Module 2 · Chapter 3

The Application

A crypto firm must be authorised before it serves clients. This chapter follows one application: what the file contains, how the regulator's deadlines run, and why most of the delay was the firm's own.

≈ 10 min read 8-question test

In this chapter

  • What an application file contains, and who owns each item
  • How the regulator's deadlines run, and what stops them
  • How much capital a crypto firm must hold, and why

3.1Authorisation in one paragraph

Before a firm may provide crypto-asset services, the regulator examines its whole business. It looks at the firm's capital, its people, its custody, its technology and its plan for closing. Then it names, in writing, the services the firm may provide (Article 59). MiCA gives the regulator short deadlines, but they start only when the file is complete.

Halcyon's application took eight months, mostly spent finishing its own file.

Key point

Completeness is the clock. The regulator's deadlines run only on a complete file. While an item is missing, no deadline runs, and the delay belongs to the firm.

Also in this chapter

  1. Why registration was not enough
  2. What the file must contain
  3. How the regulator's deadlines run
  4. The three gaps
  5. Directors must be fit and proper
  6. How much capital a firm must hold
  7. The real deadline: the end of the transitional period
  8. Your job

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