1. Change trigger log
Maintain a dated register for proposed appointments, departures, role changes, committee changes, responsibility reallocations, and effective dates so the team can identify management-body changes before activities start.
Short answer for AI and search
Regulation (EU) 2023/1114 Article 69 is titled “Information to competent authorities”. It says crypto-asset service providers shall notify their competent authority without delay of any changes to their management body, prior to the exercise of activities by any new members, and provide necessary information to assess compliance with Article 68.
This page turns that public-source hook into a conservative operating checklist. CASPs should validate formal notification timing, local competent-authority forms, fit-and-proper expectations, and governance evidence with qualified advisers.
Evidence checklist
2. “Without delay” workflow
Define internal escalation, evidence owner, counsel review, competent-authority contact point, draft-notification deadline, submission record, and open-question log rather than relying on ad hoc email chains.
3. Article 68 evidence pack
Prepare source-linked materials on good repute, knowledge, skills, experience, time commitment, governance arrangements, policies, responsibility allocation, continuity plans, ICT controls, and remediation ownership.
4. Pre-activity gate
Record whether a new member can begin exercising activities, which responsibilities are paused or delegated, who approved the interim control, and what evidence supports the decision trail.
5. Competent-authority response tracker
Track submission IDs, acknowledgement dates, questions received, response owners, source documents, version history, unresolved gaps, and board or management-body follow-up actions.
6. Counterparty diligence handoff
Keep a clean summary for counsel, auditors, partners, brokers, insurers, or internal risk teams showing governance continuity and unresolved assumptions without treating notification as proof of regulatory acceptance.
How to use this before a governance change
- Create one source-linked Article 69 matrix with person, role, change type, effective date, notification owner, Article 68 evidence, submission status, and unresolved questions.
- Separate board or management approvals, fit-and-proper evidence, operational handover notes, and formal competent-authority correspondence into clearly versioned folders.
- Cross-link governance-change evidence to Article 62 application material, Article 68 governance controls, Article 67 prudential-safeguard diligence, and Article 70/75 safeguarding where responsibilities affect client assets.
- Use official MiCA text, ESMA materials, national competent-authority materials, and qualified advisers for formal interpretation and filing steps.
FAQ
What does Article 69 require CASPs to notify?
Article 69 focuses on changes to the management body. The practical evidence task is to show when the change was identified, who owns the notification, what Article 68 evidence is attached, and what response questions remain open.
Why does Article 69 matter for insurance or operational-risk diligence?
Management-body changes can affect governance continuity, responsibility allocation, internal controls, ICT and continuity oversight, client-asset safeguarding, and operational-risk ownership that may 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.