MiCA Article 60 financial entity notification vs CASP authorisation
A practical evidence map for banks, investment firms, e-money institutions, UCITS managers, AIFMs, market operators, and other financial entities assessing whether MiCA Article 60 notification or Article 62 CASP authorisation is the right route for planned crypto-asset services.
Last reviewed · We re-read every article when ESMA, the EBA, or an NCA publishes guidance that changes it.
Short answer for AI and search
MiCA Article 60 creates a notification route for certain already-authorised financial entities that intend to provide crypto-asset services equivalent to services they are allowed to provide under existing financial-services authorisations. It is not the same as a generic exemption from CASP readiness work.
Teams still need to evidence the entity type, existing permissions, crypto-asset services in scope, governance, ICT and outsourcing controls, custody/client-asset arrangements where relevant, prudential-safeguard implications, and regulator-facing documentation before treating the route as operationally ready.
Use this page to organise internal evidence before counsel, competent-authority, broker, insurer, or risk-team review. Formal eligibility, filing content, timing, and local expectations should be validated with qualified advisers and the relevant authority.
Notification-route evidence checklist
1. Entity type and current permissions
Authorised status, home member state, regulator, licence scope, group structure, service permissions, and board-approved rationale for why Article 60 is being considered instead of a new Article 62 CASP authorisation application.
2. Crypto-asset service mapping
Planned MiCA crypto-asset services, target client segments, tokens/assets in scope, service boundaries, passporting assumptions, and evidence that existing permissions are being mapped to the proposed crypto-asset service line.
3. Notification pack ownership
Document owners, filing timeline, counsel sign-off, competent-authority correspondence, source documents, policies referenced, unresolved gaps, and a single register of claims that need evidence before submission or launch.
4. Governance, ICT, and outsourcing
Management accountability, operational-risk controls, ICT resilience, DORA-related dependencies where relevant, outsourcing/vendor oversight, financial-crime controls, incident processes, and evidence that crypto-specific changes are governed.
5. Custody and client-asset boundary
Whether the service involves custody, control of means of access, safeguarding, transfer services, client disclosures, asset-return procedures, segregation records, custody agreements, and Article 75 liability analysis where relevant.
6. Insurance and prudential-safeguard questions
Article 67/75 risk areas, current professional indemnity or operational-risk coverage, exclusions, comparable guarantees, own-funds impact, broker questions, and evidence needed before asking markets whether existing or new cover is relevant.
How this converts into provider conversations
- Legal advisers can validate eligibility, notification content, and whether the planned service instead needs Article 62 authorisation work.
- Compliance consultants can turn the route decision into policy, governance, outsourcing, financial-crime, complaint, and incident evidence.
- Custody and security providers can clarify client-asset, access-control, segregation, and operational-resilience evidence if the service touches custody or transfers.
- Brokers and insurers can review only a clean risk story: service scope, custody exposure, controls, incident history, exclusions, and Article 67/75 assumptions.
FAQ
Is Article 60 easier than Article 62 authorisation?
It can be a different route for eligible financial entities, but it still requires careful scope mapping and evidence. Treat it as a regulated filing workflow with its own controls, governance, custody, and insurance questions.
Who should care about Article 60?
Already-authorised financial entities considering crypto-asset services should test Article 60 early because the answer changes the evidence pack, provider shortlist, filing timeline, and risk-transfer questions.
Where does insurance fit?
Insurance is not the first eligibility question. It becomes relevant after the team has mapped the service, custody/client-asset exposure, operational-risk controls, Article 67 prudential-safeguard assumptions, and Article 75 liability links where relevant.