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
Source
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?
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.
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
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