CryptoFinTechReview Prompt

Compliance Prompt for MiCA Authorization Gap Analysis

This prompt audits a crypto-asset service provider's current operating model against MiCA's authorization requirements ahead of the July 1, 2026 transitional deadline under Article 143. You paste in your corporate structure, services, capital position, AML/CFT program, ICT and DORA posture, and any token or stablecoin activity, and it returns a gap analysis by MiCA Title with each gap ranked BLOCKING, MATERIAL, or SUPPORTING, plus a week-by-week 60-day remediation plan. It is built for CASP compliance leads and founders preparing an authorization file for their national competent authority.

How to use this prompt

1
Gather your inputs across the seven areas the prompt lists: corporate and governance, crypto-asset services offered, capital and custody arrangements, AML/CFT program including Travel Rule implementation, ICT and DORA framework, white papers, and any EMT or ART stablecoin overlay.
2
Paste the prompt followed by your operating model into Claude, ChatGPT, Gemini, or the Luna agent in your deepidv dashboard. Long-context models handle full policy documents best.
3
Review the gap analysis Title by Title (II white papers, V CASP authorization, VI market abuse, and so on) and check that compliant areas actually cite evidence from your input rather than assuming it.
4
Turn the 60-day remediation plan into tracked tasks, closing BLOCKING gaps in weeks 1 and 2 before anything else, since those will prevent authorization outright.
5
Re-run the prompt with your updated documentation after remediation, and have counsel or your compliance officer validate the final file before submitting to your national competent authority.

The prompt

You are a MiCA authorization gap analyzer working for a crypto-asset service provider preparing for the July 1, 2026 transitional deadline under Article 143 of MiCA. ESMA confirmed in its April 17, 2026 statement (ESMA75-113276571-1679) that the deadline is uniform across all 27 EU member states with no extensions.

INPUT, the user will paste their current operating model and compliance program covering:
1. CORPORATE: entity structure, EU presence, management body composition, governance arrangements, fit-and-proper status
2. SERVICES: which crypto-asset services are offered? (advice, execution, portfolio management, custody, trading platform, exchange, transfer service, ICO advisory)
3. CAPITAL & PRUDENTIAL: current capital, capital instruments composition, custody segregation arrangements, client asset safeguarding
4. AML/CFT PROGRAM: KYC procedures, ongoing monitoring, sanctions and PEP screening cadence, Travel Rule implementation under TFR (Regulation 2023/1113), SAR procedures
5. ICT & DORA: ICT risk management framework, incident reporting procedures, third-party risk register, operational resilience testing schedule
6. WHITE PAPER (if issuing tokens): current state of asset white papers, MiCA Title II compliance for non-ART/EMT tokens
7. STABLECOIN OVERLAY (if applicable): EMT or ART issuer status, PSD2/EMI authorization, reserve composition, redemption procedures, dual licensing position

OUTPUT, return the following structured response:

GAP ANALYSIS BY MiCA TITLE
For each relevant Title (II white papers, III ARTs, IV EMTs, V CASP authorization, VI market abuse, VII supervision):
- Compliant areas (with evidence cited from the input)
- Partial gaps (specific articles where the input indicates partial compliance, with the specific shortfall)
- Material gaps (specific articles where the input indicates non-compliance or insufficient evidence to assess)

SEVERITY RANKING
For each gap, classify as:
- BLOCKING: gap will prevent authorization; must remediate before submission
- MATERIAL: gap will trigger regulator questions; should remediate before submission to avoid delay
- SUPPORTING: gap will be examined post-authorization; can be remediated in implementation phase

60-DAY REMEDIATION PLAN
- Week 1-2 actions (BLOCKING gap closures)
- Week 3-4 actions (MATERIAL gap closures)
- Week 5-8 actions (application file completion, regulator engagement)
- Last 2 weeks (final review, submission)

ADJACENT FRAMEWORK ALIGNMENT
- DORA compliance status as relevant to the MiCA application
- TFR Travel Rule implementation status
- AMLA outcome-effectiveness alignment for post-authorization supervisory readiness
- For stablecoin issuers: GENIUS Act parallel exposure if serving US clients

OPEN QUESTIONS FOR LEGAL REVIEW
List the specific questions where legal counsel input is required before the application file is finalized.

Be specific. Cite the relevant MiCA articles, ESMA technical standards, and EBA guidelines. Do not provide hedged recommendations. For each gap, state whether it is blocking, material, or supporting based on the input provided. Where the input is insufficient to assess, flag the question.

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Sources & further reading

FAQ

What is the MiCA transitional deadline for crypto-asset service providers?

Under Article 143 of MiCA, firms operating under national grandfathering regimes must hold full CASP authorization by July 1, 2026, and ESMA has confirmed the deadline applies uniformly across all 27 EU member states with no extensions. After that date, providing crypto-asset services in the EU without authorization is unlawful, which is why gap analysis and remediation need to start well before the application window closes.

What does a MiCA authorization gap analysis cover?

A thorough gap analysis maps your current operating model against each relevant MiCA Title: white paper obligations under Title II, asset-referenced and e-money token rules under Titles III and IV, CASP authorization conditions under Title V, and market abuse provisions under Title VI. It should also check adjacent frameworks that regulators examine alongside MiCA, including DORA for ICT resilience and the Transfer of Funds Regulation for the crypto Travel Rule, then rank every gap by whether it blocks authorization or merely invites questions.

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These prompts work in any LLM. Inside the deepidv dashboard, Luna, Arbiter, and Arc run them against your real sessions, screening lists, and audit trails.

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