Since the last transitional periods ended on 1 July 2026, crypto-asset services to clients in the EU require MiCA authorisation or, for already regulated financial entities, a notification. We assess the business model, choose the Member State and prepare the company, documents, AML framework and systems for the application and for operation afterwards.
Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) created a single EU regime for crypto-asset service providers (CASPs). Its CASP rules have applied since 30 December 2024. Authorisation is granted by the national competent authority of the Member State where the company has its registered office and covers the specific crypto-asset services listed in the decision.
An authorised CASP may provide the same services in other Member States, either cross-border or through a branch, by means of a passport notification, without a separate authorisation in each country. Credit institutions, investment firms, electronic money institutions and certain other financial entities may use a notification procedure instead of full authorisation.
All national transitional periods have expired; the latest EU-wide end date was 1 July 2026. In its public statement of 23 June 2026, the European Securities and Markets Authority (ESMA) stated that providers without authorisation must wind down in an orderly manner and that non-EU providers may not serve clients in the EU, including business clients. The practical question is now where to be authorised and for which services.
MiCA is the same across the EU, but the competent authority, the national AML set-up and the way the transition period ended differ. Below are the states most often considered for a new authorisation.
| Jurisdiction | Regulator | Regime | Key points |
|---|---|---|---|
| Lithuania | Bank of Lithuania (Lietuvos bankas) | MiCA authorisation | The national transitional period ended on 31 December 2025. Providers that did not continue under MiCA were required to wind down in an orderly manner; national VASP registrations no longer support new business. |
| Czech Republic | Czech National Bank (CNB) | MiCA authorisation | Designated as the competent authority by Act No. 31/2025 Coll., effective 15 February 2025. Transition applied only to trade-licence holders who applied by 31 July 2025 and ended on 1 July 2026; by then the CNB had granted MiCA authorisation to 11 entities. |
| Estonia | Finantsinspektsioon (Financial Supervision Authority) | MiCA authorisation | Authorising authority since 30 December 2024. The Financial Intelligence Unit no longer issues virtual-asset authorisations but remains the AML supervisor. Transition ended on 1 July 2026. |
| Cyprus | Cyprus Securities and Exchange Commission (CySEC) | MiCA authorisation | The 18-month transitional period ended on 1 July 2026. National implementing details are confirmed against official texts at the assessment stage. |
| Malta | Malta Financial Services Authority (MFSA); FIAU for AML | CASP licence under the national MiCA Act | Transitional measures under the Virtual Financial Assets Act expired on 30 June 2026. Holders of VFA licences had to obtain a CASP licence or wind down. |
| Poland | Not designated | No national route | As of October 2026 Poland had not designated a MiCA competent authority, so a Polish CASP authorisation was not available. Polish clients can be served by a CASP authorised in another Member State through the passport. |
Regulatory capital is separate from state and application fees, operating costs and our fees. Our fees are agreed after the project assessment.
We map the product to the MiCA services, determine the capital class and check whether authorisation or notification applies. Result: a scope memo and project plan.
We compare regulators, substance expectations, AML supervision and passport plans. Result: a recommended jurisdiction and group structure.
Incorporation or restructuring, registered office, EU-resident director, key functions, capital and budget. Result: an entity ready to apply.
Business plan, financial model, policies, AML framework, IT and security documentation. Result: a complete application filed.
Answers to requests, interviews and document updates during the assessment. Result: a decision by the competent authority.
Passport notifications, final systems set-up, go-live and first reporting cycle. Result: an operating CASP.
MiCA sets procedural periods: acknowledgement of receipt within 5 working days, a completeness check within 25 working days and a decision within 40 working days of a complete application. A request for additional information may suspend the assessment for up to 20 working days. For passporting, the home authority forwards the notification within 10 working days, and services may start at the latest 15 calendar days after submission. The overall timeline also depends on preparation, the regulator's workload and the number of question rounds, so no decision date can be promised.
Buying, selling and exchanging digital assets for clients: exchange services, online exchangers, in-app exchange.
Learn moreSafekeeping of client assets and keys; custody infrastructure for exchanges, exchangers and platforms.
Learn moreVenues where clients trade digital assets with each other through the operator's trading system.
Learn moreExecuting client orders, agency models, access to foreign venues and liquidity.
Learn moreLicence, registration or SRO membership for virtual asset businesses in the UAE, UK, Switzerland, Hong Kong, Canada and offshore centres.
Learn moreRisk assessment, policies, KYC/KYB, sanctions and transaction monitoring, travel rule and inspection readiness for licensed and to-be-licensed financial and crypto businesses.
Learn moreDescribe your project in a few sentences. We will give you a substantive reply: which questions need answering and where to start.
Discuss your projectNo. ESMA's statement of 23 June 2026 says that non-EU crypto-asset service providers may not serve clients in the EU, including business clients. A business that wants EU clients needs an authorised EU entity and a structure built around it.
The minimum is €50,000, €125,000 or €150,000 depending on the services, or one quarter of the previous year's fixed overheads if higher. This is regulatory capital; application fees, operating costs and our fees are separate, and our fees are agreed after the assessment.
MiCA requires a registered office in a Member State where part of the services is provided, effective management in the EU and at least one director resident in the EU. How much local staff is needed beyond this depends on the business and the regulator, and we plan it with you.
The law provides 25 working days for the completeness check and 40 working days for the decision on a complete application, with possible suspension for information requests. Preparation of the company and documents comes on top, and the real timeline depends on the regulator and the quality of the file.
Transitional periods ended by 1 July 2026 at the latest. According to ESMA, providers without authorisation must wind down: no new clients or marketing, only actions to close or transfer positions, and custody only as long as strictly necessary.
As of October 2026 Poland had not designated a MiCA competent authority, so a Polish CASP authorisation was not available. Polish clients can be served through a passport from another Member State; we check the status again before any decision.
No. We help prepare and support the person appointed by the company. Outsourced support models can be discussed where the law allows; this is determined for each project.
Send a short description of the services, target markets and current structure. We will come back with a preliminary view on the capital class, suitable Member States and the scope of work; our fees are agreed after this assessment.
We will review the description and give you a substantive reply: which regime may apply and where to start.
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