Ongoing Compliance and Audits under MiCA

As the EU MiCA (Markets in Crypto-Assets) regulation fully applies in 2026, ongoing compliance and audits are essential for all CASPs (Crypto-Asset Service Providers) operating in Europe. Maintaining regulatory adherence not only ensures legal operations but also strengthens investor confidence and facilitates cross-border services across the EEA.

Key Compliance Obligations for CASPs

Under MiCA, CASPs must implement robust compliance frameworks that cover:

• AML/KYC Compliance
  • Client identification and verification
  • Risk-based due diligence
  • Transaction monitoring and reporting
• Internal Governance and Controls
  • Clear operational hierarchy
  • Appointment of compliance and AML officers
  • Risk management policies
• Cybersecurity and IT Standards
  • Secure wallet and custody infrastructure
  • GDPR-compliant data protection
  • Incident reporting protocols
• Regulatory Reporting
  • Submission of periodic reports to national authorities
  • Audit-ready documentation for regulators

Internal and External Audits

MiCA requires CASPs to conduct both internal and external audits to ensure compliance:

Internal Audits

• Regular self-assessments of governance, compliance, and risk management
• Verification of AML/KYC procedures and transaction monitoring
• Identification of gaps and implementation of corrective actions

External Audits

• Conducted by accredited auditors as mandated by the national regulator
• Verification of capital adequacy, operational controls, and IT security
• Audit reports submitted to authorities to maintain licensure

Audits help CASPs detect operational vulnerabilities and maintain MiCA compliance.

Risk Management under MiCA

CASPs must establish a comprehensive risk management framework, including:

• Operational risk assessment
• Cybersecurity threat mitigation
• Business continuity and disaster recovery planning
• Regular review of AML/KYC and internal audit procedures

A strong risk management system is critical for regulatory approval, investor trust, and EU banking relationships.

Consequences of Non-Compliance

Failing to comply with MiCA obligations may result in:

• Regulatory fines and penalties
• Suspension or revocation of CASP license
• Reputational damage with investors and partners
• Restricted access to EU banking and payment networks

Consistent compliance and audit practices are therefore vital for long-term operational security.

FAQ — Ongoing Compliance under MiCA

How often must CASPs conduct audits?

• At minimum, annual internal and external audits are required; frequency may be increased by the regulator based on risk.

Are AML/KYC updates required regularly?

• Yes, CASPs must continuously monitor and update procedures according to EU standards.

Does cybersecurity fall under compliance obligations?

• Absolutely. MiCA mandates robust IT security, secure wallet infrastructure, and GDPR-compliant data handling.

Can non-compliance affect EU passporting rights?

• Yes, persistent non-compliance can result in suspension of EU-wide operational rights.