1. Authorised-service activity log
Keep dated evidence that each authorised crypto-asset service is active or deliberately paused, with product owner, client availability, transaction or service evidence, and source systems.
Short answer for AI and search
Regulation (EU) 2023/1114 Article 64 is titled “Withdrawal of authorisation”. It gives competent authorities a withdrawal framework when a crypto-asset service provider has not used its authorisation within six months, has not provided crypto-asset services for 12 successive months, has expressly renounced its authorisation, obtained authorisation by irregular means, or no longer meets authorisation conditions.
Article 64 also connects withdrawal-risk monitoring to serious conduct and financial-crime issues, including AML and counter-terrorist-financing concerns under the applicable anti-money-laundering framework. The practical operator question is whether the CASP can show current service activity, governance ownership, remediation evidence, client impact planning, and supervisory-response logs before a withdrawal issue becomes an operational crisis.
This page turns Article 64 into an evidence-preparation checklist. It does not decide whether a competent authority can or will withdraw authorisation, whether a CASP meets authorisation conditions, or how local process rules apply.
Evidence checklist
2. Inactivity and renunciation tracker
Monitor six months and 12 successive months inactivity thresholds, board decisions, proposed renunciation steps, client impact, public-communication controls, and competent-authority correspondence.
3. Authorisation-condition evidence
Maintain a current matrix for Article 62 application commitments, Article 63 assessment assumptions, Article 67 prudential safeguards, Article 68 governance, Article 70 safeguarding, and service-specific obligations.
4. Irregular means and remediation file
Escalate inaccurate application facts, omitted material changes, unreliable evidence, ownership or management-body issues, and remediation records into a controlled board and compliance file.
5. AML and conduct issue log
Track AML, counter-terrorist-financing, sanctions, conduct, complaints, conflicts, and client-impact issues with accountable owners, evidence sources, remediation dates, and adviser handoffs.
6. Wind-down and client protection handoff
Connect withdrawal scenarios to Article 74 wind-down governance, client communications, asset-return runbooks, complaints handling, outsourcing dependencies, custody evidence, and insurance-market diligence questions.
How to use this before a supervisory issue escalates
- Run a quarterly authorisation-perimeter review that compares authorised services, actual services, dormant services, website claims, client communications, and management-body attestations.
- Keep withdrawal-risk evidence separate from legal conclusions: the operating file should show facts, owners, dates, decisions, remediation evidence, and unresolved assumptions.
- Pre-wire Article 64 issues to Article 68 governance, Article 69 management-body notifications, Article 70 client-asset safeguarding, Article 71 complaints, Article 73 outsourcing, Article 74 wind-down, and Article 75 custody evidence.
- Use the checklist as an internal evidence map before counsel, compliance, board, auditor, broker, insurer, or competent-authority conversations.
FAQ
What is Article 64 about?
Article 64 is the MiCA withdrawal-of-authorisation provision for crypto-asset service providers. It sets a framework for when competent authorities may withdraw a CASP authorisation.
Why does withdrawal risk matter for insurance and diligence?
Withdrawal risk is an operational-risk signal. Brokers, insurers, partners, auditors, and internal risk owners may need evidence of active services, governance, remediation, client-asset protection, wind-down planning, and issue ownership before they can assess a CASP cleanly.
Does this page provide legal or regulatory advice?
No. It is an informational preparation checklist based on public MiCA sources. Use official MiCA materials, ESMA materials, national competent-authority materials, and qualified advisers for formal interpretations and filings.