MiCA Solution for Broker

Editorial note: This guide is an educational overview, not legal advice. MiCA obligations depend on the services a firm provides, the crypto-assets involved, its entity structure and the approach of the relevant national competent authority. Brokers should validate their compliance design with qualified legal and regulatory advisers.

A credible MiCA solution for broker operations is not a single regulatory checkbox or a standalone identity-verification tool. It is an operating model that helps a broker evidence who it serves, what services it provides, how decisions are governed, how clients are treated and how records can be retrieved when supervisors ask questions.

For EU-facing crypto brokers, that operating model is now a business issue as much as a compliance issue. The Markets in Crypto-Assets Regulation, commonly known as MiCA, creates harmonised rules for crypto-assets and crypto-asset services that are not already regulated under existing EU financial-services law. Its purpose is to support innovation while raising standards for market integrity and protection of clients.

The practical question is therefore not simply, “Do we need MiCA?” It is, “Can our people, data and workflows demonstrate controlled delivery of the services we actually offer?” A well-designed MiCA solution helps bring that answer together across onboarding, risk assessment, approvals, client communication, operational controls and audit evidence.

主要收获

• Treat MiCA as an operating model: A broker needs connected governance, client, service and record-keeping controls, not just a policy pack.
• Begin with service and asset classification: The scope of MiCA depends on the activities and crypto-assets involved, while crypto-assets that qualify as financial instruments remain subject to the existing EU financial-services framework.
• Build evidence into ordinary work: The strongest compliance approach captures decisions, approvals, client communications and exceptions as the work happens.
• Keep specialist controls connected: KYC, sanctions screening, blockchain analytics, custody infrastructure and Travel Rule tooling each have roles. Your operating platform should make the hand-offs visible and auditable.
• Design for supervision and growth: Authorisation, ongoing governance, outsourcing oversight and customer protection should scale with the business rather than slow it down.

MiCA Broker Readiness Checklist

Use the framework in this guide to map services, owners, data sources, evidence, exceptions and remediation priorities before a board or authorisation review.

Speak with the 投资玻璃 team about designing the workflow layer behind your compliance programme.

What is a MiCA solution for a crypto assets broker?

A MiCA solution for a broker is a coordinated set of policies, controls, systems and operating workflows that supports the firm in meeting applicable MiCA requirements. It should give the broker a reliable way to govern crypto-asset services, protect clients, manage operational risk and produce evidence of how the business is controlled.

MiCA does not prescribe one technology stack. Instead, it establishes a framework that includes authorisation and operating conditions for crypto-asset service providers, or CASPs, as well as rules on market abuse, supervision and related disclosures. Title V focuses specifically on the authorisation and operating conditions of CASPs.

For a broker, the solution is usually wider than trading technology. It should coordinate the life cycle around the trade: prospect engagement, client onboarding, identity and risk checks, suitability or appropriateness steps where relevant, order or OTC workflow, custody and transaction evidence, exception handling, complaints and management reporting.

Regulatory perspective: ESMA’s supervisory briefing emphasises that CASP authorisation applicants should demonstrate real substance and governance, autonomous operation with sufficient in-country personnel, effective control of outsourcing, and technically competent management.

This does not mean every broker needs to build every control internally. It means the broker needs clear ownership, reliable data flows and demonstrable oversight. A specialist screening provider, a custody provider, a blockchain-analytics provider or a Travel Rule network may remain separate. The broker still needs an orderly way to connect their outputs to a decision, an owner, an approval and a retrievable client record.

Pro tip: Define the outcome before procuring software. For every important control, write down the event that triggers it, the data needed, the person accountable, the acceptable decision paths, the evidence retained and the escalation route. This turns a vague “MiCA platform” requirement into an assessable operating design.

When does a crypto broker need to think like a CASP?

A crypto broker should assess whether its actual services amount to crypto-asset services under MiCA, rather than relying on labels such as “broker”, “exchange”, “OTC desk” or “technology provider”. The legal analysis must map the firm’s commercial activities, client journey, entity structure and asset types against MiCA and other applicable EU rules.

MiCA is deliberately not a substitute for every financial-services rule. Where a crypto-asset qualifies as a financial instrument, it remains within the existing EU financial-services framework rather than MiCA. This boundary makes classification a foundational workstream. A broker that offers a mix of tokenised instruments, unregulated crypto-assets, custody and execution services may face multiple rule sets at once.

The following table helps translate common broker activities into practical questions. It is not a legal classification tool, but it is useful for structuring conversations with legal advisers and the relevant national competent authority.

Broker activity or capability	Practical MiCA design question	Evidence a mature operating model should retain
Client acquisition and onboarding	Who is the contracting entity, which clients and jurisdictions are in scope, and what checks apply before activation?	Identity data, risk rating, verification results, consent, approvals and audit trail.
Receiving and transmitting orders	Which service is being provided, who may accept instructions, and how are client instructions recorded?	Time-stamped order records, client authority, communication history, routing logic and exception approvals.
Execution or OTC dealing	How are prices, conflicts, execution decisions and client disclosures controlled?	Quotes, execution records, disclosure versions, conflicts register and supervisory review notes.
Custody or wallet administration	Who controls keys or access, how are client holdings segregated, and how are incidents handled?	Wallet records, reconciliations, access approvals, incident log and client communications.
Advice or portfolio services	Which staff may provide the service, what competency evidence is required, and how are recommendations documented?	Staff training, client profile, rationale, disclosures, approval records and reviews.
Crypto-asset transfers	What AML, sanctions, wallet-risk and Travel Rule processes apply?	Risk signals, counterparty checks, transfer data, alerts, decisions and retained evidence.

A broker’s first deliverable should therefore be a service perimeter map. This concise document identifies legal entities, target markets, services, customer types, assets, third-party dependencies, responsible executives and the records created at each stage. It reduces the risk of building controls around an assumed business model that does not match the real client experience.

For a practical starting point, brokers can connect this map to their crypto broker CRM workflow, making clients, accounts, compliance tasks and operational activity visible in one place rather than scattered across inboxes and spreadsheets.

Why is MiCA regulation readiness now an operating priority?

MiCA entered into force in June 2023 and the framework became fully applicable in December 2024, subject to limited national transitional measures. ESMA explains that Article 143 allowed eligible pre-existing providers in certain jurisdictions to continue temporarily during a limited national transitional period until the earlier of an authorisation decision or 1 July 2026. As of August 2026, a broker should not view grandfathering as a new implementation strategy. It should confirm its current legal position with the relevant national competent authority and advisers in the relevant member state.

This timing matters because authorisation is only one part of the picture. Supervisors can assess whether a business has sufficient governance, local substance, staff capability and oversight of outsourced activities. ESMA has stated that national competent authorities are expected to apply its supervisory principles during authorisation and ongoing supervision.

For brokers, the implication is straightforward. A credible application or ongoing compliance programme must show how the model works in practice. A policy that says “compliance monitors exceptions” is weak if no process shows what an exception looks like, how it is routed, who resolves it and where the evidence sits.

A workflow-led MiCA solution turns those high-level commitments into ordinary operations. It provides a common record for requests, due diligence, approvals, review dates, correspondence and escalation. That is valuable both when preparing for regulatory scrutiny and when onboarding new clients or entering additional EU markets; a key advantage is that, once authorised under the framework in the European Union, MiCA supports passporting across all EU countries and all 27 EU member states.

What should a MiCA-ready broker operating model cover?

A broker does not need a different system for every requirement. It needs a controlled way to link work across the organisation, and that connected design can help control compliance costs as MiCA introduces new requirements across teams and vendors. The table below sets out the seven capabilities that should be considered when selecting or configuring a MiCA solution.

能力	What good looks like	Typical operational owner	Why it matters for a broker
Service perimeter and governance	Clear service catalogue, entity map, delegated authorities, policies, board reporting and decision logs.	Board, senior management, legal and compliance.	Demonstrates that the firm understands its business model and can evidence accountability.
Client onboarding and due diligence	Digital forms, identity checks, risk scoring, beneficial-owner capture, periodic reviews and approval routing.	Compliance and operations.	Reduces manual hand-offs and makes customer acceptance decisions defensible.
Conduct and client communication	Controlled disclosures, approved templates, communication history, conflicts registers, complaints workflow and service records.	Compliance, client service and sales.	Helps show that clients receive consistent, clear and fair treatment.
Order and transaction evidence	Time-stamped client instructions, pricing or quote evidence, approvals, trade linkage and exception queues.	Brokerage operations and dealing desk.	Supports traceability across execution, OTC and voice-assisted activities.
AML, sanctions and transfer controls	Screening outputs, alert case management, wallet-risk signals, Travel Rule and counterparty processes, documented decisions.	MLRO, AML team and operations.	Connects financial-crime controls to the underlying client and transfer context.
Outsourcing and third-party oversight	Vendor inventory, materiality assessment, service levels, due diligence, incident governance and periodic review.	Risk, procurement and senior management.	Demonstrates that outsourced control activities remain governed by the broker.
Records and management information	Searchable, role-based records; retention controls; audit exports; dashboards; and issue remediation tracking.	Compliance, risk and technology.	Enables reliable supervision, internal challenge and timely remediation.

The common thread is traceability. Because MiCA guidance and technical expectations continue to evolve, the operating model should be easy to update without redesigning every control. The most useful MiCA solution does not merely collect files. It connects each file and data point to a client, activity, decision, responsible person and timestamp.

For example, an onboarding record should not end when a client is activated. It should continue to link periodic reviews, account changes, risk events, product access, transfers, complaints and offboarding. That connected history is where a broker creates operational resilience and handles compliance challenges without unnecessary rework.

Pro tip: Build a “single client and control view”. It does not mean replacing every specialist tool. It means that a reviewer can quickly see the client’s profile, risk rating, documents, tasks, open alerts, approvals, communications and linked transactions without asking five teams to reconstruct the story.

How does the MiCA broker compliance process work in practice?

A practical MiCA operating model moves from client enquiry to audit evidence through a controlled sequence. Every step should have a named owner, a defined decision and a durable record. The process below is intentionally technology-neutral so that brokers can adapt it to their own product model and national requirements.

The journey starts with client enquiry and segmentation. A broker should decide whether it will serve the prospective client, in which jurisdiction, through which legal entity and for which services. Early segmentation prevents sales activity from creating expectations that the operating model cannot support.

Next comes 数字入职 and due diligence. This is where a firm obtains and validates the information required by its policies and applicable AML or customer-protection rules. A configurable 数字化入职流程 helps teams collect consistent information and route incomplete or higher-risk cases for review.

The third stage is risk classification and approval. The point is not to assign a static score that is never revisited. The point is to document the factors behind the risk decision, the person who accepted the relationship and the review schedule. Higher-risk or complex cases should move through more robust escalation and decision paths.

The fourth stage is the brokerage service and order workflow. Depending on the model, this may include client instructions, quote requests, order acceptance, execution evidence, price verification, conflicts checks, allocations and post-trade communications. The broker should ensure that its workflow matches the exact service being offered and the disclosures made to clients.

The fifth stage is monitoring and exception handling. Alerts are valuable only if a person can assess them in context. Ongoing surveillance should cover indicators of market manipulation and insider trading under MiCA, with each decision documented against the relevant client, service or transaction to ensure transparency. AI-driven tools can support alert review and the provision of monitoring, but human oversight and recorded decisions remain necessary. A good workflow attaches alert evidence to the client, service, transaction or counterparty, records the decision and captures the follow-up action. This helps teams explain associated risks and preserves operational memory so unresolved issues are not trapped in personal inboxes.

The final stage is management information and audit evidence. Senior management should receive clear reporting on volumes, exception trends, outstanding reviews, complaints, incidents, control failures and remediation. Reporting works better when the solution uses standardized data schemas that support consistent regulatory evidence and exports. This is not a cosmetic dashboard exercise. It is how leaders demonstrate oversight and decide where to strengthen the programme.

MiCA Workflow Design Workshop

Map one client journey, from prospect to transaction review, then identify where data, accountability or evidence is currently lost.

Explore InvestGlass workflow automation for regulated financial-services teams.

Which MiCA controls should brokers prioritise first?

Brokers should prioritise controls based on legal scope, client risk, operational dependency and potential harm to clients or the market. A risk-based approach is more sustainable than trying to digitise every policy in a single project.

Start with classification and accountability

The first priority is to confirm the service perimeter and identify accountable owners. Management must know what the firm offers, where it offers it, which entity contracts with clients and which third parties support delivery. Without this clarity, it is difficult to design proportionate controls or produce a coherent authorisation narrative.

MiCA’s framework distinguishes between crypto-assets subject to the regulation and crypto-assets that are already regulated under existing EU financial-services legislation. A broker should therefore maintain a classification process that can be revisited when a new asset, product feature or jurisdiction is introduced.

Make onboarding evidence complete and reusable

A broker’s client file should be useful to sales, operations, compliance and client service while still respecting access controls and data minimisation. It should capture the source, verification status, date, owner and outcome of each important check.

This is where automation can improve quality without removing human judgement. InvestGlass KYC workflow automation can help organisations collect documents, create review tasks, route exceptions and retain a traceable process around client due diligence. The compliance decision remains the responsibility of the broker and its authorised personnel.

Treat conduct as a workflow, not a document library

Client disclosures, conflicts management, complaints, pricing transparency and communication standards are operational activities. A broker needs an approved source for templates and disclosures, clear version control, a log of meaningful client communications and a pathway for complaints or objections.

ESMA’s first MiCA CASP rule package explicitly addressed information for authorisation and CASP complaints handling, underlining that client treatment belongs in the core operating model. A pragmatic design makes it simple for staff to use the approved process and difficult to bypass it without creating an exception record.

Connect financial-crime and transfer controls

MiCA is not the only compliance regime relevant to crypto brokers. The regulation itself notes that entities offering services in its scope must also comply with applicable EU anti-money-laundering and counter-terrorist-financing requirements.

For crypto-asset transfers, the EU Transfer of Funds Regulation applies information requirements to transfers involving a crypto-asset service provider, including transfers to or from self-hosted addresses. For transfers over EUR 1,000 involving a self-hosted address, the crypto-asset service provider is required to verify whether the address is owned or controlled by its client.

That creates a need for connected but distinct controls. Screening, 交易监控 and Travel Rule network connectivity may each be provided by specialist services. A broker still needs the surrounding case workflow to collect client information, identify a counterparty, route additional checks, document a decision and retain evidence. This is the operational role described on the InvestGlass Travel Rule page, which focuses on orchestration, records, approvals and interoperable submission alongside existing specialist tools.

Build an outsourcing control plane

Most brokers rely on third parties for at least part of custody, identity verification, wallet infrastructure, market data, execution, screening or cloud services. ESMA’s supervisory guidance makes outsourcing and the limits on externalising functions a clear point of attention.

A broker should have a complete vendor inventory, named owners, risk assessments, materiality decisions, service-level monitoring, incident escalation and periodic review records. The key question is not whether outsourcing exists. It is whether the broker retains control and can demonstrate it.

What should you look for in a MiCA solution for broker operations?

A broker should evaluate a MiCA solution against its ability to support accountable work, integrate with specialised technology and produce usable evidence. The wrong procurement approach is to select a platform solely because it has a “MiCA” label. The better approach is to test whether the system makes the broker’s actual policies executable.

Evaluation area	Questions to ask a prospective solution provider	Signals of a practical fit
Workflow configuration	Can we create our own approval paths, review dates, risk triggers and escalation rules without lengthy development?	Teams can adjust processes as policies, products and national expectations change.
Client and entity records	Can individual, corporate, beneficial-owner and counterparty records be linked with permissions and audit history?	A reviewer can reconstruct the relationship without combining multiple spreadsheets.
Integration architecture	Can the platform connect to KYC, screening, custody, transaction monitoring and Travel Rule tools without duplicating decisions?	Specialist tools remain best-of-breed while the operating record remains connected.
Evidence and audit trail	Are tasks, source documents, decision reasons, approvals and timestamps searchable and exportable?	Compliance can produce a credible case history quickly.
Client communication	Can approved forms, notifications, secure documents and service messages be retained in the client record?	Communications are consistent and supportable during a complaint or review.
Information security and sovereignty	Are data location, access control, retention, role management and vendor responsibilities clear?	The broker can assess its own security, privacy and outsourcing obligations.
Management reporting	Can the system surface overdue reviews, open risks, exceptions, bottlenecks and remediation progress?	Senior management receives decision-useful information rather than raw activity counts.

A practical MiCA solution should also accommodate change. MiCA implementation will continue to evolve through supervisory practice, technical standards and national application. A rigid system that requires a new project every time a process changes can become a compliance risk in its own right.

Pro tip: Ask to see a complete exception journey in a live demonstration. For example: an incomplete 企业入职 file, a high-risk wallet alert or an OTC trade requiring senior approval. If the supplier cannot show the trigger, assignment, evidence, approval, notification and audit export, the platform may not support the workflow depth your broker needs.

How can InvestGlass support a MiCA-ready broker operating model?

InvestGlass can serve as the connected workflow layer around a broker’s MiCA programme. It is not a substitute for legal analysis, formal authorisation decisions, specialist blockchain analytics or every service-specific control. It is a platform that helps regulated teams organise client data, digital processes, approvals, communications and evidence so that the programme can operate consistently.

For brokerages, InvestGlass CRM for crypto brokers describes an environment that brings together transaction monitoring context, KYC checks, price verification and lifecycle monitoring for OTC and voice-trade operations. This is useful when a compliance or operations team needs to view a client interaction alongside the related process, rather than searching through disconnected applications.

InvestGlass can also help brokers create structured, repeatable client journeys. Its digital onboarding capabilities support custom forms and document collection, while the compliance workflow resources explain how teams can route tasks, preserve approval trails and maintain accountable processes. The goal is to create a coherent operational record, not to automate away professional judgement.

For firms that manage client positions or advisory-style information alongside crypto-asset services, InvestGlass portfolio management tools provide another connection point. Keeping portfolios, client communications and workflow tasks close to the broader client record can improve hand-offs between front office, operations and compliance.

The value is cumulative. When the broker has a common process layer, it can configure different journeys for retail and professional clients, build escalation for higher-risk cases, set regular review dates, retain decision evidence and report unresolved issues to management. That helps turn MiCA compliance from a periodic documentation exercise into a repeatable operating capability.

Illustrative example: Consider an EU-facing OTC broker that receives a corporate client enquiry. The relationship manager starts a digital intake, compliance obtains beneficial-owner and risk information, a higher-risk flag routes the case to the MLRO, and approval activates a restricted service profile. When the client later requests a transfer, the transfer process pulls the relevant client record, prompts counterparty due diligence and stores the final review decision. No system alone proves compliance, but a connected workflow makes accountability and evidence substantially easier to manage.

How should a broker implement a MiCA solution?

Implementation should be sequenced around business risk and decision readiness. A large transformation programme can be appropriate for a complex group, but most brokers benefit from delivering a controlled foundation first and then expanding service-specific workflows.

阶段	Primary objective	Practical outputs	Executive question
1. Diagnose	Understand the actual operating perimeter.	Service map, entity map, asset classification approach, jurisdiction matrix and gap register.	Do we know what we provide and where the risk sits?
2. Design	Convert obligations and policies into operating journeys.	Control library, RACI, client journeys, approval matrix, data model and evidence requirements.	Can every key requirement be performed and proven?
3. Configure	Build the high-risk, high-volume workflows first.	Onboarding, reviews, exception queue, complaints, vendor reviews, dashboards and integrations.	Does the system reflect the process people must follow?
4. Prove	Test the design with realistic cases.	Scenario tests, user acceptance testing, sample evidence packs, training records and remediation log.	Can we reconstruct a decision from start to finish?
5. Govern	Operate, monitor and improve.	Management information, control attestations, incident reviews, policy updates and periodic assurance.	Are we learning from exceptions and maintaining oversight?

During diagnosis, avoid the temptation to begin with a long list of regulatory articles. Start with the client journey and the services the broker delivers. Then map the policy requirements to the exact moments where a decision is made, information is collected or a risk is accepted.

During design, choose a small set of test cases that represent the firm’s hardest realities. Examples may include a corporate onboarding with layered ownership, a cross-border client, an elevated wallet-risk event, an urgent OTC transaction or a service complaint. These scenarios expose missing responsibilities and poor data hand-offs far earlier than a policy review alone.

During configuration, integrate specialist controls with purpose. A workflow platform should receive the evidence or decision needed to drive the next step, not necessarily every raw data point from every system. This improves usability and may support better data governance.

During proof and governance, make evidence retrieval a core acceptance test. If a manager, auditor or supervisor asked why a client was accepted, why an alert was closed or why an exception was approved, the business should be able to answer with a coherent record. This is the practical standard that matters.

Common MiCA implementation mistakes brokers can avoid

The most persistent implementation errors are usually operational rather than theoretical. They occur when a broker has suitable policies but weak ownership, incomplete data or controls that rely on individual memory.

错误	Why it creates risk	Better approach
Treating MiCA as a document project	Policies alone do not show how controls operate in real client and trading scenarios.	Map each policy to a workflow, an owner, a record and an escalation path.
Using “broker” as a legal conclusion	A commercial label may not describe the regulated service actually provided.	Perform and maintain a service-and-asset classification assessment with advisers.
Fragmenting the client record	Important decisions, documents and communications become difficult to reconstruct.	Establish a controlled source of truth for client, entity and compliance workflow context.
Automating without a human decision model	Alerts can be closed mechanically without clear accountability or appropriate judgement.	Define decision rights, exceptions and quality assurance before automating tasks.
Ignoring outsourcing evidence	The broker may be unable to demonstrate oversight of critical suppliers.	Maintain a vendor register, risk assessment, responsibilities and review programme.
Building for authorisation only	A one-off application pack does not support ongoing supervision, reviews and change.	Design recurring processes, reporting and remediation workflows from the first release.

A well-run programme also avoids overclaiming. No vendor can guarantee authorisation or declare a broker compliant in isolation. Authorisation and compliance depend on the firm’s full business model, people, governance, technology, capital, outsourcing, conduct and supervisory engagement. The role of a MiCA solution is to make that programme more controlled, observable and maintainable.

Conclusion: make MiCA compliance executable

A MiCA solution for broker operations should help turn regulatory principles into clear everyday decisions. It should let a broker connect client information, service eligibility, due diligence, approvals, communications, trading context, exceptions and evidence in a way that management can oversee.

The strongest outcome is not more software. It is a reliable operating rhythm: staff know what to do, clients receive consistent treatment, specialist systems share the right context, exceptions are visible and leaders can demonstrate control. That is the foundation for a broker seeking to operate confidently in the EU crypto-asset market.

If you are designing that foundation, explore how InvestGlass can support connected onboarding, CRM, compliance workflow automation, client communication and evidence management around your MiCA programme. Start with one high-risk client journey, make the decision points visible and build out from there.

常见问题

1. What is MiCA?

MiCA is the EU’s Markets in Crypto-Assets Regulation, Regulation (EU) 2023/1114. It provides a harmonised framework for certain crypto-assets, issuers and crypto-asset service providers that are not already covered by existing EU financial-services law.

2. Does every crypto broker need a MiCA authorisation?

Not automatically. The answer depends on the broker’s actual services, the crypto-assets concerned, the legal entity delivering the service and whether another EU financial-services regime applies. A broker should obtain tailored legal advice and engage with the relevant national competent authority as appropriate.

3. What is a CASP under MiCA?

A CASP is a crypto-asset service provider. MiCA Title V covers the authorisation and operating conditions for CASPs, while specific obligations depend on the services offered.

4. Are tokenised financial instruments covered by MiCA?

Crypto-assets that qualify as financial instruments remain subject to the existing EU financial-services framework, rather than MiCA. Classification is therefore a critical issue for brokers with mixed product offerings.

5. What should a MiCA solution for broker operations include?

A suitable solution should support the broker’s own risk-based workflows for governance, onboarding, due diligence, conduct, order or transaction evidence, outsourcing oversight, exception management, reporting and record-keeping. It should integrate with specialised systems where necessary instead of assuming one application can perform every control.

6. Can a CRM help with MiCA compliance?

A CRM can help when it becomes a controlled system of record for client data, workflow tasks, communications, approvals and evidence. It does not replace legal interpretation or specialist compliance tools, but it can make compliance processes more consistent and easier to review.

7. How does MiCA relate to AML and the Travel Rule?

MiCA does not replace EU anti-money-laundering and counter-terrorist-financing obligations. Crypto brokers may also need processes under the EU Transfer of Funds Regulation for crypto-asset transfers, including information requirements where a crypto-asset service provider is involved.

8. What is the deadline for MiCA compliance?

MiCA’s broader framework applied from December 2024, while limited national transitional measures could apply to certain pre-existing providers until the earlier of an authorisation decision or 1 July 2026. By August 2026, brokers should confirm their legal position directly with advisers and the relevant national competent authority.

9. Can a broker outsource KYC, custody or transaction-monitoring activities?

Brokers often use third parties for these services, but outsourcing does not remove the need for governance and oversight. ESMA’s guidance highlights the importance of effective limits on outsourcing, sufficient substance and accountable management.

10. How can InvestGlass support a MiCA programme?

InvestGlass can help a broker connect digital onboarding, client records, KYC workflow, approvals, communications, evidence retention and integrations with specialist compliance tools. It should be deployed as part of a wider, broker-owned compliance programme that has been validated for the firm’s particular services and jurisdictions.