MiCAR Marketing
Communications Review
Every CASP marketing communication — website copy, social media, email, influencer posts — must comply with MiCAR Articles 66–68 from the date of authorisation. Use AI-powered document review to audit your materials before the 1 July 2026 deadline.
1 July 2026 Deadline
MiCAR transitional period expires. All CASPs must hold full authorisation — and all marketing must comply from day one.
NCA Scrutiny Is Live
AFM, BaFin, and AMF are actively reviewing crypto advertising. Marketing violations are the fastest route to supervisory action post-authorisation.
Pre-Notification Required
Netherlands (AFM) and France (AMF) require 30-day NCA notification before publishing. Build review time into your campaign calendar.
MiCAR Marketing Requirements
Articles 66–68 apply to all channels and media types. Every requirement is checked in the AI review.
Fair, clear, and not misleading
All marketing communications must present a balanced view. Benefits and risks must be presented with equal prominence. Omissions that create a misleading impression are treated the same as false statements.
Clearly identifiable as marketing
Marketing content must be labelled as advertising. Sponsored posts, influencer content, and advertorials must carry explicit disclosure. The CASP is responsible for third-party marketing on its behalf.
Mandatory risk warning
Every communication targeting retail investors must include: "Crypto-assets may rapidly lose value. You may lose all the money you invest. You are not protected by any investor compensation scheme or deposit guarantee scheme." The warning must be legible and prominent.
Past performance and projections
Historical return data must be accompanied by: "Past performance is not a reliable indicator of future results." Projections must state their assumptions and cannot use cherry-picked time periods.
Comparisons
Comparisons with other financial products must be made on a like-for-like basis with the comparison basis stated. Comparing crypto-asset returns with deposit rates or equity indices requires explicit risk-profile disclaimers.
NCA notification
Where activated by the home-state NCA (AFM in the Netherlands, AMF in France), marketing communications must be notified 30 days before publication. Cross-border campaigns must check host-state requirements.
Most Common Violations
Based on supervisory guidance and enforcement actions from NCAs across EU member states, these are the issues regulators are finding most frequently in CASP marketing materials.
Risk warning absent or in illegible small print
Content labelled as editorial rather than advertising
Return comparisons without fair-presentation disclaimers
Influencer content without advertising disclosure
Claims inconsistent with the published whitepaper
Misleading references to regulatory status or investor protection
What the Review Checks
Risk warning presence and prominence
Advertising identification and labelling
Performance data disclaimer compliance
Misleading or unbalanced claims
Comparison fairness and disclosure
Regulatory status accuracy
Influencer/affiliate content obligations
Whitepaper consistency
NCA notification trigger assessment
How to Review Your Materials
Upload your document
Upload your marketing material as PDF, DOCX, HTML, or plain text. Website copy, email templates, ad scripts, social media packs — any format works.
Select the MiCAR Marketing template
Use the "MiCAR Marketing Check" quick-start template on the document review page. It pre-fills the review prompt for Articles 66–68 compliance.
Get a cited compliance report
Receive a pass/fail checklist against each MiCAR marketing requirement with article-level citations. Use the report for internal sign-off and NCA pre-notification preparation.
Frequently Asked Questions
What does MiCAR require for CASP marketing communications?
MiCAR Article 66 requires that all marketing communications from crypto-asset service providers are fair, clear, and not misleading. Communications must be clearly identifiable as marketing, consistent with the crypto-asset whitepaper, and include a prominent risk warning stating that crypto-assets may lose all value and are not covered by investor compensation schemes. The risk warning must appear clearly in all marketing materials.
Do MiCAR marketing rules apply to social media and influencer content?
Yes. MiCAR Article 66(4) explicitly states that marketing communications rules apply regardless of the medium — including social media posts, sponsored content, and third-party promotions. If a CASP engages influencers or affiliates, those communications are subject to the same requirements as direct advertising. The CASP remains responsible for ensuring compliance even when marketing is conducted by a third party.
Must CASPs notify their NCA before publishing marketing communications?
Under MiCAR Article 68, CASPs must notify their home-state NCA 30 days before publishing marketing communications, if the NCA has activated this requirement. The Netherlands (AFM) and France (AMF) have activated notification obligations. CASPs operating cross-border must check host-state NCA requirements as well.
How does the MiCAR marketing review tool work?
Upload your marketing document (PDF, DOCX, HTML, or plain text) to the document review tool. Select the MiCAR Marketing Check quick-start template to pre-fill the review prompt. The AI analyses your document against MiCAR Articles 66–68 and returns a checklist identifying missing disclosures, potentially misleading claims, non-compliant risk warnings, and required corrections — with article-level citations for legal sign-off.
AI-generated output — not legal advice. Verify independently.