MiCA Conduct and Marketing Rules for CASPs: The Full Cluster

MiCA does more than licence crypto firms. It sets a conduct regime that governs how a CASP behaves toward its clients and toward the market. Marketing is the most visible piece, but it sits inside a wider cluster: conflicts of interest, inducements, best execution, order management, the trading-platform rulebook, market abuse, and complaints handling. They share a pattern: short article text but heavy operational expectation, policed by supervisors who test the working system rather than the policy on file.

This pillar maps the cluster. It opens with the marketing rules (Articles 7 and 74) because that is where most teams start, then works through the conduct duties that apply to client-facing services and trading platforms.

What the MiCA marketing rule actually says

MiCA’s marketing rule is short by regulation standards (under three pages) and operationally substantial. The core obligations apply to anyone offering crypto-assets to the public in the EU or seeking admission to trading on a trading platform. The rules are channel-agnostic.

The four operational requirements:

1. Information must be fair, clear, and not misleading. This is the foundational fair-dealing rule shared across EU financial-services frameworks (MiFID II, PRIIPS, prospectus law). The substance is calibrated through supervisory practice and ESMA Q&A: which claims are permitted, and what disclaimers or risk language a given claim requires.

2. Marketing communications must be clearly identifiable as such. The rule echoes the broader EU consumer-law principle that advertising should be recognisable as advertising. For crypto, this matters most in influencer-led campaigns where the commercial relationship is sometimes obscured.

3. Marketing must be consistent with the white paper. Where a white paper is required (Title II for other crypto-assets, Title III for ARTs, Title IV for EMTs), marketing claims cannot exceed, contradict, or misrepresent the disclosures in the document. Promised yields, technical capabilities, partnerships, roadmap milestones — all need an underlying basis in the white paper or in operating reality.

4. Marketing must include a clear statement that the white paper has not been approved by any NCA. This is a literal disclaimer requirement. The marketing rule spells it out — the language must clearly draw attention to the fact that the white paper is a notification document, not an approved prospectus.

Which channels are in scope?

Every channel that delivers a marketing communication for in-scope crypto-assets is captured. The list includes — but is not limited to:

• Owned channels: website, mobile app in-screen messaging, push notifications, email newsletters
• Paid digital: Google Ads, Meta Ads, programmatic display, X promoted posts, TikTok ads
• Social media organic: Twitter/X, Telegram channels and groups, Discord servers, Reddit posts, Instagram, TikTok
• Influencer: paid influencer posts, ambassador relationships, community-led promotion incentivised by the offeror
• Earned media: press releases, podcast interviews, media commentary
• Events: conference sponsorships, side events, panel speaking organised to promote the asset

The substance test asks whether the communication promotes the in-scope crypto-asset, directly or indirectly. A factual ESMA-Q&A-style commentary is not marketing. A “watch this asset” Twitter thread from the issuer’s community team probably is.

Fair, clear, not misleading — the substantive test

Article 74 carries the fair-clear-not-misleading standard across all CASP communications with clients and potential clients — marketing, customer agreements, risk disclosures, terms and conditions, website content, social media. Article 7 anchors the same standard to the white paper and the offer. The phrasing is gentle and the application is not. NCAs across the EU have used the standard as the enforcement hook on marketing-conduct matters throughout 2025-2026, with fines, supervisory notices, and ordered campaign withdrawals.

The three elements are separate tests, all of which must be satisfied:

• Fair means balanced presentation. Benefits and risks both shown, material context included. Selectivity is not fair even if every individual statement is true — cherry-picked time windows, best-of-class token selection, survivorship bias, and tax-favoured net-of-fee-but-gross-of-tax calculations all fail the fair prong. The test is whether a reasonable retail investor would form an accurate impression of the typical experience.
• Clear means understandable to the intended retail audience — not to a lawyer or an existing crypto user. Industry vocabulary (yield, APY, slippage, custody, staking, liquid staking, restaking) without plain-language explanation fails the clear prong for a retail audience even where it would pass for an institutional one. NCAs in 2025-2026 specifically targeted yield products marketed as “savings accounts” or “deposits”, and staking products with APY headlines that omit slashing risk and lock-up periods, with no mention of smart-contract risk.
• Not misleading is the strictest of the three. No false statements, and no omitted material information that would change the audience’s decision. The omission branch catches a lot: success stories without typical experience, affiliate earnings without typical earnings, “risk-free trial” framing, and geographic claims (“trusted by customers in 90 countries”) that imply broader authorisation than the firm holds.

A communication can be technically true but cherry-picked (fails fair), or balanced but written in jargon (fails clear). The standard is not met until all three pass.

Risk-warning prominence — the visual test

MiCA and the EBA Guidelines require risk warnings to be at least as prominent as benefit claims and on the same page or screen. The standard is visual equivalence, not technical disclosure. In practice that means: the warning is on the same page as the benefit claim, not behind a link to terms and conditions; typography is visually equivalent (a 24-point bold benefit claim above the fold needs a readable warning above the fold too); the warning sits in the same reading flow, not after substantial scrolling; nothing is obfuscated in light grey 8-point type behind expand-to-read links; and the content is specific to the product — slashing risk for staking, liquidation risk for leveraged products, smart-contract risk for DeFi. Operators often assume the prominence test is met because the warning is technically present. NCAs apply it from the retail reader’s perspective: if the marketing reads as positive with the risk warning invisible at a glance, prominence fails.

Performance claims

Past returns may be shown with the standard “past performance does not predict future results” disclaimer. Projected returns are largely prohibited. ESMA’s Guidelines specify that performance presentations cover at least 12 months including both up and down periods. A best 90-day return for a token whose 12-month return is negative fails the fair prong even with a disclaimer.

What enforcement looks like

Through Q1 2026, ESMA and the NCAs collectively produced over 30 published enforcement actions on Article 7. The pattern of findings: fair-prong breach via selective emphasis is the most common (roughly 60% of recorded actions); not-misleading breach via unsupported institutional or endorsement claims is second (roughly 25%); format-specific placement violations (risk warning below “see more”, captions used as the warning location, missing volatility statements in video) account for roughly 10%; and aged content for roughly 5%. Fines under Article 109 have ranged from EUR 10,000-50,000 for process or record-keeping failures up to EUR 100,000 to EUR 500,000 for substantive breach patterns. The largest single action recorded through Q1 2026 was EUR 2.4 million on one CASP for a sustained fair-prong breach across multiple campaigns. NCAs in Germany, France, Italy, Spain, and the Netherlands have all issued fines; operators that respond constructively to an initial supervisory notice typically avoid the Article 109 fine.

Fair, clear, not misleading — worked examples

ESMA’s 2026 Guidelines apply the standard through worked examples. The recurring failure modes, and the rewrites that meet the standard:

Performance representation

Fails: “MiCA-licensed CASP. Bitcoin has returned 145% over the past 12 months. Start trading today.” The 145% return is the headline; the volatility risk and possibility of total loss is not in the same visible content. Accuracy does not save it — the standard is about balance, not factual accuracy alone.

Passes: “MiCA-licensed CASP. Bitcoin’s 12-month price change has been +145% — and historically the asset has also seen losses of 60% or more in single periods. Crypto-assets are highly volatile; total loss of capital is possible. Approved white paper at [link].” The same factual claim, now in fair context: supportable by evidence, retail-readable, no implied predictions.

Institutional endorsement

Fails: “Trusted by major European banks and fintech institutions.” A generalised claim of institutional trust without supporting evidence fails the not-misleading prong.

Passes: “Active institutional client base includes [Named Bank A] (Article 60 notification, Q2 2025) and [Named Fund B] (UCITS authorisation under management). See institutional case studies at [link].” Specific, named, documented.

Yield product description

Fails: “Yield-optimised exposure to algorithmic compounding strategies. Maximise your crypto-asset deployment.” Fails the clear prong for retail audiences — the technical language obscures what the product does, what risks it carries, and what return profile it offers.

Passes: “A yield product that lends your crypto-assets to authorised counterparties in return for a variable interest rate. The interest can change at any time and may go to zero. Your assets are at risk of loss if a counterparty fails. Crypto-assets are highly volatile. See product white paper at [link].” A retail reader can understand what the product does without specialist knowledge.

Aged content

Fails: A blog post from January 2026 stating “MiCA’s transitional regime gives existing CASPs until 30 June 2026 to apply.” Read in October 2026 the post is misleading, because the deadline has passed — yet it is still publicly accessible. Article 7 applies to public marketing content for as long as it is publicly accessible; the obligation does not end at publication.

Passes: The same post with a current header note: “Update October 2026: the transitional regime closed 30 June 2026. Transitional CASPs that did not file by that date have lost the right to operate.” Or the post is removed.

Influencer and KOL marketing rules

Influencer and key-opinion-leader (KOL) promotion of crypto-assets is squarely in scope. The structural point most CASPs miss: Article 7 liability does not transfer to the influencer. The CASP or issuer paying for the post carries the obligation to ensure the content is fair, clear, not misleading. Contracts that purport to make the influencer responsible do not work against the supervisor — the CASP can sue the influencer for breach of contract, but it cannot use the contract to escape MiCA enforcement. The influencer carries a separate disclosure obligation under national consumer law and the EBA/ESMA Joint Guidelines, not a substitute for the CASP’s.

ESMA’s 2026 Guidelines closed most of the ambiguity around paid social content. Format-specific risk-warning rules now read:

• Short-form video (TikTok, Instagram Reels, YouTube Shorts): risk warning visible within the first three seconds, with minimum text size and contrast.
• Twitter / X: risk warning fits in the visible portion of the post without expanding “see more” — the visible portion is the first 140 characters on desktop and 280 on mobile.
• Stories (Instagram, TikTok, Facebook): risk-warning sticker visible for the entire display duration, not just at the end.
• Static posts: risk warning in the post body, not only in a comment or caption.
• YouTube long-form video: risk warning shown for the first 10 seconds and re-shown each time the crypto-asset is mentioned.

The paid-relationship disclosure must be on the same screen as the content, in a font size proportionate to the surrounding text, using a non-misleading hashtag — #ad, #sponsored, or #partnership are acceptable; ambiguous tags like #collab or #thanksto are not.

National consumer-law overlays sit on top and create separate exposure: France’s DGCCRF rules under the 2023 Loi Influenceurs (penalties up to EUR 5 million); Italy’s Consumer Code plus AGCOM (up to EUR 500,000 per infringement); Germany’s Unfair Competition Act (UWG), with BaFin coordination on the crypto side; and Spain’s AEPD plus CNMV coordination. CASP fines run up to 5% of annual turnover under MiCA Article 110. A pan-EU influencer campaign is a multi-rulebook compliance exercise.

The Article 7 marketing-compliance checklist

The supervisory expectation is pre-publication approval by the CASP compliance function — not the marketing team, not the agency, not the influencer. The compliance function reviews and approves before publication, and the approval is recorded with date, version, and approver identity, retained for at least five years. Several NCAs flagged stale approvals as a recurring 2026 gap, so a 14-day window from approval to publication is typical; content published after the window needs re-approval.

The required disclosure elements on in-scope content: a volatility and total-loss risk warning visible in the content (not buried in the caption); a white-paper reference (link, QR code, or clear textual pointer); a reference to the CASP’s MiCA authorisation; and a paid-relationship disclosure where the content is influencer or KOL marketing. Pan-EU campaigns need a separate review against each host-state consumer-law overlay before extension — France (AMF Position, DGCCRF), Italy (Consumer Code, AGCOM), Germany (UWG, BaFin), Spain (CNMV), Netherlands (AFM). The MiCA passport extends the licence, not the marketing approval.

ESMA’s 2026 supervisory work identified four recurring findings worth designing against: stale approvals (content held past the 14-day window for an opportune publishing moment); inconsistent risk warnings (the same CASP using different phrasings across channels); email-based approval (threads that do not provide adequate audit evidence — NCAs increasingly expect a dedicated system with version control); and missing host-state overlay on campaigns extended from one market to others.

What does “consistent with the white paper” actually require?

The consistency rule is the most operationally consequential of the four. In practice it means:

Claim type	Permitted basis
Yield / return promise	Only if the white paper documents the mechanism and risk; subject to MiCA’s prohibition on stablecoin interest (set in the MiCA stablecoin rules)
Technical capability	Must reflect documented technology in the white paper; “soon” features need clear forward-looking caveat
Partnership / integration	Documented in the white paper or other public disclosure; cannot be implied through logos without basis
Total supply / tokenomics	Must match the white paper; any change requires white paper modification first
Use case / utility	Must match the white paper’s project description; cannot extend by marketing alone

Marketing teams that operate at speed, typical for crypto launches, sometimes treat the white paper as the legal artefact and the marketing as the commercial story. The marketing rule makes this approach untenable. The two must travel together.

Cited expert

We also made it clear that, despite MiCA, there will be no such thing as a safe crypto-asset.

What happens when something material changes?

If a “significant new factor, material mistake, or material inaccuracy that is capable of affecting the assessment of the crypto-assets” emerges, three things must happen in sequence:

1. The white paper must be modified. The modification follows the same notification path as the original.
2. Marketing communications must be updated to reflect the modification.
3. The NCA must be notified at least 7 working days before publication of the modified white paper, and the NCA notifies host Member States and ESMA within 5 working days of receipt.

The trigger language is broad. “Significant new factor” includes operational events (a major partnership ending, a custody-tech vendor change, a smart-contract audit finding), market events (a substantial re-pricing of the underlying), and structural events (changes in the issuer or governance). Marketing teams operationally connected to compliance catch these triggers; marketing teams operating in parallel often miss them.

How do MiCA marketing rules interact with national advertising rules?

The marketing rule does not displace national advertising rules. Member states with general consumer-protection frameworks for financial advertising (UK FCA-style rules pre-Brexit, French AMF rules under PACTE, Spanish CNMV crypto-advertising rules) layer on top of the marketing rule within the EU framework. The general pattern:

• The marketing rule is the floor. Every EU member state expects the four core obligations.
• National rules add specific tactical constraints. Particular member states impose pre-vetting, disclaimer language, prohibition on certain influencer formats, or restrictions on promotional incentives.
• Cross-border marketing requires a multi-jurisdiction approach. A campaign running in five member states needs to satisfy all five sets of national overlays plus the marketing rule.

For CASPs operating cross-border under MiCA passporting, the marketing-compliance workstream is materially heavier than for single-jurisdiction operators.

Conflicts of interest — Article 72

Conflicts of interest is the section CASP applicants most commonly under-deliver on. The substantive obligation is short (Article 72 fits on a single regulation page) but the operational expectation, set by ESMA’s RTS, is heavier than the article text suggests. The Final Report on the RTS (ESMA35-1872330276-1670, May 2024) and the follow-up Opinion on amendments (January 2025) set the detail. The expected file looks more like a regulated investment-firm conflicts register than a tech-company governance document.

Article 72 imposes four sequential obligations: identify all reasonably foreseeable conflicts (between the CASP and clients, between clients, and between the CASP’s people and clients); prevent conflicts where prevention is feasible, through organisational structure and information barriers; manage conflicts that cannot be prevented; and disclose any residual conflict to clients, clearly and before the service is provided. The hierarchy matters. Disclosure is the fallback, not the primary control — a framework that defaults to client-facing disclosure for material conflicts reads to supervisors as a control failure dressed up as transparency.

A 2026 supervisory file is expected to work through the conflict types the firm’s own business model creates, including: proprietary trading against client orders and allocation of scarce tokens between proprietary and client books; custody-related conflicts (use of client assets for the firm’s own funding, rehypothecation, lending without consent); trading-platform conflicts for Class 3 firms (listing decisions where the CASP holds an interest, market-making by the CASP or affiliates); employee personal-account dealing; and affiliate-group conflicts (preferential promotion of an affiliate-issued stablecoin). The RTS also requires conflicts disclosures in the languages the CASP uses to market or communicate with clients — a passporting CASP serving five markets in five languages needs five versions. The personal-trading policy is the section most often missing in 2026 files, and a static register filed at authorisation and never reviewed is a finding-in-waiting.

Inducements — Article 78

Article 78 borrows the MiFID II Article 24 inducements rule and applies it to crypto-asset services. A CASP may not pay or receive any fee, commission, or non-monetary benefit in connection with a service to or from anyone other than the client unless three conditions are all met: the payment is designed to enhance the quality of the service; it does not impair the CASP’s duty to act honestly, fairly, and professionally; and it is disclosed to the client. Failure on any one condition makes the inducement prohibited.

The standard captures market-maker rebates, payment for order flow, commissions from issuers for placing tokens, referrer fees for new clients, and issuer-provided research, training, or IT services. It generally does not capture standard commercial vendor terms (cloud, KYC services) not tied to specific client services, nor industry memberships or de minimis hospitality. The boundary is whether the arrangement creates incentive misalignment with client interest. Two pitfalls recur: a quality-enhancement assertion without documented evidence of specific client benefit (the condition requires substantive documentation, not a generic claim); and disclosure buried in 50-page terms and conditions, where ESMA’s Guidelines expect a dedicated, plain-language section stating the amount or calculation method. Even with disclosure, an inducement that impairs the duty of care (say, a high commission for routing to a particular issuer) is prohibited; the two tests run in parallel. ESMA enforcement in Q1 2026 included fines for sustained undisclosed payment-for-order-flow.

Best execution — Article 80

Article 80 adapts MiFID II Article 27 best-execution into the crypto context. A CASP executing client orders (a Class 2 service under MiCA Annex IV) must take all reasonable steps to obtain the best possible result across price, costs, speed, likelihood of execution and settlement, size, and other relevant factors — operationalised through a documented, published, at-least-annually-reviewed execution policy, plus monitoring and annual disclosure. The single most common error is confusing best execution with best price: lowest price at a venue with high settlement risk or low execution probability may not be best execution.

Crypto best-execution is harder than the MiFID equivalent. MiFID runs against standardised market-data infrastructure, defined venues, and consolidated tape. Crypto markets fragment across hundreds of venues with varying market-data quality and no consolidated tape, with substantial cross-venue price differentials on top — so the monitoring build is real. The execution policy must identify relevant venues (including the operator’s own platform where it runs one), set the factor-weighting framework for different client and order types, document the venue-selection process, disclose conflicts where the operator routes to its own or an affiliated venue, and set a review mechanism. Monitoring is transaction-level: executed prices against contemporaneous venue benchmarks, slippage measurement, cross-venue benchmarking, and settlement-quality tracking. The annual disclosure publishes the top-five execution venues by volume per crypto-asset class plus an execution-quality summary. ESMA has signalled that single-venue routing arrangements face heightened engagement to demonstrate the routing produces best results rather than convenient operations.

Order management — Article 82

Article 82 is the infrastructure-layer counterpart to the Article 76 rulebook. Where Article 76 sets the rules, Article 82 governs how a crypto-asset trading platform (a Class 3 service) actually handles orders. Its core obligations: fair access — non-discriminatory access for trading members meeting the platform’s documented admission criteria, modelled on MiFID II Article 18; order-type transparency — every available order type defined, documented, and publicly disclosed (not hidden behind a member-only login); anti-manipulation safeguards — pre-trade controls and real-time monitoring; and order-sequencing transparency — time- and price-priority logic disclosed, with any deviation (size-priority, pro-rata allocation, reservation pricing) explicitly documented.

The order-type menu can be substantial — market, limit, stop, and stop-limit; advanced types like iceberg, TWAP, VWAP, post-only, reduce-only, trailing-stop, and one-cancels-other; and time-in-force qualifiers (GTC, Day, IOC, FOK). Each must be defined, documented, and publicly disclosed. Anti-manipulation infrastructure runs across pre-trade controls (order-rate limits, self-trade prevention, erroneous-order interception), real-time detection (spoofing, layering, wash trading, cross-venue patterns), and post-trade investigation. Off-the-shelf platforms often carry equity-market controls that miss crypto-specific patterns like social-media-coordinated pump-and-dump and circular wash trading. The largest conflict pattern is own-account market-making on the operator’s own platform: the market-maker has order-flow visibility other members lack, so Article 82 plus the Article 72 RTS require order-information walls and separated decision-making, backed by an audit trail evidencing that market-making runs on public signals rather than asymmetric platform-internal information.

Trading-platform operating rules — Article 76

Article 76 is the operating-rules article that turns a generic exchange into a regulated venue. It applies to CASPs authorised to operate a crypto-asset trading platform (Class 3 under MiCA Annex IV) and requires a written rulebook that is established, published, and enforced — covering admission criteria, fair-and-orderly trading, market-abuse detection and reporting interfaces, conflict-of-interest management, fees, and dispute resolution. The rulebook is operationally active, not aspirational: operators that publish a rulebook and then operate differently in practice face NCA findings on rulebook breaches.

Admission criteria are the heart of the rulebook, across three sets — issuer admission (legal-entity due diligence, beneficial-ownership verification, prior regulatory record), crypto-asset admission (white-paper compliance where applicable, token-economics review, smart-contract audit, market-integrity indicators), and trading-member admission where the platform is member-based. Each set must be objective, non-discriminatory, and applied consistently with a genuine evidence trail. Article 76 sits at the intersection of several provisions: Article 67 (own funds), Article 68 (record-keeping, five-year retention), Article 72 (conflicts), Article 78 (inducements), Article 82 (order management), and Title VI (market abuse). It is the single largest compliance build for trading-platform CASPs — realistically 8-12 months from rulebook design through market-abuse infrastructure to supervisory review.

Market abuse — Title VI

MiCA did not just licence crypto firms; it imported a market-abuse regime. Title VI applies insider-dealing, unlawful-disclosure, and market-manipulation prohibitions to crypto-assets admitted to trading, closely modelled on the EU Market Abuse Regulation (MAR). The three prohibitions cover: insider dealing — dealing on inside information, plus attempting, recommending, or inducing others to deal; unlawful disclosure of inside information outside the normal exercise of employment, profession, or duties; and market manipulation through manipulative transactions, orders, and conduct. Underpinning all three is inside information — broadly, precise non-public information relating to a crypto-asset that, if made public, would likely have a significant effect on its price.

The insider-dealing prohibition is wider than “don’t trade on a tip.” It reaches anyone who possesses inside information through their employment, profession, or duties — and specifically persons with access through their role in the DLT or similar technology, which pulls validators and protocol developers into scope, along with others connected to the ledger. The duty that drives real work is the prevention-and-detection obligation: persons professionally arranging or executing crypto transactions must maintain working arrangements to prevent and detect market abuse. For a Class 3 trading platform that means operational trade surveillance, alerting and triage with documented escalation, suspicious-transaction-and-order reporting to the competent authority, and record-keeping — a written policy with no surveillance behind it does not satisfy the obligation. ESMA published Guidelines in 2025 on supervisory practices to prevent and detect market abuse under MiCA; a surveillance model built without reference to them risks being judged inadequate against the now-published expectations. The depth of obligation scales with activity — heaviest for Class 3 platforms, applying to executing activity for Class 2 firms, and lightest (but still present) for Class 1.

Complaints handling — Article 71

Complaints handling is the workstream applicants treat as a formality and supervisors treat as a test. Article 71 sets a defined obligation: a CASP must establish and maintain effective, transparent procedures for the prompt, fair, and consistent handling of client complaints, and publish a description of them. The detail is in Commission Delegated Regulation (EU) 2025/294, the RTS ESMA developed under Article 71. A generic one-page policy does not survive a reviewer’s question.

Around the core duty, the obligation builds specifics: complaints must be free of charge, and clients informed of that; the CASP must make a complaint template available, not just list an email address; procedures must be published (and complaints accepted) in the languages the CASP uses to market or communicate with clients plus the official languages of the member states concerned; records of complaints, handling measures, investigations, and responses must be kept; and the CASP must investigate and respond. The language requirement is where multi-market CASPs most often fall short — a Lithuanian CASP serving clients in Italy, Spain, and Germany cannot run an English-only complaints procedure, which connects complaints handling directly to the passporting decision. Beyond compliance, complaints data is a supervisory signal: a pattern of complaints about a product or practice tells a regulator something, so the complaints process should feed back into conduct and product oversight, and into governance, rather than sitting in an isolated silo.

Working with counsel on the conduct file

The conduct cluster is where generic answers surface fastest. The diagnostic for counsel and compliance vendors is the same across each rule — ask how the firm’s specific business model maps to the obligation, not what the obligation says in the abstract:

• Marketing. How does the firm’s workflow capture social-media-organic and influencer-led communications, and how does the modification trigger flow from operational events into the marketing pipeline?
• Conflicts (Art 72). Does the conflicts register map cleanly to the org chart and service mix, with named controls and a documented personal-trading policy — or a MiFID II template lifted across?
• Inducements (Art 78). Can the firm evidence the quality-enhancement justification per arrangement, and is the disclosure in a dedicated, plain-language section rather than buried in terms and conditions?
• Best execution (Art 80) and order management (Art 82). Can counsel describe the venue-selection and surveillance scenarios the firm’s trading model actually requires?
• Market abuse (Title VI) and complaints (Art 71). Is surveillance operational and referenced to ESMA’s guidelines, and is the complaints procedure built against Delegated Regulation (EU) 2025/294 with the right language coverage for the firm’s passporting footprint?

Counsel that gives generic answers about “MiCA compliance” has not surfaced the operational decision points. The firms in our index with documented MiCA conduct and marketing-compliance experience are listed below.