✓ MiCA Regulation (EU) 2023/1114 — In force since December 2024

✓ VASP→CASP Transition Deadline: 1 July 2026

✓ Offices in Düsseldorf · Vilnius · Tallinn

✓ Free Initial Consultation

MiCA Art. 7–9 · Class 1 CASP · €75,000 Capital

Crypto Broker License EU — MiCA CASP Brokerage Authorization Guide 2026

EU crypto broker license — MiCA CASP brokerage authorization for reception, transmission and execution of orders under MiCA Regulation 2023/1114

Operating as a crypto broker in the European Union — accepting client orders and routing them to exchanges or executing them as principal — requires a MiCA CASP authorization under MiCA Articles 7, 8, and/or 9: reception and transmission of orders (RTO), execution of orders on behalf of clients, and placing of crypto-assets. The crypto broker license is MiCA's most accessible authorization: minimum own funds of just €75,000 (Class 1 CASP), authorization in 3–6 months, and EU passporting to all 27 member states. The lowest-cost broker jurisdictions in 2026 are Poland, Czech Republic, Slovakia, Bulgaria, and Estonia. For OTC desks, crypto trading intermediaries, investment advisors, and order-routing platforms, the broker license is the right starting point. This guide explains everything you need to know.

Get Your Broker License — Free Consultation View MiCA Services ↓

MiCA Framework

What is a MiCA Crypto Broker License?

A MiCA crypto broker license is a CASP authorization granted by a National Competent Authority (NCA) under MiCA Regulation (EU) 2023/1114, covering brokerage service types: the reception and transmission of orders (MiCA Art. 7), execution of orders on behalf of clients (MiCA Art. 8), and/or placing of crypto-assets (MiCA Art. 9). Unlike an exchange license, a broker does not operate its own order book or trading platform — it acts as an intermediary between clients and trading venues, routing or executing orders on clients' behalf.

The broker license is MiCA's most accessible CASP authorization: it requires only €75,000 in minimum own funds (versus €150,000 for an exchange), carries lighter technical compliance obligations (no custody requirements unless separately authorized), and is available through fast, cost-efficient jurisdictions in Central and Eastern Europe. For new market entrants, the broker license provides a compliant EU regulatory foundation from which they can later expand to exchange or custody services through additional authorization.

Who Needs a Crypto Broker License?

OTC desks that match buyers and sellers of large crypto-asset transactions bilaterally
Crypto investment advisors and discretionary portfolio managers advising clients on crypto-asset investment
Order-routing platforms that connect client orders to third-party exchanges for execution
Introducing brokers that refer clients to crypto exchanges and receive commission for order flow
Crypto trading platforms that aggregate liquidity from multiple exchanges and route client orders to the best-price venue
Token placement agents placing crypto-assets on behalf of issuers under MiCA Art. 9

MiCA Art. 7, 8 & 9

MiCA Services: RTO, Execution, Placing

Three MiCA service definitions cover crypto brokerage operations. Each has distinct characteristics and may require slightly different compliance arrangements:

📨

MiCA Article 7 — Reception & Transmission (RTO)

Receiving orders from clients to buy or sell crypto-assets and transmitting those orders to a third-party CASP (exchange) for execution. The RTO broker does not execute trades itself — it forwards client instructions to the trading venue. This is the most common brokerage model and the lowest-risk service type. Best execution obligations apply: the broker must route to the venue offering the best outcome for the client.

⚡

MiCA Article 8 — Execution of Orders

Executing client orders as principal or agent — the broker takes the opposite side of the trade (principal) or executes on a venue on the client's behalf (agent). OTC desks typically operate under Art. 8 when they buy crypto from a client at a quoted price and later sell to another counterparty. Best execution and conflicts of interest policies are critical. May require €125,000 capital if combined with fiat exchange (Art. 6).

🚀

MiCA Article 9 — Placing of Crypto-Assets

Acting as an intermediary between a crypto-asset issuer and investors in a public offering or initial token offering — placing tokens with clients without operating as an exchange. Token placement agents, crypto investment banks, and ITO facilitators operating under the MiCA white paper framework need Art. 9 authorization. Requires detailed conflict of interest management and disclosure obligations to investors.

💡

MiCA Advice (Art. 3) — Note

Providing advice on crypto-assets (Art. 3 — personalized recommendations to clients on buying, selling, or holding specific crypto-assets) is a separate Class 1 CASP service also at €75,000 capital. Many brokers combine Art. 7 RTO authorization with an advice authorization to offer a full brokerage service with personalized recommendations. Advice-only licenses are the simplest MiCA authorization available.

Broker vs. Exchange: Choose the Right License

If your business accepts client orders and routes them to a third-party venue — you need a broker license (Art. 7) at €75,000. If you operate your own order book or matching engine — you need an exchange license (Art. 5) at €150,000. Many businesses start with a broker license and later upgrade to an exchange license as their platform scales. See our Crypto Exchange License EU page for the full exchange authorization guide.

MiCA Article 67

Capital Requirements — €75,000 Class 1

A crypto broker license falls under MiCA Article 67(1)(a) — the Class 1 tier — with a minimum own funds requirement of €75,000. This is the EU's most accessible regulatory capital threshold for a licensed financial service:

CASP Class	Service Types Covered	Min. Own Funds	MiCA Reference
Class 1	Advice; Reception & transmission (Art. 7); Execution (Art. 8); Placing (Art. 9); Transfer services	€75,000	Art. 67(1)(a)
Class 2	Exchange for fiat/crypto; Portfolio management; Transfer services (larger)	€125,000	Art. 67(1)(b)
Class 3	Trading platform operation; Custody & administration	€150,000	Art. 67(1)(c)

Note that the MiCA capital table in Article 67 uses the original article numbering from the final regulation text. The minimum own funds of €75,000 (Class 1) applies to: advice on crypto-assets, reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, and providing transfer services for crypto-assets. Any CASP adding exchange (Art. 6) or custody (Art. 70) services upgrades to Class 2 or Class 3 respectively.

Own funds must be freely available, unencumbered, and maintained at all times — not only at the authorization stage. Under MiCA Art. 67(2), own funds must also be at least one-quarter of the fixed overheads of the preceding year. For small brokers with minimal fixed overheads, the €75,000 minimum will be the binding constraint for several years.

Jurisdiction Comparison 2026

Best EU Jurisdictions for Crypto Brokers

The broker license is the most cost-efficient CASP authorization to obtain, and Central and Eastern European jurisdictions offer the best combination of speed, cost, and regulatory competence for broker applicants in 2026:

Jurisdiction	Regulator	Timeline	Gov. Fee	Corp. Tax	Best For
🇵🇱 Poland ECOSYSTEM	KNF	3–5 months	€1,000–€2,500	19%	Large domestic market, strong fintech talent pool
🇨🇿 Czech Republic	CNB	3–4 months	€500–€1,500	19%	Fast, low-cost, experienced NCA for fintech
🇸🇰 Slovakia	NBS	3–5 months	€500–€1,500	21%	Low cost, access to Czech + Slovak market
🇧🇬 Bulgaria	FSC (KFN)	3–4 months	€500–€2,000	10%	Lowest total cost — lowest gov fee + lowest tax
🇪🇪 Estonia	FSA	3–5 months	€1,000–€3,300	20%*	Tech-first culture, e-residency, fast process

* Estonia: 0% on retained profits, 20% on distributions. Timelines are for well-prepared applications. Gov. fee ranges cover standard broker CASP authorization. All jurisdictions provide full MiCA EU passporting to 27 member states.

For brokers prioritizing absolute lowest cost, Bulgaria combines the lowest government fees with a 10% flat corporate tax. For brokers wanting Central European market access, Poland offers a 38 million-person domestic market with a growing fintech ecosystem. For fastest authorization, the Czech Republic (CNB) or Estonia (FSA) are the most expedient choices in 2026.

Service Comparison

Brokerage vs Exchange License: Key Differences

Choosing between a broker license and an exchange license is the most common decision point for new CASP applicants. The table below summarizes the key differences:

Factor	Broker License (Art. 7–9)	Exchange License (Art. 5–6)
MiCA Articles	Art. 7 (RTO), Art. 8 (Execution), Art. 9 (Placing)	Art. 5 (Trading Platform), Art. 6 (Exchange)
Min. Capital	€75,000 (Class 1)	€150,000 (Class 3)
Order Book	No — routes orders to third-party venue	Yes — operates own matching engine
Client Asset Custody	Not required (add Art. 70 for custody)	Typically required (Art. 70 custody)
Technical Complexity	Lower — no exchange platform documentation	Higher — trading platform, market surveillance
Timeline	3–6 months	4–8 months
Best For	OTC desks, advisors, order-routing platforms	CEXs, swap platforms, trading venues

Start with Broker — Upgrade to Exchange

Many successful crypto businesses start with a broker license (€75,000, faster, cheaper) and later expand to an exchange license as they build the platform, client base, and compliance infrastructure required for exchange authorization. MiCA allows CASPs to add service types to their existing authorization without re-applying from scratch — making the broker license a practical first step toward a full-service EU crypto platform.

Step-by-Step

Application Process — 5 Steps to Your EU Broker License

Business Model Analysis & Jurisdiction Selection

We analyze your brokerage model — RTO, execution as principal/agent, OTC desk, or placement agent — to identify the applicable MiCA articles and the correct capital class. We assess your target markets, timeline, and budget to select the optimal EU jurisdiction from Poland, Czech Republic, Slovakia, Bulgaria, Estonia, or another NCA. Timeline: 1 week.

EU Entity Formation

We establish the legal entity in the chosen jurisdiction — Polish spółka z o.o., Czech s.r.o., Slovak s.r.o., Bulgarian OOD, or Estonian OÜ — with registered office, genuine business substance, local bank account, and a corporate structure suitable for CASP authorization. Broker applicants typically need a simpler organizational structure than exchange applicants. Timeline: 1–3 weeks.

Compliance Documentation Package

We prepare the complete CASP broker application package: business plan with revenue model and 3-year financial projections, AML/KYC program aligned with ESMA guidelines and national AML law, DORA ICT risk management framework, best execution policy (for Art. 7/8), conflicts of interest policy, client risk disclosure documents, and fit & proper materials for all directors and key function holders. Timeline: 3–6 weeks.

NCA Application Submission & Review

We submit the complete CASP authorization application to the chosen NCA and manage the statutory review process. The NCA confirms completeness within 25 working days (MiCA Art. 63), then reviews within 65 working days. We respond to all NCA information requests and liaise with the authorization department throughout. Broker applications are typically less complex than exchange or custody applications, resulting in fewer NCA information requests. Timeline: up to 65 working days.

Authorization & EU Passporting Activation

Upon CASP authorization, your broker entity is listed in ESMA's public register of authorized CASPs. We immediately initiate EU passporting notifications for all target member states, enabling you to provide brokerage services across the full EU single market. We provide post-authorization compliance support, regulatory monitoring, and ongoing NCA filing assistance. Timeline: 1–2 weeks post-authorization.

Frequently Asked Questions

Crypto Broker License EU — FAQ

What is a MiCA crypto broker license?

A MiCA crypto broker license is a CASP authorization covering brokerage service types under MiCA Regulation (EU) 2023/1114: Article 7 (reception and transmission of orders — RTO), Article 8 (execution of orders on behalf of clients), and/or Article 9 (placing of crypto-assets). A broker accepts client orders and routes or executes them, without operating its own order book. It is MiCA's most accessible authorization — Class 1 CASP at €75,000 minimum capital — making it the practical entry point for OTC desks, crypto advisors, and order-routing platforms entering the EU regulated market.

What is the minimum capital for a crypto broker license?

A crypto broker license under MiCA requires €75,000 minimum own funds under MiCA Article 67(1)(a) — the Class 1 CASP tier. This is the lowest capital requirement in the MiCA CASP framework. Own funds must be freely available, unencumbered, and maintained at all times. Under MiCA Art. 67(2), own funds must also be at least one-quarter of fixed overheads for the preceding year. Adding exchange (Art. 6) or custody (Art. 70) services to a broker authorization increases the capital requirement to Class 2 (€125,000) or Class 3 (€150,000) respectively.

What is the difference between a broker and exchange license?

The key difference is whether you operate your own trading infrastructure. A broker (Art. 7–9) routes client orders to a third-party exchange — it does not run its own order book. An exchange (Art. 5) operates a trading platform that matches multiple buyers and sellers simultaneously. Capital reflects this: broker requires €75,000 (Class 1), exchange requires €150,000 (Class 3). Brokers also have lighter technical requirements — no exchange platform documentation, market surveillance systems, or (unless separately authorized) client custody infrastructure. See our full comparison at Exchange License EU.

Which EU country is cheapest for a crypto broker license?

The cheapest EU jurisdictions for a crypto broker license in 2026 are: Bulgaria (FSC, €500–€2,000 gov fee, 10% corporate tax, 3–4 months), Czech Republic (CNB, €500–€1,500, 19% tax, 3–4 months), and Slovakia (NBS, €500–€1,500, 21% tax, 3–5 months). Bulgaria is the cheapest on a total-cost basis due to the combination of lowest government fees and EU's lowest flat corporate income tax rate (10%). For brokers targeting the Polish domestic market, Poland (KNF) is the natural choice despite marginally higher costs.

Can a broker license cover OTC trading?

Yes, with nuance. OTC trading under a broker license applies when the broker acts as agent — transmitting client orders to a counterparty for execution (Art. 7 RTO) — or when executing as principal by taking the opposite side of client trades (Art. 8 execution). However, if the OTC desk is buying crypto from one party and selling to another at a marked-up price as a regular business (acting as a market maker or dealer), this may fall under Art. 6 (exchange of crypto-assets for funds or other crypto-assets) requiring Class 2 capital (€125,000). OTC desk operators should obtain a legal opinion on the correct MiCA service classification for their specific trading model before applying.

What compliance does a MiCA broker need?

MiCA broker compliance requirements include: AML/KYC program — full KYC onboarding, transaction monitoring, MLRO appointment, PEP/sanctions screening, Travel Rule compliance; DORA ICT resilience — ICT risk management framework and business continuity plan; best execution policy (Art. 7/8 brokers) — documented process for routing orders to achieve the best client outcome; conflicts of interest policy; client risk disclosures; and ongoing capital monitoring with quarterly NCA reporting. The broker compliance burden is lighter than for exchanges or custodians — making broker authorization the most cost-efficient MiCA compliance path for intermediary businesses. Contact us for a free compliance assessment.

Crypto brokerage compliance and MiCA CASP authorization — broker desk analysis and regulatory documentation for EU broker license

MiCA Brokerage Compliance

Why the Broker License is the Right Starting Point

For businesses entering the EU regulated crypto market in 2026, the broker license offers the most practical cost-to-market path. With €75,000 capital, a 3–6 month timeline, and lower technical requirements than exchange or custody licenses, it provides immediate regulatory compliance with the flexibility to expand later.

Strategic Advantages of Broker Authorization

Lower barrier to entry: €75,000 capital versus €150,000 for exchange authorization. For early-stage businesses, the capital saving can be reinvested in product development, marketing, and talent.
Faster authorization: Broker applications are typically less complex and generate fewer NCA information requests — resulting in authorization timelines 1–2 months shorter than exchange applications in most jurisdictions.
Lower ongoing compliance cost: No custody infrastructure, no exchange platform documentation, no market surveillance systems — the broker compliance stack is significantly lighter than an exchange.
Same EU passporting: A broker license in Bulgaria, Poland, or Czech Republic grants identical MiCA Art. 65 passporting rights to all 27 EU member states — the same market access as a German BaFin authorization, at a fraction of the cost and time.
Upgrade path: A CASP authorized for brokerage can add exchange or custody services to the same authorization through a variation application — without restarting the full licensing process from scratch.

Our team has guided OTC desks, crypto advisors, and order-routing platforms through broker CASP authorization in Poland, Czech Republic, Bulgaria, and Estonia. We handle everything from jurisdiction selection and entity formation to NCA correspondence and post-authorization passporting. Schedule a free consultation to discuss your broker license timeline. Related guides: Exchange License, Custody License, AML/KYC Program.

Lead Expert — CASP Services

Elena Fischer

MiCA CASP Authorization Specialist · Düsseldorf / Tallinn

Elena Fischer leads Crypto License Europe's CASP services practice, with particular expertise in MiCA broker and brokerage-adjacent service authorizations across Poland, Czech Republic, Slovakia, Bulgaria, and Estonia. She has advised over 30 OTC desks, crypto trading platforms, and order-routing businesses on MiCA Art. 7–9 service classification, NCA application strategy, best execution policy design, and AML/KYC compliance frameworks. Elena specializes in helping businesses navigate the broker-versus-exchange classification question — a threshold decision that has major capital and compliance implications under MiCA. Prior to Crypto License Europe, Elena worked in financial regulation at a Frankfurt-based law firm advising investment firms and crypto businesses on EU financial services authorization. Speak to Elena →

€75K

Min Capital (Class 1)

3–6

Months Authorization Timeline

Countries EU Passporting

Art. 7–9

MiCA Legal Basis

Get Your Broker License — Free Consultation

Our MiCA brokerage specialists will assess your business model, select the optimal EU jurisdiction, and guide you from entity formation to CASP authorization and EU passporting. Free 30-minute consultation, response within 1 business day.

Start Free Consultation