When could CySEC suspend a CASP's registration, and what did suspension mean?
The two grounds for suspending a registered CASP, who decided, the 7-day and 15-day deadlines, and what a suspended CASP could and could not do.
By the ExamPass CY editorial teamLast reviewed 4 min read
Topic 3 of 5 · all topics in this chapter
Short answer
CySEC could suspend a CASP's registration for two reasons. If the public register information was inaccurate or incomplete, the CASP had at most 7 days to correct it or explain. If CySEC suspected non-compliance with a registration condition, it could suspend immediately and without notice, and the CASP had at most 15 days to comply. CySEC's Chairman and/or Vice-Chairman decided and told the Board at its next meeting. A suspended CASP could not provide services, take new clients or advertise as registered, but could wind down existing clients' business at their request.
Suspension at a glance
| Point | Rule |
|---|---|
| Inaccurate or incomplete register information | Suspension for a reasonable period; at most 7 days to correct the information or explain |
| Suspected non-compliance with registration conditions | Immediate suspension without other notice; at most 15 days to comply and tell CySEC what was done |
| Who decides | CySEC's Chairman and/or Vice-Chairman, who inform CySEC's Board at its next meeting |
| Not allowed while suspended | Providing crypto-asset services, entering into new business relationships or accepting new clients, or being advertised as a registered CASP |
| Allowed if existing clients wish | Completing outstanding transactions, repaying funds and returning crypto-assets, and transferring contracts to another CASP on clients' instructions |
| Publicity | Notice of the suspension on all the CASP's websites and a marking in the register |
Source: CySEC Directive R.A.D. 269/2021, as amended, paragraphs 9 and 10; Law 188(I)/2007, Articles 59(6) and 61E(5).
On what grounds could a registration be suspended?
The first ground was about the register itself. If CySEC considered that the information shown publicly about a CASP was inaccurate or incomplete, it could suspend the registration for a reasonable period. The CASP then had a maximum of seven days to correct the information or explain, after which CySEC decided whether the suspension should continue and corrected the register if needed.
The second ground was more serious. Where CySEC suspected that a CASP might not meet a registration condition, for example because it had not provided all the required information or because its managers might not be honest and competent, it could suspend the registration immediately, without any other notice or procedure. The CASP then had a maximum of fifteen days to comply with the condition in question and tell CySEC what it had done. If CySEC was satisfied, it lifted the suspension and told the CASP it could resume business. If not, it invited the CASP to make representations on possible sanctions and decided whether the suspension should continue until its final decision.
In both cases the decision was taken by CySEC's Chairman and/or Vice-Chairman, who informed CySEC's Board at its next meeting.
Terms used in this note
- Suspension
- A temporary stop on a registered CASP's right to operate, short of removal from the register.
- Representations
- The CASP's chance to put its case to CySEC before sanctions are decided.
What could a suspended CASP do?
The Directive sets these consequences in its rules on suspension for suspected non-compliance. A CASP suspended on that ground had to post a notice about the suspension on all its websites, and CySEC marked the suspension in the register. For as long as the suspension lasted, the CASP could not provide crypto-asset services or activities, enter into a business relationship with anyone or accept new clients, or be advertised as a CASP on CySEC's register.
The rules protected existing clients. If they wished, the CASP could complete its own and its clients' outstanding transactions on the clients' instructions, repay all funds and return all crypto-assets to clients, and transfer existing contracts to another CASP on the clients' instructions, unless CySEC instructed otherwise. None of these steps counted as a breach of the suspension.
With the national register replaced by MiCA since 1 July 2026, CySEC now relies on its MiCA powers over authorised CASPs, which include withdrawing an authorisation.
How to think about it
Two grounds, two clocks: wrong or missing register information gives 7 days to fix; suspected breach of a registration condition means immediate suspension and 15 days to comply. The Chairman and/or Vice-Chairman decide and tell the Board afterwards. During suspension, nothing new (services, clients, advertising), but existing clients can be looked after: finish their transactions, give back their money and crypto-assets, or move them to another CASP.
Common mistakes
Swapping the 7-day and 15-day periods. Seven days is for correcting register information; fifteen days is for curing suspected non-compliance.
Having CySEC's Board take each suspension decision. The Chairman and/or Vice-Chairman decide and inform the Board at its next meeting.
Freezing existing clients' assets during suspension. At clients' request the CASP may complete transactions, return funds and crypto-assets, or transfer contracts to another CASP.
Continuing to take on new clients while suspended. No new business relationships or clients are allowed until the suspension ends.
Legal references
- CySEC Directive for the register of crypto-asset service providers (R.A.D. 269/2021), as amended (opens in a new tab)
Paragraph 9: suspension to correct information · Paragraph 10: suspension for suspected non-compliance
- The Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 (Law 188(I)/2007), consolidated Greek text on CyLaw (amendments up to Law 25(I)/2026) (opens in a new tab)
Article 61E(5): removal, suspension and amendment of registrations · Article 59(6): administrative sanctions
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) (opens in a new tab)
Article 64: withdrawal of authorisation
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