MiCA Compliance Note
Art. 71: CASPs must have effective and transparent procedures for the prompt, fair and consistent handling of complaints (71(1)), free of charge for clients (71(2)), keep a record of all complaints (71(3)) and communicate the outcome within a reasonable period (71(4)). MiCA itself sets no fixed deadline; the RTS adopted under Art. 71(5) set the limits:
acknowledge receipt without undue delay (Art. 4(1) of Delegated Regulation (EU) 2025/294); the decision must reach the client within 2 months of receiving the complaint (Art. 6(2) of Delegated Regulation (EU) 2025/294); in exceptional situations, tell the client the reasons for the delay and the date of the decision (Art. 6(3) of Delegated Regulation (EU) 2025/294). The same regulation requires each CASP to set its own complaint-handling timeframe and include it in its published procedures (Art. 1(2)(e) of Delegated Regulation (EU) 2025/294). The 5 / 15 / 35 business-day deadlines in this demo illustrate such an internal timeframe; they are not legal requirements.
Art. 68(9): Records of services and activities, including complaint records, are kept for 5 years.
What this POC does not implement:
Real persistent database — uses in-memory state only Complaint categorization rules — submits any category without validation NCA reporting of complaint statistics — not integrated with competent authority systems Email notifications to clients — no notification system implemented Document attachment handling — no file upload capability Implements: Art. 71, Art. 68(9) — Regulation (EU) 2023/1114 |
CELEX:32023R1114 | MiCA fully applicable from 2024-12-30