Passporting notification: costs drivers
Passporting notification is a filing procedure, not a fresh licensing round. Its cost is driven by three things: how many host member states are named, how uniform the service description is across those states, and how many rounds of clarification the host authority requests. A file naming one host state with a stable service scope moves through quickly. A file naming several states with different service descriptions in each one takes longer and costs more to prepare.
What the notification actually changes
A crypto-asset service provider authorised in one EU member state does not need a second authorisation to offer the same services in another member state. It notifies its home supervisory authority, which forwards the file to the host authority. Once the waiting period runs without a blocking response, the provider may start operating in the host state under its existing authorisation.
This sounds administrative, and for a clean file it is. The cost sits in preparing a file that a host authority cannot query, and in reacting fast when it does.
Cost drivers
| Driver | Effect on cost and timing |
|---|---|
| Number of host states named | Each state adds a parallel review track and its own query risk |
| Divergence in service scope between states | A uniform description across states is faster to defend than a tailored one per state |
| Host authority queries | Every query resets the internal clock for that state and needs a substantive answer within the deadline it sets |
| Translation needs | A business plan or service description not already in the host language adds preparation time before filing |
| Existing local contact point | A named point of contact in the host state reduces back-and-forth during the waiting period |
What to do
- Compliance lead: list every host state and the exact services to be passported into each one.
- Compliance lead: align the service description across states before drafting, rather than tailoring wording state by state.
- Home authority contact: file the notification with the home supervisory authority, not directly with the host state.
- Compliance lead: monitor the waiting period and prepare draft answers to likely questions before they are asked.
- Local operations lead: confirm the go-live date only once the waiting period has run without a blocking response.
- Compliance lead: notify commercial teams of the confirmed start date, state by state, once passporting takes effect.
Who decides
The home supervisory authority receives the notification and forwards it. It does not decide whether the provider may operate in the host state; it checks that the file is complete and passes it on. The host supervisory authority reviews the file during a waiting period set by the applicable framework. If it raises no blocking question within that period, passporting takes effect without a separate approval decision.
If the host authority does raise a question, the clock for that state pauses until the provider answers. A provider naming several host states can find one state cleared while another is still in query.
If your situation differs
Some files carry a second question alongside the notification itself.
If the provider also processes personal data in the host state, a separate supervisory regime applies in parallel to the passporting file. How that authority establishes its own jurisdiction is explained separately in Supervisory authority data protection how it is proved explained.
If the passported service touches goods that could be subject to a counterfeiting claim at the border, a parallel enforcement track exists and runs on its own timeline, described in Customs application for action step by step.
If there is a live dispute over who actually holds the rights to a token being passported, the notification file should not go out until that question is settled, as set out in When the buyer of a token is not the.
What this page does not decide
This page covers the notification procedure and what drives its cost. It does not decide whether the underlying authorisation itself remains valid, whether a given service actually falls within scope for passporting, or how a host authority will treat a borderline service description. Those are file-specific questions that need a review of the actual authorisation and service terms.
It also does not cover what happens once a passported authorisation needs to be wound down rather than extended, or the internal cost of losing a key function holder mid-process.
Verified
Reviewed against the passporting notification procedure applied by supervisory authorities to crypto-asset service providers within the EU. This page describes the procedure and its cost drivers only; it does not cite specific statutory provisions, in line with our policy for procedural pages.
Related reading
The mirror question — what drives cost when an authorisation is withdrawn rather than extended — is covered in Withdrawal procedure step by step.
Next step
If the passporting file stalls because a signature on the underlying assignment was never formalised, start with When the assignment is unsigned but performed.
If the file stalls because a named key function holder has just resigned, the immediate cost of getting that wrong is covered in A key function holder resigns authorisation what it costs.
FAQ
How long does passporting notification take in practice?
There is no single figure that applies to every file. The waiting period runs from the date the home authority forwards a complete file, and it resets for any host state where a query is raised. A file naming one host state with a clean, uniform service description tends to clear well inside the standard period; a file naming several states with divergent descriptions rarely does.
Which documents are needed to start?
At minimum: the home authority's notification form, a description of the services to be passported into each host state, and confirmation of the local contact point in each state. Anything that varies by host state should be flagged before drafting, not discovered during review.
What happens if the other side does not respond?
Silence from the host authority within the waiting period is not a failure state. Once that period runs without a blocking question, passporting takes effect for that state without a separate confirmation being issued. The provider should still keep written confirmation of the date the period expired, for its own records.