Authorization of crypto-assets service providers under MiCA

Depending on whether an entity wishing to offer crypto-asset services under MiCA has already obtained a particular licence in the EU, two distinct routes are available:

For financial institutions already authorized under existing EU financial directives—such as credit institutions, central securities depositories, investment firms, market operators, electronic money institutions, and fund management companies—MiCA outlines a more streamlined pathway. These entities are not subject to the full authorization requirements but instead are required to fulfill a notification obligation to the competent authorities. The regime is therefore simplified.
For entities not covered by existing EU financial directives, the full authorization process is applicable. This requires a comprehensive application to be submitted to the competent authority, which shall include, inter alia, the entity's articles of association, program of operations, a detailed description of governance arrangements, internal control mechanisms, as well as risk and AML procedures. As a consequence, this process will be more cumbersome, time-consuming, and will require substantial preparation beforehand.