Withdrawal procedure: documents to prepare
Withdrawal of an authorisation ends the right to provide the service. The file you submit decides how fast the register closes and whether related activity must stop at once. Prepare the withdrawal request, proof of the applicant's identity, a wind-down plan, and evidence that client assets are returned. An incomplete file is not opened.
What changes once withdrawal starts
Once the regulator accepts the request, the register marks the authorisation as under withdrawal, not as withdrawn. The distinction matters: obligations toward existing clients continue until the wind-down is confirmed closed. New clients cannot be onboarded from the date of acceptance.
Where the licence holder also holds client data under separate security obligations, those measures stay in force until transfer or deletion is documented; how that boundary is drawn is set out in Security measure data protection explained.
Status "under withdrawal" is public in the register. Counterparties and platforms often act on that status before the file is formally closed, which is why the file has to be complete before submission rather than completed in stages.
Documents to prepare
The core file is short, but each document has to stand on its own — the regulator does not chase missing pieces before setting a deadline.
| Document | Purpose | Typically prepared by |
|---|---|---|
| Withdrawal request | Formal trigger; states the reason and the proposed effective date | Authorised representative of the licence holder |
| Wind-down plan | Shows how open contracts, positions and client relationships are closed in sequence | Compliance and operations |
| Client asset reconciliation | Evidence that client funds or assets are returned or transferred to a receiving provider | Custody or finance function |
| Evidence of activity up to closure | Confirms the service was actually operated up to the stated date | Operations records |
| Successor confirmation | Where clients move to another provider, confirms that provider holds a current authorisation | Corporate or legal function |
| Data closure statement | Confirms personal and transaction data are archived or deleted per the retention duty in force | Data protection function |
The evidence-of-activity document mirrors a similar exercise in a different register: Proof of use step by step walks through how continuous use is documented when a right lapses for non-use. The withdrawal file borrows the same discipline — dated records, not a narrative summary.
Disputes inside the licence holder complicate the file. If control of the entity is contested — for instance where a departing founder claims rights over the underlying product — the regulator may pause processing until the signatory's authority is clear. A comparable dispute is set out in Media, content and streaming — when a founder leaves.
Who decides and how long it takes
The competent authority that granted the authorisation also decides on its withdrawal. It reviews the file against its own published requirements, may request clarification once, and then confirms the effective date in writing. The register is updated only after confirmation, not on submission.
In practice, the length of the review depends on the state of the wind-down, not on the paperwork alone. A file where client assets are already returned moves faster than one where reconciliation is still open. There is no fixed number of days that applies to every case; the regulator sets its own working deadlines and communicates them once the file is accepted.
If your situation differs
Voluntary withdrawal and withdrawal initiated by the regulator follow a similar document set but a different starting point. A voluntary request starts the clock on submission; a regulator-initiated withdrawal starts on the date of the notice, and the licence holder's role becomes responding rather than proposing.
If the service concerns tokenised assets listed on a public marketplace, withdrawal can trigger a delisting event independent of your own timeline; the marketplace's own rules then govern what happens to holders, and that exposure is separate from the exposure to the regulator. See When a marketplace delists the collection for how that risk plays out.
If clients hold open positions with no immediate successor provider, the wind-down plan has to show a fallback — typically a return of assets rather than a transfer — and the regulator will not confirm closure until that fallback is executed, not merely proposed.
What this page does not cover
This page does not estimate how long a specific file will take; that depends on facts the regulator reviews case by case. It does not cover cross-border coordination where the same group holds authorisations in more than one register — that sequencing is a separate question. It does not set out grounds on which a regulator can refuse a voluntary withdrawal; those grounds are procedural, not documentary, and belong to a different note.
Verified
This page describes the procedural sequence as generally published by the competent authority's register and its supervisory guidance. It does not cite specific legal provisions; where a provision matters to your file, the authority's own published text is the binding version, not this summary.
Frequently asked questions
How long does the withdrawal procedure take in practice?
There is no fixed period. Timing depends on how complete the file is at submission and on whether client assets are already reconciled. A file with an open reconciliation takes noticeably longer than one submitted after assets are returned.
Which documents are needed to start it?
At minimum, the withdrawal request, the wind-down plan, and evidence that client assets are being returned or transferred. The regulator will not open a file that is missing any of the three.
What happens if the other side does not respond?
If a receiving provider or a client does not confirm receipt of transferred assets, the wind-down plan cannot be marked closed. The licence holder has to document the attempt and fall back to returning the assets directly rather than waiting indefinitely for a response.
Related publications
Withdrawal is not the only way an authorisation can be affected. Where the regulator imposes a measure without a withdrawal request, the response follows a different track, covered in Appeal against a supervisory measure step by step.
A withdrawal file is built once and reviewed once. Getting the reconciliation and the wind-down plan right before submission does more for the timeline than any follow-up correspondence afterwards.