Map services before selecting a route
BaFin’s crypto-service guidance sets out the MiCA authorisation process and relevant exceptions. It also states that applicants must demonstrate the applicable DORA requirements in their submission. Establish which services your firm will perform and which will be supplied by separately authorised partners.
Build a diagram showing onboarding, fiat receipt, execution, custody and withdrawal. Identify the legal entity controlling each step and where customers are located. A front-end website and an underlying asset-handling business can raise very different questions, even when customers see one brand.
Turn controls into named responsibilities
Prepare an ownership chart and assign accountable people for compliance, operations, technology and customer complaints. Describe how each control will work during ordinary trading and during an incident. An outsourced supplier’s brochure does not explain how your own management will supervise that supplier.
Use worked examples in the file: a failed withdrawal, unavailable custody provider, suspicious transfer or dispute over execution. Explain who identifies the issue, who decides the response and which records support the decision. These examples help expose gaps before they become operational problems.
Plan for review and ongoing operation
BaFin checks application completeness and can request missing information. Its published guidance describes fees based on the work undertaken. Build time and resources for clarification rounds into the plan instead of treating submission as the launch milestone.
After authorisation, EU expansion still needs the relevant cross-border notification process. Maintain a country-and-service rollout list rather than announcing unrestricted access everywhere. Budget for ongoing governance, reporting and resilience work, and document the conditions that must be satisfied before accepting the first customer assets.
Sources & scope
Official sources support the jurisdiction context. The working checklists are CryptoGov’s editorial preparation suggestions, not an exhaustive application or filing requirement. Confirm the rules and your circumstances before acting.