MiCA CASP Classes – Information Guide (Crypto Asset Service Provider) European Union (EU)
MiCA CASP Classes - Information Guide (Crypto Asset Service Provider) European Union (EU)
Overview of MiCA CASP Classes and Operational Permissions
Class 1 – Basic Scope (Agency, Advisory, and Portfolio Management Services)
Authorisations:
A Class 1 CASP may provide intermediation and advisory services without operating its own trading platform or holding clients’ assets.
It functions similarly to a crypto broker or investment advisor, executing client instructions via existing crypto exchanges or exchange service providers (crypto exchange offices / “kantors”).
Permitted Services:
- Reception and Transmission of Orders:
The CASP may receive an order from a client (e.g., “I want to buy 1 ETH”) and transmit it to another entity such as a crypto exchange or exchange service provider with the necessary trading infrastructure. - Execution of Orders on Behalf of Clients:
The CASP may execute transactions using external markets (e.g., Binance, Kraken, Bitstamp) without operating its own trading platform. It acts purely as an intermediary executing client instructions. - Crypto-Asset Investment Advice:
The CASP may analyse the market and provide investment recommendations concerning specific crypto-assets. - Portfolio Management:
The CASP may actively manage clients’ crypto-asset portfolios by buying and selling tokens in line with an agreed investment strategy. - Placement of Crypto-Assets:
The CASP may organise and promote the distribution of new tokens (e.g., ICOs, IDOs, STOs) on behalf of issuers. - Transfer of Crypto-Assets on Behalf of Clients:
The CASP may arrange token transfers between clients’ wallets, acting as a technical trustee for the transaction.
Practical Example:
Company A signs a contract with a client.
The client transfers EUR 10,000, and Company A purchases 0.15 BTC on Kraken on the client’s behalf.
Company A does not operate its own market; it merely intermediates and executes the order. The BTC is sent directly to the client’s wallet.
Class 2 – Extended Scope (Exchange and Custody Services)
Authorisations:
A Class 2 CASP retains all Class 1 permissions and, additionally, may exchange crypto-assets for fiat or other crypto-assets and hold clients’ assets in custody.
This model corresponds to a crypto exchange service provider (PL: kantor) and/or a custodian wallet provider.
Additional Permitted Services:
- Crypto ↔ Fiat Exchange:
Buying and selling crypto-assets against traditional currencies (e.g., EUR, USD, PLN) — similar to an online exchange office.
Example: A client deposits EUR 1,000, and the CASP sells 0.02 BTC from its own liquidity or purchases it externally. - Crypto ↔ Crypto Exchange:
Converting one cryptocurrency into another (e.g., ETH → BTC or USDT).
Example: A client wishes to exchange 10 ETH for USDT. The CASP performs the transaction using external liquidity sources. - Custody of Crypto-Assets:
Safekeeping and administration of clients’ crypto-assets, including private key management, asset segregation, and secure wallet infrastructure.
Practical Example:
Company B operates an online crypto exchange office (kantor).
A client buys BTC by card or wire transfer, and the firm sends the BTC to the client’s wallet.
Additionally, Company B offers custodial wallets, allowing users to store funds “with the broker,” who technically manages and safeguards them.
Class 3 – Full Scope (Operation of a Trading Platform)
Authorisations:
A Class 3 CASP has all rights from Classes 1 and 2 and, in addition, may operate its own crypto-asset trading platform, i.e., a crypto exchange (PL: giełda) where participants trade directly.
Additional Permitted Services:
- Operation of a Trading Platform for Crypto-Assets:
The CASP creates and maintains a marketplace where users can post buy and sell orders, and the system automatically matches them.
The CASP acts as a market operator, not just an intermediary. - The platform must maintain an order book, a matching engine, and ensure transaction transparency and fair execution.
- The CASP may define trading pairs (e.g., BTC/EUR, ETH/USDT) and set rules for token admission to trading.
Practical Example:
Company C holds a Class 3 license.
It operates a platform where users register, deposit fiat or crypto, and trade directly with one another:
- John places an order to buy 1 ETH for €2,000.
- Anna places an order to sell 1 ETH for €2,000.
The system matches both orders and executes the transaction automatically.
Company C charges a trading fee for executed transactions.
Examples of such operators include Binance, Bitstamp, Kraken, and Coinbase — all functioning as regulated market operators under the MiCA Class 3 model.
Comparative Summary
| Class | Scope of Authorisation | Typical Business Model | Minimum Capital (MiCA Art. 67 & Annex IV) |
| Advisory, intermediation, portfolio management, placement, transfer of crypto-assets | Crypto broker providing investment advice and executing orders via external exchanges | ≥ €50,000 | |
| All of Class 1 + crypto exchange (kantor) + custody | Online exchange office or custodian wallet provider offering crypto ↔ fiat exchange | ≥ €125,000 | |
| All of Class 2 + operation of own trading platform (exchange) | Full trading platform with order book and peer-to-peer matching | ≥ €150,000 |
