Is outsourcing possible under MiCA?

Yes. MiCA's stance on outsourcing is reflective of frameworks like PSD2 or MIFID, as outsourcing is doable but comes with certain guidelines to follow, in particular:

• Responsibility isn’t delegated away from crypto-asset service providers.

• Relationships and obligations towards clients remain unaltered.

• The original conditions for crypto-asset service providers' authorization stay intact.

Some additional requirements include:

• Third parties must collaborate with the competent authority of the service provider's originating Member State.

• Providers should retain the necessary resources and expertise to both assess service quality and manage associated risks.

• Data protection standards applicable in the EU must be met by third parties involved in outsourcing.

  
  

As it is the case with traditional financial institutions, crypto-asset service providers shall have a policy on their outsourcing, including on contingency plans and exit strategies. This adds to the growing list of internal policies and procedures that crypto-asset service providers should already start preparing to comply with MiCA.