MiCA Compliance Checklist: 60 Essential Items by Title (2026)

Last updated 19 September 2026

A MiCA compliance checklist has to follow the Regulation’s own structure, because Regulation (EU) 2023/1114 imposes different obligations on four kinds of actor — offerors of ordinary crypto-assets, issuers of asset-referenced tokens, issuers of e-money tokens, and crypto-asset service providers — and a single firm can be more than one at once.

Title II governs white papers for crypto-assets other than stablecoins; Titles III and IV govern the two stablecoin types and have applied since 30 June 2024; Title V governs CASP authorisation and conduct and Title VI market abuse, both applying since 30 December 2024; the transitional period for pre-existing providers ended on 1 July 2026 at the latest. The checklist below is organised by Title, then by article, with the document or control that evidences each item, so it can be worked as a gap assessment: mark each row met, partly met or not met, attach the evidence, and the open rows are the remediation plan.

Step 1: classify what you are

Our guide to asset-referenced tokens vs e-money tokens settles the stablecoin classification; the MiCA Regulation guide covers the Titles.

MiCA compliance checklist — Title II: offers and white papers

Our guide to the crypto-asset white paper covers Article 6 part by part.

Title III and IV: stablecoin issuers

MiCA compliance checklist — Title V: CASP authorisation and conduct

Title V: per-service rules

Our guide to CASP authorisation covers Articles 59–68; MiCA compliance cost covers what the Title V programme costs to run.

MiCA compliance checklist — Title VI and the obligations beside MiCA

Our guides to MiCA market abuse and the crypto travel rule cover the first two rows in depth.

Working the MiCA compliance checklist

1. Classify first. Which of the four actors you are, and for CASPs which of the ten services — the Annex IV class follows from it and so does the per-service table.
2. Assign an owner and an evidence item per row. A row without a document is a gap whatever the owner believes.
3. Score three ways. Met, partly met, not met — and date each score; the competent authority will ask what changed since authorisation.
4. Prioritise by consequence. Article 67 capital, Article 70 safeguarding and the Title VI surveillance rows are where sanctions are heaviest; the per-service rows follow.
5. Re-run at each trigger. A new service, a new listed asset, a new Member State, a significant-token classification or a technical standard update changes the rows that apply.

Frequently asked questions

What should a MiCA compliance checklist cover?
Every Title that applies to your role: II (white papers) for offerors, III or IV for stablecoin issuers, V (authorisation, conduct, per-service rules) for CASPs, VI (market abuse) for anyone dealing in listed crypto-assets — plus the travel rule, AML, DORA and GDPR obligations that sit beside MiCA.

Does the checklist differ by CASP service?
Yes. Articles 66–74 apply to every CASP; Articles 75–82 add service-specific rules for custody, trading platforms, exchange, execution, placing, RTO, advice and portfolio management, and transfer services. The Annex IV capital class also follows the services.

Which items carry the heaviest sanctions?
Market abuse (Article 111 floors of €15 million or 15% of turnover), safeguarding of client assets, prudential requirements and operating without authorisation. Prioritise those rows.

Is the transitional period still available?
No. Article 143’s grandfathering for providers operating under national law ended on 1 July 2026 at the latest, and several Member States ended it earlier; a CASP must now be authorised or notified to operate.

Does DORA apply to CASPs?
Yes, from 17 January 2025: ICT risk management, incident reporting, resilience testing and third-party risk, with the register of information — and it is part of what the competent authority assesses at authorisation under Article 62.

Where this leaves you

Use the MiCA compliance checklist as a gap assessment: classify your role, take the Titles that apply, assign an owner and an evidence item to every article-level row, score it, and let the open rows become the remediation plan — starting with capital, safeguarding and market abuse, because those are the rows the competent authority and Article 111 weigh most heavily.

References

• Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) — EUR-Lex — Titles II–VI, Articles 4–92, 111 and 143; Annex IV.
• Regulation (EU) 2023/1113 on information accompanying transfers of funds and certain crypto-assets — EUR-Lex — The travel rule.
• ESMA — Markets in Crypto-Assets Regulation (MiCA) — Technical standards, guidelines and registers.

More on MiCA

• The MiCA compliance checklist — you are here
• MiCA: the complete guide
• CASP authorisation
• The crypto-asset white paper
• Asset-referenced tokens vs e-money tokens
• MiCA compliance cost

The MiCA Gap Assessment Workbook with every article-level row above, the Title V policy and procedure set, the per-service operating procedures, the white paper templates and the market abuse and travel rule procedures are in the MiCA Toolkit, or start with the free templates.