Map the supervisory questions
Portugal’s Law 69/2025 divides MiCA responsibilities between Banco de Portugal and CMVM. The law includes coordination for provider authorisation. Establish which parts of your business create prudential, conduct, issuance or market questions before deciding how to structure the application work.
Describe each proposed service in customer terms and then in operational terms. Who accepts funds, holds keys, executes an order and handles a complaint? Record the applicant company, suppliers and customer locations. A simple map is useful for exposing activities that a marketing description such as “crypto platform” conceals.
Prepare a coherent application project
Build a working file covering ownership, management, finances, custody, technology, outsourcing and customer handling. Assign a responsible person to each section. These are preparation categories, not a claim that every applicant submits an identical statutory checklist; confirm the actual forms and requirements for the intended route.
Use one consistent operating model across the business plan, payment-flow diagram and compliance policies. If the plan says customer assets remain with a partner, the contracts and technical design should support that statement. Resolve contradictions before they become questions during review.
Separate launch from incorporation
Create explicit launch conditions for permissions, banking, custody readiness and customer disclosures. Incorporating the company or opening an office is an organisational milestone, not evidence that regulated services may begin. Track the official source and owner for each unresolved condition.
For EU expansion, maintain a country-and-service plan and verify the applicable cross-border process. Budget for ongoing controls and reporting, not just application preparation. Reassess the model when adding a token, changing custody suppliers or targeting a new customer market because those changes may alter the regulatory questions.
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.