MiCA Article 70 Compliance Architecture for Layer 2 Settlement Rails

Frequently Asked Questions

01.What is MiCA Article 70 and why does it apply to Layer 2 settlement?

MiCA Article 70 of Regulation (EU) 2023/1114 requires crypto-asset service providers to safeguard client crypto-assets and funds, keep them segregated from the CASP's own holdings, and maintain records that allow immediate reconciliation. When settlement moves onto a Layer 2 rollup, the same segregation and reconciliation duty applies to every batched, bridged, or netted balance, not only the mainnet custody wallet.

02.How does MiCA Article 70 differ from DORA Article 19 for Layer 2 operators?

Article 70 governs asset safeguarding and client-fund segregation. DORA Article 19, under Regulation (EU) 2022/2554, governs ICT incident classification and reporting. A Layer 2 settlement outage that delays client withdrawals can trigger both duties at once: an Article 70 breach if segregated balances become unreconciled, and a DORA Article 19 major-incident report if the outage crosses the regulatory severity threshold.

03.Who is the target audience for MiCA Article 70 Layer 2 compliance architecture?

VPs of engineering, CIOs, and compliance leads at licensed CASPs, exchanges, and custodians who route settlement through Arbitrum, Optimism, Base, or other Layer 2 networks and must prove segregation and traceability to their national competent authority ahead of the MiCA transitional deadline.