<b>EU MiCA Licensing Process: Reality Check on Processing Times</b>

The EU's Markets in Crypto-Assets (MiCA) regulation has introduced a complex licensing process for crypto-asset service providers (CASP). While many industry professionals still estimate the processing time to be around 1-3 months, this is overly optimistic and fails to account for various phases of review.

One key aspect that contributes to the prolonged timeline is the completeness check phase. This initial review can take up to 25 working days, during which time the National Competent Authority (NCA) assesses whether the application is complete. If information is missing, the NCA sets a strict deadline for the applicant to provide it, and may refuse to review the application entirely if that deadline is missed.

Another significant factor is the Request for Information (RFI) cycle. Regulators typically use this pre-clock phase to issue RFIs, which can stall the timeline but do not pause the 40-day clock. At least one multi-week RFI cycle should be factored into any realistic timeline.

The fit and proper assessment also plays a crucial role in the licensing process. This covers the management body and qualifying shareholders, and requires members of the management body to demonstrate good repute, knowledge, skills, and experience. In some jurisdictions, live interviews are required, which can add an extra 4-6 weeks to the timeline.