MiCA compliance checklist for crypto-asset service providers
EU crypto-asset service provider (MiCA) · 8 deadlines
The MiCA rules for crypto-asset service providers (Regulation (EU) 2023/1114) have applied since 30 December 2024. Authorisation is only the start: they also bring yearly reviews of conflicts, governance and own funds, quarterly statements to clients, and periodic reviews of execution venues and suitability. This template adds them to Regmindr with the article behind each one.
The deadlines in this template
- Annual conflicts of interest policy reviewMiCA · At least once a year
Review the policy on conflicts of interest at least annually and take measures to address any deficiencies (MiCA Art. 72(4)).
- Annual review of the fixed overheads own-funds requirementMiCA · Once a year
Recalculate a quarter of the preceding year's fixed overheads and check your prudential safeguards still meet the higher of that and the permanent minimum capital (MiCA Art. 67(1)).
- Annual review of governance arrangementsMiCA · Periodically, once a year here
The management body assesses and periodically reviews the policies, arrangements and procedures for complying with MiCA, and corrects any deficiencies (MiCA Art. 68(6)).
- Annual evaluation of AML and ICT controlsMiCA · Regularly, once a year here
Evaluate the adequacy and effectiveness of your anti-money laundering and ICT mechanisms on a regular basis and address any deficiencies (MiCA Art. 68(8)).
- Quarterly statement of position to custody clientsMiCA · At least every three months
Send each client a statement of the crypto-assets you hold for them at least once every three months, and on request (MiCA Art. 75(5)).
- Quarterly portfolio management statementsMiCA · Every three months
Send portfolio management clients a periodic statement every three months, unless they can see up-to-date valuations online and have looked at one during the quarter (MiCA Art. 81(14)).
- Execution venue assessmentMiCA · Regularly, once a year here
Assess on a regular basis whether the execution venues in your order execution policy still give clients the best possible result (MiCA Art. 78(6)).
- Suitability reassessment of advised clientsMiCA · At least every two years
Review the suitability assessment of each client you advise or manage a portfolio for at least every two years after the initial assessment (MiCA Art. 81(12)).
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8 deadlines
What depends on your services
Some obligations apply only to certain services. Custody statements (Art. 75) apply to firms that hold crypto-assets for clients, portfolio statements and suitability reviews (Art. 81) to firms that advise or manage portfolios, and the execution venue assessment (Art. 78) to firms that execute orders. Untick what you don't offer.
Add DORA as well
Crypto-asset service providers are financial entities under DORA, so its ICT risk, testing and register of information deadlines apply too. Add the DORA template alongside this one.
Start with this template
Pick this template when you set up Regmindr, tick the deadlines that apply and check each date. Your team gets an email before each one is due.
Sources
This page is a summary, not legal or regulatory advice. The rules in the sources above take precedence.