MiCA licence in Slovakia

The Markets in Crypto Assets Regulation (MiCA) has established a uniform standard for the regulation of digital assets in the European Union. Slovakia is one of the jurisdictions where the application of this regulation is becoming significant for crypto companies, infrastructure solution developers and token issuers. Národná banka Slovenska (NBS) is the national authority responsible for the admission and supervision of service providers. Since MiCA came into force, the NBS has been authorised to accept licence applications, verify applicants’ compliance with the regulation’s requirements, and supervise crypto asset market operators. The regulation covers a wide range of business models related to crypto assets, including storing digital assets on behalf of clients, brokerage operations, portfolio management, accepting and transmitting orders, exchanging crypto assets for fiat currency and for each other, providing consultancy services, and issuing and listing tokens. However, MiCA does not apply to cases where a natural or legal person conducts transactions exclusively with their own funds and does not provide services to third parties. This is an important consideration when structuring a business and assessing the risks of qualifying activities as regulated.

The licensing process in Slovakia requires the preliminary preparation and systematisation of corporate documentation. The vast majority of application materials must be submitted in Slovak. Documents written in other languages must be officially translated, unless they are prepared in Czech or English — the latter being accepted as the language of international financial communications. Before considering the merits of an application, the NBS checks that the submitted package is complete. Once the sufficiency of the documents has been confirmed, the application is considered within the time limits established by law. As there are no fast-track procedures for crypto providers, applicants should assume that the review period will be formally regulated and tied to the supervisory authority’s internal processes. Financial statements submitted with the application must be audited. These statements are considered not only as part of the business sustainability assessment, but also as the basis for calculating the annual supervisory fee. Capital, liquidity and risk management requirements stem from MiCA provisions and aim to minimise threats to customers and the market. The company must demonstrate that it has a sustainable business model, transparent sources of funding and a well-established internal control system, as well as mechanisms to prevent conflicts of interest.

Particular attention is paid to compliance and anti-money laundering measures. The Slovak regulator expects crypto service providers to implement a risk-based AML approach ensuring customer identification and verification of funds, transaction monitoring, data storage and reporting of suspicious transactions, as well as working with high-risk categories including politically exposed persons. The effectiveness and depth of the AML model directly affects the company’s interaction with the banking sector. Banks have the right to refuse service if a customer’s profile indicates a high level of risk, but this refusal must be justified. The supervisory authority emphasises that automatic de-risking is unacceptable, whereby a financial institution blocks access to banking services solely because the applicant works with crypto assets. After obtaining a licence, the provider acquires the right to provide cross-border services within the framework of passporting. This means that a company registered and authorised in Slovakia can offer services in other EU countries without having to obtain additional permits. Thus, MiCA transforms the Slovak licence into a tool for scaling up the crypto business across Europe. The implementation of MiCA in Slovakia fosters a predictable environment for market participants and establishes conditions conducive to long-term development projects. Clear regulation, a formalised admission procedure, mandatory auditing, a fixed AML framework and the ability to freely enter all European Union markets make the jurisdiction attractive for crypto companies planning to expand or launch operations in Europe. With proper preparation, transparent corporate structures and timely documentation, obtaining a licence can be a strategic step in the growth of a crypto project.

MiCA regulations in Slovakia

The regulatory process for obtaining a CASP licence in Slovakia is structured so that submitting an application is the final stage. It is recommended that applicants go through a preliminary preparation stage before applying to the National Bank of Slovakia, as this will determine how quickly and successfully they will be able to obtain authorisation. The regulator allows preliminary communication before submitting a complete set of documents. This enables you to agree on the parameters of the business model, discuss the services the applicant plans to provide under MiCA and understand the applicable requirements for the specific structure. To schedule a consultation, the company must submit a request in advance together with a completed questionnaire and any necessary attachments. These materials must be submitted in an archived and encrypted form, and it is advisable to provide a list of questions or discussion topics at least five working days in advance. At the meeting, the regulator expects to receive a clear presentation of the project, including the company’s structure, current activities, development strategy, target customer segment, list of crypto services and scaling forecasts within the EU. This format of communication enables methodological errors to be eliminated even before an application is submitted, and allows the extent to which the business model complies with MiCA regulatory requirements and additional provisions of national legislation to be assessed. When preparing for licensing, it is important for the applicant to compile a structured package of documents. The regulator pays particular attention to transparency with regard to ownership, beneficiaries and managers, as well as their qualifications and compliance with integrity requirements. The company must also describe its corporate governance system, internal controls, IT infrastructure, asset protection procedures, and risk management and compliance mechanisms. A separate area of focus is AML and KYC: applicants are expected to describe mechanisms for client identification, fund origin verification, transaction monitoring, suspicious activity handling, interaction with supervisory authorities and data retention policy maintenance. If a company intends to provide custodial asset storage services, it must demonstrate the separation of client funds and organisational assets. To enhance regulatory resilience, it is advisable to prepare a business plan, financial forecasts, risk assessments, business recovery scenarios for failure and business continuity plans.

Under MiCA, all licensed crypto service providers (CASPs) are divided into three categories depending on the nature of their activities and the level of regulatory burden. Class I includes companies that provide order transmission and execution services, as well as consulting services, but not custodial asset storage. For these companies, a minimum capital requirement of €50,000 has been set. Class II covers organisations that store client assets and exchange crypto assets. Such companies are required to have a minimum capital of €125,000. The highest level, Class III, covers trading platform and infrastructure service operators, and has the highest capital requirements, starting at €150,000.

Although MiCA is the main regulatory act, it does not exhaust all of the applicant’s obligations. Applicants must also consider the provisions on digital operational resilience (DORA), the regulation of transfers of crypto-assets and financial instruments, anti-money laundering and counter-terrorist financing legislation, financial market supervision, and accounting standards. Therefore, preliminary preparation involves more than just collecting documents; it also involves adapting the company’s internal procedures to the regulatory environment. Otherwise, the application may be returned for revision, which increases the time required to obtain a licence. Applications can be submitted once MiCA comes into force. However, a lack of structured preliminary preparation can make the process more laborious and risky. Companies that engage in consultation and prepare documentation in advance can identify and address weaknesses prior to submitting their application, thereby accelerating the subsequent licensing process. Therefore, the preparation stage prior to submitting an application to the NBS is a mandatory element of successfully completing the licensing procedure, not a formality. This stage enables you to build relationships with the regulator, prepare internal documentation, verify the maturity of the business model and ensure transparency in line with MiCA and national supervisory requirements.

As crypto asset legislation has become clearly regulated, obtaining an NBS licence requires careful preparation — submitting an application without detailed documentation and processes is unlikely to be successful. Before submitting an application, it is advisable to arrange a “pre-licensing meeting” with the regulator. This allows you to discuss your business model, the types of services you intend to offer, your company’s legal form and structure, and management and control requirements. It also enables you to understand what documents you need to prepare and what compliance standards you will have to meet. To initiate dialogue with the NBS, you should send a completed questionnaire with attachments in advance, archiving and password-protecting it at least five working days prior to the proposed meeting. You should also prepare a presentation about your company, including your plans, target clientele, development strategy, and the crypto services you intend to provide. This approach helps eliminate potential errors early on and increases the likelihood of a smooth process. Applications to provide crypto-asset services must be drawn up in accordance with the requirements of the regulations (as set out in Article 62 of MiCA) and must be accompanied by a complete set of documents. It is important that the entire set is properly formatted: attachments should be originals or certified copies; all attachments should be numbered and structured; and references to the composition of the attachments and their interrelationships should be included. If the applicant requests it, the NBS may allow some attachments to be submitted electronically (on a data carrier), provided that other regulations do not require a paper copy.

If the package contains public documents issued abroad, they must be properly legalised for the Slovak regulator, at least through an apostille or, where required, consular legalisation. An official translation must be provided where necessary. The application itself and basic internal documents (articles of association, internal regulations and management policy) must be submitted in Slovak. However, technical documentation, international agreements and confirmation of management qualifications can usually be submitted in English or Czech, especially when it comes to international standards, unless the NBS requires a translation. A key element is the reliable separation of the company’s assets from those of its clients. Client funds must be kept in a separate bank account that is never used for the provider’s own needs. Funds must be credited to this account on the first working day after receipt. Clients’ crypto assets are separated in a similar way: their private keys or wallets must not intersect with the provider’s assets — client assets must be stored at addresses where the provider’s assets have never been held. If the provider plans to use outsourcing or third-party services (e.g. custodial providers, banks or storage services), they must have agreements in place with these providers in advance, confirming that they are ready to ensure the required separation. Such agreements must be documented and attached to the application.

The regulator also pays attention to the management structure and the qualifications of the management and owners. Members of the executive and supervisory bodies must have an impeccable reputation and sufficient experience, knowledge and competencies to manage risks, security and compliance processes. They must be able to confirm that they have no criminal records, have not been subject to sanctions or administrative penalties, and have the relevant professional experience and knowledge. A detailed operational plan must also be submitted, including a description of the services, business model, technological platform, internal procedures, risk control and prevention systems, AML/CFT policy, KYC, internal control and monitoring of transactions and suspicious operations. If remote customer onboarding (online identification) is planned, the application must include a description of how identity verification, data verification and compliance with security requirements will be ensured. The company must also analyse the amount of documentation and control that will be required if any of its activities are outsourced. It must also ensure that legally binding agreements are in place with any contractors, confirming their ability to comply with the regulator’s requirements. Once the application has been prepared with a complete set of documents that meet the requirements, it can be submitted to the NBS. From 30 December 2024, all crypto providers wishing to operate legally in Slovakia will be required to follow this procedure. When submitting the application, it is important to ensure that all documents meet the requirements in terms of form and content and that internal policies and management systems are correctly set up.

Therefore, the preparation and submission stage is a strategically important step, not just a formality. Well-prepared documents, a clear business model, an organised management structure, segregated client assets, and robust compliance policies will significantly increase the chances of obtaining a licence and reduce the risk of comments from the regulator. They will also create the basis for sustainable and transparent operation in the crypto market. After an application for a crypto asset service provider (CASP) licence has been submitted, the official review process begins. On the first working day after receiving the paper version of the application, the NBS will register the case and initiate the procedure. The applicant must pay the relevant state fee and attach a copy of the payment receipt to the application.

Within five working days of receiving the documents, the NBS will send the applicant confirmation of receipt of the application. The verification process then begins, during which the regulator assesses whether the submitted package of documents is complete and drawn up in accordance with the requirements, including all necessary information, attachments, translations and confirmations relating to the company’s structure and founding documents. If the application is incomplete, the NBS will request its revision and indicate the deadline for providing the missing materials. Once these have been received, the verification process will resume. If the application is in order, the NBS will recognise it as ‘complete’ and proceed with a thematic assessment of the applicant’s compliance with the MiCA regulations. A decision on whether to grant or deny a licence must be made within 40 working days of the application being deemed complete. In some cases, the regulator may request additional information, for which they have up to 20 working days. The review period is calculated from the date of receipt of the last required data.

Once a decision has been made, the NBS will officially notify the applicant of the result within five working days, informing them whether the licence has been granted or refused. If approved, the company will be entitled to officially provide crypto services under MiCA. If refused, the applicant will receive a reasoned explanation. The actual duration of the procedure depends on the quality of the application: the more complete, structured, and well-formed the document package is, the greater the likelihood that the entire process will be completed within the minimum timeframe. Conversely, shortcomings, missing information and delays in finalising the application can significantly prolong the procedure. The stage after submission involves a formalised, step-by-step review of the application, including acceptance and registration, confirmation, assessment of completeness, a thorough substantive analysis and the possibility of requesting clarifications, before the final decision is made. A successful outcome primarily depends on preparation, including audited financial statements, proper documentation, and compliance with corporate governance, security, AML/KYC, and operational stability requirements.

The following documents are required for CASP companies to obtain a MiCA licence in Slovakia:

To obtain a Crypto Asset Service Provider (CASP) licence in Slovakia, a company must prepare comprehensive documentation confirming its structural, financial, and operational readiness to operate in accordance with MiCA and national regulatory requirements. The basic package includes the legal entity’s founding documents, information on its ownership structure, details of its ultimate beneficial owners and members of its management bodies, as well as confirmation of their business reputation, professional experience, and qualifications. The regulator will assess the management’s ability to ensure compliance with internal control procedures, manage risks, and maintain a sustainable operating model. A mandatory element is a business plan describing the services provided, the financial model, the forecast of operating expenses and sources of income, and the technical characteristics of the platform. The company must also provide internal regulations and instructions relating to risk management, accounting, cybersecurity, the protection of client assets, and the stability of IT systems. Significant attention is paid to AML/KYC documents, including procedures for customer identification, transaction monitoring and the detection of suspicious transactions, as well as interaction with financial institutions.

Alongside operational and legal documentation, applicants must submit audited financial statements and evidence of compliance with the capital requirements established for the selected CASP class. Providers offering custodial services or servicing trading platforms must also submit documents confirming the separation of client and corporate funds, mechanisms for the safekeeping of crypto assets and procedures for accessing keys or wallets. If external contractors are used, outsourcing agreements must be provided to guarantee that third parties comply with regulatory standards.

Preparing this package of documents is a central part of the licensing process. The more accurate and complete the package, the faster the NBS will be able to review the application and make a decision. The key basis for admission to the provision of crypto services in Slovakia is precisely the documentary evidence of the reliability of the model, the transparency of processes, and corporate sustainability. Following the introduction of MiCA and its incorporation into Slovak legislation, the rules governing the issuance of crypto assets have undergone significant changes. The NBS has been granted the power to supervise all processes related to the issuance and public offering of tokens, including stablecoins, asset-backed tokens and other crypto assets.

The regulation divides crypto assets into three categories:

• Electronic money tokens (EMT): stablecoin tokens pegged to an official currency.
• Asset-backed tokens (ART): stablecoin tokens whose value is backed by a basket of assets or other currencies/values.
• Other crypto assets that do not fall under the EMT or ART categories.

From 30 June 2024, EMTs may only be issued by banks or electronic money issuers who have notified the NBS of their intention in advance and provided a white paper, which must then be published publicly. Similar rules apply to ART: these can be issued either by banks, who must notify the NBS, or by issuers who have obtained the appropriate authorisation. In both cases, they must submit and publish a white paper. From 30 December 2024, the following requirement applies to ‘ordinary’ crypto assets (not stablecoins): public offerings or issuances are only possible for legal entities that have submitted a white paper to the NBS in advance and subsequently published it. For assets that were traded on platforms prior to the introduction of MiCA, a transition period applies: platforms must ensure that the relevant white paper is submitted and published by the end of 2027.

Thus, the process of issuing crypto assets is now strictly formalised. Issuers must prepare a detailed white paper disclosing the terms of issue, token structure, collateral mechanism (if applicable), holder rights, risks and other material characteristics. Without such a document and without notifying the NBS, the issuance and public offering of tokens is prohibited. Additionally, issuers (or issuing banks) must comply with the same requirements as crypto asset service providers, including robust governance, compliance, transparent structures, asset separation, AML/KYC procedures and protection of token holders’ interests. The NBS supervises and monitors to ensure that the issuance and circulation of tokens complies with MiCA and national legislation.

This scheme provides a high degree of protection for investors and consumers, increases transparency, and reduces the risks of manipulation or unfair issuance. Essentially, the regulator is transforming the crypto asset market into a controlled financial ecosystem offering fair access, effective oversight and reliable standards.

Stages of MiCA implementation in Slovakia

On 30 December 2024, the NBS assumed responsibility for supervising the crypto asset market in Slovakia. This step is part of a major regulatory transformation in line with MiCA — now, any provider of crypto-asset services (known as a CASP) must obtain a licence from the NBS to operate legally. The NBS supervises the following activities: the storage and management of crypto assets; the operation of trading platforms and exchanges; exchange transactions with fiat currencies or other cryptocurrencies; order management; consulting; portfolio management; token issuance; and other related services. At the same time, the ownership, purchase, sale or storage of crypto assets by end users (private individuals) remains outside the scope of mandatory regulation — a licence is only required for those who provide services to third parties.

Supervisory competence includes the obligation for providers to comply with several requirements, such as having sufficient capital, robust management and control systems, and separating client funds from company assets. Other requirements include implementing AML/KYC mechanisms, maintaining operational stability, and having a transparent corporate structure. The NBS also verifies that managers, beneficiaries and company management meet integrity and professional qualification criteria. Supervision does not end after a licence is issued. Licensed companies must report regularly to the NBS and comply with transparency, accountability, client asset protection and internal control standards. They must also respond promptly to any changes in structure, business model or management. In this way, the regulator ensures that CASP companies’ activities remain safe, sustainable, and compliant with MiCA and related regulations, supporting the development of the crypto-asset sector while reducing risks to customers and financial stability and making the market more predictable, understandable, and reliable for businesses.

State fee for applying for a MiCA licence in Slovakia

The fee for authorisation as a crypto-asset service provider is specified in Decree No. 5/2021 of the National Bank of Slovakia on fees for the activities of the National Bank of Slovakia, as amended by Decree No. 8/2024 of the National Bank of Slovakia. The fee is determined according to the scope of services for the requested crypto assets specified in the authorisation application, as follows: €1,700, €2,500 or €3,400.

Annual fee

A supervised entity’s annual fee shall be paid to the National Bank of Slovakia by a supervised institution that has obtained a licence or other authorisation to conduct activities on the financial market in accordance with special regulations. In accordance with Section 40(2) of Act No. 747/2004 Coll. on the Supervision of Financial Markets and on Amendments to Certain Acts, the annual fee for the relevant calendar year is determined in advance by 20 December of the previous year for all participants of the same type and within the limits of the annual fees of the participants. Annual contributions are paid by supervised entities each calendar year throughout the entire term of authorisation.

For crypto-asset service providers, annual contributions for 2025 were determined by Decision No. 4/2024 of the National Bank of Slovakia on 25 June 2024, concerning the determination of annual contributions and a special contribution for supervised financial market structures in 2025. This was amended by Resolution No. 15/2024 of the National Bank of Slovakia (full text No. 16/2024). The annual contribution for crypto asset service providers is set at 0.1% of their assets, with a minimum of EUR 1,000.

The assessment of applications complies with the deadlines set out in Article 63 of MiCA. The overall duration depends significantly on the quality and completeness of the application, the applicant’s cooperation, and the scope and complexity of the proposed services. In accordance with MiCA requirements, as set out in the ESMA Supervisory Briefing, the NBS conducts a comprehensive assessment of the governance, prudential safeguards, business model, ICT/security, AML/CFT and outsourcing requirements relevant to CASPs. Given these circumstances, deadlines may vary, but formal MiCA deadlines are always met. If an application is incomplete, the NBS will not automatically reject it. Instead, the NBS will submit a request for completion (one or more, depending on what is required). While an application is considered incomplete, the MiCA deadlines under Article 63 do not apply. You will be given the opportunity to provide all the necessary information and documents. This approach is fully consistent with both MiCA and the ESMA Supervisory Briefing on how NCAs should handle incomplete submissions.

An application will only be rejected or withdrawn if the applicant does not respond or if the application cannot meet MiCA requirements even after receiving the additional form. The National Bank of Slovakia conducts the authorisation process in full compliance with MiCA Regulation (EU) 2023/1114, delegated regulatory acts, applicable European guidelines (including the ESMA Supervisory Briefing on CASP authorisation) and all relevant national legislation. The NBS does not apply any special national policy aimed at making Slovakia ‘more cryptocurrency-friendly’ or, conversely, more restrictive. The authorisation process aims to ensure a harmonised level of investor protection, market integrity, effective supervision and the prudential and organisational soundness of authorised organisations at EU level. Thus, Slovakia offers the same opportunities for obtaining a CASP licence as any other EU member state, but always within the framework and standards set by MiCA.

Taxation of cryptocurrency in Slovakia in 2025–2026

Cryptocurrencies will remain subject to taxation under the general rules applicable to financial assets. Tax is only payable upon disposal, whether through sale, exchange, conversion to fiat currency, or other means. The mere storage of cryptocurrency does not give rise to tax liabilities. The purchase, sale and exchange of crypto assets ↔ fiat or crypto ↔ crypto are not subject to VAT, as they are considered financial services rather than the sale of goods. For individuals, profits from crypto transactions are recognised as other income and are taxed at a rate of 19% up to a certain threshold, and 25% on the excess. In addition, a mandatory contribution to the healthcare system is charged, which increases the actual tax burden. The tax base may include the costs of purchasing cryptocurrency and transaction fees. However, losses from transactions do not reduce the tax base unless the individual is engaged in entrepreneurial activity. If cryptocurrencies are used as part of a business — for instance, for regular trading or for accepting payments in digital currencies — the income is classified as business income. In this case, the tax rate may be lower for small turnovers and actual costs, such as commissions, equipment, software, mining costs and third-party platform services, may be included in expenses. This model is more profitable for active traders and miners as it enables them to operate with a full list of costs and correctly determine the tax liability.

Companies that conduct transactions with crypto assets pay income tax at rates linked to the amount of income. Withdrawals through dividends are subject to withholding tax, which affects the final tax liability of business owners. Legal entities in particular must keep full accounting records of all transactions, store supporting documents, reflect the acquisition and sale of crypto assets in the balance sheet, and comply with financial reporting requirements. Additional requirements for transparency and the exchange of tax information will come into force in 2026. Expanded automatic reporting on crypto transactions is expected at the EU level, which may affect transaction administration, though the basic principles of taxation will remain unchanged: income is generated at the time of the asset’s sale, and tax is calculated depending on the taxpayer’s status and the nature of the activity. Slovakia’s tax model remains predictable: crypto asset holders pay tax only when they make a profit; business operators can optimise costs through their corporate structure; and companies are required to keep full accounts and report cryptocurrency as an asset. This system creates conditions for the legal and transparent management of digital assets for both private investors and structured crypto projects.

How can Regulated United Europe lawyers help you obtain a MiCA licence in Slovakia?

Obtaining a MiCA licence in Slovakia is a multi-stage legal process involving the accurate preparation of a package of documents, correct corporate structuring, and strict compliance with the requirements of the Slovak regulator, the NBS. In order to be authorised to operate within the EU, a company must demonstrate that it meets the requirements relating to capital, operational security, client asset storage, anti-money laundering (AML) procedures and IT protection. It must also be able to document the maturity of its operating model. Regulated United Europe‘s lawyers help clients navigate these stages systematically, from project assessment to final licence acquisition. Their work begins with analysing the client’s business model, determining which CASP service class their activities fall under and establishing which permits and capital requirements apply and which legal format would be most effective. Based on this assessment, they develop an ownership structure, appoint governing bodies, and form internal policies, including AML/KYC procedures, risk management, rules for storing and segregating client assets, and a description of the technology platform and operational infrastructure. If the business involves custodial services or a trading platform, particular attention is given to separating client and proprietary funds, and to technical protocols for accessing wallets and keys. The team then compiles a complete licence application package for submission to the National Bank of Slovakia. This includes the company’s legal documents, incorporation details, information about directors and beneficiaries, a business plan, product description and operational processes, and a financial model, as well as confirmation of capital and audited financial statements. Lawyers will then prepare internal regulations, transaction control instructions, business continuity procedures, incident response plans and technical security standards. All documents are structured in accordance with MiCA regulations, providing the regulator with a comprehensive overview of the business without the need for additional requests. Participation in pre-licensing communication with the NBS is particularly important. Regulated United Europe organises such consultations, preparing a project presentation and sending technical and legal information to the regulator in advance, as well as responding to requests for clarification. This approach enables key terms to be agreed upon prior to submitting the application and reduces the review period. Once the package has been submitted to the NBS, specialists will support the client throughout the process, responding to letters, preparing additional explanations, updating documents as necessary and engaging in dialogue until the licence is issued. This work model relieves clients of most of the legal and regulatory burden, allowing them to focus on product and business development. Regulated United Europe‘s expertise reduces the risk of rejection, speeds up the entire procedure and ensures compliance with MiCA requirements. This opens up the possibility for the company to provide crypto services throughout the European Union via the passporting mechanism.