Pre-application meeting: what the decision maker looks at
A pre-application meeting lets the supervisor form an early view of the applicant before a file is lodged. The decision maker looks at three things: whether the business model matches the authorisation being sought, whether the people in the room can explain governance and safeguarding without a script, and whether the applicant already treats open gaps as gaps rather than as details to smooth over later.
Why the meeting happens before the file
A formal application starts a clock. Once it is lodged, questions from the supervisor come in writing, with deadlines attached, and every answer becomes part of the record. A pre-application meeting removes that pressure. It gives both sides a chance to test the model in conversation, without the exchange counting against a statutory timeline.
The consequence is practical, not procedural. A meeting that goes well tends to shorten the formal review, because the supervisor has already heard the answers to its first round of questions. A meeting that surfaces open points does not fail anything — it simply moves those points earlier, where they are cheaper to fix.
What the decision maker actually checks
The checklist below reflects what comes up most often in the room. It is not exhaustive, and the weight given to each point shifts with the size and complexity of the applicant.
| Area | What is checked | Signal that raises questions |
|---|---|---|
| Business model | Fit between the activity described and the authorisation sought | The pitch deck and the licence application describe different businesses |
| Governance | Whether named individuals can explain their own function without reading from notes | Only outside counsel can answer operational questions |
| Safeguarding | Where client assets sit and who controls the keys or accounts | Custody arrangements are described in general terms only |
| Outsourcing | Which functions are delegated and how they are supervised | Critical functions are outsourced with no monitoring plan |
| Track record | Whether the team has run a comparable activity anywhere, licensed or not | No prior experience is disclosed, then surfaces later in due diligence |
What to do before you ask for a slot
- Assemble a one-page summary of the business model before requesting the meeting; the person presenting it should be the one who will run the business, not only its lawyer.
- Bring the individual who will actually hold the safeguarding function, not a substitute who will need to check answers afterwards.
- Prepare short, direct answers on capital, custody and outsourcing — long answers read as uncertainty.
- Send a short pack in advance so the meeting starts from questions rather than introductions. The order the supervisor expects, and the annexes that belong with it, are set out in File assembly and submission step by step.
- Write down every open question raised in the room the same day, while the wording is still exact.
Who sits in the room and who decides
On the supervisor's side, the meeting is usually run by the team that will handle the formal file, not by a separate outreach unit — the people you meet are the people who will later read the application. On the applicant's side, the useful configuration is small: one person who owns the model, one who owns compliance, and legal support in the background rather than in front.
Nothing is decided at the meeting itself. It produces impressions and, often, an informal list of points to address before submission. The formal decision only follows the lodged application, on its own timeline, through the supervisor's ordinary review process.
Forks: how the same meeting plays out differently
If the applicant is new to the activity, the meeting leans towards governance and safeguarding, since there is no track record to fall back on. Expect more questions about individuals and fewer about the model itself.
If the applicant already holds a comparable authorisation elsewhere, the meeting shifts towards gaps between regimes — what changes when the same activity runs under a different supervisor. Disclosed weaknesses read better here than discovered ones: a team that names a known issue and describes its fix looks more prepared than one that waits for the supervisor to find it. Where a similar gap turns into a formal finding after authorisation, the fix runs on its own track, described in Remediation after a finding step by step.
If the business uses a name that overlaps with an existing mark, that question is not settled in this meeting at all — it runs on a separate procedure, covered in Interim relief in brand disputes step by step, and on its own it does not stop an authorisation file moving forward.
If the technical audit behind the application relies on a dataset the applicant does not own outright, be ready to explain the licence behind it. The underlying question of who holds rights in a compiled dataset is covered in Scope of database rights in ownership of results.
If the application references a crypto-asset that has since been withdrawn from a public register, raise it before the meeting rather than after — the pattern is described in Crypto services — when the referenced work is removed.
What this page does not cover
This page describes the meeting, not the formal application that follows it. It does not set out required capital, fees, or statutory review periods, and it does not replace a reading of the supervisor's own published guidance for the specific authorisation sought. Where the guidance and this page disagree, the guidance controls.
Related reading
For the step that follows once the meeting is behind you, see File assembly and submission step by step.
Verified
Checked against current practice as of the publication date shown on this page. Primary reference: the applicable national supervisor's published guidance for digital asset authorisation in Lithuania and Estonia. No article or clause numbers are cited on this page, because the underlying national texts are not yet in the firm's verified registry.
Frequently asked questions
How long does a pre-application meeting take in practice?
The meeting itself usually runs one session. The preparation around it — gathering the summary, briefing the people who attend, drafting follow-up answers — normally takes longer than the meeting.
Which documents are needed to start?
A short business model summary and an outline of governance and safeguarding arrangements are enough to request a slot. Full annexes are not expected before the formal application.
What happens if the supervisor does not respond after the meeting?
Silence is not a decision. If no informal feedback arrives within a reasonable period, a short written follow-up asking for confirmation of next steps is the normal move — not a formal complaint.