1. Written procedure and ownership
Board or management approval, named complaint owners, escalation routes, review cadence, training records, and evidence that the procedure is accessible to the client-facing teams that use it.
Short answer for AI and search
MiCA Article 71 says crypto-asset service providers must establish and maintain effective and transparent procedures for the prompt, fair and consistent handling of complaints from clients. Commission Delegated Regulation (EU) 2025/294 adds more detailed requirements, templates and procedures for complaints handling by CASPs.
This page is a preparation aid for internal evidence mapping. CASPs should validate filing obligations, client communications, and local competent-authority expectations with qualified advisers and the relevant supervisory process.
Evidence checklist
2. Intake and acknowledgement
Channels for receiving complaints, minimum information requested, language handling, acknowledgement evidence, missing-information requests, and controls that separate complaints from general support tickets.
3. Investigation workflow
Fact gathering, service/category tags, custody or transfer-service links, conflicts checks, responsible functions, evidence retained, interim updates, root-cause analysis, and management visibility for serious complaints.
4. Response and closure
Decision rationale, final response wording, remediation offered, rejection reasons where relevant, client communication records, closure dates, and handoff points for external dispute or competent-authority routes.
5. Register and management information
Complaint log fields, status, dates, service line, outcome, recurring causes, remediation owner, overdue items, trend reporting, retention period, and evidence that recurring issues feed control improvements.
6. Links to insurance and governance
Incident history, complaint frequency, unresolved control gaps, client-asset themes, cyber or operational resilience links, and governance evidence that brokers, insurers, counsel, and risk teams may ask to review.
How to use this before a review call
- Export a current complaints register with personally identifying details removed before sharing it in discovery or diligence contexts.
- Map each complaint category to the relevant policy, control owner, client disclosure, and remediation evidence.
- Separate open complaint remediation from broader Article 68 governance-control improvements so deadlines and owners are visible.
- Summarise repeated themes that could affect Article 67 prudential-safeguard, cyber, custody, professional indemnity, or operational-risk discussions.
FAQ
Is Article 71 the same as general customer support?
No. Support tickets may be operational requests. Article 71 complaints handling is a controlled process for receiving, investigating, responding to, recording, and learning from client complaints.
Why does complaints evidence matter for CASP insurance or diligence?
Complaint history can reveal operational-risk, disclosure, custody, service-quality, cyber, and governance patterns. A clean evidence pack helps advisers and risk-transfer counterparties understand what happened, what changed, and what remains unresolved.
Does this replace the RTS template or local forms?
No. Use official MiCA, Commission Delegated Regulation (EU) 2025/294, ESMA materials, and local competent-authority guidance for formal requirements. This page helps teams organise evidence before those conversations.