MiCA — the Markets in Crypto-Assets Regulation (EU) 2023/1114 — is the European Union's comprehensive crypto-asset framework. It has been fully applicable since 30 December 2024 for crypto-asset service providers (CASPs), and since 30 June 2024 for asset-referenced tokens (ARTs) and electronic-money tokens (EMTs).

Who needs to comply with MiCA?

Any natural or legal person providing one or more of the ten regulated crypto-asset services (custody, exchange, trading platform operation, brokerage, advice, portfolio management, transfer, placement, reception, execution) to clients in the European Union, plus issuers of asset-referenced tokens and e-money tokens.

What is the minimum capital requirement?

€50,000 for advice / reception-and-transmission services (Class 1), €125,000 for custody and trading-platform operation (Class 2), and €150,000 for principal-on-own-account services (Class 3). Issuers of significant asset-referenced tokens face additional ongoing capital requirements of 3% of average reserve value.

Is this checklist legal advice?

No. This checklist is informational only. MiCA implementation depends on your specific business model, member-state competent authority, and the Level 2 / Level 3 technical standards published by ESMA and the EBA. Always consult MiCA-qualified counsel before applying for CASP authorization.

MiCA Compliance Checklist (25 Questions) — Free Tool

25 questions to self-assess your readiness as a crypto-asset service provider (CASP) under EU Regulation 2023/1114. Tick the boxes that apply, get a score plus per-category breakdown. Print to PDF for your file.

Use this as a pre-filing diagnostic before engaging counsel. The questions map to the five readiness pillars examined by national competent authorities (NCAs) like BaFin, AMF, AFM, MFSA, the Central Bank of Ireland and Bank of Lithuania during CASP authorisation. For background see our EU jurisdiction guide.

1. Authorization (Articles 59-65)

CASP authorisation pillar — establishment, capital, licence application.

Q1.The legal entity is established in an EU/EEA member state (or has applied for branch authorisation under Article 60).

Q2.You have submitted (or are preparing) a CASP authorisation application to your national competent authority (NCA) under Article 62.

Q3.You hold initial capital that meets the class minimum: €50K (Class 1 — advice/reception/transmission), €125K (Class 2 — custody/trading platform), or €150K (Class 3 — principal-on-own-account).

Q4.You have identified the regulated services in scope (Article 3(1)(16): custody, exchange, trading platform, brokerage, advice, portfolio management, transfer, placement, reception & transmission, execution).

Q5.You have a transition / passport plan if you operated under a national pre-MiCA regime (PSAN, BaFin Crypto-Verwahr, etc.) and need the Article 143 grandfathering window.

2. Governance & substance (Articles 68-70)

Fit-and-proper, EU-resident management, board structure, conflicts of interest.

Q6.You have a documented fit-and-proper assessment for every member of senior management and qualifying shareholder (≥10% holding).

Q7.At least one senior manager (typically the CEO or designated executive director) is resident in the authorising member state and physically present at the office.

Q8.You operate a written governance framework covering board composition, committee structure, internal audit, and reporting lines (per ESMA RTS).

Q9.You maintain a conflicts-of-interest policy with documented identification, prevention, management and disclosure procedures.

Q10.You have an outsourcing policy covering critical and important functions (DORA Article 28-30 + MiCA Article 73).

3. AML / CFT (AMLR, AMLD6, TFR)

Travel-rule, KYC/CDD, sanctions, AMLA-readiness.

Q11.You are registered with the national AML supervisor (BaFin AML, Tracfin, AFM, FIU-Lithuania, MFSA AML, etc.) and have appointed a designated AML/CFT compliance officer.

Q12.You are Travel Rule compliant — every transfer ≥ €1,000 carries originator and beneficiary information per Regulation (EU) 2023/1113 (TFR).

Q13.You apply customer due diligence (CDD) at onboarding, plus enhanced due diligence (EDD) for self-hosted-wallet transfers ≥ €1,000 and high-risk jurisdictions.

Q14.You screen all customers and transactions against EU consolidated sanctions, OFAC SDN and UN sanctions lists in near-real-time.

Q15.You have a Suspicious Activity Report (SAR/STR) pipeline and a documented record-keeping regime of at least five years for transactions and CDD evidence.

4. Operational resilience (DORA + MiCA Articles 67, 70)

Segregation, ICT, business continuity, complaint handling.

Q16.Client crypto-assets and funds are segregated from proprietary holdings on-chain and in books and records (Article 70).

Q17.You have a documented cybersecurity policy aligned with DORA — ICT risk management framework, asset inventory, vulnerability management, multi-signature key custody.

Q18.You have a written business continuity / disaster recovery plan tested at least annually (DORA Article 11).

Q19.You have a complaint-handling procedure with a single point of contact, response SLA, and quarterly metrics (per ESMA Level 2 RTS on complaints).

Q20.You report ICT-related major incidents to your NCA within DORA's prescribed windows (initial within hours, intermediate, final).

5. Stablecoin specifics (MiCA Title III, only if you issue ART/EMT)

Skip if you are not an issuer. Article 16-58 obligations.

Q21.You have classified your token as either ART (asset-referenced — Article 16) or EMT (e-money token — Article 48) and have selected the corresponding issuer authorisation.

Q22.Your reserve composition is published monthly with a third-party attestation, and the reserve is segregated, bankruptcy-remote and held with a credit institution or qualifying custodian.

Q23.You have a published whitepaper meeting the Article 19 / 51 content requirements, notified to your NCA at least 20 working days before public offering.

Q24.You honour redemption at par on demand (or within the prescribed window for ARTs) and disclose redemption mechanics on a permanent durable medium.

Q25.You monitor the Article 23 thresholds (1M tx/day or €200M/day daily volume as means of payment) for non-EUR stablecoins, with a circulation cap and reporting framework if applicable.

Your MiCA Compliance Report

Generated

0 / 25

Tick at least one box to score.

Informational only — not legal advice. MiCA implementation depends on your member-state competent authority, services in scope, and ESMA / EBA Level 2-3 technical standards as updated through 2026. Consult MiCA-qualified counsel before applying for CASP authorisation.

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