ESMA_QA_2933
02/10/2026
Subject Matter
Technical roles of non-EU group entities in transaction signing and signing policies
Original question
1. Can a non-EU (group) entity co-sign transactions without being considered to exercise control over EU client assets or provide custody?
2. Can a non-EU (group) entity alter signing policies without being considered to exercise control over EU client assets or provide custody?
2. Can a non-EU (group) entity alter signing policies without being considered to exercise control over EU client assets or provide custody?
Status: Forwarded to EC/Public Consultation/Other
Additional Information
Level 1 Regulation
MiCA
Additional Legal Reference
Article 3(1), points (15) and (17); Articles 59, 70, 72 and 75 (9); ESMA Opinion on broker models
Topic
Crypto-Asset Service Provider (CASP)