Reverse solicitation
The narrow MiCA exception that lets a non-EU firm serve an EU client only when the client approached the firm on their own initiative.
Source
Regulation (EU) 2023/1114, Article 61; ESMA35-1872330276-2030
Last reviewed
October 16, 2026
MiCA allows a firm based outside the EU to provide a crypto-asset service to an EU client without authorisation only if the client asked for that service on their own initiative. The firm cannot use the exception to market other services to that client, and any solicitation in the EU, including through a group company or a third party, rules it out.
ESMA's guidelines of 26 February 2025 set out how narrowly the exception applies. For counterparty checks, a firm claiming reverse solicitation still holds no MiCA permission, so its EU activity needs separate evidence.