Regulated activity

Execution of orders for crypto-assets on behalf of clients

A firm that concludes buy or sell agreements on a client's behalf needs a CASP authorisation under MiCA Article 3(1)(16)(e) and 3(1)(21). The EU licence passports across the EEA without a separate application. Outside the Union, the same client order execution business sits under VASP rules, or under national broker-dealer and securities law.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Execution of orders for crypto-assets on behalf of clients: regulated activityMiCA

Definition

Concluding agreements to buy or sell crypto-assets on behalf of clients, including subscribing to offers.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where execution of orders for crypto-assets on behalf of clients can be licensedCyprusCzech RepublicEstoniaFranceGermanyIrelandItalyLatviaLithuaniaLuxembourgNetherlandsPolandSlovakiaSpainDubai (VARA)Malta
Licences in the Atlas that permit this activity
EU/EEA passportDomestic
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 Broker-Dealer Services Licence✓
Estonia: Authorisation to operate as a crypto-asset service provider✓
France: Crypto-asset service provider authorization✓
Germany: Crypto-asset service provider 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

What best execution obligations apply to crypto order execution?

MiCA requires the broker to take all reasonable steps to get the best result for the client, weighing price, cost, speed and the likelihood of execution and settlement. The firm must write down an order execution policy and disclose which venues it routes client orders to on a regular basis.

Can a firm execute client crypto orders against its own inventory?

Some jurisdictions allow it under strict disclosure, but MiCA sets firm limits. Client orders must be handled fairly and without front-running, and the client's interest comes before the broker's own inventory or an affiliate trading desk. Structural conflicts of interest still have to be managed and disclosed.

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)(e) and 3(1)(21) · retrieved 2026-09-24

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