CASP -Trading Platform Operation
CASP authorization for operating a crypto-asset trading platform with non-discretionary rules, fair and orderly trading procedures, market abuse prevention, and transparent pricing.
MiCA Article 3(15)(c), Article 76
Capital Required
€150,000 (Class 3) + 25% quarterly fixed overheads
Timeline
4-8 months
Fees
Included in general CASP authorization (€3,000-100,000)
Regulatory Body
ESMA / National Competent Authorities (NCAs)
Legislative Framework
Markets in Crypto-Assets Regulation (MiCA) 2023/1114, Payment Services Directive 2 (PSD2), Digital Operational Resilience Act (DORA)
Last updated: June 2025
Key Requirements
Maintain minimum capital of €150,000 (Class 3) per MiCA Annex IV for trading platform service provision.
Establish published, non-discretionary trading rules governing order submission, matching, execution, and settlement procedures per MiCA Article 76(1).
Implement fair and orderly market procedures including order validation, price reasonableness checks, and order rejection/cancellation protocols.
Establish documented market abuse prevention program covering position limits, order monitoring, spoofing detection, and trader surveillance.
Maintain transparent real-time pricing with published order books (or price quotes) and execution price reporting to all market participants.
Implement segregation of trading operations from settlement/custody functions with clear role separation and conflict-of-interest management.
Establish documented procedures for market participant admission, good standing monitoring, and default management.
Conduct annual third-party operational resilience assessment covering trading systems availability, cybersecurity, and disaster recovery capabilities.
Application Process
Develop comprehensive trading rules documentation including order types, matching algorithms, execution procedures, and settlement arrangements.
Design and document market abuse detection system including order monitoring, position limit controls, and trader behavioral analysis.
Establish trading system infrastructure with documented availability targets (typically 99.5% uptime), backup procedures, and disaster recovery plans.
Prepare CASP authorization application highlighting trading platform-specific governance, operational procedures, and market abuse prevention controls.
Provide detailed documentation of trading rules, member admission procedures, market surveillance program, and system resilience measures.
Engage with NCA for review of trading procedures, market abuse controls, and operational resilience arrangements.
Implement trading platform with approved rules framework, publish terms and conditions, and begin member onboarding under NCA authorization.
Expected Total Timeline
4-8 months
Ongoing Obligations
After obtaining your CASP -Trading Platform Operation, these are the continuing compliance requirements you must maintain.
Maintain published trading rules and immediately notify NCA of any material rule modifications within 15 days before implementation.
Monitor and report market abuse concerns to relevant authorities with documented investigation procedures and remediation actions.
Maintain market participant records and conduct annual good standing reviews with documented admission and removal procedures.
Publish daily/weekly market statistics including trading volumes, order activity, and price movements for transparency and surveillance purposes.
Conduct quarterly reviews of order matching and execution procedures to ensure fair and orderly market operation.
Perform annual operational resilience assessments by independent third parties and address identified deficiencies within 30 days.
Maintain conflict-of-interest policies separating proprietary trading, market making, and trading surveillance functions with documented procedures.
Cost Summary
Capital Requirement
€150,000 (Class 3) + 25% quarterly fixed overheads
Application & Licensing Fees
Included in general CASP authorization (€3,000-100,000)
Jurisdiction Setup Cost
$40,000-$120,000
Annual: $50,000-$150,000
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