MiCA Compliance Check - CASP 2026 Checklist
Assess MICA Regulation (EU Reg. 2023/1114) compliance with weighted CASP checklist. Authorization expiry 01/07/2026. Travel Rule no minimum threshold.
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Result
Fill out the checklist and press "Analyze Compliance" to view the MiCA report.
What must a CASP do for MiCA compliance by 01/07/2026?
A CASP must apply for authorization to the competent authority (in Italy: OAM or Bank of Italy) by 07/01/2026, end of the 18-month transitional period under Reg. (EU) 2023/1114 art. 143. Those already operating before MiCA can benefit from grandfathering by notifying their activity by 12/30/2024.
Is there a minimum threshold for the Travel Rule CASP-to-CASP with MiCA?
No. Reg. (EU) 2023/1113 art. 16 (Travel Rule EU) DOES NOT set a minimum threshold for transfers between CASPs. The Travel Rule applies to any amount between CASPs, even for a few euros or cents. This differs from the FATF Travel Rule which has a €/USD 1,000 threshold. Do not confuse the two regimes.
When does the temporary authorization regime for CASP MiCA expire?
The MiCA transitional regime for CASPs expires on 07/01/2026. It is calculated as: MiCA applicable from 12/30/2024 + 18 months of transition = 06/30/2026. As of 07/01/2026, an unauthorized CASP must cease operations. Source: Reg. (EU) 2023/1114 art. 143 para. 2.
What does the mandatory white paper for a crypto-asset under MiCA contain?
The MiCA white paper must include: issuer description, project details, crypto-asset information, rights and obligations, blockchain technology used, main risks, and complaint handling plan. For ART tokens, no minimum threshold applies: any issuance requires a white paper (Reg. (EU) 2023/1114 art. 17).
Who is the competent authority for CASPs in Italy?
In Italy, the OAM (Agents and Mediators Body) manages the Special Register of CASPs and accepts authorization applications. For significant CASPs, supervision falls to the Bank of Italy. For CASPs operating with crypto financial instruments, Consob also intervenes. Source: Reg. (EU) 2023/1114 art. 63 + D.Lgs. 129/2017 mod.
Does DORA also apply to CASPs subject to MiCAR?
Yes. CASPs fall under the scope of Reg. (EU) 2022/2554 (DORA - Digital Operational Resilience Act), effective from 17/01/2025. They must implement an ICT risk management framework, reporting of significant ICT incidents, digital operational resilience testing, and third-party ICT risk management. Simplified requirements apply to small CASPs.
How is it used?
- Select CASP type
Select the type of Crypto-Asset Service Provider (exchange, wallet, broker) and main activity. This determines which MiCA requirements apply to your specific situation.
- Answer the checklist
For each compliance area (authorization, governance, Travel Rule, etc.) select the status: Yes (completed), Partial (in progress), No (to do), N/A (not applicable). The Travel Rule applies to ANY amount between CASP - there is no minimum threshold.
- Analyze the result
The tool calculates the score for each section and overall, identifies the risk level (High if there's a "No" in a critical area), and generates a prioritized list of gaps.
- Prioritize gaps
The gap list is sorted by severity (weight × (1 - score)). Start with items having the highest score - often related to authorization, Travel Rule and AML/CFT, critical areas for MiCA.
MiCA and Travel Rule: obligations for VASPs in 2026
The MiCA Regulation (Reg. (EU) 2023/1114 - Markets in Crypto-Assets) is the first comprehensive European framework for crypto-assets. It fully applies from December 2024 and provides a 18-month transitional period for existing CASPs operating in the EU - the deadline is July 1, 2026. After this date, operating as a CASP without authorization is illegal in the EU.
The TFR Regulation (Reg. (EU) 2023/1113 - Transfer of Funds Regulation), alongside MiCA, governs the Travel Rule for crypto-assets. Unlike the FATF Travel Rule (threshold €/USD 1,000), the EU Travel Rule HAS NO MINIMUM THRESHOLD for CASP-to-CASP transfers. This is Pitfall #6 among the most common compliance analysis errors: do not confuse the two regimes.
CASP must collect and transmit the data of the originator and beneficiary for EVERY transfer between CASP, regardless of amount. The technical compliance system must support the Travel Rule for any value, including micropayments and amounts less than €1.
This checklist assesses 7 critical areas: CASP authorization, governance, prudential requirements, AML/CFT, disclosure (white paper), custody, and Travel Rule. Areas marked as "critical" (authorization, AML/CFT, Travel Rule) require full compliance: a single "No" in these areas raises the risk level to "High" (rule BR003).
The tool does not replace specialized legal advice. For submitting the CASP authorization application, contact an expert in financial markets and crypto-asset law. MiCA deadlines are binding and European regulators have stated that no further extensions will be granted.
Practical example: Italian CASP exchange
Consider an Italian crypto asset exchange (CASP Class 2 for custody and trading services) operational before December 2024. Thanks to the grandfathering regime, it notified its activity to the OAM by December 30, 2024, and can continue operating until July 1, 2026, while completing the formal authorization application.
Areas where CASP must focus prioritarily: (1) Travel Rule - implement a technical system by end 2025 to collect ordering/beneficiary data on EVERY CASP-to-CASP transfer without minimum threshold; (2) AML/CFT - update KYC procedures for TFR requirements; (3) Authorization - submit formal application with complete documentation (fit-and-proper, minimum capital, governance) by May 2026 to have leeway before deadline.
Typical result with partially completed checklist: HIGH risk level if any Travel Rule or AML item is "No". Risky because the competent authority may revoke the temporary regime if it finds serious compliance deficiencies during inspections.
MICA & Travel Rule Glossary
- CASP (Crypto Asset Service Provider)
- Authorized crypto-asset service provider under Reg. (EU) 2023/1114 (MiCA). Includes exchange, custodial wallet, broker, trading platform. Must obtain authorization from the competent authority for each service offered (Art. 59 MiCA).
- Transfer of Funds Regulations
- Reg. (EU) 2023/1113: obligation to transmit data of originator and beneficiary for each crypto-asset transfer between CASP. NO MINIMUM THRESHOLD for CASP-to-CASP transfers (art. 16). Different from FATF Travel Rule with €/USD 1,000 threshold. Applies from 30/12/2024.
- ART (Asset-Referred Token)
- Multi-asset crypto-asset referring to values or rights across multiple fiat currencies, commodities, or crypto-assets (e.g., multi-asset stablecoins). Subject to stricter MiCA requirements (Title III). Any issuance requires an approved white paper by the competent authority - no minimum market cap threshold.
- Temporary regime (grandfathering)
- 18-month period (12/30/2024 - 07/01/2026) during which existing CASPs in the EU can continue to operate if they notify their activity to the competent authority by 12/30/2024. Formal authorization required after 07/01/2026 (Art. 143 MiCA).
- Fit and proper attire
- Integrity, competence, and independence requirements for CASP board members (Art. 68 MiCA). Verified by the competent authority during authorization. Includes: no significant criminal convictions, financial sector experience, absence of major conflicts of interest.