The DORA Register of Information for crypto-asset service providers

A crypto-asset service provider (CASP) fills in the same Register of Information as any other financial entity, and files it with the AFM the same way. Three things differ: DORA follows your MiCA licence, you have your own entity type, and the licensed activities in B_06.01 are the services from MiCA. The route from workbook to AFM Portal is in the guide to filing with the AFM.

Does DORA apply to you

Yes, if you are authorised under MiCA (Regulation (EU) 2023/1114). DORA lists crypto-asset service providers authorised under MiCA, together with issuers of asset-referenced tokens (DORA, Article 2(1)(f) (opens in a new tab)).

• Licence from the AFM: since 30 December 2024, crypto services need a licence or notification from the AFM. Providers registered with DNB had a transition period until 30 June 2025 (AFM (opens in a new tab)).
• DORA at application: when you apply for a MiCA licence, the AFM also assesses the relevant DORA requirements (AFM (opens in a new tab)).
• Supervisor: the competent authority under DORA is the one designated under MiCA (DORA, Article 46(d) (opens in a new tab)).

If you must file with the AFM, a reporting obligation is waiting for you in the AFM Portal (AFM (opens in a new tab)).

Type of entity in B_01.01 and B_01.02

You enter eba_CT:x303, described in the EBA's list as "crypto-asset service providers". An issuer of asset-referenced tokens has its own code, eba_CT:x310 (EBA (opens in a new tab)).

Template	Field	What you enter
B_01.01	0040 Type of entity	The type of the reporting entity: eba_CT:x303
B_01.02	0040 Type of entity	Each entity in scope gets its own type; for yourself eba_CT:x303

Licensed activities in B_06.01

In B_06.01 (field 0020) you give the licensed activity of each function. The EBA's Annex 2 list maps the ten crypto-asset services from MiCA to this type (EBA (opens in a new tab)):

Code	Label (EBA)	MiCA, Article 3(1)(16)
eba_TA:x228	Providing custody and administration of crypto-assets on behalf of clients	point (a)
eba_TA:x229	operation of a trading platform for crypto-assets	point (b)
eba_TA:x231	exchange of crypto-assets for funds	point (c)
eba_TA:x232	exchange of crypto-assets for other crypto-assets	point (d)
eba_TA:x233	execution of orders for crypto-assets on behalf of clients	point (e)
eba_TA:x234	placing of crypto-assets	point (f)
eba_TA:x181	reception and transmission of orders for crypto-assets on behalf of clients	point (g)
eba_TA:x235	providing advice on crypto-assets	point (h)
eba_TA:x182	Portfolio management on crypto-assets	point (i)
eba_TA:x236	providing transfer services for crypto-assets on behalf of clients	point (j)

For supporting functions, every type of entity uses eba_TA:x276, "Supporting function".

• One identifier per combination: if a function serves several services, such as custody and transfers, create a separate function identifier for each combination of LEI, function and activity (AFM Q&A (opens in a new tab)).
• Validity: the EBA published the list for the 2025 reporting, under data model 4.0. The AFM says the data model did not change for 2026 (AFM Q&A (opens in a new tab)).

Crypto services alongside another licence

Some financial undertakings provide crypto services on the basis of a notification instead of a MiCA licence, among them banks, investment firms, UCITS management companies and AIFMs. They notify their supervisor at least 40 working days in advance (MiCA, Article 60 (opens in a new tab)).

Such an undertaking has one LEI and so one type of entity. If it fits more than one type, it chooses one for B_01.02.0040 and asks its supervisor which. The register still covers the contracts and ICT providers of all its activities (EBA FAQ Q10 (opens in a new tab)). See also the pages for investment firms and fund managers.

Further reading

• Filing the Register of Information with the AFM
• Choosing a converter
• The template pages for B_01.01, B_01.02 and B_06.01