Cross-Border & Passport

Reverse Solicitation

EU client initiates contact with a third-country CASP — narrow exception to the EU-authorisation requirement under MiCA Article 61.

Definition

Reverse solicitation under MiCA Article 61 permits a third-country firm to provide services to an EU client where the client initiated the relationship without solicitation by the firm. Narrowly applied; any subsequent solicitation or marketing brings the relationship within MiCA scope.

Regulatory citation

MiCA Article 61 ↗