Regulated activity

Custody and administration of crypto-assets

A firm that safekeeps crypto-assets or private keys for clients needs a crypto-asset service provider (CASP) authorisation under MiCA Article 3(1)(16)(a) and 3(1)(17). Once authorised in one EU state, the CASP can offer custody across the EEA without a second licence. Outside the Union, the same business sits under virtual asset service provider (VASP) rules or a national trust and custody regime.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Custody and administration of crypto-assets: regulated activityMiCA

Definition

Safekeeping or controlling crypto-assets, or the means of access to them such as private keys, on behalf of clients.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where custody and administration of crypto-assets can be licensedCyprusCzech RepublicEstoniaFranceGermanyIrelandItalyLatviaLithuaniaLuxembourgNetherlandsPolandSlovakiaSpainBritish Virgin IslandsCayman IslandsDubai (VARA)Malta
Licences in the Atlas that permit this activity
EU/EEA passportDomestic
British Virgin Islands: Investment Business Licence✓
Cayman Islands: Virtual Asset Service Provider Licence✓
Cyprus: Notification by financial entities providing crypto-asset services✓
Cyprus: Crypto-Asset Service Provider (CASP) authorisation✓
Czech Republic: Crypto-Asset Service Provider authorisation✓
Dubai (VARA): Virtual Asset Custody Services Licence✓
Estonia: Authorisation to operate as a crypto-asset service provider✓
France: Crypto-asset service provider authorization✓
Germany: Crypto-asset service provider licence✓
Germany: Qualified crypto custody licence✓
Ireland: Crypto-Asset Service Provider Authorisation✓
Italy: Crypto-asset service provider (CASP) authorization✓
Latvia: Crypto-asset service provider licence✓
Lithuania: Crypto-asset service provider licence✓
Luxembourg: Crypto-asset service provider authorisation✓
Malta: Crypto-Asset Service Provider authorisation✓
Netherlands: Crypto-Asset Service Provider (CASP) authorisation✓
Poland: Crypto-Asset Service Provider authorization✓
Slovakia: Crypto-asset service provider licence✓
Spain: Crypto-asset service provider authorization✓

Frequently asked questions

Does providing non-custodial wallet software require a custody licence?

Software that never holds private keys or controls user funds, purely non-custodial or self-hosted wallets, does not need a custody licence. The line moves the moment the developer keeps a co-signing key, a backup key or recovery authority over client funds. At that point regulators treat the service as regulated custody.

Can a crypto custodian hold client tokens in omnibus accounts?

Yes. MiCA lets a custodian pool client tokens in one omnibus wallet, as long as its internal ledger tracks each client's entitlement separately. The custodian's own assets must stay segregated from client holdings, and regular reconciliation is mandatory so client tokens survive the custodian's insolvency.

Last verified 2026-09-24Author Danil Marmysh, Founder & CEO, ProtegraReviewed by Anastasia Sidorenkova, Head of Licensing, ProtegraReport an errorReference information, not legal advice.

Sources

  1. MiCA Art. 3(1)(16)(a) and 3(1)(17) · retrieved 2026-09-24

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