What Is MiCA?
MiCA — the Markets in Crypto-Assets Regulation (EU) 2023/1114 — is the European Union's comprehensive framework governing the issuance, offering, and provision of services related to crypto-assets. Adopted by the European Parliament on 20 April 2023 and published in the Official Journal on 9 June 2023, MiCA entered into force on 29 June 2023, with stablecoin provisions (Titles III and IV) applying from June 2024 and the full regulation — including the CASP licensing regime — becoming applicable on 30 December 2024.
Before MiCA, crypto regulation across EU member states was fragmented: each country had its own VASP (Virtual Asset Service Provider) registration or licensing regime, with widely differing requirements and no mechanism for cross-border service provision without separate national authorizations. MiCA replaced this patchwork with a single, harmonized framework. For a deeper look at how the regulation works, see our guide: MiCA Regulation explained.
MiCA covers three categories of crypto-assets: asset-referenced tokens (ARTs), e-money tokens (EMTs), and a broad residual category of crypto-assets (which includes utility tokens and other digital assets not covered by existing financial law). It also establishes the CASP authorization framework — a harmonized licensing regime for businesses that provide services related to any of these crypto-asset categories.
MiCA does not apply to NFTs (unless they are fungible in practice), DeFi protocols (as they have no identifiable legal entity), and crypto-assets that already qualify as financial instruments under MiFID II (such as tokenized securities). For those categories, existing EU financial regulation applies.
The regulation is supervised by national competent authorities (NCAs) — such as Poland's KNF, Lithuania's Bank of Lithuania, and Germany's BaFin — with ESMA (European Securities and Markets Authority) providing coordination, technical standards, and oversight guidance. Read the MiCA Regulation explained for the full regulatory context.
Who Needs a CASP License Under MiCA?
Any legal entity that provides one or more of the 10 CASP services defined in MiCA Article 63 on a professional and commercial basis in the EU must be authorized as a CASP. This applies regardless of where the company is incorporated — a non-EU company providing crypto-asset services to EU clients must establish a legal entity within the EU and obtain authorization.
Key business types that require a CASP license include:
- Crypto exchanges and trading platforms — centralized exchanges (CEXs) operating order books or matching engines require CASP authorization for operation of a trading platform. See our guide to a crypto exchange license under MiCA.
- Custodians and wallet providers — entities holding client crypto-assets or private keys need CASP authorization for custody and administration services.
- Crypto brokers and OTC desks — businesses exchanging crypto for fiat or crypto-to-crypto on behalf of clients require CASP status.
- Crypto portfolio managers — discretionary management of client crypto portfolios falls under the MiCA CASP framework.
- Transfer service providers — platforms facilitating crypto transfers (comparable to payment services) need CASP authorization.
- Crypto advisors and investment platforms — entities providing investment advice on crypto-assets require CASP authorization for the advisory service.
- Stablecoin issuers and EMT providers — though governed by Titles III and IV of MiCA, entities offering or placing ARTs and EMTs intersect with CASP requirements. See our guide to the stablecoin EMT license.
Exemptions: MiCA provides limited exemptions for entities already regulated under EU financial law (credit institutions, investment firms, e-money institutions) for certain services they already perform. Entities providing CASP services incidentally (below de minimis thresholds) and pure peer-to-peer transactions without a commercial intermediary are also outside scope. Always verify your specific model with a qualified MiCA advisor before assuming an exemption applies.
Types of Crypto-Asset Services Under MiCA
MiCA Article 63 defines exactly 10 types of crypto-asset services. A CASP license must specify which services the entity is authorized to provide — and capital requirements, ongoing obligations, and conduct rules differ by service type.
A single CASP authorization can cover multiple service types simultaneously. Most full-service exchanges apply for services 1–5 and 7 as a baseline, while specialized advisory or brokerage firms may apply for a narrower subset. Each additional service category adds compliance obligations but does not require a separate license.
CASP License Requirements Under MiCA
To obtain a MiCA CASP license, an applicant must satisfy a comprehensive set of authorization requirements set out in MiCA Articles 62–76. The national competent authority assesses each application against these criteria before granting authorization.
Capital Requirements (Article 67)
| Capital Tier | Covered Service Types | Minimum Own Funds |
|---|---|---|
| Tier 1 — Basic | Advice, reception & transmission, execution of orders, placing | €50,000 |
| Tier 2 — Mid | Exchange services (fiat & crypto-to-crypto), portfolio management, transfer services | €125,000 |
| Tier 3 — Full | Custody & administration, operation of a trading platform | €150,000 |
Note: Own funds must also not fall below one-quarter of fixed overheads from the preceding year, if that figure exceeds the minimum threshold. For growing businesses, this dynamic requirement often sets a higher effective capital floor.
AML/KYC Compliance
All CASPs are subject to EU anti-money laundering obligations. Applicants must demonstrate a robust AML/KYC compliance program aligned with AMLD6 and the EU Transfer of Funds Regulation (crypto travel rule). This includes Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) procedures, transaction monitoring systems, appointment of an AML compliance officer, and established suspicious activity reporting channels to the national Financial Intelligence Unit.
Fit & Proper Requirements
All directors, senior managers, and qualifying shareholders must pass a fit and proper assessment. NCAs evaluate: absence of criminal convictions (financial crimes, fraud, money laundering), professional qualifications and relevant experience, and financial integrity. Most NCAs require a minimum of two directors with EU residency and demonstrable experience in financial services or regulated industries.
IT Security & DORA
The Digital Operational Resilience Act (DORA), applicable from January 2025, applies to CASPs. Applicants must present a documented ICT risk management framework, digital resilience testing protocols, major incident reporting procedures, and a third-party ICT risk management policy. For custody and trading platform services, additional cybersecurity standards apply.
Crypto-Asset White Paper (Article 66)
CASPs that offer, place, or admit crypto-assets to trading must prepare a MiCA-compliant crypto-asset white paper. The white paper must include details of the issuer or offeror, a description of the crypto-asset project, rights and obligations attaching to the asset, underlying technology disclosures, and risk factor statements. It must be filed with the NCA and published on the company's website prior to any public offer or trading admission.
Other Organizational Requirements
- Legal establishment: Registered legal entity in an EU member state (SA, GmbH, UAB, OÜ, or equivalent)
- Local presence: Genuine operational substance — not a letterbox entity
- Complaint handling: Documented procedures for handling client complaints
- Conflict of interest policy: Written policies identifying and managing conflicts of interest
- Custody segregation: For custodians — strict segregation of client assets from firm assets
- Insurance or guarantee: Some NCAs require professional indemnity insurance as an alternative to maintaining excess capital
MiCA License Cost and Timeline
The total cost of obtaining a MiCA CASP license varies significantly by jurisdiction and the scope of services applied for. Below is a realistic breakdown of the main cost components.
Government and NCA Fees
ESMA does not charge an EU-level authorization fee. Each national competent authority sets its own application fee. Fees vary considerably: Poland's KNF charges application fees in the range of PLN 10,000–25,000 (approximately €2,500–€6,000); Lithuania's Bank of Lithuania charges fees in a similar range; some larger NCAs such as BaFin apply higher examination fees. Annual supervisory levies typically range from €3,000 to €15,000 per year depending on the jurisdiction and the scale of operations.
Professional Fees
Legal and compliance consulting fees — covering document preparation, regulatory strategy, AML program design, white paper drafting, and NCA liaison — typically range from €25,000 to €80,000 for a complete CASP authorization mandate. Costs are driven by the complexity of the business model, the number of service types applied for, and whether the company requires significant organizational build-out (board recruitment, substance establishment, DORA compliance).
Minimum Capital Requirement
The minimum own funds of €50,000–€150,000 (depending on tier) must be held permanently. This is not a fee — it remains the company's capital — but it must be available at authorization and maintained on an ongoing basis.
Operational Setup Costs
- Company formation: €1,500–€5,000 (varies by jurisdiction)
- Registered office and substance: €3,000–€12,000/year
- AML compliance officer (local or outsourced): €12,000–€36,000/year
- DORA-compliant IT documentation and systems: €5,000–€20,000
- Professional indemnity insurance (where required): €5,000–€15,000/year
Timeline
MiCA sets a mandatory review clock: the NCA has 25 working days to assess completeness of the application, then up to 40 working days to make an authorization decision (extendable once by 20 working days for complex cases). In practice, the total timeline from initial engagement to authorization decision runs 3 to 6 months, depending on jurisdiction, application quality, and NCA workload.
EU Passporting — One License for 27 Countries
One of MiCA's most significant commercial benefits is EU passporting: a CASP authorized in any one EU member state can provide the same authorized services across all other 26 EU member states without obtaining a separate license in each country. This eliminates the multi-jurisdiction licensing burden that characterized the pre-MiCA era. Read our detailed guide to EU Passporting: one license for 27 countries.
The notification procedure is straightforward: the CASP submits a passporting notification to its home NCA, specifying which services it intends to provide in which member states. The home NCA transmits the notification to the host country NCA within 10 working days. The CASP can then commence services in the host country without awaiting any additional decision — the host NCA may only intervene on consumer protection or AML grounds.
This mechanism makes the choice of initial authorization jurisdiction strategically important. CASPs often choose their home jurisdiction based on cost, speed, and regulator pragmatism — then passport services into larger markets including Germany, France, and the Netherlands. For a full analysis, see our guide to EU Passporting: one license for 27 countries.
How to Apply for a MiCA CASP License: 6-Step Process
VASP to CASP Transition: What Existing Operators Must Do
If your business was registered or licensed as a VASP under national law before 30 December 2024, MiCA Article 143 grants you a transitional period — but the clock is running. For a complete comparison of the two regimes, read our guide on VASP vs CASP differences and the VASP to CASP transition guide.
Existing VASPs must submit a full MiCA CASP authorization application before 1 July 2026 (18-month transitional period) — or before 30 June 2025 in member states that opted for the 12-month shortened period. Missing the deadline means immediate cessation of crypto-asset services. See MiCA deadline 2026 for country-by-country status.
Key Transitional Provisions
- Continued operation: VASPs with valid national authorization may continue providing services during the transitional period without a CASP license — provided they submit their CASP application before the deadline.
- Simplified procedure: NCAs may apply a simplified assessment for entities already subject to national AML/VASP requirements, focusing on gaps relative to MiCA standards rather than conducting a full de novo review.
- No grandfathering of services: Transitional rights cover only services the VASP was already authorized to provide under national law. Adding new service types requires full CASP authorization for those services.
- Country variations: Several member states (including Estonia and Lithuania) applied the shorter 12-month transitional period. If your VASP is registered in one of these jurisdictions, the June 2025 deadline already passed — you must hold a CASP license or cease operations.
Crypto License Europe has guided 30+ VASPs through the MiCA transition process. Contact us for a gap analysis comparing your current national authorization against MiCA CASP requirements. Read the full VASP to CASP transition guide for detailed procedural information.
