The digital asset landscape is changing — and banks are no longer on the sidelines.
With the Markets in Crypto-Assets (MiCA) regulation taking shape across the EU, traditional financial institutions must now grapple with the same expectations of transparency, accountability, and compliance as crypto-native players. For banks and neobanks expanding their digital asset services, MiCA is not just a regulatory hurdle—it’s a roadmap to trust, growth, and institutional credibility.
MiCA is the EU’s first comprehensive regulatory framework for crypto-assets. Designed to harmonize rules across member states, it focuses on ensuring consumer protection, market integrity, and financial stability in digital asset markets.
MiCA timeline (as of April 2025):
While much of the regulatory focus has historically been on exchanges and crypto-native startups, traditional banks are increasingly in scope—especially as they begin offering custody, trading, or tokenized asset services.
Banks may not always consider themselves crypto asset service providers (CASPs), but under MiCA, activities like safekeeping private keys, executing crypto orders, or enabling access to trading platforms fall within the regulatory perimeter. As the EU moves to harmonize the treatment of crypto-assets across all providers, banks will need to meet the same transparency, reporting, and governance standards as crypto native businesses like exchanges.
Whether launching digital asset services in-house or via partnerships, banks offering crypto-related activities will be treated as CASPs under MiCA.
Key reasons why banks must prepare:
MiCA doesn’t distinguish between crypto-native firms and banks. If you offer regulated digital asset services, you're in scope — and expected to comply accordingly.
MiCA introduces a structured compliance framework, but many of its requirements rely on interpretation by national regulators—making adaptability critical.
Here are the major areas where banks must prepare:
Before offering crypto services, CASPs must obtain CASP authorization from their national competent authority (NCA). This includes submitting governance documentation, operational workflows, internal controls, and evidence of robust compliance capabilities.
That said, banks and certain other financial entities (investment firms, e-money institutions, etc.) can sometimes leverage their existing licenses to provide crypto services by notifying their regulator instead of undergoing a full new CASP authorization (Article 60).
Under MiCA, banks aren’t subject to the same capital requirements as non-bank crypto providers, since they're already covered by strict banking rules (CRR/CRD).
Banks can offer crypto services without holding extra MiCA-specific capital (Article 60), but must still assess and cover crypto risks under existing frameworks. Banks are still expected to maintain sufficient capital for crypto risks, especially given global guidance that treats unbacked crypto as high-risk, but CRR/CRD capital rules are typically considered sufficient protection for their crypto activities.
Client asset segregation
Banks offering custody services are expected to implement wallet architecture that supports segregation. This often involves using distinct blockchain addresses or sub-accounts for client holdings versus the bank’s treasury holdings, or maintaining robust on-chain tagging and off-chain bookkeeping to delineate ownership. MiCA does not prescribe the technical method, but the arrangements must be sufficient to ensure clear ownership.
MiCA mandates strict segregation of client-held crypto-assets from the firm’s proprietary holdings, both technically and legally. This applies to hot and cold wallet structures.
Example: Each client’s on-chain assets must be independently identifiable, with sub-ledgers reflecting balances that can be reconciled against on-chain data.
Banks must maintain detailed, immutable records for a period of 5 years (or up to 7, where requested by a NCA prior to 5 years being elapsed- Article 68 section 9) of:
While daily reconciliation is considered best practice, it’s not always externally mandated. Regulators will expect periodic reports on financial condition, exposure, and safeguarding—formats and frequency subject to supervisory guidance.
MiCA requires comprehensive internal controls across:
If a bank (or any entity) issues a crypto-asset or offers one to the public, MiCA requires a crypto-asset white paper that includes detailed information about the project, underlying technology, risks, rights of investors, and costs/fees associated with the asset.
For example, if a bank were to issue its own stablecoin or tokenized deposit, it would need to publish a MiCA-compliant whitepaper disclosing all relevant risks (volatility, tech risk, governance, etc.) and any fees.
Any MiCA-regulated activity must meet EU Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CTF) standards, including:
Cryptio is an enterprise-grade crypto back-office platform built to meet the demands of MiCA (and other major regulatory frameworks such as ADGM, VARA, PSA and FCA) for data integrity, transparency, and reporting.
Cryptio transforms on-and-off-chain activity into structured journal entries and audit-ready records:
Banks can export general ledger-ready reports compatible with SAP, Oracle Netsuite, and other ERP systems.
Cryptio’s audit trails and reports support evidence generation for regulatory submissions.
Cryptio integrates with custody solutions, trading platforms, and general ledger systems—offering both APIs and no-code options to reduce onboarding time and implementation costs.
Banks don’t need to rip and replace core infrastructure. Cryptio becomes the crypto compliance layer between their digital asset services and regulators.
MiCA may raise the bar—but for banks with the right infrastructure, it also levels the playing field. With a platform like Cryptio, banks can go beyond reactive compliance to build secure, scalable, and regulator-ready digital asset offerings.
Join leading institutions like Circle and Gemini, who already trust Cryptio to power audit-ready, MiCA-compliant crypto operations.
See how Cryptio can reduce your MiCA compliance burden—book a demo today.