When a licence is suspended pending review: what to do first
A suspension pending review freezes your crypto-asset licence without cancelling it. The authorisation stays on the register, but you cannot use it to onboard clients, run new services, or advertise as authorised until the supervisory authority closes its review. Acting inside the first days protects the file and the deadline that is already running against you.
Basis
Suspension powers over crypto-asset service providers sit inside Regulation (EU) 2023/1114 (MiCA), the framework that grants and withdraws authorisation across the EU. Where the file also covers information that must travel with a transfer of crypto-assets, the parallel framework is Regulation (EU) 2023/1113 (TFR). Neither regulation fixes a suspension period in advance; the competent national authority sets its own procedural clock and states it in the suspension notice itself.
What changes once the suspension applies
The register entry usually shows a status change rather than a removal. Existing clients and their holdings do not lose protection automatically, but new business conducted under the licence stops from the date named in the notice. Contracts signed during the suspension window carry a higher risk of challenge later, because the authorisation behind them was not active when the client relied on it.
Internal deadlines keep moving even though nothing external appears to change: reporting cycles, safeguarding checks, and any transaction monitoring duties run on the same clock as before the suspension started. A frozen licence is not a frozen calendar, and treating it as one is the most common early mistake.
Reading the notice: three signals worth separating
| Signal in the notice | What it usually means |
|---|---|
| Suspension "until further notice" | No fixed end date; the authority reviews continuously and lifts the measure once its own conditions are met. |
| Suspension "for a defined period" | A named end date; the authority commits to review inside that window and to communicate the outcome by then. |
| Suspension "subject to conditions" | The measure lifts only once the named steps are completed and confirmed, not automatically at a calendar date. |
What to do first
- Read the suspension notice line by line. The compliance officer confirms the exact scope: full suspension, a suspension of specific services only, or a hold on new clients while existing service continues.
- Freeze outward communication that claims active authorisation. Marketing copy, onboarding scripts, and the website status line all need the compliance officer's sign-off before they go out again.
- Preserve the file as it stood on the suspension date. Whoever holds the licence file exports records, transaction logs, and prior correspondence with the authority before anything is amended.
- List every deadline still running. Legal counsel maps appeal windows, reporting due dates, and any conditions attached to the suspension, then assigns a named owner to each one.
- Prepare the response file the authority actually asked for. Whoever manages the regulatory relationship collects the specific evidence named in the notice, not a general defence of the business.
- Brief the client-facing team on the exact status. Staff explain what has changed without speculating on the outcome or committing to a timeline the authority has not confirmed.
Who decides, and where
The competent national authority that granted the original licence under MiCA decides whether to lift, extend, or convert the suspension into a withdrawal. It works from the file it already holds together with whatever the notice asked the licence holder to submit. There is no separate court hearing at this stage; the forum is the authority's own supervisory procedure, and legal counsel corresponds directly with the case handler named in the notice.
Three situations that change the sequence
If your review coincides with a separate check of security duties owed as a supplier, the two files usually stay open in parallel rather than merging into one. See Security duties reach you as a supplier data protection for the steps that track alongside the suspension.
If the suspension follows a dispute over a tokenised asset listed on a marketplace, the listing itself may be pulled before the licence question is settled. That sequence is covered separately in When a marketplace listing is taken down.
If the review exposes gaps in how the platform's code or design was contracted out, resolve the ownership question before it becomes part of the authority's file. Freelancers signed nothing ownership of results sets out that sequence on its own.
If the suspension touches a tokenised right whose underlying referenced work has since been taken down elsewhere, treat that as a separate matter rather than evidence for the suspension review itself. The referenced work is removed tokenised rights walks through that sequence independently.
What this page does not cover
This page does not set out how long a review takes, because that period is fixed case by case and stated in the notice itself, not in the regulation. It also does not cover the separate appeal track that opens once the authority reaches a final decision — that sequence starts only after this one ends, and it runs on a different clock with a different forum.
Related situations
Once the authority issues its decision and a refusal follows, a different deadline starts running. When an appeal deadline follows a refusal: what to covers that next step in detail.
Verified
Reviewed on 4 June 2025. Primary sources: Regulation (EU) 2023/1114 (MiCA); Regulation (EU) 2023/1113 (TFR). Procedural detail — the deciding authority, the forum, and the applicable notice period — follows the individual suspension notice rather than the regulation text, and is confirmed against the file at the time of review.
FAQ
What is the first step when a licence is suspended pending review?
Read the suspension notice in full before responding to anyone outside the compliance team. It states the scope of the suspension and the conditions attached to lifting it, and every later step follows from what it says.
Which deadline is already running?
Usually more than one: any appeal window against the suspension itself, the underlying reporting and safeguarding deadlines that continue unaffected, and any condition-specific deadline named in the notice. Legal counsel lists all three before drafting a response.
Who decides, and on what evidence?
The competent national authority that granted the original licence decides, using the file it already holds together with whatever the notice specifically requested. It is not a court process at this stage.