Under MiCA, advice on crypto-assets is a service reserved to authorized CASPs. But there is a second door: investment firms (ESIs), including EAFs, can provide crypto-asset services equivalent to those of their MiFID license by notifying the supervisor. Choosing the right route is half the project.
Want to give crypto advice? We’ll tell you your route within 24h
Tell us what you are today (nothing yet, an EAF or another investment firm, a former VASP, a platform) and what you want to offer, and we’ll map out your path to authorization.
CASP authorization or notification as an investment firm: six services to get you authorized through the right route and to operate with a suitability process that stands up to the supervisor’s review.
If you are starting from scratch or come from the crypto world, we handle your authorization as a crypto-asset service provider with advice included in your program of operations: business model, governance, resources and policies ready for the supervisor’s review.
If you are already an EAF or another investment firm, you can provide, for crypto-assets, the services equivalent to your MiFID license by notifying the supervisor. We prepare the notification and adapt your policies so the service starts out in good order.
The Spanish transitional period ended on December 30, 2025: VASP registration no longer authorizes you to operate. We transition your business.
Adapting the test to crypto-assets means collecting knowledge, loss tolerance and time horizon with extra rigor.
Regulation (EU) 2023/1114 governs the issuance of crypto-assets and crypto-asset services across the EU. Here is the full map.
Advising on crypto-assets goes hand in hand with anti-money laundering obligations: tailored identification and due diligence.
This page is the bridge between two worlds: the traditional financial advisor looking toward crypto and the crypto operator that wants to offer recommendations. These are the cases we see most often.
"My clients have bitcoin and ether they bought on their own, and they ask for my opinion. Until now I avoided the conversation; with the notification as an investment firm, I can build it into my advice, with the test and warnings in order."
"We execute client orders in crypto-assets, but ‘what should I buy?’ was a question with no legal answer. Extending our CASP authorization to advice lets us answer it, and charge for it."
"Our VASP registration stopped being valid on December 30, 2025. Now we have to decide our map of CASP services, and advice is the piece that sets our offering apart from the competition."
"We want to advise on mixed portfolios: funds, shares and crypto-assets. The design question is where to start (an EAF with a notification, or a CASP), and the answer depends on how much weight each world has in our model."
Advice on crypto-assets is a reserved activity: the question is not whether you need authorization, but which one. It depends on what you already are.
If you have no license (yet): you need authorization as a CASP under MiCA with advice included in your program of operations, or you can set up an investment firm (for example, an EAF) and notify the extension to crypto-assets. The choice depends on the weight of crypto versus traditional financial instruments in your model.
If you are already an investment firm (EAF, securities broker or broker-dealer): you can provide, for crypto-assets, the services equivalent to those of your MiFID license by notifying the supervisor. An EAF that gives advice can advise on crypto-assets; what your license does not cover, the notification does not cover either.
If you were a registered VASP: the Spanish transitional period ended on December 30, 2025. VASP registration no longer authorizes you to operate: continuity requires CASP authorization, and adding advice requires including it expressly in the program of operations.
| Who wants to advise | Route | Condition |
|---|---|---|
| New project (CASP) | Authorization as a CASP under MiCA with advice in the program of operations | Full application: governance, resources, policies and fit and proper assessment of officers; advice must be expressly included |
| Existing investment firm (EAF, securities broker, broker-dealer) | Notification to the supervisor to provide crypto services equivalent to its MiFID license | Equivalence is decisive: an EAF extends its advice; it cannot use this route to add services its license does not cover |
| Former registered VASP | Transition to CASP authorization: the Spanish transitional period ended on December 30, 2025 | VASP registration no longer authorizes you; operating without authorization means carrying out a reserved activity without a license |
We analyze your starting point and your target service, tell you whether your path is CASP authorization, notification as an investment firm or setting up the investment firm first, and prepare the full application: program of operations, policies, suitability applied to crypto and compliant advertising. First consultation free of charge.
As a general rule, two types of entity:
Outside those routes, advice on crypto-assets is a reserved service: providing it without authorization means operating outside the law, with the corresponding penalty regime.
Yes, through equivalence: as an investment firm, your EAF can provide for crypto-assets the service it is already licensed for under MiFID (advice) by notifying the supervisor.
The notification is not just a form: it should come with a real adaptation of the service (suitability, warnings, advertising, conflicts) so the extension starts out in good order. And remember the limit: equivalence means you cannot use this route to add services your MiFID license does not cover.
Then the design decision is which world carries more weight in your model. If your business is essentially crypto (with execution, custody or other MiCA services), aim for CASP authorization with advice in the program of operations. If your offering is broad financial advice where crypto is just one more asset class, considering setting up an EAF and notifying the extension afterwards may be the more consistent route.
Both routes require a serious application; the difference lies in the day-to-day supervisor, the catalog of services and the product your business revolves around.
Not with the VASP registration: the Spanish transitional period ended on December 30, 2025. Since then, providing crypto-asset services has required CASP authorization under MiCA.
If your activity continued without that authorization, you have a reserved-activity problem that you should regularize as soon as possible. We explain the full process in transition from VASP to CASP, including adding advice to your program of operations if you want to offer it.
With the same logic as under MiFID and an extra degree of rigor: before recommending, you assess the client’s knowledge and experience in crypto-assets (their stock market experience is not enough), their financial situation and ability to bear losses (including total loss), and their objectives and time horizon.
The result must show in the recommendation: clients without the knowledge or the capacity to bear losses should not receive crypto proposals, and the file has to prove it. Our method is explained on our suitability test page.
Those required by the applicable framework in each case, plus a minimum of supervisory common sense: make the product risk clear in writing, including the possibility of losing everything invested, its volatility and, depending on the crypto-asset, the absence of the protections that traditional products offer.
For advertising, CNMV Circular 1/2022 on crypto-asset advertising also applies: warnings, balanced messaging and internal control of campaigns. Marketing communications are one of the first places the supervisor looks.
You are providing a reserved service without a license, with the penalty regime for that infringement: fines, a possible public reprimand and the reputational damage of being named by the supervisor. It also taints any future authorization application.
The relevant line is the usual one: generic information or training on crypto-assets is one thing; personalized recommendations on specific crypto-assets to a specific client are something else entirely. If you are unsure which side you are on, it is time to stop.
For both: it is the bridge between the firm’s two worlds. If you come from financial advice, your natural path continues with setting up an EAF and the equivalence notification. If you come from the crypto ecosystem, continue with CASP authorization and the full MiCA Regulation.
In between lies what matters: whatever your background, the end service looks very similar (suitability, warnings, controlled advertising and evidence), and that is where you win or lose before the supervisor.
Getting authorized is half the work; the other half is making sure every recommendation is backed by a file. This is the full route we follow, depending on your starting point.
We x-ray your situation (current licenses, target services, weight of crypto in your model) and choose the path: CASP authorization, notification as an investment firm or setting up the investment firm first. This is where the project’s timeline and cost are decided.
We prepare the CASP authorization with advice in the program of operations, or the equivalence notification with your adapted policies. In both cases, the documentation matches how you actually operate: that is what avoids requests for information.
A suitability test adapted to crypto-assets, warnings, advertising compliant with Circular 1/2022, conflicts of interest and KYC. The goal: any recommendation from your firm can be defended with documents, not with memory.
Would you rather we set it up with you? Depending on your case, start with CASP authorization, with setting up your EAF or with the transition from VASP to CASP.
Nine concepts that make the difference between an authorized crypto advice service and a reserved activity carried out without a license.
The European regulation on markets in crypto-assets: it governs the issuance, admission to trading and services relating to crypto-assets across the EU.
An entity authorized under MiCA to provide crypto-asset services. It may only give advice if that service is in its program of operations.
Recommending specific crypto-assets to a specific client. A reserved service: this is what sets it apart from generic information or training.
Investment firms can provide, for crypto-assets, the services equivalent to their MiFID license by notifying the supervisor.
The communication to the supervisor through which an investment firm enables its crypto services. It should be accompanied by policies that have already been adapted.
The Spanish register of exchange and custody providers. Its transitional period ended on December 30, 2025.
Client assessment adapted to crypto-assets: specific knowledge, capacity to bear total loss, objectives and time horizon.
CNMV Circular on crypto-asset advertising: warnings, balanced messaging and internal control of communications.
Providing reserved services without authorization triggers the corresponding penalty regime and taints future authorizations.
The right route, and a current one: CASP authorization with advice in the program of operations, or equivalence notification as an investment firm.
Authorization decision or filed notification, program of operations and an analysis of how the service fits, on file.
A test adapted to crypto-assets, applied before each recommendation, with a result consistent with the advice given.
Versioned questionnaires, client files with the assessment, and a suitability justification for each recommendation.
Client informed in writing of the risks (including total loss), costs and nature of the recommended crypto-asset.
Warning templates, delivery and acceptance records, and pre-contractual information on file.
Crypto-asset campaigns compliant with CNMV Circular 1/2022, with internal control before they are released.
Advertising approval procedure, materials archived with their warnings, and a campaign log.
KYC and due diligence adjusted to crypto risk, and the service’s conflicts of interest identified and managed.
Updated AML manual, KYC files, conflicts register and revised inducements policy.
Five situations we see often that a supervisor would read as a reserved activity without control. If they sound familiar, act now.
This page connects the firm’s two practices. If your background is financial advice, the EAF path is for you; if your background is the crypto ecosystem, the MiCA path. The destination is the same: an authorized service backed by evidence.
The financial advisor’s license: requirements, capital and the CNMV application. The perfect base to extend to crypto later.
Issuers, services and supervision of the crypto-asset market: the full framework in which a CASP operates.
CASP authorization travels: how to extend your crypto services (advice included) to the rest of the Union.
Everything we do in the ecosystem: authorizations, white papers, crypto AML and ongoing support.
Still unsure about the route? Compare CASP authorization with extending your EAF, review the VASP-to-CASP transition if you come from the old register, and rely on the suitability test so the service starts out backed by evidence.
Tell us your starting point and your target service, and we’ll tell you whether your route is CASP authorization, notification as an investment firm or a combination of both.
Recommending specific crypto-assets to specific clients is no longer a gray area: under Regulation (EU) 2023/1114 (MiCA), advice on crypto-assets is a service reserved to authorized CASPs, with a second, specific route for the traditional financial sector: investment firms, including EAFs, can provide crypto-asset services equivalent to those of their MiFID license by notifying the supervisor. Add to this a date that no longer leaves room for nuance: the Spanish transitional period for VASPs ended on December 30, 2025, so the old register no longer authorizes anyone to operate.
Anyone building a business on crypto-assets (execution, custody, exchange) who wants to add personalized recommendations needs advice to appear expressly in their program of operations as an authorized CASP. Authorization requires demonstrating governance, resources, policies and good repute, and the reward is twofold: a high-value service that sets you apart from the competition, and the option to extend it across the EU through the MiCA passport. For former VASPs, this is also the only path to continuity after the end of the transitional period: we explain it in detail in transition from VASP to CASP.
The second door is designed for the traditional financial advisor: an EAF (or any other investment firm) can provide for crypto-assets the services equivalent to those of its MiFID license by notifying the supervisor. The key word is equivalence: an EAF that gives advice can extend its advice to crypto-assets, but it cannot use this route to add services its license does not cover (execution, custody). For anyone considering entering the sector, this makes the EAF an interesting platform: first the MiFID license (the path is set out in setting up an EAF) and then the notification that opens up the crypto asset class.
Getting authorized is a necessary condition, not a sufficient one. A crypto recommendation requires a suitability assessment that is taken seriously: the client’s specific knowledge and experience in crypto-assets, ability to bear losses (including total loss), objectives and time horizon. It also requires written information and warnings, with a record of delivery. On the commercial side, crypto-asset advertising falls under CNMV Circular 1/2022: mandatory warnings, balanced messages and internal control of campaigns. Supervisory experience is consistent: files fall apart because of day-to-day operations (generic tests, overly upbeat advertising) more often than because of formal authorization.
If you have arrived here from the world of traditional advice, your natural route continues through the MiCA framework and the crypto-asset regulation, to understand the ground you are stepping onto. If you come from the crypto ecosystem, the reverse direction is what matters to you: how the MiFID discipline of suitability, conflicts and information, which MiCA carries over to advice, works in practice. In both cases the final standard is the same one we apply across the firm: every recommendation backed by a file you can show the supervisor without editing it first.
Key legislation, linked to the official text:
Legislation and links reviewed in .