CySEC CASP vs MiCA Passporting: How Cyprus Unlocks EU Market Access

MiCA Passporting: The Strategic Context

The Markets in Crypto-Assets Regulation is, at its commercial core, a single market instrument. Its primary policy objective — alongside consumer protection and financial stability — is to eliminate the regulatory fragmentation that has made operating legally across the EU an expensive, time-consuming, and jurisdiction-specific exercise for crypto-asset businesses.

Before MiCA, a crypto firm wanting to serve clients across Germany, France, the Netherlands, Poland, and Lithuania faced five separate national registration or licensing processes, five different regulatory frameworks, five different AML law implementations, and five different supervisory relationships. Some jurisdictions were more permissive, some more demanding; some were faster, some glacially slow. The result was a patchwork that most firms navigated by registering in one or two markets and operating in others with varying degrees of regulatory visibility.

MiCA replaces that patchwork with a single licensing framework and a single passport. A CASP authorised by any EU national competent authority can provide its authorised services across all 27 EU member states through a notification process that bypasses the need for local authorisation entirely.

For a firm that has obtained CySEC CASP authorisation, this means: one regulator, one AML framework, one authorisation — and 26 additional markets accessible through notifications rather than applications. The commercial and operational value of this structure is substantial, and it is the primary reason the MiCA passport has made EU licensing a strategic imperative for any crypto firm with genuine EU market ambitions.

This article examines the MiCA passporting mechanism in detail — how it works, what it covers, what host member states can still require, where the limitations lie, and why Cyprus is positioned as one of the strongest EU passporting hubs for CASPs.

What Passporting Actually Means Under MiCA

Passporting under MiCA is the right of a CASP authorised in one EU member state — its home member state — to provide its authorised crypto-asset services to clients in other EU member states — host member states — without seeking separate national authorisation in those states.

Several important clarifications are essential from the outset:

The passport is not automatic. A CASP must actively notify CySEC of its intention to provide services in each host member state. The passport is triggered by the notification process — not by the act of obtaining authorisation.

The passport covers authorised services only. The passport extends to precisely the services listed in the CySEC authorisation. Providing services in a host member state that are not within the scope of the authorisation is not passporting — it is unauthorised provision of crypto-asset services, which is a regulatory breach in the host member state.

The passport applies to both natural and legal persons in host member states. A CySEC CASP can provide passported services to both individual and corporate clients in host member states. There is no restriction on client type for passported services, though the CASP’s own onboarding criteria and AML/CFT programme still apply.

The passport does not override all host member state law. Host member states retain competence over certain areas — primarily national consumer protection law and national AML/CFT law (until the AMLR supersedes it). A CySEC CASP providing services in Germany may need to comply with certain German consumer protection requirements even though it does not need German CASP authorisation.

The passport is not mutual recognition with the UK. Post-Brexit, the UK is not an EU member state and there is no UK-MiCA mutual recognition arrangement. Providing services to UK clients requires FCA registration or authorisation — separately from the MiCA passport. Conflating EU passporting with UK market access is one of the most consequential planning errors for crypto firms targeting both markets.

The Legal Basis: MiCA Article 65 Explained

MiCA Article 65 is the passporting provision — the legal mechanism through which a CySEC-authorised CASP gains the right to operate across the EU. Understanding the article’s mechanics is essential for planning the passporting process correctly.

Article 65(1) — the right to provide services cross-border. Any CASP authorised in accordance with MiCA Article 63 may provide its authorised crypto-asset services in host member states on a cross-border basis, subject to the notification procedure in Article 65(2).

Article 65(2) — the notification obligation. A CASP wishing to provide services in a host member state must notify its home member state competent authority (CySEC) of:

• The member states where it intends to provide services
• The specific services it intends to provide in each member state
• A start date for provision of services
• Any other information required by ESMA’s technical standards

Article 65(3) — the timeline. CySEC must forward the notification to the competent authority of each host member state within 15 working days of receipt. The CASP may commence providing services in the host member state from the date CySEC communicates the notification to the host NCA.

Article 65(4) — branch establishment. Where a CASP wishes to establish a branch in a host member state — a physical presence through which services are provided locally — a separate notification under Article 65(4) applies. Branch establishment involves additional requirements including the appointment of a person responsible for the branch’s compliance and disclosure of the branch’s governance structure.

Article 65(5) — host NCA involvement. Host member state NCAs are copied on the notification but cannot block the passport. Their role is supervisory notification — they are informed that the CASP is operating in their jurisdiction, enabling them to exercise their supervisory powers where applicable.

The deliberate design of Article 65 — particularly the 15-working-day forwarding timeline and the immediate commencement right upon communication — reflects MiCA’s single market ambition. The host NCA is informed, not asked. The passport is a right flowing from the home authorisation, not a concession from each host jurisdiction.

The Cross-Border Notification Process: Step by Step

The practical mechanics of the passporting notification process through CySEC involve the following steps:

Step 1: Prepare the notification. The notification to CySEC must include the prescribed information under MiCA Article 65(2) and any applicable ESMA regulatory technical standards (RTS) on notification content. At minimum: the host member states identified, the specific authorised services to be provided in each, and the intended start date.

Step 2: Submit to CySEC. The notification is submitted through CySEC’s prescribed channel — typically the same electronic portal used for regulatory submissions. CySEC does not charge a separate notification fee for each passporting notification, though the authorisation itself carries the applicable annual supervision fees.

Step 3: CySEC processes and forwards. CySEC has 15 working days from receipt of the notification to forward it to the competent authority of each identified host member state. CySEC will conduct a brief review to confirm the notification is complete and that the services notified fall within the scope of the firm’s authorisation. Notifications for services not within the authorisation will be rejected.

Step 4: Commencement. The CASP may commence providing services in the host member state from the date CySEC communicates the notification to the host NCA. This date is confirmed by CySEC. In practice, for well-prepared notifications, commencement can occur within three to four weeks of submission — a fraction of the time a full national authorisation process would take.

Step 5: Record-keeping. The CASP must maintain records of all passporting notifications, the services notified for each host member state, the commencement dates, and any amendments made. CySEC may request sight of these records as part of supervisory engagement.

Notification for multiple member states simultaneously. A single notification can cover multiple host member states — a CASP entering five EU markets simultaneously can notify CySEC of all five in a single submission. CySEC forwards the relevant notification to each host NCA. This is a material operational efficiency compared to conducting five separate national regulatory processes.

What CySEC Does After Receiving Your Notification

CySEC’s role in the passporting process is that of the home regulator — the competent authority responsible for the authorisation and primary supervision of the CASP. Its actions after receiving a passporting notification are:

Completeness review. CySEC confirms that the notification contains all required information and that the services notified are within the scope of the firm’s authorisation. An incomplete notification or one seeking to passport services beyond the authorisation scope will be returned.

Communication to host NCAs. Within 15 working days, CySEC forwards the notification — including the firm’s details, authorised services, and the services notified for each host member state — to each identified host NCA. CySEC also communicates the notification to ESMA for publication on ESMA’s public CASP register.

Ongoing supervision primacy. Even after passporting, CySEC remains the primary regulator for the CASP — responsible for authorisation, ongoing supervision of compliance with MiCA requirements, and enforcement. Host NCAs have limited supervisory powers in relation to passporting CASPs — primarily in the areas of consumer protection and national AML law (where these remain national competences).

ESMA register update. ESMA maintains a public register of all authorised CASPs and their passported services across the EU. CySEC notifies ESMA of passporting notifications, ensuring the register reflects the CASP’s actual operational scope across the EU.

Host Member State Rights: What They Can and Cannot Do

A common misconception about MiCA passporting is that host member states have no role once the notification is received. This is incorrect — host member states retain meaningful supervisory powers in specific areas, and understanding these powers is essential for operating compliantly in passported markets.

What host NCAs cannot do:

• Require the CASP to obtain separate national authorisation for passported services
• Block or delay the commencement of passported services beyond the notification timeline
• Impose requirements that are inconsistent with MiCA — including capital requirements, governance standards, or conduct obligations that differ from MiCA’s harmonised framework
• Discriminate against a passporting CASP relative to locally authorised CASPs on matters within MiCA’s scope

What host NCAs can do:

• Apply national consumer protection law to the CASP’s activities in their jurisdiction — to the extent that such law is not pre-empted by MiCA’s harmonised conduct requirements
• Apply national AML/CFT law — until the AMLR supersedes national law. This means a CySEC CASP passporting into Germany, France, or the Netherlands may face national AML/CFT obligations in those jurisdictions that differ from Cyprus AML law. The practical impact of this varies by jurisdiction and will diminish materially once the AMLR applies.
• Supervise the CASP’s activities in their jurisdiction for purposes of consumer protection and any retained national competences
• Request information from the CASP directly where their supervisory powers extend to the relevant matter
• Take action against the CASP for violations of local consumer protection or AML law within their jurisdiction

The practical implication. For most CySEC CASPs operating cross-border on a purely digital basis without a physical branch, the host NCA’s practical supervisory reach is limited. The primary areas of host NCA authority — consumer protection and national AML law — are areas where the CASP should already be operating compliantly as a matter of good practice. CaSPs that build their compliance frameworks to the standard required by the most demanding EU member states, rather than calibrating only to Cyprus AML law, are best positioned across all passported markets.

Branch Establishment vs Cross-Border Services: Key Differences

MiCA distinguishes between two modes of providing services in host member states, with different notification requirements and operational implications:

Cross-border services — providing services remotely to clients in a host member state without a physical presence in that state. This is the standard passporting model — a Cyprus-established entity providing exchange, custody, or advisory services to clients across the EU through a digital platform. The notification process under MiCA Article 65(2) applies.

Branch establishment — creating a physical presence in a host member state through which services are provided locally. A branch is not a separate legal entity — it is an extension of the Cyprus entity operating under the Cyprus authorisation. The branch notification process under MiCA Article 65(4) applies.

Branch establishment involves additional requirements compared to cross-border services:

• Appointment of a named person responsible for the branch’s management and compliance in the host member state
• Documentation of the branch’s governance structure and reporting lines to the Cyprus head office
• Disclosure of the branch address and contact details to the host NCA
• Ongoing compliance with any specific host member state rules applicable to branches of foreign CASPs

When is branch establishment appropriate? For most CySEC CASPs serving clients digitally, cross-border services under Article 65(2) are sufficient. Branch establishment becomes relevant where: the CASP requires local physical presence for operational or commercial reasons (e.g., local business development team, face-to-face client servicing), the host member state’s consumer protection or AML law requires local representation, or the CASP’s business development strategy in a specific market benefits from a local presence.

Branch establishment in a major market like Germany or France creates ongoing operational obligations in that jurisdiction — local staff, local management responsibility, and potential local supervisory engagement — that cross-border services do not. The decision to establish a branch should be taken with full understanding of the incremental compliance burden.

Scope of the Passport: Which Services Travel and Which Do Not

The MiCA passport covers the services listed in the CASP’s CySEC authorisation. This creates a direct dependency: the breadth of the passport is a function of the breadth of the authorisation. A CASP authorised only for advice and reception/transmission of orders cannot passport custody or exchange services — those services are outside its authorisation and therefore outside its passport scope.

Services that can be passported. All ten MiCA-defined crypto-asset services can be passported — provided they are within the CASP’s authorisation. There is no distinction between service categories for passporting purposes.

Services that cannot be passported include any activity outside the CASP’s authorisation. This includes services that the CASP provides as a purely factual or technical matter — if those services constitute regulated crypto-asset services under MiCA, providing them in a host member state without the corresponding authorisation is a regulatory breach.

Asset class scope. The passport applies to crypto-asset services as defined in MiCA. Activities involving crypto-assets that fall outside MiCA’s scope — for example, NFTs that are genuinely unique and not fungible, or financial instruments that happen to be issued on blockchain — are not covered by the MiCA passport. CASPs providing services involving both MiCA-scope and non-MiCA-scope assets need to map each activity carefully to the appropriate regulatory framework.

ART and EMT services. Crypto-asset services relating to Asset-Referenced Tokens (ARTs) and E-Money Tokens (EMTs) — the two stablecoin categories under MiCA — are within passport scope for CASPs. However, the issuance of ARTs and EMTs is a separate regulatory activity under MiCA, subject to distinct authorisation requirements (issuers of significant ARTs/EMTs are supervised by the EBA). CASP authorisation covers services in relation to ARTs and EMTs — not issuance itself.

Amending Your Passport: Adding Services or New Member States

The initial passporting notification does not fix the passport permanently. A CySEC CASP can expand its passport scope in two ways:

Adding new host member states. A new notification to CySEC under the same Article 65 procedure — covering the additional member states and the specific services to be provided there. The same 15-working-day forwarding timeline applies.

Adding new services in already-notified member states. If the CASP has obtained an amendment to its CySEC authorisation — adding new services — a supplementary passporting notification can be submitted to extend the passport scope for the new services into already-notified host member states.

Withdrawing from host markets. A CASP that ceases to provide services in a host member state must notify CySEC, which in turn notifies the host NCA. Maintaining a formal passporting notification for markets where services are no longer actively provided creates unnecessary regulatory complexity and may trigger supervisory queries from host NCAs.

The amendment process illustrates why the initial CySEC authorisation scope matters strategically. A firm that obtained a limited initial authorisation — to compress its application and get to market faster — and subsequently amends its authorisation to add services will need to go through both the authorisation amendment process with CySEC and supplementary passporting notifications for all host member states. This is manageable but creates sequencing complexity. Firms with clear multi-service ambitions benefit from planning authorisation scope with the full service roadmap in mind.

AML/CFT Obligations in Host Member States

Until the EU AML Regulation (AMLR) applies and supersedes national AML law, CySEC CASPs passporting into other member states face a nuanced AML/CFT landscape. Each host member state has its own implementation of the EU AML Directives, and while the core obligations are substantially harmonised, implementation details vary.

The harmonisation baseline. The Fourth and Fifth AML Directives set a substantially harmonised framework across the EU — CDD, EDD, beneficial ownership, STR obligations, and record-keeping are consistent in their broad architecture across all member states. A CASP operating to a high standard under Cyprus AML law will largely meet the equivalent standard in most EU host member states.

Where national variation creates practical obligations. Areas where national AML law implementation varies meaningfully across the EU include: the specific list of designated high-risk third countries (which may include national additions beyond the EU harmonised list), the local FIU reporting channel (each member state has its own FIU — STRs must be filed with the relevant host FIU for suspicious activity arising in that jurisdiction), and local supervisory guidance and circular requirements.

The STR filing question. For CASPs providing services cross-border, the question of which FIU to file an STR with — MOKAS in Cyprus, or the host member state FIU — can be complex. The general principle is that the STR obligation follows the jurisdiction of the suspicious activity. A suspicious transaction conducted by a German client through a Cyprus-authorised CASP may require filing with both MOKAS and the German FIU (the Zentralstelle für Finanztransaktionsuntersuchungen — FIU Germany), depending on the nature of the suspicion and the nexus to each jurisdiction.

Post-AMLR simplification. Once the AMLR applies — expected from mid-2027 — the AML/CFT obligation set will be harmonised directly at EU level, eliminating the national variation that currently creates complexity for passporting CASPs. CASPs operating to AMLR standards from the outset will find the passporting AML landscape materially simpler post-2027.

Consumer Protection Requirements in Host Markets

Consumer protection is an area where host member states retain meaningful competence alongside MiCA’s harmonised conduct requirements. For CASPs providing services to retail clients across the EU, understanding the interaction between MiCA’s consumer protection framework and national consumer protection law in each host market is operationally important.

MiCA’s harmonised conduct requirements. MiCA establishes EU-wide conduct standards for CASPs — including requirements on client communication, marketing, best execution, suitability assessment for advisory services, and complaint handling. These requirements apply uniformly across all EU member states and cannot be departed from by host NCAs.

National consumer protection law. Beyond MiCA’s harmonised requirements, host member states may apply national consumer protection law to CASPs providing services to their residents. This may include: cooling-off periods, language requirements for client-facing documentation, local advertising standards, and sector-specific consumer protection rules applicable to financial services. These national requirements vary significantly across the 27 member states.

Language requirements. A practical consumer protection issue for cross-border CASPs is the language in which client communications, terms of service, and risk disclosures are provided. While MiCA does not mandate specific language requirements, many member states’ consumer protection law requires that consumer-facing documentation be provided in the local language. CaSPs marketing actively to German clients are expected to provide German-language documentation; the same applies to French, Spanish, Italian, and other major EU markets.

Marketing compliance. MiCA’s marketing communication requirements — including the requirement that marketing communications are fair, clear, and not misleading — apply uniformly. National advertising standards in host member states may impose additional requirements, particularly around financial promotions. CySEC CASPs should review the marketing regulation framework in each major host market before launching marketing campaigns targeting local clients. For the VARA equivalent, see ComplyFactor’s VARA marketing regulations guide for comparative context.

Reverse Solicitation: A Narrow and Risky Exception

MiCA Article 4(3) provides that MiCA’s authorisation requirements do not apply where a third-country CASP provides crypto-asset services exclusively at the own exclusive initiative of an EU client — the “reverse solicitation” exception. This provision is directed at third-country firms, not at EU CASPs operating under the passport. However, it is relevant context for CySEC CASPs because many firms have previously relied on reverse solicitation arguments to serve EU clients without local authorisation — an approach that becomes significantly more constrained under MiCA.

ESMA’s position on reverse solicitation. ESMA has published clear guidance indicating that it will scrutinise reverse solicitation claims carefully. The exception applies only where the client approached the firm entirely of their own initiative — without any solicitation, advertising, or marketing by the firm in the client’s member state. ESMA has noted that:

• Any form of marketing or advertising directed at clients in the EU by an unauthorised CASP — including through social media, paid search, content marketing, or referral programmes — negates the reverse solicitation exception
• A client who makes an initial contact at their own initiative, but who is then actively approached by the CASP to expand the relationship, is no longer within the reverse solicitation exception for the subsequent services

Why this matters for CySEC CASPs. CySEC-authorised CASPs that passport services into host member states do not rely on reverse solicitation — they operate under the MiCA authorisation. But the reverse solicitation framework is relevant context for understanding why competitors operating without MiCA authorisation face growing regulatory risk, and why the passport provides genuine commercial advantage over reverse solicitation reliance.

For analysis of the risks of operating without appropriate authorisation across EU markets, see ComplyFactor’s guide on VASPs operating illegally across jurisdictions.

The Pre-MiCA Landscape: Why Passporting Changes Everything

To fully appreciate the strategic value of MiCA passporting, it is worth understanding what came before it. The pre-MiCA EU crypto regulatory landscape was a jurisdiction-by-jurisdiction patchwork — each member state implementing its own national framework for crypto-asset service providers, with widely varying requirements, processing timelines, and supervisory cultures.

Countries like Lithuania, Poland, Czech Republic, and Bulgaria had established relatively accessible national VASP registration regimes — as detailed in ComplyFactor’s MiCA country guides for Lithuania, Poland, Czech Republic, and Bulgaria. Many crypto firms registered in multiple of these jurisdictions — building a portfolio of national registrations to achieve de facto multi-market presence.

The problems with this approach were significant: each national registration carried its own compliance obligations, supervisory relationship, and renewal process; national AML law implementations varied; and crucially, national registrations in one member state provided no legal basis for providing services in another. A firm registered in Lithuania could not legally provide regulated crypto-asset services in Germany on the basis of that registration — it needed to either obtain German registration or rely on the contested reverse solicitation exception.

MiCA’s passporting mechanism eliminates this fragmentation. A single CySEC authorisation — with the substantive governance, AML, and capital requirements that authorisation entails — provides legal access to 26 additional EU markets through notifications rather than applications. The total compliance cost of a CySEC authorisation plus 26 passporting notifications is substantially lower than the cost of 27 separate national regulatory processes — and the resulting regulatory standing is materially higher.

For firms that built pre-MiCA portfolios of national registrations, MiCA’s transitional provisions and passporting framework create a consolidation opportunity — rationalising multiple national relationships into a single CySEC home member state structure. The transitional period for existing registrations (running through June 2026 in Cyprus) creates a window for this rationalisation.

Why Cyprus Is a Strategic Passporting Hub

Within the EU CASP landscape, CySEC is positioned as one of the strongest home member state choices for firms prioritising passporting as a commercial strategy. Several structural factors contribute to this positioning:

Established application infrastructure. CySEC has processed significantly more CASP applications than most EU NCAs — its application procedures, guidance, and reviewer experience are more developed than in jurisdictions where MiCA is a genuinely new regulatory function. Established processes reduce uncertainty and support more predictable timelines.

Proactive passporting administration. CySEC’s track record with passporting under MiFID II — where Cyprus CIFs passport into the EU extensively — means CySEC’s operational capacity to process passporting notifications efficiently is already proven. The MiCA passporting infrastructure builds on existing MiFID II notification systems.

Tax structure. Cyprus’s 12.5% corporate tax rate and double treaty network — combined with its EU membership — makes it one of the most tax-efficient EU regulatory homes available to crypto firms. The combination of regulatory credibility and tax efficiency is a structural advantage over higher-tax EU jurisdictions.

English-language regulatory environment. CySEC publishes regulatory requirements, circulars, and guidance in English. Application processes and supervisory communications are conducted in English. For internationally-oriented CASP applicants — whose management teams often lack Greek language capacity — this practical advantage significantly reduces friction.

Legal services ecosystem. Nicosia and Limassol have a mature financial services legal and advisory ecosystem, with numerous law firms and compliance consultancies experienced in both CySEC regulatory work and corporate structuring for international businesses. The availability of experienced local support is an underrated advantage for applicants unfamiliar with Cyprus.

Geographical positioning. Cyprus’s position as an EU member state with strong cultural and business ties to the Middle East, Russia/CIS, and Asia-Pacific markets creates natural business development advantages for CASP founders from these regions. The Cyprus-based entity provides EU regulatory standing alongside proximity to the founder’s home markets.

Common Passporting Mistakes and How to Avoid Them

Assuming the passport is automatic post-authorisation. The passport requires an explicit notification for each host member state. A newly authorised CASP that begins marketing to German clients without submitting a passporting notification is providing services in Germany without regulatory authorisation — even though it holds a valid CySEC CASP authorisation.

Passporting services beyond the authorisation scope. Submitting a passporting notification for services not within the CySEC authorisation. CySEC will reject such notifications, but the rejection may not occur before the CASP has already commenced unlawful activity in the host member state.

Ignoring host member state consumer protection requirements. Operating in host member states without reviewing the applicable national consumer protection law — particularly language requirements for client documentation and local advertising standards. The passport covers the regulatory authorisation, not immunity from consumer protection law.

Failing to notify host market exits. Ceasing to provide services in a host member state without filing a withdrawal notification with CySEC. This leaves the CASP formally registered as active in a market it is no longer serving, creating potential supervisory complexity.

Treating the UK as a passported market. Providing services to UK clients on the basis of the MiCA passport. The UK is not in the EU; MiCA does not extend to UK clients. Serving UK clients requires FCA authorisation or registration separately from the MiCA passport.

Conflating reverse solicitation with passporting. Operating in host member states without notifying CySEC, on the basis that clients approached the firm. Reverse solicitation is an extremely narrow exception; any active marketing activity directed at the host market negates it entirely.

For comprehensive ongoing compliance support — including jurisdiction compliance matrix maintenance, passporting notification management, and multi-market AML/CFT programme support — ComplyFactor’s AML advisory services, global MLRO services, and AML compliance programme services support CySEC CASPs across their full EU operational footprint.

Frequently Asked Questions

How long does the passporting notification process take?

CySEC must forward the notification to the host member state NCA within 15 working days of receipt. The CASP may commence services from the date CySEC communicates the notification to the host NCA. For a complete, accurate notification submitted without issues, commencement of services in the host member state can occur within approximately three to four weeks of notification submission to CySEC.

Can we passport all 26 other EU member states simultaneously?

Yes. A single notification can cover multiple or all EU member states simultaneously. There is no requirement to notify states sequentially. For firms planning to launch across the EU broadly, a single comprehensive notification covering all intended markets is the most efficient approach.

Do we need separate passporting notifications for each service we provide in a host member state?

No — a single notification can cover multiple services in a host member state. The notification must specify which of the authorised services will be provided in each host member state. If you provide advisory and custody services in Germany, both are covered in a single Germany notification.

What happens if we provide services in a host member state without notifying CySEC?

Providing regulated crypto-asset services in an EU member state without either local authorisation or a valid MiCA passporting notification is a regulatory breach in that member state. The host NCA has the authority to take action — including requiring cessation of services and imposing administrative sanctions — regardless of the CASP’s valid CySEC authorisation. CySEC may also view the omission as a notification failure and take supervisory action from the home member state perspective.

Does passporting cover services provided to EU nationals living outside the EU?

No. The MiCA passport covers services provided in EU member states — the geographical scope is the location of the service provision, not the nationality of the client. Services provided to an EU national living in Switzerland or Singapore are not passported EU services; they are services provided in a third country and subject to the regulatory framework of that country.

How does the forthcoming AMLR affect passporting CASPs’ AML obligations in host member states?

The AMLR — expected from mid-2027 — will supersede national AML law in its scope, standardising CDD, EDD, STR, and other AML/CFT obligations directly across the EU. Post-AMLR, a CySEC CASP operating in any EU member state will have a uniform AML/CFT obligation set — the national variation that currently requires jurisdiction-specific compliance mapping will be substantially eliminated. This is one of the most significant practical improvements that the AMLR delivers for cross-border CASPs.

How does ComplyFactor support CySEC CASPs with EU market expansion?

ComplyFactor provides end-to-end support for EU market expansion — including passporting strategy, notification preparation, jurisdiction compliance matrix development, host market AML/CFT programme mapping, and ongoing MLRO and compliance support across the full EU operational footprint. Our practitioners have direct CySEC experience and operate across EU, UK, and UAE regulatory environments. Contact us to discuss your EU expansion strategy.