Pre-application meeting: stages and deadlines
A pre-application meeting is an informal exchange with the supervisory authority before you file for authorisation. It lets both sides flag obvious gaps early, confirm which documents matter most, and agree a realistic date for submission. It carries no legal weight of its own and does not replace the formal review that follows once a file is lodged.
What actually happens
The meeting is a conversation, not a filing. The authority's case team asks about your intended activities, your governance structure, and how client assets or client funds would be held. You ask about gaps in the draft file, about which annexes the authority expects in full at submission stage, and about how long the formal review is likely to run once the file is complete. Neither side commits to an outcome at this stage.
Most authorities treat the meeting as optional but strongly advisable for applicants with a non-standard model. A business built around a novel token structure or a cross-border service offering benefits more from this step than a straightforward, well-precedented file.
| Stage | What happens | Typical driver |
|---|---|---|
| Request | Applicant asks for a slot and outlines the intended activity in a short note | Applicant |
| Scoping | Authority reviews the note and decides which team members attend | Authority |
| Meeting | Structured discussion of the model, governance and open questions | Both sides |
| Follow-up note | Authority or applicant summarises agreed points and open items in writing | Either side, by agreement |
Before you request the meeting
Preparation decides whether the session is useful or wasted. Follow these steps in order.
- Draft a one-page activity description. State the service, the client type and the jurisdictions you intend to serve.
- Map the token or asset arrangement. If the offering rests on a tokenised right, be ready to explain how the token is proved as a matter of record, not just as a technical claim.
- Clear ownership of the underlying build. Where code, models or documentation were produced by contractors, confirm that contractual override in ownership of results actually sits with the applicant entity, not with the developer.
- List open questions. Bring three to five genuine uncertainties rather than a rehearsed pitch.
- Assign one contact. The authority expects a single point of contact for the follow-up note.
Who runs the meeting and on what timeline
The competent supervisory authority for the relevant activity decides whether to grant a meeting, who attends from its side, and how the follow-up is recorded. There is no universal fixed window between request and meeting; it depends on the authority's current caseload and on how complete your scoping note is. Treat the meeting as a checkpoint, not a queue position: a well-prepared request tends to move faster than a vague one, regardless of when it was submitted.
Common variations
If your file already carries a supervisory history — for instance an earlier finding on a related activity — say so upfront. The authority will want to know whether any remediation after a finding is complete or still open, since an unresolved item from a prior file tends to surface again during authorisation review.
If a third party disputes your brand or trade mark rights around the same time, that dispute does not usually stop the meeting, but it can affect how the authority reads your governance answers. Where a competitor claims bad faith, keep the underlying facts separate from the authorisation conversation and be ready to say so plainly if asked.
If you are still deciding between two structural options for the offering, say that too. Authorities generally prefer an honest "we are choosing between A and B" to a confident answer that changes at submission.
What this page does not cover
This page describes the meeting itself, not the formal filing that follows it. It does not set out fee levels, does not fix a statutory deadline for the authority's decision, and does not list every document annex — those depend on the national authority handling your case and on the specific activity. It also does not address what happens after a refusal; that is a separate track with its own timing.
Verified
This overview reflects general procedural practice as observed across pre-application engagement with digital asset supervisors, current as of the review date on this page. It does not cite specific statutory provisions, because the exact procedural rule sits with each national authority and varies between them. Where a specific deadline or fee matters to your file, confirm it directly with the authority handling your case rather than from this page.
Related reading
The natural next step after the meeting is putting the file together. See file assembly and submission step by step for how the annexes discussed at the meeting turn into a submitted file.
If the meeting does not resolve things
A pre-application meeting is not an appeal forum and not a decision point. If your file is later refused, the meeting record does not extend or shorten your options — see an appeal deadline follows a refusal for what to do first once a refusal actually lands.
FAQ
How long does a single pre-application meeting usually take?
Most sessions fit into one meeting slot. Authorities sometimes schedule a short follow-up call afterwards if the discussion raised a question neither side could answer on the spot.
Which documents are needed to start the process?
A short activity description and an outline of your governance and asset-handling model are usually enough to request a slot. Full annexes come later, at formal submission, not at this stage.
What happens if the authority does not respond after the meeting?
Send a written follow-up summarising the points discussed and the open items you understood the authority to be considering. If there is still no response after a reasonable interval, a polite status request through your assigned contact is the normal next step, not an escalation.