Key Takeaways
- • MiCA's CASP license does not authorize payment services, derivatives trading, or futures operations—founders pursuing MiCA authorization alone face a critical regulatory gap if their business model depends on any of these services, requiring separate licensing frameworks.
- • The regulatory scope of MiCA covers ten categories of crypto-asset services including custody, exchange, execution, routing, advice, and portfolio management, but this "substantial" coverage is not complete for full-stack crypto platform operations.
- • Crypto founders commonly assume MiCA authorization represents the finish line for EU compliance, when in fact it addresses only a portion of their regulatory obligations; the remainder depends on which specific services the platform actually provides.
- • Payment services and derivatives require entirely different regulatory frameworks beyond the CASP license structure, creating operational and legal exposure for platforms that operate across multiple service categories without proper segmentation and authorization.
Summary
The tenth installment of LegalBison's MiCA Decoded series, a collaborative weekly column by Co-Founding and Managing Directors Aaron Glauberman, Viktor Juskin, and Sabir Alijev, directly challenges a widespread misconception among crypto and fintech founders pursuing European regulatory compliance. Most market participants view a Crypto-Asset Service Provider (CASP) license as the definitive endpoint of EU compliance—apply, wait for authorization, and operate across the EU. This framing fundamentally misinterprets what MiCA actually permits.
A CASP license grants permission to provide specific crypto-asset services as defined in the regulation, but it explicitly does not authorize payment institution operations, electronic money issuance, or derivatives trading venue operations. These activities fall under entirely separate regulatory regimes. For platforms whose commercial models depend on one or more of these services, the MiCA license alone leaves a material operational and legal gap. The article maps this gap service by service, demonstrating that the assumption of full-stack authorization through a single CASP license is a significant error.
While MiCA is comprehensive in scope—covering ten categories of crypto-asset services spanning custody, exchange, execution, routing, advice, and portfolio management—this breadth of coverage does not equate to completeness for multi-service platforms. The regulation covers "substantial" portions of retail crypto platform operations but not the complete service offering many platforms require. LegalBison's expertise in advising crypto and fintech companies on MiCA licensing, VASP applications, and regulatory structuring across Europe positions this analysis as authoritative guidance for institutional investors evaluating crypto platform compliance posture and operational risk in EU markets.
A CASP license grants permission to provide specific crypto-asset services as defined in the regulation, but it explicitly does not authorize payment institution operations, electronic money issuance, or derivatives trading venue operations. These activities fall under entirely separate regulatory regimes. For platforms whose commercial models depend on one or more of these services, the MiCA license alone leaves a material operational and legal gap. The article maps this gap service by service, demonstrating that the assumption of full-stack authorization through a single CASP license is a significant error.
While MiCA is comprehensive in scope—covering ten categories of crypto-asset services spanning custody, exchange, execution, routing, advice, and portfolio management—this breadth of coverage does not equate to completeness for multi-service platforms. The regulation covers "substantial" portions of retail crypto platform operations but not the complete service offering many platforms require. LegalBison's expertise in advising crypto and fintech companies on MiCA licensing, VASP applications, and regulatory structuring across Europe positions this analysis as authoritative guidance for institutional investors evaluating crypto platform compliance posture and operational risk in EU markets.
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