Legal identity
Reconcile name, legal form, legal entity identifier, branch details where relevant, commercial name, website, and public contact details against current company and authorisation records.
What Article 109 changes operationally
Register of crypto-asset white papers, issuers, and crypto-asset service providers: Regulation (EU) 2023/1114 Article 109 says ESMA shall establish a public register covering crypto-asset white papers, issuers of asset-referenced tokens and e-money tokens, and crypto-asset service providers.
For CASP operating teams, the practical issue is register hygiene: matching legal identity, legal entity identifier, commercial name, contact details, competent-authority source, list of crypto-asset services, host Member States, starting date, other non-MiCA services, and date of authorisation or withdrawal to the firm’s internal evidence pack.
This page is an evidence-preparation checklist. It is not a legal interpretation, authorisation opinion, register filing guide, broker recommendation, provider endorsement, or assurance that any firm’s register entry is complete.
ESMA-register evidence matrix
Competent-authority source
Keep the name, address, and contact details of the competent authority that granted authorisation with the source file, submission owner, and last review date.
Service-scope list
Map the list of crypto-asset services in the register to Article 62 application material, internal service definitions, client terms, and live product boundaries.
Host Member States
Track host Member States where services are intended to be provided and reconcile that list with Article 65 cross-border notifications, planned start dates, and market-launch records.
Authorisation dates
Preserve the starting date or intended starting date, date of authorisation, and any withdrawal status with versioned evidence and competent-authority correspondence.
Operating-model handoffs
Link register fields to Article 66 conduct, Article 68 governance, Article 70 client-asset safeguarding, Article 73 outsourcing, Article 75 custody, and Article 85 scale-monitoring evidence where relevant.
Review-ready tracker
- Register owner: named owner for public-register checks, internal data sources, competent-authority correspondence, and escalation decisions.
- Field-by-field evidence: source URL, internal source record, last reviewed date, unresolved assumptions, and correction owner for each public register field.
- Service and geography reconciliation: service list, host Member States, start dates, non-MiCA services, Article 65 notifications, and live product boundaries.
- Change-control bridge: links to Article 62 authorisation material, Article 64 withdrawal monitoring, Article 69 competent-authority information, and governance records.
FAQ
What does MiCA Article 109 cover?
Article 109 covers ESMA’s public register for crypto-asset white papers, issuers of asset-referenced tokens and e-money tokens, and crypto-asset service providers, including CASP register information supplied through competent authorities.
Why should a CASP keep a register evidence file?
Register entries can become a public trust surface for partners, counsel, auditors, insurers, brokers, and internal risk teams. A field-by-field file makes it easier to spot stale identity, service-scope, geography, or authorisation data.
How does Article 109 connect to CASP insurance or diligence?
Insurance and operational-risk reviewers often start with public identity, authorisation, services, geography, custody exposure, outsourcing, and governance evidence. Article 109 register hygiene should therefore link to Article 67, 68, 70, 73, 75, and 85 evidence where relevant.