CASP group structure: holding company

Q&A on CASP group structure: holding company.

Authority	ESMA
Q&A ID	ESMA_QA_2746
Status	Question Published
Published	5 January 2026
Legal basis	Article 59 MiCA
Source	ESMA Q&A

Question

Under MiCA, can a group structure exist where a non-regulated holding company acts as the principal commercial counterparty (contracting customers, maintaining relationships, issuing invoices), while a licensed CASP within the same group performs and executes the regulated crypto-asset services without directly contracting with or invoicing end customers, provided all MiCA requirements (governance, outsourcing, conflicts of interest, conduct of business) are met?

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Answer

ESMA has not yet published an answer to this question. Its current status in the ESMA Q&A register is Question Published (submitted 5 January 2026). This page will be updated if and when ESMA publishes a response.

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Source: ESMA original document

Related

• crypto-asset — defined term used on this page
• crypto-asset — defined term used on this page
• subsidiary — defined term used on this page
• group — defined term used on this page