Own funds evidence: what the decision maker looks at
An applicant for a crypto-asset authorisation must show that its own funds meet the required level, and it must go on proving this at every stage of review, not only at filing. The decision maker checks the source, the availability and the composition of the funds. Evidence that cannot be traced to an identifiable owner gets rejected.
What changes once the file is submitted
Submission starts the clock for substantive assessment. Before that point, the applicant can withdraw a draft file and rework it freely. After the file is logged as received, a gap found by the reviewing team no longer closes the case; it extends it. This is the point of no return in the procedure: submission fixes the file as the object of review, and any correction now runs through a formal request rather than a quiet resubmission.
A second, quieter point of no return sits inside the substantive stage. Once the decision maker has issued its first request for further information, the applicant is expected to answer that specific request rather than restart the argument. A new theory of where the funds came from, introduced late, tends to reopen the whole file rather than settle the open question.
Preparing the file
- Compile bank statements and ledger extracts covering the full reporting period; the finance officer signs each extract before it goes into the file.
- Attach a solvency confirmation from the auditor, dated no earlier than the agreed reference date.
- Trace every capital contribution back to its origin; the compliance officer records the source of funds against each entry.
- Build the supporting file with the same discipline used for a Records of processing review step by step exercise: one document per claim, indexed and dated.
- Match the format of any formal filing to current expectations, in the same way covered by Filing formalities in ownership of results: consistent naming, consistent signatures, no undated pages.
- Send the completed file to the assigned contact at the authority; the managing director countersigns the cover letter.
Who reviews the file and how long it takes
| Stage | Who acts | Typical timing |
|---|---|---|
| Completeness check | Case officer | Within the first working week after receipt |
| Substantive review | Review team | Several weeks, depending on the size of the file |
| Request for further information | Decision maker | Pauses the clock until the applicant replies |
| Final decision | Head of the authorising unit | Issued once all substantive questions are closed |
In many respects, the reviewing team's method mirrors how a panel handles Opposition proceedings step by step: completeness is checked first, and only a complete file earns a substantive read.
Common branches
- If the applicant belongs to a group, then the file must isolate funds specific to the entity being authorised; consolidated group figures alone are not accepted.
- If the funds come from a recent capital increase, then the confirmation of receipt must post-date the increase itself, not the resolution approving it.
- If part of the file was already produced for a separate authorisation, then the applicant may reference the earlier file but must still supply fresh, current confirmations.
What this page does not cover
This page does not decide whether a given transaction can be evidenced or established for reporting purposes; that sits with a separate check, run on its own facts. For a boundary-focused view of what such a check can and cannot establish, see Transaction in Estonia and its limits.
Verified
Checked 5 June 2025. Primary sources: the authority's published application guidance and its standard forms for own funds evidence.
Related procedures
A comparable staged review applies before a provider begins outsourcing a function; see Outsourcing notification step by step.
Next step
Own funds evidence rarely arrives alone. If a related licensing question sits alongside your file — for example where the terms of a smart contract diverge from the signed licence — read When a smart contract conflicts with the written licence before you bring both matters to the same review.
Frequently asked questions
How long does own funds evidence take in practice?
The completeness check is usually finished within the first working week. The substantive stage takes longer and depends on the size of the file and on whether a request for further information pauses the clock.
Which documents are needed to start?
Bank statements and ledger extracts for the reporting period, a dated solvency confirmation from the auditor, and a source-of-funds trace for each capital contribution. A file built without one of these three is treated as incomplete.
What happens if the other side does not respond?
If a bank, auditor or other third party fails to confirm a detail the file relies on, submit the documentary evidence already held and explain the gap in writing. The review may continue on that basis, or it may pause until the missing confirmation arrives.