ESMA · ESMA_QA_2933 Forwarded to EC/Public Consultation/Other

Technical roles of non-EU group entities in transaction signing and signing policies

Regulation
MiCA
Article
Article 3(1), points (15) and (17); Articles 59, 70, 72 and 75 (9); ESMA Opinion on broker models
Topic
Crypto-Asset Service Provider (CASP)
Submitted
2026-10-02
Browse MiCA Crypto Registry → More Q&As on this regulation →

Question

1. Can a non-EU (group) entity co-sign transactions without being considered to exercise control over EU client assets or provide custody? 2. Can a non-EU (group) entity alter signing policies without being considered to exercise control over EU client assets or provide custody?
No answer published yet.
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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.

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