Third-party advice by independent contractors not authorised as CASPs under Article 62(2)(q) of the MiCA Regulation

ESMA Q&A 2830 on Third-party advice by independent contractors not authorised as CASPs under Article 62(2)(q) of the MiCA Regulation.

Authority	ESMA
Q&A ID	ESMA_QA_2830
Status	Question Rejected
Published	6 April 2026
Legal basis	Article 62(2) MiCA
Source	ESMA Q&A

Question

Under Article 62(2)(q) of the Markets in Crypto-Assets Regulation (MiCAR):

1. May independent contractors provide advice on crypto-assets on behalf of crypto-asset service providers (CASP) without being authorised as CASPs nor directly employed by said CASPs?
2. May independent contractors be hired by CASPs to provide crypto-assets advice on behalf of said CASPs?

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Answer

ESMA has not published a final answer to this question. Its current status in the ESMA Q&A register is Question Rejected (submitted 6 April 2026). This page will be updated if ESMA publishes a final response.

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Source: ESMA original document