Passporting notification: stages and deadlines
Passporting notification lets an authorised digital asset firm offer the same services in another EU member state without seeking a fresh licence there. The file starts with your home regulator, moves to the host regulator, and becomes irreversible once the home regulator confirms it has been forwarded. From that point, withdrawing the notification is a separate procedure, not a cancellation of the original one.
What passporting notification actually does
The notification does not create a new authorisation. It extends the one you already hold to a second market, on the understanding that your home regulator remains your primary supervisor. The host regulator receives the file, checks that the scope matches what you are authorised to do at home, and does not run a parallel approval process. This is why the file matters more than any cover letter: the host regulator reads what was submitted, not what you meant to submit.
What changes once the file is filed
Two things change the day the file leaves your desk. First, you lose the ability to adjust the scope of services described in it without restarting part of the process. Second, a clock starts running on the home regulator's side, and that clock is not paused by questions you ask afterwards. Firms that treat the filing date as a soft milestone tend to discover, weeks later, that the home regulator already forwarded the file with the scope as submitted, gaps included.
Stages, in the order they actually happen
The sequence below reflects how the notification moves through both regulators, not how a firm might prefer to sequence its own internal sign-offs.
| Stage | Who acts | What moves the file forward |
|---|---|---|
| Preparation | Applicant firm | Scope description, list of host states, supporting records assembled into one file |
| Intake | Home regulator | Confirms the file is complete against its own checklist; incomplete files are returned, not queued |
| Internal review | Home regulator | Checks the described scope against the existing authorisation; no new substantive assessment is made |
| Forwarding | Home regulator to host regulator | Point of no return: the file is now the host regulator's record, not a draft |
| Host acknowledgement | Host regulator | Confirms receipt and, where relevant, registers the firm for local supervisory purposes |
| Activation | Applicant firm | Services may begin in the host state once acknowledgement is on file |
Fees attached to the notification are not fixed for the life of the authorisation. They move on the same kind of tariff cycles described in our note on what changed in fee schedules tokenised rights, so a figure quoted last year is not a figure you can rely on this year.
Who decides, and how long it runs in practice
The home regulator decides whether the file is complete and whether the described scope matches the existing authorisation. It does not decide whether the host state approves of your business model; that question sits outside the notification. The host regulator's role is closer to registration than approval, which is why most delay happens on the home side, not the host side.
Timing depends on how the home regulator's internal review queue is running that quarter, and firms should treat any published target as an average rather than a promise. If a question comes back from either regulator, it usually arrives as formal correspondence rather than a phone call, and the way that correspondence is handled matters as much as the answer given. Our note on supervisory correspondence step by step covers what a decision-maker is actually looking for when it reads a firm's reply.
Documents: what the file needs to hold together
The documents themselves are less important than whether they read as one consistent record. Where the file includes assets or rights whose ownership history matters, the same discipline used in ownership analysis applies here: the regulator wants an unbroken chain, not a single certificate produced on request. Firms familiar with the logic in chain of title ownership of results explained will recognise the pattern, even though the underlying subject matter is different.
In practice this means the scope description, the list of host states, and any supporting attachments should describe the same business in the same words. A file that describes a broader service in the attachment than in the main form is not read generously; it is read as inconsistent, and inconsistency is what triggers a return-for-completion rather than a straightforward forward-and-acknowledge.
Common scenarios
If you are notifying one host state and the scope has not changed since authorisation, the file is usually the shortest version of this process: preparation and intake dominate the timeline, and forwarding tends to follow quickly. If you are notifying several host states at once, expect the home regulator to review the file once but forward it separately to each host regulator, which staggers the acknowledgement stage even though the underlying file is identical.
If your organisation already runs other staged notifications internally, the shape of this one will feel familiar. A customs-side procedure such as the one described in customs application for action step by step follows the same intake, review, and activation logic, even though the subject matter has nothing in common with digital asset services.
If the host regulator does not acknowledge receipt within the period your home regulator would normally expect, the correct response is a written enquiry to the home regulator, not a direct approach to the host regulator. The home regulator forwarded the file; it remains the point of contact until acknowledgement is confirmed.
What this page does not cover
This page describes the notification procedure itself. It does not describe what services you are permitted to add once passported, how withdrawal of a notification is handled, or what happens if the home authorisation is itself withdrawn while a notification is pending. Those are separate procedures with separate triggers, and treating them as one continuous process is a common source of missed steps.
Related reading
Firms revisiting this process often do so alongside a related question about ending, rather than extending, a market presence. Withdrawal procedure step by step covers that separate sequence in the same level of detail.
Verified
Verified: 12 May 2025. Primary source: the notification procedures published by the competent national authorities responsible for authorising crypto-asset service providers, as applied to cross-border service provision within the EU.
FAQ
How long does passporting notification take in practice?
There is no single fixed period across all home regulators. Most of the elapsed time sits in the home regulator's internal review before forwarding; the host regulator's acknowledgement step is usually the shortest part of the sequence.
Which documents are needed to start?
A scope description consistent with your existing authorisation, a list of the host states involved, and any supporting records that establish the chain behind assets or rights named in the file. Inconsistent wording between the form and its attachments is the most common cause of a return-for-completion.
What happens if the other side does not respond?
If the host regulator has not acknowledged receipt within the period your home regulator would normally expect, raise it with the home regulator in writing. The home regulator, not the host regulator, is the point of contact until acknowledgement appears on file.