CASP Suitability Assessment for Investment Advice

MiCA Art. 81 — Assess client suitability before recommending crypto-asset investment services

Client Profile & Assessment

Client Name *

Crypto Knowledge Level

Years of Crypto Experience

Investment Objective

Risk Tolerance

Financial Capacity

Annual Income (EUR)

Investable Assets (EUR)

Proposed Crypto Position (%)

Service Type (Art. 81 applies to advice & portfolio management)

Quick load scenarios:

MiCA Compliance Note

Implemented: Art. 81 — Requirements for providing advice on crypto-assets and portfolio management (suitability assessment, client profiling, mandatory warnings, periodic review requirements)

Implemented: Art. 81(9) — Five mandatory warnings (volatility, loss risk, illiquidity, no investor compensation, no deposit guarantee)

Implemented: Art. 81(12) — Periodic suitability review requirement (at least every 2 years)

Implemented: Art. 81(11) — Refusal condition: CASP must NOT recommend unsuitable services per Art. 81(11)

Implemented: Art. 81(13) — Suitability report generation with advice given and how it meets client profile

Out of scope: Art. 66 — Honest, fair and professional dealing (full compliance communication workflow not modeled in UI)

Out of scope: Art. 75 — Custody safekeeping requirements (Art. 81 applies only to advice/portfolio management, not custody per Art. 75)

What This POC Does Not Implement

❌ Real KYC/AML verification — Client identity verification requires licensed identity provider and regulatory integration
❌ Persistent client records — Assessments are in-memory; real systems require database, audit trails, and record retention per Art. 68(9)
❌ Independent advice — the additional conditions of Art. 81(3) for advice presented as independent are not modelled
❌ Electronic delivery of suitability reports — Art. 81(13) requires the report to be made and communicated in an electronic format; implementation depends on distribution infrastructure
❌ Real product availability database — Service suitability depends on actual product catalog and current conditions; this POC uses static service types
❌ Actual refusal mechanism — When verdict is unsuitable (Art. 81(11)), the CASP must refuse recommendation; this POC shows the verdict but lacks enforcement/blocking of recommendation
❌ NCA notification & escalation — Serious compliance breaches must be reported to competent authorities; out of scope for UI demo