MiCA-Compliant Outsourcing: How Smart Crypto-Asset Service Providers Navigate Regulatory Requirements 

How to Establish MiCA-Compliant Outsourcing Operations

Through our experience supporting CASP operations and analysing ESMA (European Securities and Markets Authority) guidelines, we’ve identified five key provisions to ensure MiCA-compliant outsourcing:

1. Responsibility cannot be delegated, only execution.

Crypto companies who are outsourcing are still held responsible for all actions of their company, but also the actions executed through their outsourcing provider. This requires maintaining robust risk assessment frameworks, ongoing oversight capabilities, and clear boundaries around outsourcing scope.

How we handle this in practice:

CoreX teams work exclusively within your approved SOPs, using your tools and documentation standards. 

Additionally, our scope of work is limited to strictly operational functions (read more about it in our Guide to MiCA Licensing), with clearly established escalation chains and tasks such as policy interpretation, risk scoring, and regulator engagement remaining under your direct control. We empower your teams — not replace them.

2. Regulatory reviews span to include the outsourcing company as well.

When regulatory reviews occur, you need complete visibility into outsourced operations. Every outsourced function requires proper documentation with clear escalation protocols, performance monitoring, and audit trails. 

How we handle this in practice:

If your business is audited, CoreX’s processes are ready to be included in the scope. We provide: 

• Clear documentation of agent activity logs 
• Process maps and workflows 
• Access to SOPs and QA reports
• Explanation of escalation protocols and review layers.

You retain final say over what is shared — but we ensure that everything is traceable, current, and audit-aligned. 

3. Outsourcing partnerships must demonstrate appropriate technical and organisational measures.

With GDPR compliance and financial data protection requirements, outsourcers need to abide by the same data handling security standards as CASPs, including role segregation to prevent conflicts of interest.

How we handle this in practice:

We’ve built CoreX processes specifically to meet the operational expectations under MiCA and related frameworks (e.g. DORA, GDPR), including, but not limited to:

• ISO 9001 & ISO 27001 certification 
• PCI DSS-compliant data environments 
• GDPR training.

Being EU-based (Croatia) also makes the overall process of ensuring full regulatory compliance straightforward and far more simple to navigate compared to outsourcers outside the EU.

In the early stages of team planning, we segregate roles in a way to avoid conflicts (e.g. no overlap between verification and escalation ownership). 

4. All outsourced personnel must meet “fit and proper” standards. 

This includes background checks as well as ongoing training on industry-specific requirements.

 How we handle this in practice:

• We run background checks on candidates during hiring
• The whole outsourced team trained on industry-specific terminology and sensitivity 
• Performance is continuously monitored and documented.

5. EU-based outsourcing providers require less regulatory checks.

When it comes to the location of the third-party outsourcer, outsourcing arrangements that involve entities located outside the EU need to meet additional requirements, including an evaluation of the third country’s regulatory framework to ensure equivalence with MiCA.

 How we handle this in practice:

CoreX is Croatia-based and offers the possibility to hire talent solely within the EU, making it easier for CASP clients to comply with EU regulatory requirements.

What You Can (and Cannot) Outsource Under MiCA

MiCA provides clear guidance on what types of functions can and cannot be outsourced. Based on ESMA’s technical standards and our implementation experience with CASP clients, here’s the practical breakdown:

Permissible Outsourced Functions:

• KYC/KYB identity verification and data collection 
• Transaction monitoring support (first-level review and flagging) 
• Customer support, complaint triage and resolution support 
• Document validation and audit preparation 
• Knowledge base and SOP development based on approved materials

Functions That Must Remain In-House:

• Policy interpretation and development
• Risk scoring and final compliance decisions
• Direct regulator engagement and reporting
• Strategic compliance oversight

This distinction reflects MiCA’s underlying principle that regulated entities must retain ultimate responsibility for compliance decisions while being able to scale operational execution. 

Common Pitfalls in MiCA Outsourcing

So, where do crypto-asset service providers usually fall short when it comes to their outsourcing strategy? In our experience, it’s usually one of these common challenges that create compliance challenges in the future:

The “Cost-First” Approach: Selecting providers based purely on pricing without considering jurisdictional requirements or regulatory alignment. Under MiCA, this approach can create significant compliance gaps.

The “Delegation Mindset”: Treating outsourcing as simple task delegation rather than an ongoing supervisory relationship. MiCA requires continuous oversight and documentation.

The “Standard Contract” Trap: Using generic BPO agreements without MiCA-specific provisions for regulatory reporting, audit access, and supervisory cooperation.

Building Your MiCA-Compliant Outsourcing Strategy

What can be done to avoid the pitfalls and set up a successful outsourcing strategy that is also MiCA compliant? Here’s the framework we recommend:

Phase 1: Regulatory Alignment Assessment

Before engaging any outsourcing partner, conduct a comprehensive review of your operational requirements against MiCA obligations. This includes mapping which functions can be delegated whilst maintaining supervisory control.

Phase 2: Partner Due Diligence

Evaluate potential partners against the five provisions outlined above. This assessment should demonstrate to regulators that you’ve conducted proper risk evaluation.

Phase 3: Structured Implementation

Deploy outsourced functions gradually with robust monitoring and documentation. Establish clear KPIs, escalation protocols, and regular review mechanisms.

Phase 4: Ongoing Supervision

Maintain continuous oversight through regular audits, performance reviews, and compliance assessments. Comprehensive documentation ensures regulatory transparency.

The Strategic Benefits of Compliant Outsourcing

At this point MiCA might seem simply as yet another regulatory burden, but when implemented correctly, MiCA-compliant outsourcing can help you operate and grow your fintech business more efficiently. By shifting the way you think and operate, you’re actually building a stronger and more organized foundation of your business, especially when it comes to:

• Operational Scalability: Enables you to more easily scale customer base and transaction volumes without proportionally increasing internal headcount with clearly defined outsourcing protocols and processes.
• Regulatory Expertise: Directs you and your outsourcing partner to train specialists who will understand both operational execution and regulatory requirements.
• Cost Predictability: Helps transform variable compliance costs into predictable operational expenses.
• Risk Mitigation: Requires you and your outsourcing partner to maintain more robust risk management frameworks.
• Audit Readiness: Requires structured documentation and oversight mechanisms to align with regulatory expectations.

Preparing for What Comes Next

As MiCA implementation continues to evolve, enhanced focus on outsourcing arrangements is expected. ESMA continues developing detailed guidance on acceptable outsourcing practices, while national authorities build expertise in reviewing these arrangements.

Crypto-asset service providers that approach outsourcing as a strategic compliance tool rather than simply a cost reduction exercise position themselves for long-term success.

At CoreX, our approach focuses on creating genuine outsourcing partnerships where we become an extension of your compliance framework, not a separate entity. This means providing complete transparency and ensuring that you retain full supervisory control whilst benefiting from operational scaling within the EU.

Ready to explore MiCA-compliant outsourcing for your CASP operations? 

Let’s talk.