MiCA Decoded: We Have an EU Office Is Not Enough: Heres What Regulators Actually Want to See
Tech MiCA Decoded: ‘We Have an EU Office’ Is Not Enough: Heres What Regulators Actually Want to See MiCA Decoded is a 12-article weekly series for News, co-authored by LegalBisons Co-Founding and Managing Directors: Aaron Glauberman, Viktor Juskin and Sabir Alijev. LegalBison advises and FinTech companies on MiCA licensing, CASP and VASP applications, and regulatory structuring across Europe and beyond. Most founders approaching their first CASP application understand, at least abstractly, that MiCA requires a real EU presence. What they underestimate is how the regulator defines “real.” The typical early-stage setup looks coherent on paper: a registered office in a favorable EU jurisdiction, a director named in the governance documents, ICT systems either cloud-hosted or managed from the groups global infrastructure, and paid-in capital sitting in a newly opened bank account. From the inside, this feels like an EU company. From a National Competent Authoritys perspective, it may look like a letterbox with a director attached. This article maps what MiCAs substance requirements actually demand across personnel, technology, and financial resilience, and explains why regulators treat each category as a functional test rather than a documentation exercise. The concern driving all of it is the same: preventing letterbox companies, entities that exist on paper in a favorable