Can CASPs offer crypto-asset lending services under MiCA, and if so, under which conditions, in particular with respect to the use of clients’ crypto-assets?

How should the perimeter of advice on crypto-assets under MiCA be understood, and to what extent is it comparable to the notion of investment advice under MiFID II?

In particular, do introductory services – where a person recommends a crypto-asset service provider and/or a crypto-asset service to a client, without recommending specific transactions on crypto-assets – fall within the scope of advice on crypto-assets under MiCA?

When a reporting entity (e.g., an issuer, offeror, or person seeking admission to trading) notifies a modification of a white paper originally submitted before the entry into application of Commission Implementing Regulation (EU) 2024/2984 on 23 December 2025, is the reporting entity required to submit the modified white paper in the machine-readable format specified in the regulation?

Under the MiCA framework, can a group structure be set up whereby a non-regulated holding acts as the principal commercial counterparty towards customers (including entering into customer contracts, maintaining customer relationships, and issuing invoices), while a licensed Crypto-Asset Service Provider (CASP) within the same group (daughter company) performs and executes the regulated crypto-asset services?
In such a structure, would it be permissible for the CASP to provide the regulated services without directly contracting with, or invoicing, the end customers, provided that all MiCA requirements (including governance, outsourcing, conflict of interest, and conduct of business rules) are appropriately met?

What are the respective responsibilities of offerors, persons seeking admission to trading, operators of trading platforms and other CASPs mentioned in Article 66(3) of MiCA with regard to white papers for crypto-assets other than ARTs and EMTs that were admitted to trading prior to 30 December 2024?