MiCA Changes for EEA Users

Transak serves users in the European Economic Area (EEA) under the EU Markets in Crypto-Assets Regulation (MiCA), as a Crypto Asset Service Provider (CASP) licensed by the Austrian Financial Market Authority (FMA).

MiCA adds new requirements for EEA users: a pricing disclaimer on every quote, a one-time consent for existing users, extra KYC data, stricter ID documents, and a restricted token list. This guide explains each change and what you need to update for your integration mode.

Who is an EEA user?

Transak treats a user as an EEA user when their KYC country is one of the 30 EEA countries below. Before the user completes KYC, Transak uses the country you pass in the quote. See Show the MiCA Quote Disclaimer.

The United Kingdom and Switzerland are not part of the EEA. UK users continue to follow the FCA flow.

Changes at a Glance

1. Show the MiCA Quote Disclaimer

The FMA requires every EEA user to see that the exchange rate is an estimate before they pay. The Get Quote API returns this disclaimer as MICA_EEA_BUY or MICA_EEA_SELL in the termsIds array.

What you need to do:

1. Get the quote as the logged-in user. Pass the user authentication headers so Transak uses the user’s KYC country. Without them, termsIds is always empty: quoteCountryCode and the user’s IP do not decide it. Get a new quote once the user logs in.
2. Show the disclaimer on both the quote screen and the order confirmation screen, above the button, in full and without scrolling. The user does not need to accept it.

2. Collect MiCA Consent from Existing EEA Users

EEA users who completed KYC with Transak before MiCA must give a one-time MiCA consent. Until they do, the user cannot place orders.

When it is required

The Get KYC Requirement API returns ADDITIONAL_FORMS_REQUIRED, and the Get Additional Requirements API returns a CONSENT form. CONSENT is usually returned first. Process forms in the order they are returned.

{
  "data": {
    "formsRequired": [
      { "type": "CONSENT" }
    ]
  }
}

New EEA users who complete KYC after MiCA go-live do not get the CONSENT form.

What to show the user

Show one screen with the following content. The data fields are read-only. Prefill them from the Get User Details API.

How to submit it

{
  "consentedAt": "2026-11-26T10:15:00Z"
}

{
  "data": {
    "status": "SUBMITTED"
  }
}

consentedAt rules:

• Use the time the user agreed, not the time you send the request.
• Include seconds and a time zone offset (Z or ±HH:mm), for example 2026-11-26T10:15:00Z, 2026-11-26T10:15:00.000Z or 2026-11-26T11:15:00+01:00. Milliseconds are optional.
• It cannot be in the future, and it cannot be earlier than Transak’s MiCA go-live date.

KYC Reliance using API: send the same timestamp in the consent object of the Identity Details API instead of calling Submit MiCA Consent. To check whether a user needs it, call Get KYC Requirement with the quoteId and the user authentication headers. If it returns ADDITIONAL_FORMS_REQUIRED, call Get Additional Requirements. If formsRequired contains type: CONSENT, send the consent object. Otherwise, leave it out.

3. Collect Source of Income, Employment Status and Nationality

EEA users must provide their source of funds, expected monthly volume, employment status and nationality. This applies to all EEA users, not only Enhanced KYC. Simple KYC is not offered to EEA users.

The SOURCE_OF_INCOME form

For a new user, Transak decides whether the user is an EEA user from the address country sent with Patch User Details, not from the fiat currency. Until an EEA address is submitted, the SOURCE_OF_INCOME form and its EEA options are not returned, so call Get Additional Requirements again after patching the address.

For EEA users, the SOURCE_OF_INCOME form from Get Additional Requirements returns the options for each field in metadata:

{
  "data": {
    "formsRequired": [
      {
        "type": "SOURCE_OF_INCOME",
        "metadata": {
          "options": [
            { "name": "Salary payments", "value": "salary_payment" },
            { "name": "Savings", "value": "savings" }
          ],
          "sourceOfFundsTypeOptions": [
            { "name": "Salary payments", "value": "salary_payment" },
            { "name": "Savings", "value": "savings" }
          ],
          "employmentStatusOptions": [
            { "name": "Student", "value": "student" },
            { "name": "Mid-Level Employee", "value": "mid_level_employee" }
          ],
          "countryOfCitizenshipOptions": [
            { "name": "Germany", "value": "DE" },
            { "name": "France", "value": "FR" }
          ]
        }
      }
    ]
  }
}

The example is shortened. Always build the dropdowns from the options in the response, and send the value of the selected option. For EEA users, employment status and nationality are part of the SOURCE_OF_INCOME form, not a separate form, so the user completes all four fields on one screen.

Submit the form

Call the Submit Source of Income API:

{
  "monthlyVolume": "1000",
  "sourceOfFundsType": "salary_payment",
  "employmentStatus": "mid_level_employee",
  "countryOfCitizenship": "DE"
}

SUBMITTED means the data was recorded. FAILED (still HTTP 200) means it was not, so retry the request. Validation and authentication problems return a 4xx error. See API Errors.

Employment status values

Source of funds values

salary_payment, savings, property_sale, sale_of_crypto, inheritance, pension, loan, dividends, gift_or_donation, income_from_services_provided, stock_share_sale

4. Accepted Identity Documents

Driving licences are not accepted for new EEA users or when an existing EEA user verifies again. Existing users who verified with a valid driving licence can continue until the document expires or a KYC refresh is required.

• Whitelabel API and Headless KYC: the Transak-hosted ID check only offers the accepted documents. No change is needed.
• KYC Reliance using API: do not send DRIVING_LICENSE in Document Details for EEA users.
• KYC Reliance using Sumsub: share tokens for EEA users must contain a passport or national ID card.

5. KYC Refresh for Existing Users

After the consent step, Transak can ask an existing EEA user to verify again. This happens when, for example, the ID document has expired, the user completed KYC more than 12 months ago, or Transak’s risk checks require it.

There is no new KYC status. A user who needs a refresh returns NOT_SUBMITTED or ADDITIONAL_FORMS_REQUIRED from Get KYC Requirement. Handle them exactly as in the standard KYC flow: patch user details if asked, then complete every form returned by Get Additional Requirements, including a new ID proof check (IDPROOF) if returned.

KYC Reliance using API: if Get KYC Requirement returns ADDITIONAL_FORMS_REQUIRED for a returning EEA user, call Get Additional Requirements and submit Identity Details again with the sourceOfIncome and additionalDetails objects, plus the consent object if formsRequired contains type: CONSENT.

6. Tokens and Products Not Available to EEA Users

Some crypto assets do not meet MiCA requirements and are not available to EEA users for buying or selling, on any network. These include USDT, DAI, PYUSD and Tether Gold (XAUT). Transak may restrict more assets as regulators publish new guidance.

When an EEA user requests a quote for a restricted asset, Get Quote returns:

{
  "error": {
    "statusCode": 400,
    "message": "You are not allowed to buy USDT on ethereum. Please change the cryptocurrency to proceed",
    "errorCode": 5011
  }
}

Show the message and ask the user to pick another asset.

The following products are not available to EEA users at launch:

• NFT Checkout
• Virtual Account Payments

7. Transaction Limits

EEA users have their own transaction limits, set in EUR, for each payment method and KYC level. Do not hard-code limits. Read them from the Get User Limits API for the user before you show the amount screen.

Integration Checklist by Mode

API Overview

API Errors