Estonia Crypto License — CASP Authorization Guide 2026

To obtain an Estonia CASP authorization, companies must satisfy Finantsinspektsioon's requirements under MiCA Regulation (EU) 2023/1114 and Estonia's national implementing legislation. Finantsinspektsioon applies a thorough, substantive review — the legacy of Estonia's 2022 VASP supervision reform, which significantly raised the bar for crypto licensing in the country. The following are the core requirements:

MiCA Article 67 sets three minimum own funds tiers based on authorized CASP service types. These thresholds are harmonized across all EU member states — Estonia applies them without national add-ons at the authorization stage:

Under MiCA Art. 67(2), own funds must at all times be at least one-quarter of the fixed overheads of the preceding year — so capital requirements grow as the business scales. Finantsinspektsioon conducts ongoing prudential supervision to ensure capital adequacy is maintained throughout the license lifetime. CASPs must hold capital in instruments that are fully paid up and freely available, without any pledge, lien, or other encumbrance.

A single Finantsinspektsioon CASP authorization grants full EU passporting rights under MiCA Article 65 — enabling your company to provide crypto-asset services in all 27 EU member states from one Estonian entity. Estonia's well-established position in EU financial regulation and Finantsinspektsioon's respected supervisory standing mean that an Estonian CASP authorization carries strong credibility with counterparties, banking partners, and institutional clients across Europe.

How Estonia CASP Passporting Works

• Notification procedure: Your company notifies Finantsinspektsioon of the target member state(s), service types, and intended start date. Finantsinspektsioon forwards the notification to the host NCA within 10 working days.
• Immediate market access: Services may commence in the host member state on the date of forwarding — no waiting for the host NCA to approve or reject. The notification is not a new authorization process.
• ESMA register visibility: All Finantsinspektsioon-authorized CASPs appear in ESMA's public register. Cross-border clients and partners can instantly verify your authorization status.
• Home-state supervision: Finantsinspektsioon retains supervisory responsibility for prudential requirements. Host-state NCAs supervise conduct-of-business requirements in their territory.

Compared to Lithuania and Poland, Estonia's NCA is known for its thorough pre-authorization process — but once authorized, an Estonian CASP benefits from one of the most digitally capable supervision frameworks in the EU. See our guide on EU passporting under MiCA for full procedural details.

Estonia adopted a shorter VASP-to-CASP transitional period under MiCA Article 143. Estonia's transitional window ended on 30 December 2025 — one year from MiCA's full application date. Any crypto business that was operating as a VASP in Estonia and had not obtained a CASP authorization by that date was required to cease providing virtual currency services. As of 2026, there is no remaining grandfathering protection for Estonian VASPs.

Key Points for Estonian VASP Operators

• Transition period expired: Estonia's 12-month VASP transitional window closed on 30 December 2025. There is no extension. Crypto businesses must hold a Finantsinspektsioon CASP authorization to operate legally in Estonia.
• FIU VASP registrations not transferable: Estonia's historic virtual currency service provider registrations were issued by the FIU (Rahapesu Andmebüroo). These registrations have no automatic carryover or legal equivalence under MiCA — a separate CASP authorization from Finantsinspektsioon is required.
• Prior VASP track record may support application: Finantsinspektsioon may take into account a prior FIU registration and documented compliance history when assessing a CASP application — a well-documented operating history can shorten the substantive review process for established operators.
• New service types require full authorization: Any crypto-asset service type not covered by a prior FIU VASP registration requires full MiCA CASP authorization. The transitional protection — which has now expired — covered only previously registered service types.
• No transitional passporting: EU passporting rights were not available under any VASP transitional arrangement. Full EU passporting across 27 member states activates only upon CASP authorization by Finantsinspektsioon.