MiCAR In Practice: Lessons From CASP Notifications And License Applications

The Markets in Crypto‑Assets Regulation (MiCAR) became fully applicable at the end of 2024 as the first EU‑wide regulatory framework for crypto‑asset services. This regulation provides harmonised rules across all Member States and replaces the previously fragmented national regimes. For crypto‑asset service providers (CASPs), MiCAR means they must obtain a license or, where possible, follow a notification procedure to top-up their existing license. Early experiences with both CASP license applications and CASP notifications offer valuable insights into the practical requirements and supervisory expectations.

In practice, both routes require clear, complete and well-substantiated documentation. The Dutch Authority for the Financial Markets (AFM) places particular emphasis on the quality and completeness of the information submitted, whether in the context of a CASP notification or a licence application.