How CASP Capital Requirements Work
MiCA Article 67 requires every authorised crypto-asset service provider to hold prudential safeguards at all times equal to the higher of two amounts: a permanent minimum capital fixed by service class, or one quarter of the fixed overheads of the preceding year. The minimum capital is the floor; the overheads figure scales the requirement up for firms with larger cost bases.
This is not a deposit you lodge and forget. It is own funds the business must maintain on an ongoing basis, monitored by your National Competent Authority as part of supervision. Falling below the threshold is a supervisory breach.
The Three Capital Classes
Annex IV groups CASP services into three classes with rising minimum capital:
| Class | Minimum capital | Services covered |
|---|---|---|
| Class 1 | €50,000 | Reception & transmission of orders; execution of orders; placing; providing advice; portfolio management; transfer services. |
| Class 2 | €125,000 | All Class 1 services plus custody and administration of crypto-assets; exchange of crypto-assets for funds or for other crypto-assets. |
| Class 3 | €150,000 | All Class 1 and Class 2 services plus operating a crypto-asset trading platform. |
The classes are cumulative: your class is set by the highest-tier service you are authorised to provide. A firm doing custody and running an exchange order book sits in Class 3, not Class 2.
Which Class Applies to Your Business
Map your business model to the service list before you apply:
- Advisory / portfolio management firm → Class 1 (€50,000). See our portfolio management licence page.
- Custodian / wallet provider → Class 2 (€125,000). See crypto custody licence.
- OTC desk / broker → Class 1 or Class 2 depending on whether it deals on own account or exchanges crypto for funds. See crypto broker licence.
- Exchange operating an order book → Class 3 (€150,000). See crypto exchange licence.
Most exchanges end up in Class 3 because they combine trading-platform operation with custody and fiat on-ramps. Getting the classification right at application stage avoids re-capitalising mid-process.
The One-Quarter-of-Fixed-Overheads Safeguard
The minimum capital is only the floor. If a quarter of your preceding year's fixed overheads exceeds your class minimum, that higher figure becomes your requirement. Fixed overheads broadly means recurring operating costs — staff, premises, software, professional fees — that the business incurs regardless of activity volume.
Worked example: a Class 1 advisory firm with €1,200,000 of annual fixed overheads must hold €300,000 (a quarter of overheads), not €50,000 — because the overheads figure is higher. For a lean start-up the class minimum usually governs; for an established operator the overheads test often bites. Budget for whichever is greater.
Own Funds vs an Insurance Policy
The prudential safeguard can be met through own funds (capital instruments and retained earnings qualifying as Common Equity Tier 1), an eligible insurance policy or comparable guarantee, or a combination of the two. The insurance route can free up working capital, but the policy must meet MiCA's conditions on coverage, term, and the insurer's standing.
Most applicants use own funds for the core minimum and consider insurance for the marginal amount above it. The right mix is a treasury decision we model during authorization.
Ongoing Obligations After Authorization
Capital is a continuing condition, not a one-off entry ticket. You must monitor own funds against the requirement, recalculate the overheads test annually, and notify your NCA of material changes. Significant ART and EMT issuers face additional, heavier own-funds rules under Titles III and IV that go well beyond these CASP figures.
Pair your capital plan with the rest of the file — governance, AML, and ICT resilience under DORA — so the application stands up as a whole.
