MiCA acquisition control evidence

MiCA Article 84 CASP acquisition assessment checklist

A source-backed, conservative evidence checklist for proposed CASP acquisitions and qualifying-holding changes under Regulation (EU) 2023/1114 Article 84.

Informational only. Not legal, regulatory, brokerage, underwriting, or insurance advice.

What Article 84 changes operationally

Content of the assessment of proposed acquisitions: Regulation (EU) 2023/1114 Article 84 addresses the content of the assessment of proposed acquisitions of crypto-asset service providers. After Article 83 identifies the qualifying-holding notification path, Article 84 turns the transaction into an evidence file: the reputation of the proposed acquirer, the reputation, knowledge, skills and experience of people who will direct the CASP, financial soundness, the CASP's ability to comply and continue to comply, and money laundering or terrorist financing risk.

This page is an evidence-preparation checklist. It is not a legal interpretation, transaction recommendation, ownership approval opinion, acquisition filing guide, broker recommendation, or assurance that a proposed transaction will be accepted.

Assessment evidence matrix

Proposed-acquirer reputation

Maintain source-backed identity, ownership, regulatory-history, sanctions/adverse-media, conflict, and governance notes for each direct or indirect proposed acquirer or acting-in-concert group.

People directing the CASP

Map the reputation, knowledge, skills and experience of any person who will direct the business after the acquisition, with handoffs to Article 68 management-body evidence.

Financial soundness

Document funding sources, group support assumptions, business-plan fit, solvency-sensitive dependencies, prudential-safeguard impacts, and any broker, insurer, auditor, or counsel questions that need qualified review.

Continued compliance

Show how the CASP will comply and continue to comply with Title V after the ownership change: governance, conduct, client assets, outsourcing, custody, complaints, conflicts, ICT, records, and service-specific procedures.

AML/CTF risk file

Prepare financial-crime ownership, FIU/AML consultation readiness, beneficial-owner evidence, source-of-funds notes, high-risk jurisdiction assumptions, and transaction-risk escalation records.

Operating-model handoffs

Connect Article 84 findings to Article 62 application files, Article 67 prudential safeguards, Article 70 safeguarding, Article 73 outsourcing, Article 75 custody, and any insurance diligence questions.

Review-ready tracker

FAQ

What does MiCA Article 84 cover?

Article 84 concerns the content of the competent-authority assessment of proposed CASP acquisitions, including acquirer reputation, management fitness, financial soundness, continued compliance, and money laundering or terrorist financing risk.

How does Article 84 connect to Article 83?

Article 83 is the proposed-acquisition notification and process article. Article 84 describes the criteria that make the acquisition evidence file review-ready.

Why mention Commission Delegated Regulation (EU) 2025/414?

Commission Delegated Regulation (EU) 2025/414 is a related RTS on acquisition of qualified holding in CASPs. The directory cites it as a source-backed hook for evidence planning, not as a substitute for legal review.