ESMA · ESMA_QA_2746 Question Published

CASP Group Structure under MiCA

Regulation
MiCA
Topic
Crypto-Asset Service Provider (CASP)
Submitted
2026-01-05
Browse MiCA Crypto Registry → More Q&As on this regulation →

Question

Under the MiCA framework, can a group structure be set up whereby a non-regulated holding acts as the principal commercial counterparty towards customers (including entering into customer contracts, maintaining customer relationships, and issuing invoices), while a licensed Crypto-Asset Service Provider (CASP) within the same group (daughter company) performs and executes the regulated crypto-asset services? In such a structure, would it be permissible for the CASP to provide the regulated services without directly contracting with, or invoicing, the end customers, provided that all MiCA requirements (including governance, outsourcing, conflict of interest, and conduct of business rules) are appropriately met?
No answer published yet.
View original on European Securities and Markets Authority ↗

This Q&A is published by European Securities and Markets Authority and is non-binding. It does not constitute legal advice. Updated weekly from official ESA sources.

Similar Q&As

Commingling clients’ crypto-assets with crypto-assets from other entities of the group when acting as custodian

Answered 2025-06-17

Crypto-Asset lending services under MiCA

Answered 2026-06-18

Tied agents under MiCA

Answered 2024-09-12

Proprietary trading under MICA

Answered 2025-06-06

Payouts in fiat currency by CASPs in the context of exchange services

Answered 2026-02-18

More Q&As on this topic

Crypto-Asset lending services under MiCA

Answered 2026-06-18

Perimeter of advice under MiCA compared to MiFID II

Answered 2026-06-18

Overlap between offers of crypto-assets and placing

Answered 2026-02-18

Clarification on Withdrawal Requirements under Article 75 of MiCA for CASPs

Answered 2026-02-18

Payouts in fiat currency by CASPs in the context of exchange services

Answered 2026-02-18

📋 Track EU financial regulation continuously

Forseti monitors EU financial regulation and delivers personalised alerts anchored to verified official sources.

Start free trial → Learn more

14-day free trial. No credit card required.