EU MiCA CASP Licence — European Union
Expert advisory on EU MiCA CASP licensing. Single authorisation for all 27 EU member states. From jurisdiction selection to passporting.
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What is the EU MiCA CASP Licence?
The EU MiCA CASP Licence is the single European Union authorisation for Crypto-Asset Service Providers under the Markets in Crypto-Assets Regulation (EU) 2023/1114. MiCA has been fully in force since 30 December 2024, replacing the patchwork of national VASP registration regimes that previously operated across EU member states.
One MiCA authorisation in any EU member state grants passporting rights to operate across all 27 EU member states — a transformative change from the previous regime where separate national registrations were required. This makes the EU the largest single market with a harmonised crypto regulatory framework.
CASPs that were registered under national VASP regimes before 30 December 2024 may operate under transitional arrangements, but national sunset dates vary — most expire between July 2025 and July 2026. Any third-country firm serving EU clients requires MiCA authorisation; the reverse solicitation exemption is narrow and cannot substitute for authorisation.
Who Needs EU MiCA CASP Licence?
MiCA CASP authorisation is required by any firm providing crypto-asset services to EU clients, regardless of where the firm is incorporated.
- —Crypto exchanges (fiat-to-crypto and crypto-to-crypto)
- —Custodian wallet providers and digital asset custodians
- —Crypto brokers and dealers
- —Trading platform operators
- —Transfer service providers
- —Portfolio managers dealing in crypto-assets
- —Investment advisers advising on crypto-assets
The most common misconception is that the reverse solicitation exemption allows non-EU firms to serve EU clients without authorisation. ESMA has made clear that reverse solicitation is a narrow exemption requiring genuine, unsolicited client initiation — it cannot be relied upon as a business model. Firms marketing to EU clients, operating EU-facing websites or advertising in EU markets require MiCA authorisation.
Key Requirements
Capital Requirements
€50,000 for advisory services, reception and transmission of orders. €125,000 for custody and administration of crypto-assets, exchange services (fiat-to-crypto and crypto-to-crypto). €150,000 for operating a trading platform for crypto-assets. Capital must be maintained on an ongoing basis.
Governance & Fit and Proper
Fit and proper assessment for the management body. At least two directors resident in the EU. Most NCAs expect genuine local substance — not virtual office arrangements. The management body must demonstrate collective competence in crypto-assets, compliance and risk management.
AML & Financial Crime Controls
AML programme compliant with EU AMLD6 (Anti-Money Laundering Directive 6) and the FATF Travel Rule as implemented by EU Transfer of Funds Regulation (TFR 2023/1113). Chain analysis, crypto-specific CDD and ongoing transaction monitoring are expected.
DORA Compliance
The Digital Operational Resilience Act (DORA) applies to MiCA CASPs from January 2025. ICT risk management frameworks, incident reporting procedures, digital operational resilience testing and third-party ICT risk management must be documented in the application.
EU Substance Requirements
Most NCAs require genuine local presence — office space, local employees, EU-resident management. Virtual offices and nominee directors are specifically targeted for refusal. The degree of substance required varies by NCA.
Crypto-Asset White Papers
Where applicable, crypto-asset white papers must be prepared to MiCA standards. White papers are required for certain crypto-asset issuances and must include specific mandatory disclosures prescribed by MiCA.
The Application Process
Jurisdiction Selection and Service Category Mapping
Regulatory Counsel maps your business model to MiCA CASP service categories to determine the capital tier and white paper obligations. We recommend the optimal NCA based on assessment timeline, substance requirements and institutional positioning. Key jurisdictions: Lithuania (fastest, 3–4 months), Ireland (strongest institutional reputation, 6–12 months), Poland, Malta. Timeline: 2–3 weeks.
EU Entity Establishment
We incorporate the entity in the chosen member state, establish genuine local presence, appoint a local management body with EU-resident majority and open an EU bank account. Local substance must be in place before application submission. Timeline: 4–8 weeks.
Application Documentation
Regulatory Counsel prepares the full MiCA application: regulatory business plan, AML/CTF programme (AMLD6-compliant, Travel Rule framework), governance and risk framework, DORA ICT risk management documentation, fitness and propriety submissions, and MiCA white paper where required. Timeline: 6–10 weeks.
NCA Portal Submission
The completed application is submitted to the chosen National Competent Authority. Completeness check within 25 working days under MiCA Article 63. Timeline: 1 week submission, 25 working days completeness check.
NCA Assessment
The NCA reviews the application and may issue queries and information requests. Regulatory Counsel manages all correspondence. Management interviews may be conducted depending on the NCA. Assessment timelines vary by jurisdiction: Lithuania 3–4 months, Ireland 6–12 months. Timeline: 3–12 months.
Authorisation and EU Passporting
On authorisation, we file passporting notifications with ESMA for all target member states. Services can commence in each target state 15 working days after notification — without requiring separate national authorisation. Timeline: 15 working days per target state.
Total expected timeline: 5–16 months from instruction depending on jurisdiction.
Why Applications Fail — and How We Prevent It
Wrong Jurisdiction Selection
Choosing a jurisdiction based solely on speed without considering banking partner access, ongoing supervisory style and the reputational implications for institutional clients. Lithuania is fast but may not carry the institutional weight required by certain client bases. Ireland is slower but carries stronger reputational positioning. Regulatory Counsel advises on the strategic trade-offs for each firm.
Insufficient Local Substance
NCAs reject applications where there is no genuine local management presence. Virtual offices, nominee directors and mail-forwarding arrangements are specifically targeted. Most NCAs expect at least two EU-resident directors with demonstrable involvement in the business, physical office space and local operational capability.
DORA Readiness Gap
MiCA applications are rejected where the firm has not demonstrated digital operational resilience frameworks consistent with DORA. This is a new failure mode that many applicants miss — DORA applies to MiCA CASPs from January 2025 and the ICT risk management, incident reporting and resilience testing frameworks must be documented in the application.
Transitional Deadline Missed
Firms that fail to submit a MiCA application before their national transitional deadline lose the right to continue operating under the previous national registration and must immediately cease EU-facing crypto-asset services. Most transitional deadlines fall between July 2025 and July 2026.
How Regulatory Counsel Can Help
End-to-End Application Management
We manage the complete MiCA CASP application — from jurisdiction selection and EU entity establishment through to NCA authorisation and EU-wide passporting.
Regulatory Business Plan
We prepare MiCA-standard regulatory business plans with AMLD6-compliant AML programmes, DORA ICT risk frameworks and internally consistent financial projections.
Ongoing Compliance Support
Post-authorisation compliance support including ESMA passporting notifications, ongoing supervisory reporting, AMLD6 programme updates and DORA compliance maintenance.
Regulatory Counsel has advised on crypto licensing across multiple EU jurisdictions. We combine deep MiCA expertise with practical experience of NCA assessment processes in Lithuania, Ireland, Poland and Malta. Our jurisdiction-agnostic approach ensures that each firm is matched to the NCA that best serves its strategic objectives.
Frequently Asked Questions
Capital requirements are set by MiCA, not by individual member states: €50,000 for advisory, reception, transmission and execution services; €125,000 for custody and administration, fiat exchange or crypto-to-crypto exchange; €150,000 for operating a trading platform. Capital must be maintained on an ongoing basis.
Yes. MiCA includes full EU passporting. After authorisation in a home member state, the CASP notifies ESMA and can begin providing services across all 27 EU member states 15 working days after each host member state notification — without separate national authorisation.
Lithuania (Bank of Lithuania) is consistently the fastest EU authoriser — typical NCA assessment of 3–4 months from complete application. Ireland (Central Bank of Ireland) takes 6–12 months but carries stronger institutional credibility. The right jurisdiction depends on business model, banking relationships and counterparty expectations — not speed alone.
Yes. Third-country firms — including UK firms post-Brexit — serving EU clients in crypto-asset services require MiCA CASP authorisation in an EU member state. The reverse solicitation exemption under MiCA Article 61 is narrow and cannot be used as a systematic business model.
Transitional arrangements vary by member state — most EU member states set national transitional deadlines between July 2025 and July 2026. Firms operating under transitional arrangements that miss the deadline must immediately cease EU-facing crypto services. Contact Regulatory Counsel for the current status of your jurisdiction's transitional window.