Read the CySEC Circular C794
Memo #44-2026
CySEC Circular No: C794
Date: 07/08/2026
Subject: ESMA launches a Common Supervisory Action with NCAs on CASPs’ digital operational resilience for custody
Purpose: To inform the Crypto Asset Service Providers (CASPs) that the ESMA has launched a Common Supervisory Action for 2026.
In Summary:
CySEC has issued the Circular C794 on 06/08/2026 to inform the Crypto Asset Service Providers (CASPs) that the European Securities and Markets Authority (“ESMA”) has launched a Common Supervisory Action for 2026 (“CSA 2026”) with National Competent Authorities (“NCAs”) on CASPs’ digital operational resilience for custody.
In accordance with Circular C794, the CSA will assess the maturity of CASPs’ digital operational resilience frameworks in relation to custody activities. It will focus on risks inherent to distributed ledger technology (DLT), including governance arrangements, key and storage management, transaction controls, incident detection and response, smart contract risks, and dependencies on third-party providers.
CySEC notes that NCAs will carry out the exercise on a risk-based sample of authorised CASPs. The exercise will run from the second half of 2026 to the first half of 2027. In the context of the CSA 2026, CySEC is planning to conduct on-site visits and/or desk-based reviews on a sample of CASPs. The sample of NCA’s should include only CASPs that:
• have already been authorised and
• are authorised to provide custody services (to be consistent with the scope of the CSA).
CySEC further notes that the CSA will focus on the following digital operational resilience risks:
• Governance and control framework.
• Management of storage and keys.
• Controls over transactions.
• Threat monitoring, incident detection and response.
• Controls on smart contracts.
• Third party risk management.
CySEC expects CASPs to adhere to the content of Circular C794 as it will form part of CySEC’s supervisory review for the purposes of the CSA 2026.
Read the CySEC Circular C794
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