Guide
MiCA licence register: how to check a firm is actually authorised
Updated
There is one authoritative list and it belongs to ESMA. A logo on a website, a national registration from 2023 or a licence in a third country are none of them evidence of a MiCA authorisation.
What Article 109 requires
Article 109 of Regulation (EU) 2023/1114 requires ESMA to establish a register of crypto-asset white papers, of issuers of asset-referenced tokens and e-money tokens, and of crypto-asset service providers. Competent authorities feed it: they must communicate the Article 109(5) information within two working days of granting an authorisation, and ESMA must publish it by the date the provider starts trading (Article 63(13)). Entities using the Article 60 notification route are added the same way (Article 60(12)).
The other register, the one nobody advertises
Article 110 requires a separate register of non-compliant entities providing crypto-asset services in breach of Article 59 or Article 16. If you are doing counterparty diligence, that list is as informative as the first one.
How to check
- Go to ESMA's databases and registers page and open the MiCA entries. ESMA has published the MiCA register as a set of CSV files updated at weekly intervals during the interim period.
- Match the legal entity, not the brand. Groups commonly operate one authorised EU subsidiary alongside several unauthorised affiliates.
- Check which services the authorisation covers. Article 59(6) requires the authorisation to specify them, and adding a service needs an extension request under Article 59(8), assessed like a fresh application.
- Cross-check the national competent authority's own register. It is the authority that grants and withdraws, and it publishes withdrawals first.
What an authorisation gets a firm
A single authorisation is valid across the Union. Article 59(7) allows an authorised provider to serve clients throughout the EU through the right of establishment, including a branch, or the freedom to provide services, and expressly says it does not need a physical presence in a host member state. That is the commercial point of MiCA and the reason firms tolerate the file.
A firm that says it is "MiCA compliant" is not saying it is MiCA authorised. Only the register settles that.