The technical half of your licence application.
Regulators read the technology sections line by line: ICT architecture, the third-party register, key management, business continuity, AML and Travel Rule flows. We write them from the system you will actually run, mapped to your regime, and answer the follow-up questions. Your lawyers file the application.
- regimes mapped: MiCA, CBA, SPK, VARA
- 4
- Pro, one-time
- €6,300
- credited against a platform licence
- 50%
- from scoping call to first draft
- 2 weeks
Four regimes, four deadlines.
Georgia, Kazakhstan (AIFC) and El Salvador on request.
MiCA with DORA
The MiCA transitional periods ended on 1 July 2026. Firms without authorisation are applying again, and the file needs the ICT risk section and the register of ICT third-party providers.
Central Bank of Armenia
Operators already active have until 31 January 2027 to hold a CBA licence, and review takes three to six months. The application asks for IT security, continuity and real-time monitoring.
SPK and TÜBİTAK criteria
Information-systems requirements for crypto asset service providers, section by section, with TRY rails and data localisation on self-hosted deployments.
VARA
Technology and custody controls for a Dubai application, with wallets and keys inside your own perimeter.
Written from your deployment, not from a template.
Delivered as a branded document set in English. Turkish or Russian on request.
- Architecture and data flows
- Components, environments, hosting locations and every data flow between them and to third parties, as diagrams and text.
- ICT risk and DORA
- ICT risk framework mapping, incident classification, register of ICT third-party providers, exit plans for critical providers.
- Business continuity
- Continuity plan, backup policy and a recorded restore drill with timings, run on your deployment.
- Key management and custody
- Wallet tiers, key generation and storage, M-of-N approvals, segregation of client assets, reserve reconciliation method.
- AML, KYT and Travel Rule
- KYC tiers and providers, address screening, transaction monitoring flow, Travel Rule data capture and thresholds.
- Security testing
- Penetration-test scope, summary of the latest results and remediation status, vulnerability disclosure policy.
- Regulator questions
- Engineer answers to the technical follow-up questions while the application is under review (Q&A support, monthly).
Two levels.
| Lite | Pro | |
|---|---|---|
| Price | €1,250 one-time | €6,300 one-time |
| For | BitPolaris platform customers | Applicants who will run BitPolaris, before or after signing |
| Regime mapping | Standard sections, your regime noted | Section by section to one regime |
| Diagrams | Standard set | Your deployment and your hosting |
| DORA third-party register | — | Included |
| Recorded restore drill | — | Included |
| Regulator Q&A support | — | €1,450 / month while under review |
| Credit | — | 50% back against a platform licence signed within 6 months |
Clear lines.
We are not your lawyers
Your counsel runs the application and gives the legal opinions. We supply the technical sections and the evidence behind them.
No outcome guarantee
The regulator decides. We make sure the technical answers are accurate, complete and consistent with the system you run.
Not an audit
The pack describes controls; it does not certify them. Independent testing and audits stay with accredited firms.
Two weeks to a draft your counsel can work with.
- Day 1
Scoping call
Regime, deployment model, hosting, KYC and KYT providers, key roles.
- Week 1
Draft
Diagrams, registers and sections written against your configuration.
- Week 2
Review with your counsel
Corrections, gaps closed, final set delivered.
- Under review
Regulator questions
Engineer answers to follow-up questions, with Q&A support.
Questions
Can we buy the pack before choosing a software vendor?
Yes. The pack describes the BitPolaris deployment you would run. If you license the platform within six months, half of the Pro fee is credited.
Do you file the application?
No. Your counsel files it and handles the legal sections. We deliver the technical sections and answer the regulator's technical questions.
Which regimes do you cover?
MiCA with DORA, the Central Bank of Armenia, SPK in Türkiye and VARA in Dubai. Georgia, Kazakhstan (AIFC) and El Salvador on request.
What do you need from us?
Company details, the deployment model and hosting you have chosen, your KYC and KYT providers, and who holds the key roles. One scoping call covers it.
What does Q&A support include?
An engineer answers the technical follow-up questions during review and updates the affected sections. €1,450 a month, cancel any time.
Applying this year?
Tell us the regime and your target date. We reply with the scope and a delivery date.