Regulated activity

Transfer services for crypto-assets

Moving a client's crypto-assets between distributed-ledger addresses or accounts needs a CASP authorisation under MiCA Article 3(1)(16)(j) and 3(1)(26). The EU authorisation passports across the EEA. Outside the Union, the same transfer business sits under VASP rules that implement the FATF travel rule instead.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Transfer services for crypto-assets: regulated activityMiCA

Definition

Moving crypto-assets on behalf of a client from one distributed-ledger address or account to another.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where transfer services for crypto-assets can be licensedCyprusCzech RepublicEstoniaFranceGermanyIrelandItalyLatviaLithuaniaLuxembourgNetherlandsPolandSlovakiaSpainDubai (VARA)Malta

Frequently asked questions

What travel rule obligations apply when transferring crypto-assets?

The provider must obtain, verify and pass on originator and beneficiary information to the counterparty institution with every transaction. Under the EU rules implementing FATF's standards, that duty applies to any crypto transfer between regulated intermediaries, with no minimum transaction value.

Does mining or blockchain transaction validation constitute a regulated crypto transfer service?

No. Miners, validators and node operators confirm transactions on the network, but they are not moving a specific client's assets as an intermediary. They supply decentralised computing infrastructure, not a customer-facing transfer service, so CASP transfer rules do not reach them.

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)(j) and 3(1)(26) · retrieved 2026-09-24

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