Own funds evidence: stages and deadlines
Own funds evidence moves through four stages: internal preparation, submission, review, and confirmation. Each stage has its own internal deadline, set by the authority handling the file rather than by a fixed calendar rule. The clock resets whenever the authority requests further information. There is no universal statutory timetable; once a clarification request lands, firms should plan in weeks, not days.
What changes once the clock starts
Submission is not the start of a countdown by itself. The countdown starts when the authority formally acknowledges receipt of a complete file. Until that acknowledgement arrives, the file sits in a pre-check queue, and gaps in the documentation are the usual reason for delay at this point.
Firms relying on tokenised custody arrangements carry an added layer of complexity. The custodian's own capital position often feeds directly into the applicant's own funds calculation, because the two figures are not independent. What changed in custody expectations tokenised rights sets out how supervisory expectations for custodians holding client tokens shifted, and why that shift matters for the calculation an applicant submits.
Steps to prepare the evidence
The table below sets out the stages in the order the authority expects to see them, with the person responsible for each step.
| Stage | What happens | Who is responsible |
|---|---|---|
| Preparation | Underlying figures are compiled and reconciled against the latest management accounts. | Finance lead, with external accountant sign-off |
| Internal review | A second reviewer checks the calculation methodology and the supporting evidence for consistency. | Compliance officer |
| Submission | The file is sent through the channel the authority designates for this purpose. | Authorised signatory |
| Authority review | The authority checks completeness first, then substance; clarification requests reset the internal clock. | Competent authority case handler |
| Confirmation | The authority confirms the figure is accepted, or specifies what remains outstanding. | Competent authority |
Before submission, run an internal check on how the underlying records were compiled, not only on the final total. Records of processing review step by step covers the same discipline applied to personal data files, and the audit trail a reviewer expects is comparable across both procedures.
The calculation itself often draws on a database compiled by a third-party administrator rather than produced in-house. Rights over that compiled data sit outside this procedure and outside the authority's review. Sui generis right ownership of results explained sets out how such rights work and who can rely on them later.
Who reviews the evidence and how long it takes
The competent authority responsible for authorisation reviews the file. It does not delegate the substantive check to an outside auditor, even where the applicant's own figures were produced by one. The authority's acknowledgement letter, not the submission date, is the reference point for any deadline that follows.
Where part of the underlying accounting or calculation work is handled by an outsourced provider, that arrangement usually needs to be notified separately, on its own track and timetable. Outsourcing notification step by step walks through that parallel process, which can run before, during, or after the own funds file is submitted.
Common branches
- If the figure is accepted without query, confirmation follows the acknowledgement stage directly, and no further evidence is due.
- If the authority requests supporting documents, the internal clock pauses until the firm responds in full.
- If the authority disputes a figure outright, the exchange resembles a contested proceeding elsewhere in the practice. Opposition proceedings step by step describes how a similar contest unfolds for trade marks, including the point at which silence is read as agreement rather than as an open question.
What this page does not cover
This page does not set the minimum amount an applicant needs to hold, and it does not calculate a figure on a reader's behalf. It covers the sequence of steps and the deadline mechanics only. It also does not address what happens after authorisation is granted, when supervisory monitoring of own funds becomes an ongoing obligation rather than a one-off submission.
Verified
Last reviewed: January 2025. This overview reflects publicly available procedural guidance issued by national competent authorities responsible for digital asset service provider authorisation. It does not reproduce or summarise any specific legal provision.
Frequently asked questions
How long does own funds evidence take in practice?
There is no fixed universal period. Timing depends on how complete the initial file is and how many clarification rounds follow. A clean file with no queries moves fastest; each clarification request adds a further stretch of weeks.
Which documents are needed to start?
At minimum, the underlying management accounts, the calculation methodology, and evidence of how the figures were reconciled. Where custody or outsourcing arrangements feed into the number, supporting agreements for those arrangements are usually requested as well.
What happens if the other side does not respond?
If the authority does not respond within its own indicative period, the file remains pending rather than lapsing automatically. A firm can request a status update through the same channel used for the original submission, but there is no automatic escalation built into the process.
Related publications
Where this connects
Own funds evidence is one of several points where an authorisation file draws attention from a supervisor for reasons unrelated to the figures themselves. An on-site inspection is announced authorisation what it costs covers a related moment in the same supervisory relationship. Firms still building out their token offering should also check Marketing is treated as an offer token issuance, since an early misstep there can complicate the authorisation file that own funds evidence forms part of.