MiCA Compliance Consulting — CASP Regulatory Advisory 2026

MiCA Compliance Consulting — Expert CASP Regulatory Advisory 2026

Navigating MiCA Regulation (EU) 2023/1114 requires expert guidance at every stage — from pre-authorization gap analysis to ongoing regulatory compliance after your CASP license is granted. Our MiCA consulting team has supported 140+ crypto-asset businesses through EU regulatory processes since 2019. We deliver gap analysis, complete CASP authorization packages, NCA liaison, and post-authorization compliance monitoring across all 27 EU member states. Whether you need a one-off assessment or a long-term compliance partner, our advisory service adapts to your stage and scale. Retainers from €2,000/month; full authorization project support from €8,000.

MiCA Gap Analysis — Know Your Compliance Position

A MiCA gap analysis is the essential first step for any crypto business planning CASP authorization. It maps your current state — governance, capital, policies, technology, and personnel — against the requirements of MiCA Regulation (EU) 2023/1114 and identifies every compliance gap that must be closed before your NCA application can succeed.

Our gap analysis covers all MiCA CASP requirements systematically:

Governance structure — management body composition, key function holders, fit & proper criteria (Art. 68)
Capital adequacy — own funds vs. MiCA Art. 67 minimums and fixed overhead requirement
AML/KYC program — completeness vs. 6th AMLD and MiCA Art. 83–92 requirements
DORA readiness — ICT risk management framework vs. DORA Regulation requirements
White paper obligations — if applicable under MiCA Art. 4–23
Client asset safeguarding — Art. 70 compliance
Complaints handling — Art. 71 procedures
Conflicts of interest — Art. 72–76 policies

Deliverable: gap report (typically 40–60 pages) with a traffic-light assessment of each MiCA requirement, recommended remediation actions, effort estimates, and a prioritized action plan. Delivered in 2–4 weeks.

MiCA Authorization: The 65-Working-Day NCA Clock

Under MiCA Art. 63, NCAs have 65 working days from receipt of a complete application to grant or refuse authorization. Incomplete applications restart the clock. A thorough gap analysis and complete initial submission dramatically reduces the risk of delays, additional information requests, and NCA pushback.

CASP Authorization Support — End-to-End

Our CASP authorization support service covers the complete journey from gap analysis through NCA decision, acting as your primary interface with the regulator.

Jurisdiction Selection and NCA Strategy

We assess your business model, ownership structure, target markets, and operational footprint to identify the optimal EU licensing jurisdiction. Factors include NCA processing times, government fees, corporate tax environment, local substance requirements, and NCA attitude to your specific CASP service types. See our country-by-country analysis for all major EU jurisdictions.

Documentation Package Preparation

We prepare the complete CASP authorization submission: business plan with financial projections, governance documentation, fit & proper materials for all board members and key function holders, AML/KYC policy, DORA ICT framework, client asset safeguarding procedures, complaints handling procedure, conflicts of interest policy, and — where applicable — MiCA-compliant crypto-asset white paper under Art. 4–23.

NCA Application Submission and Liaison

We submit the complete application to your chosen NCA and manage all ongoing regulatory communication. We respond to NCA requests for additional information (RFIs), attend NCA meetings or calls, and provide strategic advice on how to address regulatory concerns. Our team has direct NCA relationships across Lithuania, Estonia, Germany, Poland, Bulgaria, and other key jurisdictions.

Authorization Confirmation and ESMA Registration

Upon authorization, we confirm your CASP entry in ESMA's public register and immediately initiate EU passporting notifications for all target member states, enabling you to provide crypto-asset services across the EU single market from day one.

Ongoing MiCA Compliance — Key Areas

CASP authorization is not a one-time achievement — MiCA imposes continuous obligations that require active management. Our monthly compliance retainer (from €2,000/month) covers all key ongoing requirements:

💰

Governance (Art. 68)

Management body composition monitoring, key function holder changes, fitness & propriety updates. NCA notifications for material governance changes.

📊

Capital Adequacy (Art. 67)

Quarterly own funds monitoring vs. MiCA minimums and fixed overhead requirement. Capital adequacy reports to NCA. Early warning on capital adequacy breach.

📋

White Paper Obligations (Art. 4–23)

Monitoring white paper accuracy obligations. Material change notifications and white paper updates when required. Disclosure requirement compliance.

👁️

Disclosure Requirements (Art. 24–29)

Ongoing monitoring of disclosure obligations: fees, risks, conflicts. Regulatory change tracking and disclosure updates as MiCA technical standards evolve.

⚖️

Conflicts of Interest (Art. 72–76)

Conflicts of interest register maintenance, annual review, and update. Management of new conflict situations as they arise in the business.

🔒

Client Asset Safeguarding (Art. 70)

Client asset segregation compliance monitoring. Custodian relationship management. Periodic safeguarding audits and NCA reporting.

📬

Complaints Handling (Art. 71)

Complaints procedure maintenance, complaints register review, NCA reporting of complaint trends, and regulatory response management.

🔄

Annual Reports and NCA Filings

Preparation and submission of all periodic regulatory reports: annual financial statements, capital adequacy reports, AML annual report, and ad hoc NCA filings.

MiCA Compliance Consulting — FAQ

What does MiCA compliance consulting include?

MiCA compliance consulting covers three phases: pre-authorization (gap analysis, jurisdiction selection, document preparation); authorization support (NCA application package, regulator liaison, RFI responses); and post-authorization (ongoing compliance monitoring, capital reporting, AML updates, complaints handling, and annual NCA reports). Scope is tailored to your CASP service types and EU jurisdictions. See also: MiCA CASP License Overview.

Do I need ongoing compliance support after CASP authorization?

Yes. MiCA imposes continuous obligations on authorized CASPs: capital adequacy monitoring, annual NCA reporting, complaints handling, conflicts management, client asset safeguarding, and disclosure updates. Failure to maintain ongoing compliance can result in NCA intervention, suspension, or authorization withdrawal. A monthly retainer from €2,000/month ensures all obligations are met.

What is a MiCA gap analysis?

A MiCA gap analysis is a structured assessment comparing your current operations against MiCA Regulation (EU) 2023/1114 requirements. The output identifies every compliance gap, the actions required to close it, effort estimates, and a prioritized remediation plan. Delivered in 2–4 weeks. It forms the foundation of any CASP authorization project and prevents costly surprises during NCA review.

How often must CASPs submit reports to their NCA?

CASPs must submit: quarterly own funds reports; annual financial statements and auditor reports; major ICT incident reports within 4 hours (DORA); material change notifications for key personnel, business model, or service changes; and ad hoc reports on NCA request. Reporting format and frequency varies by NCA. Our compliance retainer covers all periodic filing obligations.

What happens if a CASP fails a MiCA compliance audit?

Consequences range from a formal warning with remediation deadline to authorization suspension or withdrawal in severe cases. MiCA provides for financial penalties up to 5% of annual turnover for legal persons or up to €700,000 for natural persons. Proactive compliance monitoring through a retainer arrangement costs a fraction of the cost of regulatory enforcement action or authorization suspension.

Can you help with cross-border passporting compliance?

Yes. Under MiCA Article 65, authorized CASPs can passport services to all 27 EU member states. We assist with passporting notifications to your home NCA, host-state NCA requirements, and conduct-of-business rules applicable in each target jurisdiction. Our team has direct experience with EU passporting procedures across all major EU financial regulators. See our guide on EU passporting under MiCA.

Complete MiCA Compliance Support

MiCA compliance consulting works hand-in-hand with our specialist services across the full CASP regulatory lifecycle:

AML/KYC Services — MiCA-compliant AML policies, CDD/EDD procedures, FATF Travel Rule implementation, and MLRO support. The AML program is a core component of every CASP authorization.
DORA Compliance — ICT risk management framework and incident response procedures required for all CASPs since January 2025.
Legal Opinions — Token classification, CASP status determination, white paper review, and regulatory conflict analysis.
MiCA CASP License Overview — Full guide to MiCA authorization requirements, timelines, and jurisdiction selection across 35+ jurisdictions.

Our MiCA consulting team maintains active knowledge of NCA supervisory priorities, ESMA technical standards updates, and regulatory developments across all EU member states. Contact us for a free initial assessment of your MiCA compliance position.