ESMA_QA_2746

Status: ⏳ Pending / Forwarded to EC

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Regulatory Context

Level 1 Regulation: MiCA

Topic: Crypto-Asset Service Provider (CASP)

Subject Matter: CASP Group Structure under MiCA

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Question

Submission Date: 05-01-2026

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 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?

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ESMA Answer

No answer has been published yet for this question.

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This document was automatically extracted from the ESMA EMIR Q&A database.