CASP Governance & Fitness Assessment
Demonstrates MiCA Art. 68 requirements for management body fitness & propriety
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MiCA Compliance Note
Implemented: Art. 68.1 — Management body fitness & propriety assessment framework. This POC demonstrates ONE approach to operationalizing Art. 68.1's qualitative requirements ("sufficiently good repute," "appropriate knowledge, skills and experience," no AML/CFT convictions) into a quantitative model. The scoring thresholds (60/100 minimum, point allocations for education/experience) are NOT in the regulation—they represent this POC's illustrative interpretation. Real CASPs defend fitness through documentation, interviews, and professional judgment to satisfy their NCA, not via automated scoring.
Key assumption: This POC assigns 100 points total with weights for qualifications (40%), experience (30%), training (10%), and reputation (20%). MiCA specifies no such formula. Thresholds (60 for compliant, 50 for conditional) are assumed, not regulatory.
Out of scope: Art. 60, 68.2–68.9 — Full CASP authorization requirements, governance arrangements (beyond individual fitness), business continuity (Art. 68.7), record-keeping (Art. 68.9), conflicts of interest policy, and all Art. 69–85 operational requirements.
Out of scope: Art. 68.5 — Fitness assessment for non-management personnel (employees). This POC covers only management body members.
What this POC does not implement:
- ❌ Real identity verification — No integration with official registries or identity providers
- ❌ Criminal record checking — No access to court/police databases
- ❌ NCA authorization workflows — Not connected to actual regulatory authority systems
- ❌ Ongoing fitness monitoring — Assessments are static snapshots, not continuous tracking