQ

Is this a legal checklist?

No. It is an operational evidence-pack structure for discovery and preparation. CASPs should validate legal and regulatory interpretation with qualified advisers and their competent authority process.

What is the highest-value use of this page?

Use it before a broker, counsel, or regulator-facing adviser call so the team can separate missing evidence from genuine product, capital, custody, or risk-transfer decisions.

Why include insurance in an application evidence pack?

Because Article 67 explicitly allows insurance or comparable guarantees as part of prudential safeguards, and custody/client-asset exposure under Article 75 often becomes a risk-transfer and underwriting diligence topic.