FitStep 1
Which services you can provide
Each type of institution can only provide the crypto-asset services equivalent to those it is already authorized for. We check it service by service.
MiCA Art. 60(1)–(6).
MiCA Article 60 Notification for Financial Institutions
If you are a bank, an investment firm, a management company, an EMI, a central securities depository or a market operator, you can provide crypto-asset services without applying for a CASP licence: you only need to notify the authority at least 40 working days in advance. We prepare the notification and everything that must accompany it.
Does your institution want to offer crypto services?
Tell us what type of institution you are and which crypto-asset services you want to provide, and we will tell you what you need to notify them.
- Reply within 24 h
- No commitment
- Confidential
- Minimum advance notice
- 40 working days
- Review of the notification
- 20 working days
- CASP licence
- Not required
- MiCA authority in Spain
- CNMV
What we do
Your Article 60 notification, complete the first time
The notification is not an authorization, but it has to be complete: while information is missing, the institution cannot start providing the services.
ProgramStep 2
Programme of operations
We draft the programme setting out the services, the crypto-assets, the clients, and where and how they will be marketed.
MiCA Art. 60(7)(a).
AMLStep 3
Anti-money laundering
We adapt your internal control, policies and money laundering and terrorist financing risk assessment to crypto-assets.
MiCA Art. 60(7)(b).
ICTStep 4
Systems and security
We coordinate the technical documentation, business continuity and the non-technical description that MiCA requires.
MiCA Art. 60(7)(b) and (c).
ClientsStep 5
Segregation and custody
We describe the segregation of clients’ crypto-assets and funds and, if you provide custody, the custody and administration policy.
MiCA Art. 60(7)(d) and (e).
ServicesStep 6
Policies for each service
Execution policy, commercial policy and pricing, platform rules, staff knowledge and transfers.
MiCA Art. 60(7)(f)–(k).
Scenarios
Who uses Article 60 instead of the CASP licence
These are the institutions that consult us most. Each has a different scope.
Bank
A bank that wants to offer crypto purchase and custody
Credit institutions can provide crypto-asset services by notifying 40 working days in advance, without a CASP licence.
ESI
A broker-dealer or securities broker that already executes orders
It can provide the crypto services equivalent to the investment services it is authorized for, such as reception and transmission of orders or advice.
Management company
A management company that wants to manage portfolios with crypto
UCITS and AIF management companies can provide crypto-asset portfolio management and the ancillary services they are authorized for.
EMI
An EMI that issues its own e-money token
It can safekeep and transfer on behalf of clients the e-money tokens it issues, by notifying beforehand.
What the law says
MiCA Article 60 in figures
Data from Regulation (EU) 2023/1114 (MiCA) and Law 6/2023.
MiCA Art. 60(1)
40 working days
Minimum advance notice a bank must give the authority before providing crypto-asset services for the first time.
MiCA Art. 60(8)
20 working days
Time the authority has to check whether the notification is complete.
MiCA Art. 60(8)
20 working days
Maximum time the authority can give to supply the missing information.
MiCA Art. 60(8)
No start
The institution cannot start providing the services while the notification is incomplete.
MiCA Art. 60(7)
11 items
Information to be notified, from (a) to (k): programme of operations, money laundering, ICT, segregation, custody and policies.
Art. 251 Law 6/2023
CNMV
Competent authority for MiCA in Spain, except for matters that fall to the Bank of Spain.
Shall we prepare your institution’s notification?
We review which crypto-asset services you can provide under your current authorization and leave the notification and its policies ready for you.
Frequently asked questions
MiCA Article 60 notification: frequently asked questions
Which institutions can provide crypto services without a CASP licence?
Those listed in Article 60 of MiCA: credit institutions, central securities depositories (custody only), investment firms, electronic money institutions (custody and transfer only of the tokens they issue), UCITS and AIF management companies and market operators (trading platform). It is enough to notify the authority.
How far in advance must the notification be made?
At least 40 working days before providing the services for the first time (Art. 60(1)–(6)). The authority has 20 working days to check whether the notification is complete and, if information is missing, it may allow up to 20 working days to provide it; in the meantime, the period is suspended (Art. 60(8)).
Can an ESI provide any crypto service?
No. Only those equivalent to the investment services it is authorized for. MiCA sets the equivalences: for example, custody of crypto-assets is equivalent to custody of financial instruments, and operating a trading platform to operating an MTF or an OTF (Art. 60(3)).
What must the notification include?
A programme of operations; money laundering controls, policies and risk assessment; a continuity plan; technical documentation of the ICT systems; segregation of clients’ crypto-assets and funds; and, depending on the services, a custody policy, platform rules, a commercial policy, an execution policy, staff knowledge and the way transfers will be provided (Art. 60(7)).
Who receives the notification in Spain?
The competent authority of the home Member State. In Spain, the CNMV is the competent authority for MiCA, and the Bank of Spain supervises asset-referenced tokens and issuers of e-money tokens (Art. 251 of Law 6/2023).
Do I have to resubmit what I already submitted for my licence?
Not necessarily: MiCA states that information already provided to the authority does not have to be submitted again, as long as it is identical (Art. 60(9)). It is advisable to identify it clearly in the notification.
How much does it cost to prepare the notification?
It depends on the services you want to provide and on what you already have: advising on crypto-assets is not the same as holding them in custody or operating a platform. After the diagnosis we give you a fixed quote.
Practical guide
How we prepare the Article 60 notification
We start from what your institution is already authorized for and add only what MiCA requires.
What you already have
Current authorization, policies and systems.
What is missing
Adapting each item of Art. 60(7) to crypto-assets.
The review
Check that the notification is complete.
Your notification in 10 steps
- We identify which crypto-asset services you want to provide and to which clients.
- We check that they are equivalent to those your authorization already covers.
- We draft the programme of operations.
- We adapt internal control and the money laundering risk assessment to crypto-assets.
- We coordinate the technical documentation of the systems and the continuity plan.
- We describe the segregation of clients’ crypto-assets and funds.
- We prepare the policies for each service: custody, execution, commercial or platform.
- We document the knowledge of the staff who advise or manage portfolios.
- We submit the notification at least 40 working days before you start.
- We handle the authority’s requests for information until the notification is complete.
Source: Regulation (EU) 2023/1114 (Art. 60) and Law 6/2023 (Art. 251).
Working glossary
Key concepts of the Article 60 notification
Terms from the MiCA Regulation and Law 6/2023.
CASPProvider
Crypto-asset service provider
Entity authorized under MiCA to provide crypto-asset services.
MiCA Art. 59.
Art. 60Route
Notification by financial institutions
Route for already authorized institutions to provide crypto services without a CASP licence.
MiCA Art. 60.
EquivalenceScope
Equivalent service
Crypto-asset service that corresponds to an investment service already authorized.
MiCA Art. 60(3).
CustodyService
Custody and administration
Safekeeping of crypto-assets or of the means to access them on behalf of clients.
MiCA Art. 3.
SegregationClients
Segregation
Keeping clients’ crypto-assets and funds separate from those of the institution.
MiCA Art. 60(7)(d).
ProgrammeDocument
Programme of operations
Description of the services, the crypto-assets and how they will be marketed.
MiCA Art. 60(7)(a).
Playbook
What each institution can provide by notifying
Credit institution
Crypto-asset services: Crypto-asset services.
Article: MiCA Art. 60(1).
Central securities depository
Crypto-asset services: Only custody and administration on behalf of clients.
Article: MiCA Art. 60(2).
Investment firm
Crypto-asset services: Those equivalent to the investment services it is authorized for.
Article: MiCA Art. 60(3).
Electronic money institution
Crypto-asset services: Custody and transfer of the e-money tokens it issues.
Article: MiCA Art. 60(4).
UCITS or AIF management company
Crypto-asset services: Crypto-asset portfolio management and authorized ancillary services.
Article: MiCA Art. 60(5).
Market operator
Crypto-asset services: Operating a crypto-asset trading platform.
Article: MiCA Art. 60(6).
Common mistakes in the Article 60 notification
These are the ones that delay the start of activity.
- Notifying services that the current authorization does not cover.
- Starting to provide the services before 40 working days have passed.
- Copying securities policies without adapting them to crypto-assets.
- Not describing the segregation of clients’ crypto-assets.
- Forgetting the crypto-specific money laundering risk assessment.
Contact
Book a call
Tell us what type of institution you are and which crypto-asset services you want to provide, and we will prepare a diagnosis and a tailored quote.
MiCA Article 60: crypto-asset services for already authorized institutions
Updated November 4, 2026
Regulation (EU) 2023/1114 (MiCA) generally requires authorization as a crypto-asset service provider (CASP) to provide crypto services. Its Article 60 makes an exception for financial institutions that are already authorized and supervised: they can provide certain services if they notify the authority of their home Member State.
Who and what
Credit institutions can provide crypto-asset services; investment firms, those equivalent to their authorized investment services; UCITS and AIF management companies, portfolio management and ancillary services; EMIs, custody and transfer of their own e-money tokens; central securities depositories, custody; and market operators, a trading platform (Art. 60(1)–(6)).
Deadlines
The notification is submitted at least 40 working days before starting. The authority checks within 20 working days whether it is complete; if not, it sets a period of up to 20 working days to complete it, and the institution cannot start in the meantime (Art. 60(8)).
Alternatives
If your institution is not on the Article 60 list, it needs the CASP licence. You can see which entities already hold one in authorized CASPs in Spain and the full framework in the MiCA Regulation. We cover anti-money laundering for crypto in crypto-asset compliance.