Withdrawal procedure: stages and deadlines

Withdrawal of a digital-asset authorisation moves through four stages: notice, response, decision, and appeal window. Each stage carries its own deadline, set by the supervisory authority rather than by a fixed statute. The point of no return arrives when the withdrawal decision takes effect — usually the date stated in the decision itself, not the date you receive it.

Practical consequence

Once the supervisory authority opens a withdrawal file, the firm's authorisation does not disappear on day one. It stays valid until the decision itself says otherwise, but every client relationship taken on during this window carries risk: if the withdrawal is confirmed, those contracts still have to be wound down under supervision.

Record requests usually arrive early. The authority asks for transaction logs, client files and internal decisions covering the period under review. Handling that request well follows the same logic decision-makers use when they assess Access request handling step by step: confirm scope, confirm who holds the material, and answer within the window the authority sets rather than the window you assume applies.

A second consequence is quieter but costs more time: any pending filing tied to the authorisation freezes until the file closes. Renewals, notifications and change requests submitted mid-procedure sit in a queue rather than being rejected outright.

Stages of the procedure

Four stages repeat across withdrawal files, though the authority can compress or extend any of them depending on the grounds.

The response stage is where most files are won or lost. A late or incomplete submission narrows the authority's options at the decision stage, because it has less on file to weigh against the original grounds.

What to do

1. Read the notice line by line and calendar the deadline the same day it arrives. The deadline runs from the date stated in the notice, not from the date someone opens the letter.
2. Assign one person inside the firm to own the file. Withdrawal procedures move fast enough that shared ownership usually means no one answers on time.
3. Build the evidence file the way a registry expects it: dated, complete, sourced. The discipline is close to what we describe for Proof of use step by step in trade mark registers — a chronological record outperforms a narrative summary every time.
4. If the withdrawal forces client relationships to move to another authorised entity, treat the handover as a formal assignment rather than an informal introduction. The mechanics described in Assignment ownership of results explained carry across registers and apply to the handover file as well.
5. Where the authorisation covers tokenised instruments, check filing status before the decision takes effect. Recent changes covered in What changed in filing formalities tokenised rights affect who can still submit on the firm's behalf during the response window.
6. Submit the response before the deadline stated in the notice, not the deadline you infer from a previous case. Every file sets its own clock.

Who decides

The supervisory authority that granted the authorisation is also the body that issues the withdrawal decision. It sets the response deadline in the notice, reviews the submission internally, and issues a decision that states its own effective date. The same decision names the forum for appeal and the deadline for filing one — both belong to the authority's own procedure, not to a fixed external clock.

Forks

If you dispute the grounds stated in the notice, the response stage is the place to say so in writing, with evidence attached — silence at this stage is read as agreement with the grounds, not as a reserved position.

If you accept the grounds and want to limit damage, a remediation plan submitted at the response stage can lead the authority to narrow the withdrawal rather than confirm it in full.

If a counterparty or client is affected by the outcome, notify them once the decision is issued, not before — an early notice based on the draft grounds can create claims the firm did not need to invite.

Limit

This page sets out how the procedure runs, who decides, and where the deadlines sit. It does not cover what a replacement authorisation requires, how long a fresh application takes, or what the work of preparing a response file costs. Those questions sit outside a procedure page and belong to a separate conversation once the file is open.

Verified

Reviewed against the supervisory authority's published withdrawal guidance and current case-handling practice. Where a notice or decision in your file states a different deadline or forum, the notice controls — this page describes the general shape of the procedure, not the wording of any single file.

Related publications

A withdrawal decision is one of several supervisory measures a firm can face; the stages differ enough to warrant a separate read: Appeal against a supervisory measure step by step.

FAQ

How long does withdrawal procedure take in practice?
The authority sets each deadline in its own notice and decision, so total length varies by file. A response stage that ends in a remediation plan usually runs longer than one that ends in an unanswered notice.

Which documents are needed to start?
The notice itself is the starting document. From there, the firm needs the records the notice asks for — typically transaction logs, client files and internal decisions covering the period under review.

What happens if the other side does not respond?
If the firm does not respond within the stated deadline, the authority decides on the file as it stands. A missed deadline does not pause the procedure; it removes the firm's chance to shape the decision.

If a notice has already landed on your desk, the next move matters more than the deadline on the calendar: When an authorisation is withdrawn sets out what to do first.

— Aleks Vaher, AURELIS