Own funds evidence: documents to prepare
Own funds evidence is the set of documents a digital-asset business submits to prove it holds the minimum capital its authorisation requires. Preparation typically takes two to six weeks, depending on how many group entities and bank accounts are involved. The file must show current balances, not projections, and every figure needs a matching bank or audit document behind it.
What changes once the file is open
Once the supervisor opens the own funds check, the clock on the wider authorisation file usually pauses on that specific point. Other sections of the application can move forward, but the licence itself will not be granted while the capital evidence is incomplete. A gap here is one of the most common reasons an otherwise ready application sits unresolved for weeks.
Delay has a second cost. If bank balances shift between the date of the statement and the date of the decision, the supervisor may ask for a refreshed statement. Building a small buffer above the required minimum reduces the chance of a second request triggered by ordinary account movement.
What to prepare
The file is built from a small number of document types, each answering a different question the supervisor will ask. The table below groups them by purpose rather than by format, because the acceptable format varies by bank and by jurisdiction.
| Document category | Question it answers | Typical source |
|---|---|---|
| Bank balance confirmation | Does the money exist today? | Issuing bank, dated within days of submission |
| Capital contribution evidence | How did the balance reach this level? | Payment records, share subscription agreements |
| Source-of-funds statement | Where did the underlying money originate? | Ultimate beneficial owner, sometimes notarised |
| Ownership chain confirmation | Who controls the entity holding the funds? | Corporate register extract, internal group chart |
| Auditor or accountant letter | Does an independent party confirm the figures? | External auditor or licensed accountant |
Several of these documents identify individuals — the ultimate beneficial owner, signatories, directors. Treat that content as personal data from the first draft, not as an afterthought once the file is compiled; the handling rules are set out in Personal data in data and security.
Compile the file in this order:
- Finance requests a current-date balance confirmation from every bank holding relevant funds.
- Finance assembles the paper trail showing how each contribution reached the account.
- Compliance drafts the source-of-funds statement for the ultimate beneficial owner and arranges signature.
- Legal confirms the ownership chain matches the corporate register exactly, including recent changes.
- An external auditor reviews the package and issues a confirmation letter.
- Compliance assembles the final set and checks every figure against the supporting document behind it.
Who decides and how long it takes
The competent authority handling the wider authorisation reviews the own funds file as part of that application. There is no separate forum; correspondence runs through the same case officer assigned to the file. The authority responds within the timeframe set out in its published service standard, and a request for clarification restarts that clock for the specific point raised, not for the whole application.
A register entry showing pledged capital or share movements works the same way an entry in any specialised register does: it is evidence to submit, not a guarantee that the reviewer accepts it without question. The same caution applies in unrelated registers, including the one described in Industrial manufacturing — when an agency keeps the design: what the register shows and what the file needs to prove are not automatically the same thing.
Common forks
If the entity is newly incorporated with no trading history, expect the source-of-funds statement to carry more weight than the bank confirmation, since there is little transaction history to point to instead.
If part of the required balance sits in crypto-assets rather than fiat, add a separate valuation document and treat any statement that a token itself carries an authorisation as a distinct question — see When a token claims to carry a licence before relying on it in the file.
If another party disputes the ownership chain behind the funds — a former shareholder, a lender with a pledge — collect the supporting evidence early rather than waiting for the authority to ask. The discipline is the same one applied to a contested filing in Opposition proceedings step by step: whoever produces a complete file first controls the timeline.
What this page does not cover
This page covers the documents themselves and how the review runs. It does not cover which entities need authorisation in the first place, how much capital a given business model must hold, or how outsourced functions affect the calculation — those are separate questions with their own procedures.
Related reading
The next document set most teams assemble at the same stage concerns outsourced functions: Outsourcing notification step by step.
Verified
Reviewed for accuracy against current supervisory practice at the time of publication. This page describes procedure and file structure; it does not cite specific statutory provisions, because verifying a citation against the relevant national implementing measure sits outside the scope of this material. Confirm exact filing formats with the case officer handling your authorisation.
FAQ
How long does own funds evidence take in practice?
Most applicants need two to six weeks to assemble the file, longer where several banks or group entities are involved. The authority's own review time runs separately once the file is submitted.
Which documents are needed to start?
A current bank balance confirmation and the ownership chain confirmation are the two documents that unlock the rest of the process; everything else builds on them.
What if the authority does not respond within the expected period?
A written follow-up through the assigned case officer is the standard next step. Keep a record of every submission date, since a missed acknowledgement is easier to raise with a clear timeline attached.