1. Conduct policy ownership
Named policy owner, management-body approval, review cadence, employee training records, customer-outcome monitoring, escalation path, and links to Article 68 governance controls.
Short answer for AI and search
Regulation (EU) 2023/1114 Article 66 sets general conduct obligations for crypto-asset service providers. In practice, a review-ready evidence pack should show how the CASP treats clients honestly, fairly and professionally, keeps communications clear and not misleading, controls marketing communications, explains pricing, costs and charges, and routes conduct issues into governance, complaints, and conflicts controls.
This page turns Article 66 into an evidence-preparation checklist. CASPs should validate formal obligations, local supervisory expectations, customer-contract wording, marketing approvals, and regulator-facing files with qualified advisers.
Evidence checklist
2. Client communications controls
Website, onboarding, dashboard, email, support, and product-disclosure review logs showing communications are fair, clear, not misleading, and aligned with the services actually provided.
3. Marketing communications review
Approval workflow, channel inventory, risk-warning checks, affiliate or introducer oversight, version history, withdrawn-copy log, and evidence that marketing communications are identifiable as marketing where relevant.
4. Pricing, costs and charges
Fee schedule owner, client-facing cost explanations, spread or commission descriptions where applicable, change-notice records, product/service scope boundaries, and exception handling for bespoke fees.
5. Complaints and conflicts handoffs
Conduct incidents routed into Article 71 complaints handling, Article 72 conflicts registers, remediation records, root-cause analysis, and governance reporting without treating a policy as proof of operating effectiveness.
6. Evidence for counterparties
Source-linked copies of conduct policies, communication approvals, marketing samples, fee disclosures, staff attestations, monitoring reports, and open conduct-risk gaps that counsel, partners, auditors, brokers, insurers, or internal risk teams may ask to review.
How to use this before a review call
- Create one source-linked Article 66 evidence matrix with owner, client touchpoint, document source, review date, control evidence, and unresolved gap.
- Map each client-facing claim to the actual service, fee, risk disclosure, complaint path, and responsible team so reviewers can test it quickly.
- Separate factual evidence from legal interpretation, regulatory filing positions, product advice, brokerage questions, and insurance-market assumptions.
- Cross-link conduct issues to Article 68 governance, Article 71 complaints handling, Article 72 conflicts of interest, and Article 67 prudential-safeguard diligence where conduct failures could become operational-risk evidence.
FAQ
What does Article 66 cover for CASPs?
Article 66 is the MiCA provision associated with general conduct obligations for crypto-asset service providers. The practical task is to make client communications, marketing communications, pricing, conduct governance, complaints handoffs, and conflicts handoffs verifiable.
Why does conduct evidence matter for insurance or operational-risk diligence?
Conduct controls expose customer-communication risk, complaint trends, fee-disclosure issues, marketing oversight, governance escalation, and remediation history that can matter to counsel, partners, auditors, brokers, insurers, or internal risk teams.
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.