What the application must contain
Article 62(2) is the list the completeness check runs against. Everything here has to be present before the 40-working-day assessment can even begin.
Two things are worth noticing before the list itself. The first is that it is a list of evidence, not of documents, several items are satisfied by proof rather than by a policy, and proof usually means something a third party issued. The second is that the list has a common core plus service-specific additions, so the size of your file is set by what you chose on the service classes page, not by the size of your firm.
| Ref | What is required | Typical owner |
|---|---|---|
| (a) | Legal name, any commercial name, LEI, website, contact email, telephone and physical address | Corporate |
| (b) | Legal form | Corporate |
| (c) | Articles of association, where applicable | Corporate |
| (d) | Programme of operations: which services, and where and how they will be marketed | Business |
| (e) | Proof that the prudential safeguards in Article 67 are met | Finance |
| (f) | Description of governance arrangements | Governance |
| (g) | Proof the management body is of sufficiently good repute with appropriate knowledge, skills and experience | Governance |
| (h) | Identity of direct and indirect qualifying holders, the size of their holdings, and proof of their repute | Shareholders |
| (i) | Internal control mechanisms, policies and procedures to identify, assess and manage risks including money laundering and terrorist financing, plus the business continuity plan | Compliance |
| (j) | Technical documentation of ICT systems and security arrangements, and a description of them in non-technical language | Technology |
| (k) | The procedure for segregating clients’ crypto-assets and funds | Operations |
| (l) | Complaints-handling procedures | Compliance |
The item most applicants underestimate
Article 62(2)(j) requires the technical documentation of ICT systems and security arrangements to be accompanied by a description in non-technical language.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
A non-technical description of your ICT systems is not a courtesy summary. The people assessing operational risk are not necessarily engineers, and an architecture document that only an engineer can follow leaves them unable to form a view. Firms that hand over a systems diagram and a penetration-test report have supplied the technical half and skipped the half the regulation actually names separately.
The programme of operations is a commitment, not a pitch
Article 62(2)(d) requires a programme of operations setting out the types of crypto-asset services the applicant intends to provide, including where and how those services are to be marketed.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
Note the second half: where and how the services are to be marketed. This binds into the passporting regime: a programme that describes marketing across the Union is describing cross-border provision, which has its own notification route. A programme written as promotional copy tends to promise breadth the authorisation does not cover.
Service-specific additions
Each of these attaches only if you are applying for that service. They are the reason two class 2 applicants can file files of very different sizes.
| If you intend to provide | You additionally file |
|---|---|
| Execution of orders on behalf of clients | Execution policy (Article 62(2)(p)). |
| Providing advice on crypto-assets | Proof that the individuals advising have the necessary knowledge and expertise (Article 62(2)(q)). |
| Providing portfolio management on crypto-assets | Proof that the individuals managing portfolios have the necessary knowledge and expertise (Article 62(2)(q)). |
| Providing custody and administration of crypto-assets on behalf of clients | Custody and administration policy (Article 62(2)(m)). |
| Exchange of crypto-assets for funds | Non-discriminatory commercial policy and the methodology for determining price (Article 62(2)(o)). |
| Exchange of crypto-assets for other crypto-assets | Non-discriminatory commercial policy and the methodology for determining price (Article 62(2)(o)). |
| Operation of a trading platform for crypto-assets | Operating rules of the platform, plus the procedure and system to detect market abuse (Article 62(2)(n)). |
Present is not the same as adequate
The completeness check under Article 63(2) asks whether the information listed in Article 62(2) has been submitted. A thin policy counts as submitted. It then meets the substantive assessment, where Article 63(10) asks whether the applicant fails, or is likely to fail, any requirement of the Title. Passing the completeness check tells you nothing about your prospects; it only means the clock has started.
Regulatory references on this page were read against the primary text on 14 September 2026. Every figure is held in the source register with the document it came from.