On the 4th of April 2025, the Malta Financial Services Authority (“MFSA”) published a circular addressed to all crypto-asset service providers (“CASPs”) licensed under the Markets in Crypto-Assets Act, Chapter 647 of the Laws of Malta, which integrates the EU’s Markets in Crypto-Assets Regulation (“MiCAR”). The circular informs CASP licence-holders (“LH”) of the publication of the Crypto-Asset Service Provider Return (“CASP Return”).
The CASP Return forms part of the MFSA’s efforts to build a consistent and transparent regulatory framework for CASPs in Malta. Through the introduction of formalised reporting obligations, the Authority will support greater regulatory oversight and contribute to the orderly development of the digital asset market.
The CASP Return must be completed and submitted through the MFSA LH Portal by no later than the 30th of April 2025. Thereafter, submissions are to be made in accordance with the deadlines set out in the Markets in Crypto-Assets Rulebook and further detailed in the CASP regulatory documentation table.
The latest version of the CASP Return (enumerated as ‘v25-01-a’) is available here. It remains the sole responsibility of the licence-holders to ensure that the CASP Return is submitted within the prescribed timeframes and that the information provided is complete and accurate, in line with the applicable regulatory framework. Failure to comply may result in regulatory action pursuant to the Authority’s enforcement procedures.
The introduction of the CASP Return further strengthens the MFSA’s well-established framework for the supervision of CASPs. The Authority has demonstrated a consistent and progressive approach, initially under Chapter 590 of the Laws of Malta (the Virtual Financial Assets Act, which will eventually be repealed) and now under Chapter 647 (Malta’s ‘Markets in Crypto-Assets Act’). This development reflects the MFSA’s continued commitment to maintaining high regulatory standards within the crypto-asset sector, aligning national oversight with evolving European requirements.
The reporting requirements under the CASP Return must also be viewed in conjunction with the MFSA’s issuance of the Markets in Crypto-Assets Rulebook (the “Rulebook”) earlier in March 2025. The Rulebook, available here, provides detailed guidance on licensing, conduct of business, prudential requirements, and reporting obligations for crypto-asset service providers operating in Malta under MiCAR. The publication of the Rulebook in March 2025 and the CASP Return in April 2025 both demonstrate the MFSA’s proactive approach to supervising CASPs, ensuring full compliance with the EU regime whilst factoring in Malta’s industry needs.
Our FinTech team can assist with queries related to the application, authorisation, and ongoing licensing obligations under the EU’s MiCAR and Malta’s rules.
This document does not purport to give legal, financial or tax advice. Should you require further information or legal assistance, please do not hesitate to contact Dr. Katya Tua or Dr. Mario Mizzi