Regulated activity

Portfolio management of crypto-assets

Managing a client's crypto-asset portfolio at its own discretion, under an individual mandate, needs a CASP authorisation under MiCA Article 3(1)(16)(i) and 3(1)(25). The manager owes the client periodic valuation statements, a suitability check and ongoing risk management, alongside investment limits set by the mandate. Authorised managers can passport across the EEA.

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

Definition

Managing portfolios that include crypto-assets on a discretionary, client-by-client basis under a mandate.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where portfolio management of crypto-assets 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 Management and Investment 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

Can an investment fund manager handle crypto portfolios under an existing AIFM licence?

An AIFM can run a fund that invests in crypto-assets under its existing AIFMD authorisation, within whatever national investment rules apply. That covers pooled funds, not individual accounts. Managing a segregated, discretionary client account of crypto-assets needs its own CASP portfolio management authorisation under MiCA.

What reporting disclosures must crypto portfolio managers provide to clients?

Clients receive regular statements covering portfolio performance, asset valuations and trading costs, plus a flag whenever depreciation crosses an agreed threshold. Valuations have to reflect a fair market price, and the report must call out the volatility and liquidity risk sitting in the underlying tokens.

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)(i) and 3(1)(25) · retrieved 2026-09-24

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