What is a crypto custodian?

In short

A custodian is a firm that holds assets on behalf of clients, keeps them apart from its own, and moves them only on the client's instruction. A crypto custodian holds or controls the private keys, and in the EU is a crypto-asset service provider authorised for custody under MiCA, or a bank or financial firm that has notified its authority.

Also called
Digital asset custodian, Crypto custodian, Custody provider
Family
Crypto and trading
Facts checked

What a crypto custodian does

  • Generates and stores keys, in hardware security modules or by MPC, across hot and cold tiers
  • Applies each client's approval policy: who may instruct, limits and allow-lists
  • Keeps a record of every client's positions and reconciles it with the blockchain
  • Handles events such as forks, airdrops and staking rewards
  • Reports: statements, audit trails and evidence for the client's auditors

The service is sold to institutions: funds, exchanges, token issuers, banks and fintechs that prefer not to run key infrastructure themselves.

Who may act as a custodian in the EU

Custody is one of MiCA's crypto-asset services, so a firm needs authorisation as a CASP that names it. Article 60 lets some regulated firms notify their authority instead, at least 40 working days before starting: among them a credit institution, a central securities depository, and an investment firm for services equivalent to those it is already authorised for.

A custodian that uses another provider for custody may use only an authorised CASP, and tells its clients. Issuers of asset-referenced tokens place reserve assets with a custodian that is a separate legal person.

Why a product appoints a custodian

A fintech that appoints a custodian still designs the customer experience. The split of roles decides the licence: whichever firm controls the keys is the one providing custody.

Custodian, wallet provider or exchange?

Wallet-as-a-service provider
Supplies the technology for creating and operating wallets. Whether it is also a custodian depends on whether it can move the assets.
Exchange
Holds customers' assets as a consequence of trading. Safekeeping is a custodian's whole business.

Where a custodian shows up in a platform

Modules that do the work

Platforms that need it

Guides that go deeper

Where it is written

The laws and standards this page's facts come from.

General information, not legal advice: what applies to you depends on your services and your market.

Every term

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