Launch EU Crypto Services in 40 Days: The MiCA Article 60 Fast Track Most Firms Don't Know Exists
- Yiannos Ashiotis
- 19 hours ago
- 8 min read
Most firms pursuing EU crypto market access assume they face one path: applying for CASP (crypto-asset service provider) authorization under MiCA, which typically requires four to six months of regulatory review, minimum capital from €50,000 to €150,000, and building compliance infrastructure from scratch.
But there's a dramatically faster route hiding in plain sight within MiCA's 148 articles—one that lets certain entities launch comprehensive crypto services in just 40 working days without obtaining separate CASP authorization, without additional capital requirements, and without repeating governance assessments.
It's called Article 60, and it represents the most significant competitive advantage in European crypto regulation that most firms haven't heard of.
1 What Article 60 Actually Does
Article 60 of MiCA creates a notification regime (not authorization) for six categories of already-regulated financial entities. Instead of applying for separate CASP authorization, these entities simply notify their competent authority 40 working days before providing crypto services—and commence operations when that period expires.
The regulatory logic is straightforward: banks already demonstrate capital adequacy through billions in regulatory capital under CRR/CRD. Investment firms already maintain governance standards under MiFID II. Asset managers already comply with AML/CFT frameworks under UCITS or AIFMD. Requiring these entities to obtain separate CASP authorization would duplicate assessments of the same capital, governance, and compliance capabilities already validated under existing frameworks.
Article 60 eliminates that duplication. Banks, investment firms, asset managers, and other authorized entities can extend into crypto-asset services equivalent to their existing authorizations via simple notification—launching in 40 days versus six months.
But here's the critical distinction: Article 60 applies only to entities already authorized in EU member states. If you're a crypto-native startup, an international financial group, or an EU firm lacking relevant authorization, you can't directly use Article 60.
However, you can access its benefits indirectly—through partnership, acquisition, or building appropriate EU entities. This article explains exactly how.
2 Who Can Use the MiCA Article 60 Directly
Six categories of EU-authorized entities qualify for the Article 60 fast track:
Entity Type | Services Available via Article 60 | Timeline |
Credit Institutions | ALL crypto services (custody, trading, exchange, advice, portfolio management, etc.) | 40 days |
MiFID Investment Firms | Crypto services equivalent to MiFID authorization (must map existing services) | 40 days |
UCITS/AIFMs | Crypto portfolio management, advice, reception/transmission of orders | 40 days |
Central Securities Depositories | Crypto custody only | 40 days |
Electronic Money Institutions | Custody/transfer of own issued e-money tokens only | 40 days |
Market Operators | Crypto trading platform operation | 40 days |
2.1 Credit Institutions: Universal Scope
Banks authorized under CRR/CRD enjoy the broadest Article 60 scope: they may provide any and all crypto-asset services upon notification. No equivalence limitations. No restrictions.
This means European banks can offer:
Custody of crypto-assets in segregated accounts
Trading platforms for crypto-assets
Exchange services (crypto to fiat, crypto to crypto)
Portfolio management including crypto allocation
Investment advice on crypto-assets
All other MiCA crypto services
Why universal access? Regulatory judgment that banks operating under the EU's most stringent prudential framework possess capital, governance, and oversight sufficient for any crypto service model.
The competitive implication: While standalone CASPs spend on average six months on authorization, European banks can notify and launch comprehensive crypto offerings in eight weeks.
2.2 MiFID Investment Firms: The Equivalence Test
Investment firms authorized under MiFID II may provide crypto services equivalent to MiFID services they're specifically authorized for.
The regulation establishes explicit equivalences:
Your MiFID Authorization | Article 60 Crypto Service Available |
Safekeeping of financial instruments | Custody of crypto-assets |
Operating MTF/OTF | Operating crypto trading platform |
Dealing on own account | Exchange crypto/fiat or crypto/crypto |
Execution of orders | Execution of crypto orders |
Portfolio management | Crypto portfolio management |
Investment advice | Crypto investment advice |
Reception/transmission of orders | Reception/transmission crypto orders |
Critical constraint: You can only provide crypto services equivalent to your existing MiFID authorization. An execution-only broker cannot provide custody via Article 60 without safekeeping authorization. A portfolio manager cannot operate a trading platform via Article 60 without MTF/OTF authorization.
2.2.1 Example - Full-Service Wealth Manager:
MiFID authorization: Portfolio management, investment advice, execution, safekeeping
MiCA Article 60 enables: Comprehensive crypto wealth management—custody, discretionary management, advice, execution. The firm replicates its traditional services for crypto-assets.
2.2.2 Example - Execution-Only Broker:
MiFID authorization: Execution of orders, reception/transmission only
Article 60 enables: Crypto trade execution only
Cannot provide: Custody (no safekeeping auth), advice (no advisory auth), portfolio management (no management auth)
The strategic problem: Without custody, this firm can't offer wallet services. It likely needs full CASP authorization for comprehensive crypto offerings.
2.3 UCITS/AIFMs: Portfolio Management and Advisory
UCITS management companies and AIFMs may provide crypto portfolio management, investment advice, and (for AIFMs) reception/transmission of orders.
Strategic applications:
Launch crypto-focused AIFs without separate CASP authorization
Integrate crypto into multi-asset discretionary portfolios
Provide crypto allocation advice as part of wealth planning
Key limitation: Asset managers cannot provide custody via Article 60 (unless also authorized as banks or MiFID firms with safekeeping). They need custody partnerships with banks using Article 60, standalone CASPs, or specialized crypto custodians.
2.4 CSDs, EMIs, Market Operators: Narrow Scopes
Central Securities Depositories: Custody of crypto-assets only
Electronic Money Institutions: Custody and transfer of own issued e-money tokens only (cannot provide services for third-party crypto-assets)
Market Operators: Trading platform operation only
These entities face service-specific Article 60 scopes aligned to their core functions. Services beyond these boundaries require separate authorization.
3 How to Access the MiCA Article 60 Indirectly: 4 Practical Pathways
If you don't currently hold relevant EU authorization, Article 60 remains accessible through strategic pathways.
3.1 Pathway 1: Partner with EU Entities Using MiCA Article 60
Timeline: 3-6 months | Investment: €50K-€200K | Control: Shared
Best for: Fast market testing, limited capital, international firms wanting EU distribution without local entity
How it works:
Identify EU MiFID firms or banks that have completed (or will complete) Article 60 notifications. Structure partnerships:
White-label arrangements: Partner's Article 60 services branded as yours
Revenue share models: Split fees on clients you introduce
API integration: Embed partner's crypto services into your platform
Referral agreements: Send clients to partner, earn referral fees
Example: An international wealth manager partners with Irish MiFID firm using Article 60 for crypto custody and execution. International firm sources clients, Irish firm provides regulated services, revenue split 60/40.
Advantages:
✅ Fastest route (3-6 months)
✅ No authorization burden or regulatory capital
✅ Test market viability before full commitment
Disadvantages:
❌ Revenue share reduces margins
❌ Dependency on partner's capabilities
❌ Less control over client experience
When this makes sense: Fast market entry, limited capital, testing demand before authorization investment.
3.2 Pathway 2: Acquire Existing EU MiFID Firm, Then Use MiCA Article 60
Timeline: 7-12 months | Investment: €500K-€5M+ acquisition | Control: Full
Best for: Full operational control, acquiring existing infrastructure/clients, faster than building from scratch
How it works:
Identify EU MiFID investment firms with authorization scopes matching your crypto objectives
Conduct acquisition due diligence (regulatory standing, authorization scope, clients, infrastructure)
Complete acquisition (requires competent authority approval for change of control)
Integrate acquired firm into your structure
Acquired firm notifies under Article 60 for crypto services
Launch crypto services 40 days after notification
Timeline breakdown:
Target identification and diligence: 2-3 months
Negotiations and documentation: 2-4 months
Regulatory approval: 2-3 months
Integration and Article 60 notification: 1-2 months
Total: 7-12 months (vs. 18-24+ months for new MiFID authorization)
Target profiles:
Small execution brokers seeking exit (retiring owners)
Wealth management boutiques with established clients
Investment firms with broad authorizations but limited scale
Advantages:
✅ Faster than building MiFID firm from scratch
✅ Acquire existing clients, revenue, infrastructure, regulatory relationship
✅ Full control vs. partnership dependency
✅ Once acquired, Article 60 enables 40-day crypto launch
Disadvantages:
❌ Significant acquisition capital (€500K-€5M+)
❌ Due diligence complexity and integration challenges
❌ May inherit legacy issues or authorization limitations
When this makes sense: You have acquisition capital, want full control, need existing client base, and strategic rationale extends beyond crypto.
3.3 Pathway 3: Establish New EU MiFID Firm, Then Use MiCA Article 60
Timeline: 9-13 months | Investment: €1M-€2.5M+ | Control: Full
Best for: Clean slate, no suitable acquisition targets, long-term strategic EU presence
How it works:
Choose EU member state
Incorporate entity, appoint directors
Apply for MiFID investment firm authorization
Build infrastructure during authorization (hire compliance, implement systems, establish procedures)
Receive MiFID authorization (12-18 months)
Immediately notify under Article 60 for crypto services
Launch crypto services 40 days after notification
Capital requirements:
MiFID minimum capital: €50K-€730K depending on services
Authorization costs: €150K-€300K (legal, advisors, documentation)
Infrastructure setup: €200K-€500K (technology, office, recruitment)
Operational runway: €500K-€1M+ (12-18 months until revenue scales)
Total: €1M-€2.5M+
Advantages:
✅ Clean slate—no legacy liabilities
✅ Full control over structure and strategy
✅ Design authorization scope optimally from inception
✅ Once MiFID authorized, Article 60 enables 40-day crypto launch
Disadvantages:
❌ 9-13 month timeline
❌ No existing client base—start from zero
❌ Build everything from scratch
❌ Significant capital commitment
When this makes sense: Strategic EU presence for broader reasons than just crypto, acquisition targets don't fit, willing to invest 9-13 months and €1M-€2.5M for clean build.
3.4 Pathway 4: Establish Standalone EU CASP (Most Efficient for Crypto-Only)
Timeline: 5-7 months | Investment: €500K-€1.5M | Control: Full
Best for: Pure crypto-focused strategy without need for traditional financial services
How it works:
Choose EU member state
Incorporate entity
Apply for CASP authorization under MiCA Article 59 for desired crypto services
Build crypto-specific infrastructure (custody, wallets, nodes, AML tools, trading platform if applicable)
Receive CASP authorization
Launch crypto services
Capital requirements:
CASP minimum capital: €50K-€150K depending on services
Authorization costs: €75K-€150K
Technology infrastructure: €200K-€500K
Operational runway: €300K-€600K
Total: €500K-€1.5M
Advantages:
✅ Fastest authorization for crypto-only (5-7 months vs. 12+ for MiFID)
✅ Lower minimum capital than MiFID
✅ Authorization designed specifically for crypto services
✅ Clean, focused structure
Disadvantages:
❌ No Article 60 benefits (standard authorization, not 40-day notification)
❌ CASP market is new—limited precedent
❌ Start from zero
❌ Cannot provide traditional financial services without separate authorization
When this makes sense: Your business model is crypto-only, 5-7 months is acceptable, and you want authorization designed for crypto rather than adapting traditional frameworks. This is the default choice for crypto-focused businesses.
3.5 Strategic Decision Matrix
Pathway | Timeline | Investment | Control | Best For |
Partner with EU Entity | 3-6 months | €50K-€200K | Shared | Fast test, limited capital |
Acquire MiFID Firm | 7-12 months | €500K-€5M+ | Full | Control + infrastructure |
Build New MiFID Firm | 12+ months | €1M-€2.5M+ | Full | Clean slate, long-term EU presence |
Build Standalone CASP | 5-7 months | €500K-€1.5M | Full | Crypto-only (most efficient) |
4 Recommendations by Use Case
Crypto exchange/platform wanting EU access: → Build standalone CASP (5-7 months, most cost-efficient for crypto-focused business)
International asset manager wanting crypto portfolio management in EU: → Partner with MiFID firm (3-6 months, fast) or acquire MiFID firm (7-12 months, full control)
Existing EU tech/payments firm wanting crypto services: → Partner with MiFID firm (fastest) or build CASP (full control, crypto-only sufficient)
Building comprehensive EU financial services platform (crypto + traditional): → Acquire or build MiFID firm (7-12+ months), then use Article 60 for crypto. Only makes sense if you need EU securities/wealth management beyond crypto.
Stablecoin issuer wanting EU distribution: → Partner with existing EU EMI (3-6 months). Don't build EMI (18-24 months—completely unrealistic).
5 What NOT to Do
❌ Don't pursue EU EMI authorization to access Article 60
Timeline: 18-24 months (absurdly long)
MiCA Article 60 scope: Only for your own issued e-money tokens
Reality: Partner with existing EMI (3-6 months)
❌ Don't pursue EU banking authorization to access Article 60
Timeline: 36-48+ months
Investment: €15M+ minimum
Reality: Unless you need banking for entirely separate reasons, this makes zero sense for crypto access
❌ Don't try to acquire existing CASP to save time
CASPs are brand new (2024-2025)
Very few quality targets exist
Reality: Building new CASP (5-7 months) is faster and cheaper
6 Conclusion: Choose Your Path
The MiCA Article 60 represents a direct fast track for EU-authorized financial institutions and an indirect opportunity for everyone else—accessible through smart strategic pathways.
The pragmatic approach:
Pure crypto focus? → Build CASP (5-7 months, most efficient)
Fast market test? → Partner (3-6 months, low capital)
Want control + infrastructure? → Acquire MiFID firm (7-12 months)
Long-term strategic EU presence? → Build MiFID firm (12+ months)
The next article examines exactly how to execute the Article 60 notification process once you have relevant EU authorization—what documentation to submit, how to avoid delays, and how to achieve 40-day launches versus 90-day failures.
About the Author
This article was written by Yiannos Ashiotis, Managing Partner at Pnyx Hill, an international advisory firm specializing in regulatory compliance, corporate governance, risk management, and digital asset regulation across the UAE and Europe. Our teams support banks, investment firms, asset managers, and crypto service providers with Article 60 eligibility assessment, notification execution, and MiCA compliance.
For advisory support on MiCA Article 60 strategy, equivalence analysis, or EU crypto market entry pathways, contact our EU and UAE digital asset advisory practice.