ESMA_QA_2932
01/10/2026
Subject Matter
Transient exposure of EU client crypto-assets in a non-EU hot wallet during deposits, withdrawals and settlement
    In the context of in/out transfers (deposits/withdrawals) from an EU authorised CASP, can assets from EU clients temporarily be held in a (hot) wallet at an entity not authorised as a CASP under MiCA? Under what conditions, if any, would the temporary presence of EU client crypto-assets in that wallet be considered a purely technical/transient transfer step rather than custody, administration or transfer services being provided by the non-authorised entity?
    Status: Question Published

    Additional Information

    Level 1 Regulation
    MiCA
    Additional Legal Reference
    MiCA Article 3(1), points (15) and (17); Articls 59; Article 70(1); Article 75(9); Commission Delegated Regulation (EU) 2025/303; ESMA Opinion on broker models paragraph 8 and footnote 10; ESMA Q&A 2608
    Topic
    Crypto-Asset Service Provider (CASP)