Reporting crypto-assets: What do the CASP-MV, Art. 501d CRR and the annual template require?

Editorially reviewed: 22 October 2026 · Legal status checked up to: 31 August 2026 (manuscript “Crypto-assets in Austrian regulatory reporting”); regulation text and annexes re-checked in the RIS on 22 October 2026 · Register status: ESMA register 31 July 2026 (updated weekly). Time-bound statements are dated; legal acts that are announced but not yet published are marked as such.

For whom: Banks (SI) Banks (LSI) Crypto-asset service providers Banks and investment firms with a permission under Art. 60 MiCAR and authorised crypto-asset service providers. Austrian legal sources are available in German.

Five reported values, semi-annually, without counterparty, country or token – that is all the periodic CASP-MV template sees of a crypto-asset transfer; event-driven reports, record-keeping duties and the authority's information rights stand beside it. The same annex asks for the country of the user, the individual token of the holdings and the counter-venue of trading. For the transfer it asks for none of the three. That is not a limit of the possible but a choice.

Why are there two reporting channels for crypto-assets?

Because crypto-asset service providers report directly to the FMA, while all other reporting runs through the OeNB. Austrian regulatory reporting has grown around the OeNB as the central reporting hub (sections 74 and 75 BWG, section 44a NBG). Two institutions carry it: the common reporting data model (GMD), which derives reports from one uniform Basic Cube, and AuRep, founded in 2013, through which by its own account around 90 % of Austrian credit institutions report. None of that applies to the crypto sector. The OeNB has run MiCAR as a separate collection since 2025 – but only for issuers. Crypto-asset service providers report under section 4 MiCAR-CASP-MV directly to the FMA, bypassing the reporting hub. According to the authority's explanatory notes, the content of the reporting framework follows the established securities reporting regime; the submission channel does not. It is not the reporting concept that was reinvented but the route on which it travels.

What does the MiCAR CASP Reporting Regulation govern?

The regulation was promulgated on 30 March 2026 as Federal Law Gazette II No 71/2026, based on section 10(4) of the Austrian MiCA Enforcement Act, and entered into force on 15 June 2026; the first reference date was 30 June 2026, the first submission due by 11 August 2026. Section 2 covers “any person established in Austria” with an authorisation under Art. 63 MiCAR or a permission for financial entities under Art. 60 MiCAR. The passporting gap is therefore written into the regulation itself: a provider passporting into Austria from another Member State has no reporting obligation under this Austrian periodic reporting regulation – regardless of how many Austrian clients it serves; its duties towards its home authority and the EU-level event-driven and record-keeping obligations remain unaffected. Art. 65 MiCAR requires from it only a one-off notification before commencing activity, no ongoing reporting.

The last row is the finding for banks: financial entities permitted to provide crypto-asset services under Art. 60 MiCAR report the service data only once a year; master data and annual accounts they do not owe under this regulation, because they already deliver them under their primary statute. The same transfer is thus reported half as often periodically when it runs through a credit institution. In the latest scenario of periodic reporting, a transfer of 2 January appears after a good seven months at an authorised provider, after around thirteen and a half months at a financial entity – a statement about the regulation's maximum deadlines, not about every actual moment of awareness by the authority. The authority's own explanatory notes speak of a “for now (only) annual” report – the brackets are the regulator's.

Which three design decisions shape the regulation?

• The valuation option of section 3(2). Crypto-assets are converted either at the average euro spot price of the three highest-volume EU trading platforms or at the market price of a recognised price data provider; only documentation and consistency are required. The consultation draft of 18 December 2025 still provided a hierarchy; the promulgated version places both sources side by side as equal. Consequence: the transfer volume summed across all obliged entities can be computed but is methodologically heterogeneous – two firms may value the same token on the same date differently.
• The submission channel of section 4. “Reports … shall be submitted to the FMA.” Neither a transmission system nor a file format is prescribed; according to its own explanatory notes, the FMA provides the Incoming Platform “on a voluntary basis” because the enabling provision does not cover the channel. A reporting regime for eleven obliged entities thus knows neither a binding format nor a binding channel – while the parallel issuer reporting names XML, Excel and XBRL precisely.
• The annexes. The operative part comprises ten sections; Annexes 1 to 3, to which sections 6 and 7 refer in twenty places, are kept as separate PDF documents in the consolidated version in the Austrian Legal Information System (RIS) and are additionally published on the FMA website (there as of 15 May 2026). Whoever reads only the main text does not find the reporting content.

Annex 3, section 10: Which five figures must be reported?

Annex 3 is modular: section 6(4) and section 7(2) tie each of its ten sections to a crypto-asset service under Art. 3(1)(16) MiCAR; only what is actually provided is reported. As at the register status of 31 July 2026, nine of the eleven providers authorised in Austria held an authorisation for transfer services; the register is updated weekly. Section 10 contains the only expressly transfer-related data points in all of Austrian regulatory reporting:

Open questions remain: where a transfer to a third-country entity belongs that is neither a self-hosted address nor a crypto-asset account within the meaning of the Transfer of Funds Regulation; whether failed transfers are to be distinguished by technical cause, AML rejection or incomplete client data; and how the volume is distributed within the half-year. Collection is not the problem – transmission is: under Delegated Regulation (EU) 2025/1140 the provider records, for every transfer, the information under Art. 14 of the Transfer of Funds Regulation, the means of verification and every rejection with its reason, and keeps it for five to seven years. It simply does not transmit it to the supervisor.

Issuer reporting: Who has to file it in Austria?

As at 31 July 2026, nobody: no issuer subject to reporting was registered in Austria. The MiCAR Issuer Reporting Regulation (Federal Law Gazette II No 170/2025, in force since 31 July 2025) requires reports to the OeNB (XML or Excel via MeldeWeb) and – according to the OeNB's procedural description – directly to the EBA in XBRL. According to the ESMA register, as at 31 July 2026 no issuer of asset-referenced tokens was authorised anywhere in the Union, and of the 21 issuers of e-money tokens registered in the Union at that time none was Austrian. A fully defined, technically implemented and legally binding reporting system therefore had, at that register status, not a single addressee in Austria.

Art. 501d CRR: Why is it a transitional regime without an expiry date?

Crypto-assets reach credit institutions' regulatory reporting by a fourth route: the balance sheet. Art. 501d CRR as amended by CRR III contains a complete but expressly provisional regime, applicable since 9 July 2024 according to the EBA. Exposures to tokenised traditional assets are treated like the assets they represent; asset-referenced tokens of MiCAR-compliant issuers referencing traditional assets receive a risk weight of 250 %; all other crypto-assets 1,250 %. Total holdings outside the first two tiers may not exceed 1 % of Tier 1 capital – the reference is Tier 1, not CET1. Art. 430(1)(i) CRR requires the reporting of crypto-asset exposures, Art. 451b their disclosure, without the materiality and confidentiality exemption of Art. 432.

How robust is the regime in practice? Supervisory reporting data under Art. 430(1)(i) is not published; neither the EBA Risk Dashboard nor the EBA risk reports show crypto positions. The only reliable orders of magnitude come from the ECB's Financial Stability Review of May 2025 for significant institutions in the euro area: direct crypto-asset holdings of around one million euros at year-end 2024, derivatives with crypto-assets as underlying of 600 million euros, custody services and crypto-related investment products of 4.7 billion euros. Regulatory effort and actual exposure diverge systematically in the crypto area.

What does this mean for banks with a crypto offering?

1. Check the permission under Art. 60 MiCAR and establish the reporting obligation under section 2, point 2, CASP-MV: Annex 3 service data annually as at 31 December, submission by 11 February – for the first time for the reference date 31 December 2026.
2. For section 10, derive the split into self-hosted addresses and crypto-asset accounts from the Travel Rule data – the terms come from Art. 3(19) and (20) of the Transfer of Funds Regulation.
3. Determine, document and consistently apply the price source under section 3(2); the choice determines the reported volume.
4. Map Art. 501d CRR in COREP and Pillar 3: three-tier risk weighting, 1 % cap on Tier 1 capital, reporting under Art. 430(1)(i), disclosure under Art. 451b without materiality exemption; breaches of the cap must be notified to the authority without delay (para 4).
5. Keep the records under Delegated Regulation (EU) 2025/1140 so that they can be handed over on request of the authority under Art. 94 MiCAR – five years from the end of the contract, extendable to seven.

Frequently asked questions

Do banks with a crypto offering have to observe the MiCAR-CASP-MV?

Yes, if they are permitted to provide crypto-asset services under Art. 60 MiCAR and are established in Austria (section 2, point 2). They report the Annex 3 service data annually as at 31 December with submission by 11 February; they do not owe master data and annual accounts under this regulation.

What does the FMA see of crypto-asset transfers?

Five figures per reporting period: number of transfers, total volume in euros, share to self-hosted addresses, share to crypto-asset accounts, number of rejected or failed transfers – without counterparty, country, token or time distribution within the half-year.

Which price source applies for conversion into euros?

Under section 3(2), at the obliged entity's choice, the average euro spot price of the three highest-volume EU trading platforms on the reference date or the latest available market price of a recognised price data provider. The chosen source must be documented and applied consistently.

How are crypto-assets treated in own funds?

Under Art. 501d CRR in three tiers: tokenised traditional assets like the underlying, MiCAR-compliant asset-referenced tokens at 250 %, all other crypto-assets at a 1,250 % risk weight; cap of 1 % of Tier 1 capital for the third tier. The regime is expressly provisional – the permanent regime has been overdue since mid-2025.