MiCA passporting: which entity actually holds your account

One licence can serve several markets. That is what passporting is for, and it means the brand you clicked is not automatically the company that holds your balance. The counterparty on your statement is a legal entity with its own registration number, its own supervisor and its own place in an insolvency queue. For a reader with a position open, that entity is the risk, not the logo.

Passporting is a notification, not a second licence

A passporting arrangement lets a firm authorised in one jurisdiction provide the same service in another after a notification, rather than a fresh authorisation. The home supervisor keeps supervising. The host supervisor is told, and can act, but the licence does not arrive as a new document.

The commercial logic is straightforward. One compliance function, one treasury, several markets. The customer-facing logic is the part that gets lost, because a single interface then has to represent several possible contracting parties.

Which entity you face usually depends on where the account was opened and which service you are using. Two readers on the same homepage can be customers of two different companies with two different regulators.

The entity is named in three documents

Three documents settle the question, and all three are usually public. None of them is the homepage.

The client agreement

The terms you accepted name the counterparty, usually in the first two pages and again in a definitions schedule. Look for the registered name, the company number and the registered office. A trading name in the header is marketing. The registered name is the party that owes you the balance.

If the agreement incorporates separate product terms, check which entity appears in those too. A group can hold the account in one company and book the earn product in another.

The public register

Most licensing regimes publish a register of authorised firms. The entry should match the registered name in your terms, not the brand. Where the register lists permitted activities, check that custody and fiat transfer appear.

A firm can be authorised for one service and not another. The interface will not tell you which one you are using, and the answer can differ between the spot balance and a savings product.

The reserve disclosure

Reserve reporting is a snapshot, not a guarantee. We treat a disclosure as evidence of a balance at a stated time, and the three numbers that matter sets out what such a report can support.

The question to add here is whose balance sheet the report covers. If the entity holding your account is not the entity in the report, the report describes someone else’s assets.

Why the entity decides the outcome

Complaint routes follow the licence. A dispute goes to the supervisor named on the register, not to the regulator of the country you happen to live in. That can mean a process in a language you do not speak, on a timetable you did not choose.

Segregation and custody rules are set by the licensing jurisdiction. What happens to client assets in a wind-down is a question about that jurisdiction’s insolvency law, and about whether the assets were segregated before the wind-down started.

Deposit protection, where it exists, generally covers bank deposits rather than crypto balances. A licence is not insurance.

A reading order that takes ten minutes

Open the client agreement, search for the word registered, and write the legal name down. Then open the register and confirm the name appears with the services you use. Then open the reserve page and check whose balance sheet it describes.

Our board ranks 24 venues as of October 2026, and the top row carries roughly a third of the sampled 24-hour volume. Size is not clarity. A large venue can still route you to a small entity, and the small entity is the one in the queue.

What to do next

Write the legal name in your notes next to the account, the way you would note a bank’s sort code. When the interface changes, the entity sometimes changes with it, and the change arrives in the terms rather than on a landing page.

Keep the version you accepted. A dated copy is the difference between an argument about what the contract said and a check of what it says now.

For the wider comparison, our venue board lists 24 exchanges as of October 2026 and the methodology note explains what the columns measure. Neither substitutes for the register entry, which is the only document that names a supervisor.

The check is cheap because the information is public. The failure mode is expensive, because you discover the counterparty at the moment you need to enforce something against it.