White-label custody under MiCA

When the MiCA transitional period ended in July 2026, the market consolidated sharply. Thousands of registered VASPs were reduced to a handful of authorized operators across the EEA. For institutions exploring digital asset services, this open a choice: pursue a multi-year CASP authorization or partner with a regulated custodian under a white-label model.

The second path has become the practical choice for many institutions. This month,
Nexo reaffirmed compliant operations across the EEA using this model, naming Tangany as its licensed custody partner alongside DLT Finance for brokerage. But how does it actually work in practice? Read on, or download our guide to learn more.

→ Download the guide

What white-label custody is

White-label custody is an arrangement where a licensed custodian provides the regulated custody service and a partner delivers it to end customers under its own brand. The model divides responsibility between these two parties. 

The custodian holds the private keys, executes settlements, and bears regulatory accountability for the custody service. The partner owns the brand, the customer relationship, and product strategy. From the customer's perspective, they continue to see and interact with the brand they are used to.

This mirrors how traditional finance has worked for decades. A custodian bank holds assets on behalf of a fund administrator, yet the administrator remains the customer-facing entity.

MiCA's article 59 reserves crypto-asset services to authorized CASPs and certain regulated financial institutions. Rather than a tied-agent model, it leaves room for commercial white-label arrangements, provided the regulatory perimeter is respected and the regulated service is clearly delivered by the licensed CASP.

Where accountability sits

The licensed CASP owns the regulated custody product and bears the regulatory accountability for operating it. The partner owns the brand and customer relationship, along with the obligations that come with them. 

This division is the legal foundation for this model. As Deloitte Legal partners note, structuring a white-label model "requires a thorough legal analysis, in which civil law and regulatory legal issues in particular must be coordinated between the cooperating parties."

In practice, this means client-facing communications must clearly identify the licensed CASP as the regulated service provider, and the operational setup must withstand supervisory scrutiny at any point.

The technical foundation

Technical controls enforce the regulatory boundary. The custodian retains the private keys. The partner never holds, accesses, or controls them, and can request transactions but not execute them.

Several layers make this work: private keys stored in an HSM controlled by the custodian, a controlled API through which the partner requests but never executes transactions, audit logging of every signing event, and full infrastructure segregation between partner and custodian systems.

This aligns with Article 75 of MiCA, which reserves custody-and-administration services to licensed CASPs. The segregation-of-duties model is proven across the EEA, with the majority of institutional clients operating under it. Nexo and flatexDEGIRO both run on this structure, with Tangany as their licensed custody partner.

When white-label makes sense

Three questions are worth addressing early.

• Is getting your own license worth it? The white-label model works best for brokerages, banks piloting crypto, and fintechs extending into digital assets. If you have the scale, ambition and time to become a licensed CASP, building in-house is a possible path.

• Which licensed CASP is the right partner? Look for a full compliance stack (AML, CFT, KYC, KYB, KYT, PEP, sanctions screening), a recognized Travel Rule solution, DORA compliance, and a proven track record across multiple European jurisdictions.

• Are responsibilities clearly allocated? KYC, AML, transaction monitoring, regulatory reporting, and custody each need to be assigned and documented, in a way that withstands supervisory scrutiny.

The bottom line

MiCA has raised the bar for operating crypto services in Europe. For many institutions, white-label custody can be a faster path to market, compressing go-to-market timelines from 18–36 months to 3–9 months*.  

For the full framework, including the technical architecture, the complete evaluation checklist, and a side-by-side comparison of white-label vs. own MiCA authorization:

→ Download our white-label guide

*Timelines are illustrative and based on Tangany's observations across custody projects; actual timelines vary by institution, licensing status, and technical scope.