Understanding MiCA: The European Union’s Framework for Crypto Regulation

The introduction of the Markets in Crypto-Assets Regulation (MiCA) is one of the most significant milestones in the global evolution of digital asset regulation. Designed and adopted by the European Union, MiCA aims to bring order, clarity and legal certainty to the rapidly expanding and previously fragmented crypto market across Europe. Prior to this framework’s establishment, each EU Member State had its own interpretation and rules regarding the treatment of crypto-assets, resulting in inconsistencies, regulatory arbitrage, and uncertainty for businesses and investors.

MiCA is part of the European Commission’s broader Digital Finance Strategy, which aims to modernise financial services by embracing innovation while ensuring stability and consumer protection. The EU recognised that, while digital assets create unprecedented opportunities for innovation, they also pose new challenges, such as the risk of fraud, market manipulation and financial instability. Without a harmonised framework, projects often faced substantial barriers to entry due to drastically different compliance requirements between countries. For instance, a company licensed in one Member State could not automatically operate in another, resulting in inefficiencies and additional costs.

Through MiCA, the European Union aims to unify the regulatory landscape for digital assets by establishing a single, coherent set of rules applicable to all 27 EU Member States. This means that crypto businesses – ranging from exchanges and wallet providers to issuers of tokens – can operate under a single licence recognised across the entire EU. This ‘passporting’ concept, which has long been used in traditional financial services, will create an integrated market in which innovation can flourish within a framework of transparency, trust and consumer protection.

The introduction of MiCA also reflects the growing maturity of the crypto industry itself. What began as a decentralised and largely unregulated ecosystem has evolved into a structured market involving institutional investors, publicly traded companies and governments. Consequently, the European Union recognised the need to move beyond temporary national licensing regimes and establish a framework that would ensure market integrity and investor confidence.

Beyond its regulatory function, MiCA carries symbolic weight: it positions the European Union as a global leader in digital finance governance. While other regions, such as the United States, Asia and the Middle East, are still navigating fragmented approaches to crypto regulation, the EU’s proactive and comprehensive stance signals its readiness for the future of finance. It shows that innovation and regulation can coexist when balanced by a thoughtful, principle-based approach.

The introduction of MiCA has far-reaching implications. For crypto businesses, it provides a predictable legal environment in which compliance grants access to the entire European market. For investors, it ensures greater transparency and security, reducing the risk of fraud and market abuse. For regulators, it offers a standardised framework that strengthens oversight while enabling technological progress.

Ultimately, the adoption of MiCA marks the beginning of a new era for digital assets in Europe, one that is characterised by legal certainty, investor protection and a unified financial ecosystem that fosters sustainable growth and innovation.

So, what is MiCA (Markets in Crypto-Assets Regulation)?

MiCA (the Markets in Crypto-Assets Regulation) is the European Union’s comprehensive legislative framework designed to regulate the issuance, trading and custody of crypto-assets across all EU member states. Adopted officially in 2023, MiCA is the result of several years of consultation and negotiation between European policymakers, regulators and industry stakeholders, who aimed to create a balanced approach that would promote innovation while ensuring financial stability and consumer protection.

At its core, MiCA forms part of the European Union’s wider Digital Finance Package, a legislative initiative that aims to modernise Europe’s financial system and adapt it to the realities of a digital economy. The regulation establishes clear definitions for various categories of crypto-assets, sets out obligations for issuers and service providers, and introduces a harmonised licensing regime applicable throughout the European Economic Area (EEA).

MiCA divides the crypto market into several key categories of assets and participants, each with its own regulatory treatment. These include:

• Asset-referenced tokens (ARTs), which are cryptocurrencies pegged to a basket of assets, such as commodities, fiat currencies or other crypto-assets
• E-money tokens (EMTs), which are primarily backed by a single official currency and function similarly to stablecoins
• Utility tokens, which provide access to a specific application or service within a blockchain ecosystem

MiCA also introduces a licensing regime for crypto-asset service providers (CASPs), which covers exchanges, custodial wallet providers, brokers, portfolio managers and other intermediaries operating in the digital asset space. The regulation also defines crypto-asset service providers (CASPs), a broad category encompassing exchanges, custodial wallet providers, brokers, portfolio managers, and other intermediaries operating in the digital asset space.

Each of these categories is subject to distinct licensing, disclosure and compliance obligations. Issuers of ARTs and EMTs must publish a detailed white paper, obtain prior authorisation from their national competent authority and maintain adequate reserves to guarantee stability and protect token holders. While utility token issuers are subject to lighter requirements, they must still ensure transparency and fair communication to prevent misleading investors. CASPs, on the other hand, must secure authorisation before offering services such as trading, exchange, custody or portfolio management of crypto-assets. This ensures that all market participants operate under the same high standards of integrity and accountability.

One of MiCA’s most transformative elements is its passporting mechanism, which enables companies authorised in one EU Member State to operate freely throughout the EU without requiring additional licences in other jurisdictions. This approach mirrors the structure of existing financial frameworks, such as the Markets in Financial Instruments Directive (MiFID II), thereby creating consistency between traditional and digital finance. For crypto businesses, this means that, once they have achieved compliance with MiCA, they can scale their operations across Europe under a single regulatory umbrella-a major advantage compared to the fragmented systems that existed previously.

The regulation also places a strong emphasis on consumer protection. MiCA introduces strict rules on information disclosure, operational security and the management of client assets, ensuring that users of crypto services are adequately informed and safeguarded against risks such as market abuse or loss of funds. Service providers must maintain sufficient capital, implement robust governance and risk management systems, and comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations in line with existing EU directives.

Another critical aspect of MiCA is its focus on market integrity and transparency. The regulation aims to prevent manipulation, insider trading and other forms of misconduct that have historically plagued the crypto market. By aligning these rules with those governing traditional financial instruments, the EU ensures that digital assets are treated with the same seriousness and oversight.

MiCA’s implementation timeline is carefully structured to allow both regulators and businesses to adapt. While certain provisions came into force in mid-2024, the complete framework is expected to be fully operational by 2025, marking the beginning of a unified era for crypto regulation across Europe. During this transitional period, Member States are working to align their national laws and regulatory authorities to ensure consistent enforcement and interpretation.

Ultimately, MiCA is more than just a piece of legislation – it is a strategic foundation for the future of digital finance in Europe. By providing clarity and consistency, MiCA empowers businesses to innovate responsibly, attracts institutional participation and strengthens Europe’s position as a global hub for regulated digital asset activity. In doing so, it bridges the gap between innovation and regulation, establishing a model that other jurisdictions around the world are already studying and seeking to emulate.

MiCA licensing for CASPs

At the heart of the MiCA framework lies the concept of authorisation for crypto-asset service providers (CASPs) – the entities responsible for offering a wide range of services involving digital assets, from exchange operations and custody solutions to advisory and portfolio management activities. The introduction of this licensing requirement marks a turning point in the European crypto industry, transforming what was once a largely unregulated environment into a structured, transparent and credible market operating under clear, uniform standards.

Under MiCA, any company wishing to provide crypto-related services within the European Union must obtain authorisation from a national competent authority (NCA), such as the Bank of Lithuania, BaFin in Germany, the AMF in France or the MFSA in Malta. Once this authorisation is granted, the company can operate throughout the EU and EEA via passporting rights without needing additional licences in other member states. This framework aligns crypto-assets with traditional financial services regulation, providing a familiar structure for regulators and institutional participants.

The MiCA licensing process is comprehensive and is designed to ensure that only entities with robust operational, financial and compliance foundations can enter the market. To apply, a CASP must prepare a detailed set of documentation outlining its business model, internal governance, risk management framework, and security controls. The application must also include information about the company’s management team, beneficial owners, and the measures in place to comply with anti-money laundering (AML) and counter-terrorism financing (CTF) obligations. Regulators place particular emphasis on the integrity, competence and experience of the management body, as they are ultimately responsible for ensuring ongoing compliance and ethical conduct.

A key element of MiCA licensing is the capital adequacy requirement. Depending on the nature and scale of the services provided, CASPs must maintain a certain level of initial capital to ensure they have the financial resilience to fulfil their obligations to clients and withstand potential market shocks. These capital thresholds vary by service type – for instance, custodial services and trading platforms usually require higher levels of capital than advisory services do. This approach protects consumers and contributes to the stability and reliability of the digital asset market.

In addition to financial soundness, MiCA imposes rigorous requirements regarding operational security and governance. Service providers must implement robust policies to protect users’ assets and data, including technical safeguards such as encryption and the secure storage of private keys, as well as mechanisms to prevent unauthorised access to or misuse of funds. They must also establish clear procedures for handling conflicts of interest, ensuring that client interests always take precedence over the company’s own.

Transparency is another cornerstone of the MiCA licensing process. CASPs must disclose detailed information about their services, fees and operational procedures. Clients must be fully informed about the risks associated with digital assets before engaging in any transactions. This obligation reflects the EU’s broader commitment to consumer protection and fair market practices. Furthermore, providers must maintain detailed records of all transactions to ensure full traceability and enable effective monitoring by regulators.

Even after being authorised, CASPs are not exempt from oversight; they must comply with ongoing supervision and reporting obligations. Regulators will continue to assess whether licensed entities adhere to MiCA’s principles, maintain adequate capital and operate transparently. Non-compliance may result in sanctions, the suspension of activities or even licence revocation. This system of continuous supervision ensures that the high standards set during the authorisation phase are maintained throughout the business’s lifetime.

The benefits of obtaining a MiCA licence are considerable. Authorised CASPs can operate across all EU Member States under a single legal framework, which enhances scalability and efficiency. This harmonised approach eliminates the need for separate national authorisations, reducing administrative and financial burdens. Furthermore, licensed providers gain significant credibility with investors, banking partners and clients as authorisation under MiCA signals adherence to one of the world’s most stringent and respected regulatory standards.

In addition to fostering market confidence, the MiCA licensing regime is expected to encourage greater institutional participation in the digital asset ecosystem. Traditional financial institutions, which have often been reluctant to engage with the crypto sector due to regulatory uncertainty, can now partner with or invest in licensed CASPs safe in the knowledge that these entities operate under recognised and enforceable rules.

In essence, MiCA licensing is a foundation for trust in Europe’s digital finance landscape, not merely a formality. It ensures that innovation proceeds within a framework of accountability and professionalism, allowing legitimate projects to flourish while deterring unregulated or high-risk actors. By standardising the rules for authorisation, the European Union has paved the way for a more transparent, resilient and integrated market, in which technology and compliance work together to shape the future of finance.

Country-by-country comparison within the EU

While MiCA introduces a single, harmonised framework for all EU Member States, the practical implementation and experience of obtaining authorisation can vary considerably from one jurisdiction to another. Each country retains its own national competent authority (NCA) responsible for enforcing the regulation, and these authorities differ in their internal procedures, timelines, communication efficiency and interpretation of certain provisions. For crypto businesses seeking a MiCA licence, it is crucial to understand these differences in order to select the most suitable jurisdiction.

Over the past few years, several European countries have established themselves as leading hubs for digital assets, attracting blockchain and fintech companies from around the world. Lithuania, for instance, has established itself as one of the most crypto-friendly jurisdictions in the EU. Its regulator, the Bank of Lithuania, has developed streamlined procedures and a practical approach towards financial innovation. Lithuania’s experience with electronic money institutions (EMIs) and virtual asset service providers (VASPs) has given it a head start in interpreting and implementing MiCA’s requirements. The country offers many startups a combination of efficiency, relatively low operational costs and an open regulatory dialogue, making it one of the preferred choices for obtaining MiCA authorisation.

In contrast, Germany represents a more conservative but equally significant market. Supervised by the Federal Financial Supervisory Authority (BaFin), Germany’s regulatory environment is renowned for its rigorous standards, comprehensive compliance requirements, and meticulous applicant scrutiny. Companies applying in Germany must demonstrate robust governance structures, substantial capital and a well-documented risk management framework. While this process can be time-consuming and resource-intensive, German authorisation carries substantial prestige and credibility, particularly among institutional investors and banking partners. Businesses seeking to access larger or more traditional financial markets often view Germany as a strategic jurisdiction, despite the higher regulatory threshold.

France, under the supervision of the Autorité des Marchés Financiers (AMF), developed one of the most comprehensive national regimes for digital assets prior to the adoption of MiCA. The French Digital Asset Service Provider (DASP) licence provides a clear structure for market participants and is now being transitioned into the MiCA framework. The AMF is renowned for its professionalism and consistency, although its licensing process tends to involve meticulous documentation and lengthy review periods. Nevertheless, France’s large domestic market and strong investor base make it an attractive destination for companies looking to establish a long-term presence in Europe.

Estonia has historically been one of the first countries to regulate cryptocurrencies, but it has become more cautious in recent years. Following an initial surge in VASP registrations, the Estonian Financial Intelligence Unit (FIU) introduced stricter AML requirements and a more selective licensing approach. While this increased regulatory rigour reduced the number of active licences, it strengthened Estonia’s international reputation for transparency and compliance. Under MiCA, Estonia is expected to maintain this balance, offering opportunities for serious projects that can meet its high standards, while discouraging those that are less prepared or underfunded.

Malta, often referred to as the ‘Blockchain Island’, remains a jurisdiction with deep expertise in crypto legislation. The Malta Financial Services Authority (MFSA) has been operating under the Virtual Financial Assets (VFA) Act since 2018, the principles of which already mirror many of those set out in MiCA. This early adoption gives Malta a unique advantage in terms of experience and regulatory know-how. However, the Maltese licensing process is generally more time-consuming due to its detailed due diligence and comprehensive documentation requirements. Despite the longer approval period, companies seeking strong reputational benefits and a regulator with proven familiarity in digital assets often find Malta a suitable choice.

Other jurisdictions, such as Spain, Portugal and the Netherlands, are gradually enhancing their regulatory frameworks and building internal expertise to align with MiCA. Spain’s Banco de España and the Comisión Nacional del Mercado de Valores (CNMV) have recently become more open to digital assets, with the aim of positioning the country as a bridge between the European and Latin American crypto markets.

Even before MiCA came into force, the FMA had taken an active stance on cryptocurrencies. Since 1 October 2019, it has been possible to apply for registration as a virtual-asset service provider (VASP), and from 10 January 2020, VASP registration and AML supervision by the FMA has been mandatory under Austria’s AML framework (FM-GwG). This five-year period familiarised the market with fit-and-proper tests, governance and AML controls, positioning the FMA to act swiftly once MiCA was introduced.

Where is the FMA today on MiCA? The FMA has published a dedicated MiCA hub with plain English pages for applicants, including a CASP roadmap, ‘Information for CASP applicants’, and notes on ‘Specific aspects of crypto-asset services’. In these documents, the FMA explains what it will look for in an authorisation file and how it will coordinate notifications for entities already supervised in other sectors. This guidance reflects a practical, process-driven approach and encourages applicants to prepare early, given that national supplementary rules and technical standards are being introduced.

MiCA requirements in Austria (what your file needs to show). To obtain a CASP authorisation from the FMA, applicants must demonstrate the following:

• A clear business model and programme of operations
• Robust governance and fit-and-proper management
• Capital and own funds appropriate to the services
• Safeguarding of client crypto-assets and funds
• IT and operational resilience (including key management and security)
• Conflicts of interest and outsourcing controls
• Transparent disclosures and complaints handling
• Full AML/CTF compliance aligned with Austria’s FM-GwG

These expectations align with MiCA Articles 59–73 and are reiterated in the FMA’s applicant guidance and CASP roadmap.

State fees and cost mechanics. Austria applies two layers of public fees: (i) procedure fees payable for conducting the authorisation (irrespective of the outcome), under the Gebührengesetz (GebG); and
(ii) supervisory fees, charged if authorisation is granted, under the FMA-Gebührenverordnung (FMA-GebV). The FMA notes that the normative setting of specific MiCA fee items under the FMA-GebV is proceeding in parallel with national supplementary MiCA legislation. Applicants should therefore budget for GebG fees at the application stage and for FMA-GebV items once licensed. (Exact euro amounts are specified in the fee regulations as they are updated.)

How the last five years have shaped expectations. From 2020 to 2024, Austria operated a comprehensive VASP registration regime centred on AML and governance, resulting in a smaller yet higher-quality group of providers. This experience is now feeding directly into MiCA: the FMA is comfortable with assessing crypto custody, exchange and brokerage setups, and it is aligning its practices with ESMA convergence tools (e.g. market abuse surveillance guidance for crypto). For applicants, this translates into thorough file reviews and clear expectations rather than mere compliance.

Practical takeaways for applicants: Expect a methodical review, early questions on senior management competence and key function holders, and detailed scrutiny of IT security and safeguarding arrangements. Build your file to MiCA standards, but follow the FMA’s roadmap structure to avoid omissions. Align your AML controls with FM-GwG practice, and budget for GebG/FMA-GebV fees, as well as advisory and build-out costs. Firms that meet institutional-grade expectations generally find that Austria is a credible and predictable venue for EU-wide passporting under MiCA.

Belgium: Regulatory designation is pending (expected to be the Financial Services and Markets Authority – FSMA).
Belgium has been an active, consumer-protection-oriented jurisdiction for crypto. Day-to-day supervision of the sector is carried out by the FSMA, which has run a national registration regime for virtual asset service providers (VASPs) since 1 May 2022 under the ‘Virtual Currency’ Royal Decree. This regime applies to exchange and custodian wallet providers based in Belgium, and it imposes operating and AML/CTF conditions. It also prohibits non-EEA providers from offering these services in Belgium without proper establishment or registration.

Under MiCA, each Member State must designate a national competent authority (NCA). As of 22 July 2025, ESMA’s official list still shows that Belgium’s NCA is “TBA” (to be announced). In practice, market guidance and supervision continue to come from the FSMA while the formal MiCA designation is finalised.

This is how Belgium’s approach has evolved over the last five years.
From 2020 onwards, Belgium has moved quickly to address AML and conduct risks around retail crypto. First, the FSMA anchored AML/CTF expectations for VASPs in the 2020 law implementing 5AMLD, and then introduced mandatory VASP registration in May 2022, along with prudential-style organisational and governance conditions. In 2023, Belgium became one of the first EU states to impose binding rules on the advertising of virtual currencies to consumers. These rules require fair and balanced messaging and standard risk warnings such as ‘Virtual currencies, real risks. The only guarantee in crypto is risk’, as well as pre-notification of mass campaigns to the FSMA. This trajectory demonstrates a consistent risk-based approach: embracing innovation while maintaining robust safeguards for retail users.

MiCA requirements in Belgium (how to prepare).
Even before the formal NCA designation, Belgium has aligned with EU-level MiCA files and ESMA materials. A Belgian VASP application under MiCA will need to demonstrate the core EU-wide conditions, which include: a clear programme of operations; fit-and-proper leadership and governance; own funds appropriate to the services provided; safeguarding of clients’ crypto-assets and fiat currencies; robust ICT and operational resilience (e.g. key management, segregation and incident response); controls relating to conflicts of interest and outsourcing; disclosure and complaints handling; and full AML/CTF compliance. ESMA’s MiCA pages and 2025 guidelines (e.g. those relating to staff knowledge and competence) provide an indication of the supervisory direction that Belgian applicants can expect to follow. Until MiCA authorisation is in place, firms operating in Belgium must also comply with FSMA’s advertising rules for consumer marketing.

State fees: what we know now vs. under MiCA.
For current (pre-MiCA) Belgian VASP registration, public sources indicate a one-off fee of €8,000 per registration (€16,000 for both exchange and custody). This fee covers the FSMA’s review of the application. Ongoing supervisory levies may also apply under the FSMA’s general fee schedules. Specific MiCA authorisation fees for Belgium have not yet been published alongside the formal NCA designation. Expect a MiCA-specific tariff to be confirmed in the implementing measures once the authority is officially appointed.

Transitional regime and timing.
MiCA’s staged rollout gives CASPs operating under existing national regimes a grandfathering window. Belgium follows the EU rule in Article 143(3): entities that were lawfully active before 30 December 2024 can use the transitional period (until mid-2026 at the latest, depending on national choices). However, they must still comply with the conduct rules specific to Belgium, such as the FSMA advertising regulations, if they are marketing to Belgian consumers during the transition.

Practical overview – what this means for applicants.
Belgium offers a credible path into the EU market with a focus on retail safeguards. Strengths include clear consumer protection guidance and a supervisor with hands-on experience from the 2022–2025 VASP era. Points to plan for are: (i) marketing controls and pre-notification for large campaigns, (ii) strict AML/CTF compliance, and (iii) an imminent formal MiCA NCA designation that will clarify the exact authorisation process and fee structure. Firms that are well-prepared and already meet MiCA-level governance and ICT standards should find Belgium a predictable venue once the designation is finalised. Those with retail-heavy strategies must be ready to comply with the advertising rulebook from day one.

Bulgaria: Regulatory designation pending (expected to fall under the Financial Supervision Commission – FSC).

Bulgaria has split responsibilities, which have been formally confirmed in ESMA’s register of designated authorities. The FSC is the default MiCA supervisor for CASPs and most issuers, while the BNB takes the prudential lead where MiCA assigns powers over electronic money tokens (EMTs). In practice, applicants deal with the FSC for CASP authorisations and with the BNB for EMT issuance by credit/e-money institutions. ESMA

This is how Bulgaria’s approach has evolved over the last five years.
Prior to the introduction of MiCA, Bulgaria operated an AML-driven registration system whereby exchanges and custodian wallet providers were required to register with the National Revenue Agency (NRA) under the Money Laundering and Terrorist Financing Prevention Act (MAMLA). The register was launched in 2020 with a firm onboarding deadline and remained the operative gatekeeper through successive AML updates in 2023. As MiCA came into force across the EU, Bulgaria enacted domestic legislation in the form of the Crypto-Asset Markets Act (often shortened to CAMA or the ‘BG MiCA Act’), which came into force on 8 July 2025. This shift moved the sector from NRA registration to full licensing by the FSC (with the BNB responsible for EMTs). This marks a clear shift from AML registration to a more prudential authorisation process, guided by ESMA-level convergence tools.

This is where MiCA stands today, with transitional rules and timing.
With the BG MiCA Act in force, Bulgaria has opened CASP licensing and aligned its timelines with those of MiCA. Entities that were duly registered in the NRA register before 30 December 2024 may continue to operate only in Bulgaria during the transition period, which ends on 1 July 2026 or when their CASP licence is granted or refused, whichever is sooner. Entities entered in the NRA register between 30 December 2024 and 8 July 2025 must file a CASP licence application by 8 October 2025. Any pending NRA registrations not completed by 8 July 2025 will be terminated and must be refiled as MiCA licence applications to the FSC.

This is what a Bulgarian MiCA (CASP) file needs to show:
Substantively, the FSC expects the full MiCA suite, including an articulated programme of operations and business model, fit-and-proper management and qualifying-holder assessments, own funds commensurate with services, safeguarding of client assets and funds, ICT and operational resilience (including key management, incident response and continuity), outsourcing and conflicts-of-interest control, and disclosure and complaint-handling processes, as well as alignment with national law on AML/CTF. According to local commentary, the law imposes specific competency and probity standards for board members and controllers of CASPs and keeps EMT issuers under the BNB’s licensing perimeter (as credit or e-money institutions).

Fees – what has been officially published and how to budget.
Following the BG MiCA Act, Bulgaria adopted fee rules for FSC activities. Authoritative practice guides report a two-part model: (i) fixed charges by service type, and (ii) a small variable levy on annual income. For example, public guidance illustrates a variable fee of 0.03% of total annual income, plus fixed charges such as approximately BGN 12,000 (≈ EUR 6,135) for operating a crypto-asset trading platform, BGN 3,200 (≈ EUR 1,636) for exchange services, BGN 1,000 (≈ EUR 511) for executing client orders, and BGN 800 (≈ EUR 409) for custody. There are also scaled amounts for advisory services, portfolio management, transfers and placements. Separate legal analyses of the new Act also describe class-based application fees for CASP licences (e.g. BGN 5,000/10,000/30,000 for Classes 1/2/3), as well as a BGN 25,000 fee for authorisation of a public offering/admission of asset-referenced tokens. Market summaries caution that some figures may differ across sources, while by-laws are finalised. In other words, budget for the one-off licence fee, service-specific fixed costs and a modest annual percentage levy, and confirm the exact tariff with the current Financial Supervision Commission (FSC) ordinance when you file.

This is the practical experience you should expect.
Bulgaria has transitioned from a relatively accessible AML registration environment to a structured MiCA authorisation regime within a short timeframe, and the authorities have explicitly stated that applications can be submitted and processed, even while certain by-laws are still being finalised. Prepare for a submission involving a large amount of documentation and an iterative Q&A process with the FSC. Also expect questions related to EMT to be directed to the BNB where relevant, and anticipate that the supervisor will rely on ESMA’s supervisory briefings (e.g. reverse solicitation monitoring and knowledge/competence) to ensure that local practices remain in line with those of EU peers. For firms that held NRA registrations, the transition window is valuable, but it does not allow for passporting – only a granted MiCA CASP licence from the FSC unlocks EU-wide access.

Bottom line:
Bulgaria now offers a clear, EU-harmonised path under MiCA, with a defined split between market supervision (FSC) and EMT prudential oversight (BNB). The country’s five-year journey – from NRA AML registration to full MiCA licensing – means that supervisors have a substantial dataset on local providers and an AML-first approach, resulting in rigorous governance, controller and ICT scrutiny. Fees are transparent and comparatively moderate by EU standards, and there are statutory timelines in force. Well-prepared dossiers should find Bulgaria to be a workable and predictable venue for CASP authorisation with EU passporting upon grant.

Croatia: The authority is not yet officially listed by ESMA, but it is expected to be the Croatian Financial Services Supervisory Agency (HANFA).

Croatia’s MiCA supervisor is HANFA, which has day-to-day oversight of crypto-asset service providers (CASPs). HANFA has treated crypto as a supervised financial activity for several years, advising the public to use only HANFA-authorised firms and maintaining registers for firms active under Croatian law. The agency has also aligned itself with ESMA guidance on classifying crypto-assets and on MiCA supervision, signalling a mainstream, investor-protection-first approach.

The last five years at a glance.
From 2020 onwards, Croatia operated an AML-centric regime whereby virtual-asset service providers had to register with HANFA under national AML rules (Articles 9.a and 9.b of the AML framework), and HANFA published lists of registered providers. International assessments in 2023–24 noted that Croatia had set up a VASP register and applied FATF-style controls. This AML backbone is the platform that Croatia is now using to transition to full MiCA authorisation.

Where MiCA stands today: transition and timing.
Croatia has opted for the full EU transitional period: firms that were active prior to 30 December 2024 can continue operating under national legislation until 1 July 2026, or until the outcome of their MiCA application is known, whichever is sooner. HANFA has echoed ESMA’s advice to start preparing early, and industry trackers and legal analyses also cite Croatia’s 18-month transition period for HANFA-registered VASPs. In practice, this means that existing firms can continue operating while transitioning to the MiCA standard, whereas new entrants must comply with MiCA requirements from the outset.

This is what a Croatian MiCA (CASP) file needs to show:
Applications must adhere to the EU-level MiCA core requirements, which include providing a clear programme of operations and business model, ensuring fit-and-proper senior management and qualifying holders, holding sufficient own funds for the intended services, implementing robust safeguarding measures for client assets and fiat, demonstrating ICT and operational resilience (including key management, incident response, continuity and cyber security), establishing controls for outsourcing and conflicts of interest, ensuring customer disclosures and complaints handling, and achieving full AML/CTF alignment. HANFA’s public notices make it clear that prior approval is required to provide crypto services from Croatia, and that authorised firms are listed in its registers. ESMA’s MiCA guidelines (e.g. knowledge and competence, reverse solicitation and transfers) provide the framework for how HANFA converges supervision with that of other EU NCAs.

State fees and budget considerations.
Under the pre-MiCA AML registration, reputable guides noted that no administrative state fee was payable to HANFA (timelines varied widely). Under MiCA, Croatia is moving to a classic authorisation and supervision levy model. The detailed CASP fee grid is being embedded in HANFA’s tariff and ordinances alongside other sectoral fees. As HANFA’s published fee pages currently focus on legacy sectors such as funds and AIFs, applicants should budget for a one-off authorisation fee upon filing and ongoing supervisory levies, and verify the exact figures against the current HANFA tariff at the time of submission.

Market realities and practical takeaways.
Croatia is welcoming but meticulous. Expect HANFA to test the expertise of senior management (fit and proper), probe IT/security and safeguarding in depth, and ask for documentary evidence of end-to-end AML controls. The transitional regime favours incumbents who were registered with HANFA before 30 December 2024, but it does not grant passporting; only a granted MiCA CASP authorisation unlocks EU-wide access. Marketing to Croatian consumers should be conservative and fully risk-balanced, in line with ESMA’s tone of consumer protection. For well-prepared firms, Croatia offers a predictable path from an established AML register to a MiCA licence with a supervisor already engaged in ESMA convergence topics.

Cyprus: The Cyprus Securities and Exchange Commission (CySEC) is a long-established financial regulator that oversees investment and crypto-related firms.

Cyprus’ competent authority for MiCA is CySEC. ESMA’s official register of national competent authorities names CySEC as the home supervisor for CASPs in Cyprus. However, prudential oversight for payment/e-money matters remains with the Central Bank of Cyprus, as is the case with other EU regimes. This reflects the long-standing split in Cyprus between market conduct and prudential supervision, giving CASPs a clear, single point of contact for MiCA authorisation and ongoing supervision.

Over the past five years, Cyprus has transitioned from an AML-based registration system to a comprehensive EU licensing framework. In June 2021, CySEC issued its Directive on the Register of Crypto-Asset Service Providers (RAA 269/2021), launching a domestic register and setting out the content of applications, fit-and-proper tests, operational prerequisites and review timelines. This register, which is run under Cyprus’ AML Law, created a supervised cohort and forced early investment in governance and controls. As a result, when MiCA arrived, Cyprus already had files, on-site experience and remediation practice specific to crypto intermediaries.

With MiCA now in effect for CASP authorisations, CySEC has transitioned to the EU rulebook while ensuring continuity. It opened a preliminary application phase at the end of 2024, and then rolled out the MiCA process as the regulation became fully applicable on 30 December 2024. CySEC recognised the EU transitional window for incumbents: firms that were lawfully active under national rules before the cut-off date may continue operating during the transition period until 1 July 2026, or until their MiCA application is granted or refused. CySEC has also asked transitional firms to provide evidence of pre-cutoff compliance and submit structured documentation in advance, in line with ESMA’s convergence materials.

The information that CySEC expects to see in a MiCA application reflects the core of the regulation: a coherent programme of operations; fit and proper management and qualifying holders; own funds calibrated to the services; robust safeguarding of client crypto and fiat, including wallet key management and reconciliations; ICT and operational resilience with incident response; outsourcing and conflicts of interest governance; clear customer disclosures and complaints handling; and AML/CTF alignment with Cyprus law. CySEC’s public circulars during 2024–25 also emphasise staff knowledge and competence, sanctions-screening systems, and data quality in regulatory returns, which are useful signposts for how files will be reviewed in practice.

Fees have evolved as the regime has shifted from AML registration to MiCA licensing. Under the old CASP register, multiple practitioner summaries recorded a non-refundable examination fee upon filing and a €5,000 annual renewal fee after registration. Under MiCA, reputable Cypriot guidance now sets out a new authorisation tariff administered by CySEC. This includes a flat, non-refundable application fee of €8,000 per proposed service, as well as separate annual supervisory and notification/modification fees. As the MiCA tariff is granular and tied to services, applicants must carefully map their business model – an exchange and a custody service, for example, would incur two application fees – and budget for ongoing levies once authorised.

For applicants, the practical experience in Cyprus is methodical but predictable. CySEC has several years of crypto-specific supervision experience and will assess governance, key personnel competence, and ICT resilience early in the Q&A process. While transitional incumbents benefit from operational continuity, they should not mistake the window for passporting – only a granted MiCA CASP authorisation unlocks EU-wide access. New entrants who arrive with MiCA-level policies, clear safeguarding architecture, and evidence of effective sanctions screening and AML controls will generally find that Cyprus is a cooperative venue with clear lines of communication and a transparent fee model aligned to the scope of services.

Czech Republic: The Czech National Bank (ČNB) will handle MiCA authorisations and supervision.

The Czech Republic has positioned the CNB as the central supervisory anchor for MiCA. In CNB materials and government communications via the Financial Analytical Office, the message is consistent: The CNB is the national competent authority that will license and supervise crypto-asset service providers (CASPs) under MiCA. MiCA-related drafts and guidance are channelled through the CNB and the European supervisors (ESMA/EBA). This consolidates crypto oversight alongside the rest of the Czech financial market, giving applicants a single supervisory home for authorisation and ongoing supervision.

Over the past five years, the Czech approach has evolved from a trade licence plus AML model into a full EU licensing regime. Prior to MiCA, crypto exchange and custody activities were conducted under the Trade Licensing Act, with anti-money laundering obligations enforced by the Financial Analytical Office. In that era, the CNB was not the day-to-day gatekeeper for VASPs. MiCA reverses this: the lighter registration/notification model gives way to a prudential-style authorisation process at the CNB, with EU-level technical standards and Czech implementing rules. The CNB has begun publishing a ‘MiCA landing zone’, which includes links to ESMA/EBA texts, interpretative documents and Q&As, signalling the shift from national AML registration to EU-harmonised licensing and supervision.

Transitional arrangements are now in place and have strict time limits. Under the implementation of the Czech Digital Finance Act, firms that were legitimately operating before 30 December 2024 can only continue temporarily if they submit a MiCA application to the CNB before the national deadline. Public legal summaries and industry notes emphasise the requirement to submit an application by 31 July 2025 in order to benefit from continuity until a decision is taken. The absolute EU cut-off date is 1 July 2026, when transitional regimes will end across the bloc. ESMA’s published list of Member State ‘grandfathering’ decisions confirms the Czech dates. In practice, incumbents who file by the deadline can continue operating under national law while the CNB processes their MiCA application, whereas new entrants must follow the full MiCA process from day one.

The CNB’s expectations for a MiCA CASP file are in line with the EU rulebook and the convergence tools that ESMA and EBA are implementing. Your dossier must set out a clear programme of operations and business model, demonstrate fit-and-proper management and qualifying holders, show that you have own funds appropriate to the services you will provide and provide evidence of robust safeguarding of client crypto-assets and fiat (including key management, reconciliations and segregation). The CNB will also look for ICT and operational resilience, including incident response and continuity, as well as outsourcing and conflicts of interest governance, customer disclosures and complaint handling, and full AML/CTF alignment under Czech law. The CNB’s MiCA pages direct applicants to the ESMA/EBA guidelines and Q&As, which will influence day-to-day supervisory expectations during reviews and follow-up questions.

Regarding fees, the Czech framework is formal but still evolving for MiCA-specific items. The CNB maintains an official Schedule of Charges for its financial market services and publishes regulatory fees in sectoral contexts. However, a dedicated MiCA tariff is being developed as part of the ongoing implementation process. It is prudent to assume that applicants will face a non-refundable authorisation fee upon filing, followed by ongoing supervisory charges, in line with CNB practice in other sectors. The exact MiCA line items should be confirmed against the current CNB schedule at the time of submission. Do not base your budget on unrelated licences (e.g. historic securities dealer fees) and check the live CNB fee pages when you are ready to file.

In practice, the Czech Republic offers a measured and predictable route to the EU market once your governance, competence, safeguarding and ICT controls genuinely meet MiCA standards. CNB’s approach is methodical, so expect early scrutiny of senior management expertise and key function holders, detailed questioning on IT security and custody architecture, and attention to AML hygiene and sanctions screening. This reflects the AML-first legacy and the new EU-level standards. If you are an incumbent, bear in mind the 31 July 2025 filing deadline to ensure continuity of operations during the transition. If you are a new entrant, ensure you have comprehensive policies, operational playbooks that have been tested, and sufficient capital to support your service offering.

Denmark: Finanstilsynet (the Danish Financial Supervisory Authority) is responsible for enforcing MiCA standards and monitoring CASPs.

Finanstilsynet is Denmark’s national competent authority for MiCA. According to ESMA’s official register, Denmark is applying the full 18-month grandfathering window under Article 143(3) of MiCA. However, there is a Denmark-specific condition: to benefit from this transition, a CASP must have filed its MiCA application by 30 December 2024. After this date, firms will need to hold a MiCA authorisation if they wish to continue operating beyond the EU-wide end date of 1 July 2026. This combination of maximum duration and early filing captures Denmark’s general stance: open to an orderly transition, but firm on timetables and documentation discipline.

Over the past five years, Denmark has run a registration and AML regime for crypto providers while MiCA was being finalised at the EU level. Under the Danish Anti-Money Laundering Act, businesses offering the exchange, transfer, issuance or custody of virtual currencies were required to register with Finanstilsynet (the Danish Financial Supervisory Authority) and implement full AML/CTF controls. The FSA’s published guidance and local practitioner notes set out that VASP (virtual asset service provider) registration, risk assessments, customer due diligence and ongoing monitoring applied broadly and were enforced in practice. Meanwhile, the Danish National Bank highlighted systemic safeguards relevant to MiCA, most notably that national central banks can restrict the issuance of certain tokens (e.g. a krone-referencing ART) under MiCA if they threaten payment security or monetary policy transmission, signalling Denmark’s prudential sensitivity to stablecoin-like instruments.

As MiCA moved from text to implementation, Denmark aligned with ESMA’s convergence work and began processing full CASP authorisations. A notable milestone was the public announcement by Danish fintech company Lunar that it had received a MiCA CASP licence, replacing its prior national registration and unlocking EU passporting. This is evidence that the authorisation machinery of Finanstilsynet is active and producing decisions. The public report highlights how Denmark is transitioning established players from the AML registration category to the EU licence category.

The information required for a Danish MiCA file mirrors that set out in the Regulation and ESMA materials referred to by Finanstilsynet: a coherent programme of operations and business plan; fit-and-proper management and qualifying holders; own funds calibrated to the services offered; rigorous safeguarding of client crypto-assets and funds (segregation, key management and reconciliations); ICT and operational resilience, including incident response and continuity; governance of outsourcing and conflicts of interest; transparent disclosures and complaint handling; and full alignment with Danish AML/CTF legislation. ESMA’s MiCA hub establishes the common supervisory baseline that Denmark will follow during the transitional phase and beyond.

Regarding fees, Denmark has long operated with published FSA fee schedules across sectors, but a MiCA-specific tariff is being introduced as national measures align with the EU framework. In practice, applicants should budget for a non-refundable authorisation fee upon filing, as well as ongoing supervisory levies once licensed. This is consistent with Finanstilsynet’s approach in other regimes. The exact MiCA line items should be confirmed against the current DFSA fee pages at the time of submission, as the generic fund/UCITS fee pages are not indicative of CASPs.

The practical experience in Denmark is methodical and timetable-driven. Incumbents active under national law could continue during the 18-month window only if they submitted a complete MiCA application by 30 December 2024. Newcomers must be MiCA-ready from day one. Be prepared for early and detailed questions on senior management competence, IT security, custody architecture and AML compliance, reflecting the country’s AML-first history and the central bank’s sensitivity to token risks. Well-prepared firms can look forward to a predictable path to an EU passport from a highly credible supervisor, as demonstrated by the first public MiCA authorisations in Denmark in 2025.

Estonia: The Financial Intelligence Unit (FIU) – Estonia’s dedicated AML authority – continues to supervise crypto-asset service providers under the MiCA framework.

Estonia’s MiCA home supervisor is the Estonian Financial Supervision and Resolution Authority (Finantsinspektsioon, often shortened to FSA). This was hard-wired by the adoption of the Market in Crypto-Assets Act (Krüptovaraturu seadus, or KrüTS), which came into force on 1 July 2024. The act places CASP licensing and supervision with the FSA, while also aligning national law with MiCA. Meanwhile, the FIU/RAB remains visible in the ecosystem because it supervised the pre-MiCA VASP regime and continues to oversee legacy licences during the transition.

The last five years at a glance.
From 2020 to 2022, Estonia had one of Europe’s most active VASP regimes; then, in March 2022, it introduced major AML Act amendments that sharply tightened standards. These changes increased entry requirements, governance expectations, and capital, triggering a wave of exits and consolidations as firms adapted to higher compliance standards. The FIU’s own risk analysis highlighted the reasons why: weak ties between many licensees and Estonia, and elevated ML/TF risks in parts of the sector. By mid-2024, the legal pivot to MiCA/TrÜTS had transferred responsibility for granting new crypto licences to the FSA. The FIU is now focusing on winding down and overseeing the old cohort until the transition ends.

This brings us to where MiCA stands today: who does what and the transition window.
Estonia has formally designated the relevant authorities under MiCA and has implemented the national act. In practice, all new authorisations for crypto-asset services are processed by the FSA under KrüTS and MiCA. FIU-issued VASP licences will only be valid during the EU transition period; after this, only FSA-issued MiCA authorisations will be recognised. Government materials spell this out plainly: FIU licences will be supervised until 30 June 2026 and providers without an FIU licence must follow the MiCA path by 30 December 2024. Across the EU, transitional regimes will end on 1 July 2026.

This is what an Estonian MiCA (CASP) file needs to show.
It mirrors the Regulation and the FSA’s public landing page for crypto licences. Your dossier should present a coherent programme of operations and business plan, demonstrate fit-and-proper leadership and qualifying holders, provide evidence of sufficient own funds for the services offered, and set out robust safeguarding of client crypto and fiat, including key management, segregation, reconciliations, and incident playbooks. You can expect deep scrutiny of ICT and operational resilience (continuity, cyber security and outsourcing oversight), as well as conflicts of interest controls, transparent customer disclosures and complaint handling, and full AML/CTF alignment with Estonian law. The FSA explicitly links the national process to the scope of MiCA, meaning that EU technical standards and ESMA/EBA guidance will influence day-to-day expectations.

State the fees and budget accordingly.
Estonia applies the usual two-step public cost model seen in other FSA regimes: a non-refundable authorisation fee upon application and ongoing supervisory levies once licensed. As MiCA is new to national law, the precise CASP line items are included in the FSA’s current tariff/ordinances and related government fee acts. Applicants should budget for the filing fee plus annual supervision, and check the current schedule at the time of submission (do not assume that legacy FIU/VASP figures apply to MiCA).

Market realities and practical takeaways. Estonia is currently welcoming but exacting.

Latvia: Financial and Capital Markets Commission (FKTK): now part of the Bank of Latvia’s organisational structure and responsible for supervising MiCA.

Latvia has consolidated financial market supervision within the central bank, Latvijas Banka, which has incorporated the former Financial and Capital Market Commission since 2023. Under MiCA, the Bank of Latvia is the national competent authority for authorising and supervising crypto-asset service providers (CASPs), and it runs a detailed public gateway describing the process, documents, and supervisory expectations. The merger with the market regulator and the central bank’s dedicated MiCA pages signal the creation of a single, technically capable point of contact for applicants.

Until MiCA took effect, Latvia relied on anti-money laundering (AML)-anchored oversight and sectoral rules while restructuring supervision. On 1 January 2023, the FCMC was integrated into Latvijas Banka. During 2024, the bank published its crypto-licensing ‘landing zone’, and from 2 January 2025, it began accepting MiCA applications. It also offered free pre-licensing consultations to help firms prepare their applications. This sequence of structural mergers, public rulebooks and live intakes maps a clear trajectory from registration-style oversight to EU-grade licensing under MiCA.

Where MiCA stands today: timelines and scope.
Latvijas Banka’s official guidance confirms that MiCA authorisation requirements will apply from 30 December 2024, and that authorisation from a home Member State will unlock EU passporting once granted. The bank outlines the ten CASP services that require prior authorisation (custody, platform operation, exchange, execution, placement, reception/transmission of orders, advice, portfolio management and transfer services), providing applicants with a precise scoping tool prior to filing.

The bank also provides a detailed overview of what a Latvian MiCA (CASP) file must show.
The bank’s portal mirrors MiCA and the ESAs’ RTS/ITS, and includes the following: a full programme of operations; fit-and-proper management and qualifying holders; own funds of €50,000–€150,000, depending on the services provided (or one quarter of the prior year’s fixed overheads, if higher); robust safeguarding of client crypto and fiat, including key management, segregation, reconciliations, and incident playbooks; hardened ICT/operational resilience; outsourcing and conflicts of interest governance; transparent disclosures and complaint handling; and end-to-end AML/CTF controls under Latvian law. The portal also links directly to the MiCA RTS/ITS application form, enabling firms to build to the EU template from day one. It sets 25 working days for the completeness check and 40 working days for the substantive review after the check is complete (extensions are possible if information is insufficient).

It also provides official figures for state fees and ongoing levies.
Latvijas Banka explicitly sets out the public cost model: an application review fee of €2,500, payable upon filing; then an annual supervisory payment of up to 0.6% of gross income from CASP activities, with a minimum of €3,000 per year. These are published on the authority’s MiCA page and are recalibrated annually within the bank’s supervision-funding framework.

Practical experience and takeaways.
Latvia has quickly become one of the more operationally transparent MiCA venues. The central bank provides a step-by-step pre-application meeting and a pre-licensing form, as well as a clear list of documents, reducing iteration risk and signalling what ‘complete’ means before the statutory clock starts. For applicants, this means they can plan more predictably: map services to the published own-funds grid, demonstrate governance and IT/custody architecture to production standards, and use the free consultation to reduce scope and sequencing risk. Once authorised, passporting across the EU follows the standard MiCA notification process, enabling firms to expand from a Baltic hub to the single market.

In Lithuania, the Bank of Lithuania is the country’s central bank and main supervisory authority. It is well known for its proactive approach towards fintech and crypto regulation.

Lithuania has designated the Bank of Lithuania (Lietuvos bankas) as the national competent authority for MiCA. The central bank runs the authorisation gateway for crypto-asset service providers (CASPs) and clearly states that anyone intending to provide MiCA services in Lithuania must submit a dossier and obtain a licence or approval before commencing activity. This single-door model, overseen by a central bank with a prudent approach to supervision that already regulates EMIs and payment institutions, establishes Lithuania as a clear and technically capable home supervisor for CASPs.

The last five years in brief.
Before MiCA came into force, Lithuania operated an AML-anchored VASP regime based on notification to the Register of Legal Entities and compliance with national AML/CTF legislation, rather than requiring a full financial-market licence. This created a supervised cohort and basic governance expectations while the EU finalised MiCA. International observers (including the IMF) have explicitly recognised Lithuania’s intention to bring VASPs under the supervision of the Bank of Lithuania from the end of 2024, indicating a shift from registration to authorisation.

Where does MiCA stand today in terms of timelines and transition?
Lithuania has introduced MiCA authorisations and has opted for a 12-month grandfathering period for existing firms that were lawfully active before 30 December 2024. In practice, these firms can continue operating domestically during the transition period while their applications are being assessed; however, EU-wide passporting will only begin once a MiCA authorisation has been granted. The Bank of Lithuania has confirmed that the grandfathering period will end in Lithuania on 1 January 2026. New entrants must comply with MiCA from day one.

This is what a Lithuanian MiCA (CASP) file must show.
Substance tracks the Regulation and the central bank’s guidance. Your dossier should set out a coherent programme of operations and business model, demonstrate fit-and-proper management and qualifying holders, show own funds appropriate to the services (MiCA’s baseline tiers of €50k–€150k apply, depending on the services offered) and provide evidence of robust safeguarding of client crypto and fiat (segregation, reconciliations, wallet-key governance and incident response). You can expect close scrutiny of ICT and operational resilience (continuity, cyber security and outsourcing oversight), conflicts of interest controls, transparent disclosures, complaints handling and full AML/CTF alignment under Lithuanian law. The Bank of Lithuania’s CASP page provides practical guidance on structure and expectations.

Fees and public costs model.
Lithuania follows the familiar two-part approach of a non-refundable authorisation/processing cost upon application and ongoing supervisory levies once authorised. The methodology and annual calibration for supervised sectors are set by the Bank of Lithuania. As MiCA fee line items are embedded in evolving national instruments, applicants should confirm the current tariff at the time of submission, rather than relying on historic VASP-era practice or third-party estimates.

Practical experience and takeaways.
Lithuania combines a crypto-savvy ecosystem with a central bank that has extensive experience in supervising EMIs and payment firms. Expect an orderly but exacting review involving early questions on the competence of key persons, detailed probing of custody architecture and IT security, and evidence that AML/CTF controls are production-grade. If you are an incumbent relying on the 12-month transition period, treat it as a full re-authorisation project and plan backwards from 1 January 2026. If you are new to the sector, be MiCA-ready from day one to take advantage of Lithuania’s predictable process and, once authorised, the EU passport.

Spain: The Comisión Nacional del Mercado de Valores (CNMV) and the Banco de España are jointly responsible for supervising CASPs and token issuers under MiCA.

Spain’s MiCA architecture places the CNMV at the centre of supervision of the crypto-asset markets, while the Banco de España retains responsibility for matters relating to banking, payment services and certain stablecoin/e-money issues. The legal basis is Law 6/2023 on Securities Markets and Investment Services, which explicitly designates the CNMV as Spain’s competent authority for MiCA. Since spring 2025, the CNMV has published MiCA-related materials, including reporting templates and investor guidance, to implement the regime.

The supervisory stance evolved from 2020 to 2025.

For most of the last five years, Spain’s framework has revolved around AML registration of VASPs at the Banco de España (since 2021), alongside robust advertising controls overseen by the CNMV (Circular 1/2022). As MiCA approached, the CNMV intensified consumer warnings and fintech engagement, expanded its DLT/innovation pages and, crucially, recast its crypto communications for the new EU rulebook. By late 2024, Spain had pivoted to MiCA. CNMV materials flagged the EU-wide launch on 30 December 2024 and explained that certain providers could continue operating temporarily in 2025 under transitional arrangements. However, Spain opted to conclude the transition period on 30 December 2025, which is earlier than the deadline set by MiCA.

MiCA requirements in Spain prioritise substance over process.

Applicants for CASP authorisation are assessed by the CNMV against the directly applicable MiCA rulebook in terms of fit-and-proper management, governance and IT/security, conflicts and conduct controls, client-asset safeguarding, complaints handling and initial capital requirements of between €50k and €150k, depending on the service class (with at least a quarter of these being fixed overheads). CNMV documentation also directs firms to the evolving ESMA/EBA guidance that harmonises interpretations across the EU. In parallel, Spain’s banking supervisor continues to engage with models that touch on payment/e-money or the banking perimeter.

State fees and ongoing levies

MiCA leaves fees to national law. In Spain, fees payable to the CNMV are governed by the CNMV fee framework (Law 16/2014 and CNMV schedules). The CNMV’s fee portal explains the requirements for representing non-resident fee payers and how to pay CNMV fees. Currently, Spain has not published a unique, fixed ‘MiCA state fee’ in primary CNMV guidance. Instead, CASPs should expect standard CNMV authorisation fees and annual supervisory charges to be set and collected under the aforementioned framework as MiCA applications progress. Always confirm the current tariff directly on the CNMV website when filing.

Overview and outlook

In practice, a CASP bound for Spain should compile a MiCA-grade dossier (programme of operations, ownership and control map, policies for safeguarding, outsourcing and IT risk, and capital planning) and factor in Spain’s shorter transitional period, which ends on 30 December 2025. The CNMV’s approach combines investor protection messaging with operational clarity in terms of reporting formats, register checks and fintech pages. Meanwhile, Spanish headlines throughout 2025 will reflect a consistent flow of MiCA licences for both established and crypto-native companies, demonstrating that the CNMV is processing applications while continuing to advise retail investors on the risks and limitations of MiCA’s protections.

Sweden: Finansinspektionen (FI) – the Swedish Financial Supervisory Authority and the national regulator for MiCA authorisation and enforcement.

The authority responsible for implementing and supervising the Markets in Crypto-Assets Regulation (MiCA) in Sweden is the Finansinspektionen (FI). The FI oversees the banking, securities, insurance and payments sectors, and under MiCA it also serves as the national competent authority for the authorisation and supervision of crypto-asset service providers (CASPs). Sweden’s transition into MiCA builds upon its long-standing tradition of strong consumer protection, financial stability, and prudential regulation.

Evolution of the Regulatory Approach

Over the past five years, Sweden’s regulatory stance on crypto-assets has evolved from cautious observation to proactive integration within the EU regulatory framework. Historically, Sweden has maintained one of the most conservative approaches in the Nordic region, with both the FI and the Swedish Tax Agency (Skatteverket) taking an early interest in monitoring cryptocurrency activities. From 2019 onwards, entities providing exchange and wallet services were required to register under the Swedish Money Laundering and Terrorist Financing Prevention Act. This meant that they had to comply with AML/KYC obligations and undergo fit-and-proper checks by the FI.

However, this earlier registration regime did not equate to full financial authorisation; it was an AML gatekeeping system designed to monitor and prevent illicit activity rather than overseeing prudential risks. During the same period, Sweden also became a leader in blockchain experimentation, with state institutions such as the Riksbank exploring the e-krona project – a digital version of the national currency. Although the e-krona project is distinct from the private crypto market, it has fostered a deeper understanding within Sweden’s institutions of the potential and risks associated with digital assets.

Between 2022 and 2024, as the legislative process for MiCA advanced, the FI began preparing for its supervisory role by consulting market participants, publishing educational materials and participating in working groups of the European Securities and Markets Authority (ESMA). This proactive approach has positioned Sweden to implement MiCA smoothly and in a way that is consistent with its broader financial-market philosophy of high compliance standards, strong governance and investor protection.

MiCA Requirements under Finansinspektionen

From 30 December 2024, MiCA will apply directly in Sweden. This means that crypto-asset service providers wishing to operate there must obtain authorisation from FI before offering regulated services such as custody, exchange, portfolio management, operating a trading platform, or providing advice.

Under the MiCA framework, Swedish CASPs must comply with:

• Initial capital requirements ranging from €50,000 to €150,000 depending on the nature of their services and always amounting to at least 25% of annual fixed overheads;
• Fit-and-proper assessments for management and key personnel, including checks on integrity, experience, and competence;
• Robust governance and control systems, including AML/CFT policies, risk management, internal audit and IT/cybersecurity safeguards; and
• Segregation and safeguarding of client assets to ensure client holdings are fully protected and recoverable;
• They must also demonstrate transparency and fair conduct, with clear disclosures, pricing policies, and complaint-handling mechanisms in place.

The FI has announced that it will review applications for completeness within 25 working days and issue a final decision within 40 working days of receiving a complete file, in line with the timeframes set out in MiCA.

State Fee and Ongoing Supervision

Sweden’s MiCA-related fees follow the model used for other financial institutions supervised by the FI. While MiCA establishes the substantive rules, national legislation determines the state fee structure. Based on the FI’s 2025 fee schedule, the application fee for authorisation as a crypto-asset service provider is expected to be approximately SEK 30,000–50,000 (around €2,600–€4,300), depending on the complexity and service type.

In addition, authorised CASPs will pay annual supervisory fees to cover the FI’s ongoing monitoring costs, which are calculated proportionally to the company’s revenue from crypto-asset activities. These recurring levies are consistent with those applied to other financial institutions under Sweden’s Financial Supervision Act (Lag om finansinspektionen).

Applicants are expected to submit detailed documentation, including a programme of operations, governance structure, ownership information, risk and compliance frameworks, and financial projections, in line with MiCA and FI’s procedural requirements.

Sweden’s adoption of MiCA reflects its broader commitment to responsible innovation and European regulatory harmonisation. Unlike some jurisdictions that have adopted a lenient approach to crypto-assets, Sweden has taken a steady and cautious route, prioritising compliance, market integrity and investor safety. The FI’s involvement ensures that the crypto industry in Sweden operates under the same standards of transparency and prudence as the country’s well-regulated banking and investment sectors.

At the same time, Sweden remains supportive of innovation. The FI maintains an open dialogue with fintech companies through its Innovation Centre, which allows technology-driven financial firms to consult directly with regulators before launching new products. This collaborative ecosystem encourages responsible experimentation and ensures that market participants understand regulatory expectations from the outset.

In summary, Sweden’s implementation of MiCA under the auspices of the FI marks the country’s transition from a cautious observer to an active participant in the shaping of Europe’s regulated crypto landscape. The Swedish model balances rigorous supervision with openness to innovation, establishing the country as a secure and credible hub for compliant digital asset activity in Northern Europe.

Regulators across the EU and their roles

The success of the Markets in Crypto Assets Regulation (MiCA) as a unified European regulatory framework depends on the effectiveness and consistency of its National Competent Authorities (NCAs)—the institutions designated in each EU member state to supervise and enforce the new rules. Although MiCA establishes a common legislative foundation, authorization, supervision, and compliance will still occur at the national level under the oversight of these authorities. Each regulator plays a dual role, acting as the local gatekeeper for market entry while contributing to the harmonized European supervision system envisioned by the European Commission and the European Securities and Markets Authority (ESMA).

One of the most dynamic examples is the Bank of Lithuania, which has earned a strong reputation for its proactive, innovation-driven approach. For several years, the Lithuanian regulator has been at the forefront of digital finance, developing a clear framework for electronic money institutions (EMIs) and virtual asset service providers (VASPs) well before MiCA took effect. This early experience has positioned Lithuania as one of the most efficient and knowledgeable jurisdictions in processing MiCA applications. The Bank of Lithuania maintains open communication channels with market participants, encourages innovation through its regulatory sandbox, and continuously updates its internal processes to accommodate technological developments.

In Germany, the supervisory function is carried out by the Federal Financial Supervisory Authority (BaFin), one of the world’s most established and respected financial regulators. BaFin’s approach is characterized by precision, thoroughness, and strict adherence to national and European financial laws. The authority evaluates every application in depth, with a particular focus on governance structures, risk management, and financial resilience. Although the process is time-consuming, a license granted by BaFin is highly credible, particularly among institutional investors and banks. The regulator’s stringent oversight is seen as a mark of trust, reflecting Germany’s broader financial culture of reliability and prudence.

France’s Autorité des Marchés Financiers (AMF) plays a similarly influential role. Recognizing the potential of digital assets early on, the AMF was among the first European regulators to introduce a comprehensive licensing regime through its Digital Asset Service Provider (DASP) framework. This framework now serves as the foundation for the AMF’s transition into MiCA. The AMF’s regulatory culture emphasizes investor protection, transparency, and robust disclosure requirements. Its well-organized procedures and experienced staff make France one of the most mature and sophisticated environments for crypto regulation in Europe.
In Malta, the Malta Financial Services Authority (MFSA) is overseeing the transition from the Virtual Financial Assets (VFA) framework to MiCA. The MFSA was a pioneer in establishing legislation for blockchain and digital assets, providing clear definitions and obligations for service providers as early as 2018. The Maltese regulator is recognized for its expertise and hands-on supervisory approach. Although its procedures are detailed and sometimes lengthy, they demonstrate a thorough understanding of the sector and an unwavering commitment to compliance and market integrity.

Estonia’s Financial Intelligence Unit (FIU) occupies a unique position within the European regulatory landscape. Estonia was one of the first countries to recognize and license virtual asset service providers, initially attracting hundreds of companies. However, following global AML concerns, the FIU tightened its oversight drastically and introduced rigorous compliance obligations. Under MiCA, the FIU continues to apply this risk-based philosophy, ensuring that only well-structured and transparent businesses operate under its jurisdiction. These high standards have helped reinforce Estonia’s reputation as a secure and trustworthy jurisdiction for responsible digital asset activity.

Another cornerstone of European regulatory excellence is the Dutch Central Bank (De Nederlandsche Bank — DNB). Known for its institutional discipline and risk management culture, the DNB supervises cryptocurrencies with a blend of caution and technical sophistication. The bank places significant emphasis on cybersecurity, operational resilience, and the prevention of financial crime. Though often described as conservative, the Dutch regulator commands respect for its competence and consistency. Many institutional players consider the Netherlands an ideal jurisdiction for establishing operations that demand a stable and predictable regulatory environment.

Meanwhile, regulators in Poland and the Czech Republic — the Polish Financial Supervision Authority (KNF) and the Czech National Bank (CNB), respectively — are still expanding their internal expertise in digital assets. Both have taken a measured, step-by-step approach toward integrating MiCA requirements, prioritizing prudence over speed. As these countries continue to develop their national frameworks, they are expected to play increasingly important roles in Central Europe’s crypto ecosystem, particularly for companies targeting regional markets.

At the European level, the European Securities and Markets Authority (ESMA) and the European Banking Authority (EBA) serve as coordinating bodies to ensure harmonization and prevent regulatory fragmentation. ESMA is responsible for issuing technical standards, guidelines, and Q&A documents that help national competent authorities (NCAs) interpret MiCA consistently. ESMA also facilitates information exchange between national regulators and monitors the overall functioning of the crypto-asset market across the EU. Meanwhile, the EBA focuses on the prudential aspects of issuers of asset-referenced and e-money tokens to ensure the stability of these projects within the broader financial system.

Together, these institutions form a multilayered regulatory ecosystem designed to balance national flexibility with European coherence. Each authority brings its own strengths, such as Lithuania’s agility, Germany’s rigor, and Malta’s specialized experience, but they all operate within the shared objective of ensuring a safe, transparent, and innovative crypto market. This coordination between national and European supervisory bodies is one of MiCA’s most significant achievements. It lays the groundwork for a truly integrated financial market that reflects the European Union’s diversity and unity.

Advantages and Disadvantages of Different Jurisdictions

Although MiCA establishes a harmonized framework for the regulation of crypto-assets throughout the European Union, national implementation still reflects each Member State’s unique characteristics. Factors such as regulatory culture, administrative efficiency, experience with digital finance, and the maturity of local financial ecosystems create tangible differences in how companies experience the licensing process. Each jurisdiction offers a distinct combination of advantages and challenges. The choice of where to apply for a MiCA license can significantly impact a company’s operational strategy, cost efficiency, and long-term growth prospects.

Among the jurisdictions that have positioned themselves as front-runners, Lithuania remains one of the most attractive destinations for both startups and established crypto businesses. The country’s greatest advantage lies in its combination of speed, clarity, and cost-effectiveness. The Bank of Lithuania has built a reputation for being open to fintech innovation and is known for maintaining transparent communication with applicants throughout the authorization process. Its experience supervising electronic money institutions and virtual asset service providers gives it a solid foundation for efficiently handling MiCA licensing. Companies benefit from the regulator’s responsiveness and the country’s well-developed legal and technological infrastructure. However, the banking sector’s cautious stance toward crypto businesses remains a limitation. While the regulatory environment is favorable, obtaining reliable banking relationships can still be challenging for newcomers.
Estonia offers a different but equally valuable advantage. The Estonian Financial Intelligence Unit (FIU) is recognized for its rigorous anti-money laundering (AML) supervision and high compliance standards. Companies licensed in Estonia have a strong reputation for transparency and credibility, which is instrumental when building international partnerships. The Estonian digital ecosystem, known for its advanced e-governance and digital identity systems, provides a technologically efficient environment in which to operate a crypto business. However, this comes at a cost. The FIU’s demanding due diligence requirements and cautious approach mean applicants must be exceptionally well-prepared financially and operationally. Estonia is best suited for companies that already have mature compliance frameworks and a long-term commitment to governance.

Malta, often called the “Blockchain Island,” offers one of the most comprehensive and experienced regulatory environments in Europe. Since 2018, the Malta Financial Services Authority (MFSA) has been licensing crypto and blockchain firms under a framework that anticipated many of MiCA’s principles. This maturity gives Malta an advantage in expertise and legal certainty, particularly for projects seeking to operate under a well-established institutional regime. The country’s English-speaking environment and common law system further add to its appeal for international investors. However, Malta’s greatest strengths — its attention to detail and depth of supervision — also translate into longer processing times and higher administrative demands. The process can be slow, and the regulator’s expectations for documentation and internal controls are substantial. Malta is ideal for companies that prioritize long-term credibility and regulatory robustness over rapid market entry.

Germany, supervised by BaFin, represents the most prestigious institutional jurisdiction in the EU. A license granted in Germany signals a level of seriousness and reliability that resonates strongly with financial institutions and investors worldwide. The country’s large, mature financial sector offers unparalleled access to banking, investment, and partnership opportunities. However, Germany’s advantages come at a price. The authorization process is complex and time-consuming and requires significant capital. BaFin expects applicants to demonstrate full regulatory compliance, financial soundness, detailed governance structures, and a high degree of operational security. As such, Germany is best suited for established companies with sufficient resources and a long-term strategic presence in Europe.
The Netherlands offers similar institutional benefits through its regulator, the Dutch Central Bank (DNB). The DNB is known for its meticulous and methodical oversight and provides a stable and predictable environment for digital asset businesses. The country’s highly developed financial ecosystem makes it an appealing location for companies targeting institutional investors. However, operational costs in the Netherlands are among the highest in Europe, and the DNB is known for its conservative approach, particularly regarding AML compliance and risk management. The Dutch market favors well-capitalized, compliance-driven entities that can meet high regulatory expectations.

In Central Europe, both Poland and the Czech Republic are emerging as promising jurisdictions under the MiCA framework. Poland’s Financial Supervision Authority (KNF) takes a cautious yet pragmatic approach and is gradually building expertise in digital finance. The country offers a large domestic market, an educated workforce, and growing interest in fintech innovation. While traditionally conservative, the Czech National Bank (CNB) provides a stable and predictable legal environment supported by the country’s strong economic fundamentals. However, both countries are still developing the institutional experience and administrative agility seen in more mature markets, such as those in Lithuania and France. Companies seeking faster approval may find that these countries are slower to process applications, though they remain cost-effective and strategically located.

When comparing these countries, it becomes clear that no single member state offers a universal advantage; rather, each caters to different business models and strategic priorities. Lithuania appeals to agile fintech startups that value efficiency and flexibility. Estonia attracts compliance-oriented firms that seek a transparent and secure regulatory environment. Malta and Germany are ideal for companies pursuing long-term institutional credibility, and the Netherlands provides a sophisticated environment for large-scale, risk-managed operations. Meanwhile, Poland and the Czech Republic offer opportunities for cost-conscious projects seeking access to emerging Central European markets.

The disadvantages of each jurisdiction are largely the natural consequence of their strengths. Fast-track jurisdictions may offer speed, but they require additional effort for banking integration. Prestigious regulators provide credibility, but they come at a higher cost and with greater complexity. Many crypto firms find that the optimal approach is to assess their long-term business goals, target audience, and operational capacity before selecting the most suitable jurisdiction for MiCA licensing.

MiCA’s greatest achievement is that it unifies these countries under the same legal framework. This means that, regardless of the chosen jurisdiction, the rights and obligations under EU law remain consistent. This balance between national diversity and regulatory unity makes the European approach to digital finance sophisticated and sustainable, allowing businesses to choose an environment that fits their needs while maintaining equal access to the European single market.

The Future of MiCA and Global Impact

Adopting the Markets in Crypto-Assets Regulation is not just a European achievement, but also a turning point in the global evolution of digital finance. MiCA is the first comprehensive, enforceable, supranational framework for crypto-assets. It has already begun shaping how other jurisdictions perceive and approach the regulation of this rapidly developing industry. As the European Union implements MiCA fully through 2025 and beyond, the regulation’s influence will extend far beyond its borders. It will set a global benchmark for transparency, investor protection, and technological innovation.

In the coming years, MiCA will serve as a model for other regions seeking to balance innovation with oversight. Countries and economic blocs, such as the United Kingdom, Singapore, the United States, the United Arab Emirates, and Hong Kong, are closely observing the European experience and studying how harmonized rules can foster market integrity without stifling growth. The EU’s ability to implement a common legal framework across its 27 Member States demonstrates the regulatory coordination that many other regions have struggled to achieve. This success positions MiCA as a blueprint for international crypto governance, and similar principles will likely emerge elsewhere under different legal systems.

For the European Union, MiCA is expected to stimulate the institutionalization of the crypto sector. By introducing clear licensing requirements, capital thresholds, and compliance standards, the regulation creates a safer and more predictable environment in which traditional financial institutions can engage with digital assets. Banks, investment funds, and payment providers can now collaborate with licensed crypto-asset service providers (CASPs) without facing the industry’s previous uncertainties. This will lead to greater convergence between the traditional financial system and the digital asset economy, accelerating the mainstream adoption of blockchain-based financial products.

The regulation is also likely to foster market consolidation. Smaller or less compliant operators that once thrived in regulatory gray areas will now face higher operational standards and compliance costs. Consequently, the industry is expected to evolve toward fewer, stronger, and better-regulated participants. Larger players, particularly those with sufficient capital and professional management, will benefit from economies of scale and enhanced trust. Smaller startups, on the other hand, may seek partnerships or mergers to remain competitive. This process will contribute to a more stable and professionalized European crypto market where consumer protection and accountability are fundamental principles.

Another significant outcome of MiCA’s implementation will be increased investor confidence. With clearer disclosure requirements, stricter anti-fraud mechanisms, and improved market supervision, both retail and institutional investors will be more willing to engage in the digital asset space. Enhanced transparency of token issuances, mandatory publication of white papers, and enforcement of operational safeguards will reduce risks and promote informed decision-making. Over time, this is expected to translate into increased liquidity, broader participation, and deeper integration of crypto assets within the mainstream financial system.
From a technological perspective, MiCA will encourage innovation under regulatory clarity. Projects that were previously hesitant to launch due to legal uncertainty can now operate within a defined, stable framework. Fintech and blockchain startups will be encouraged to develop new products, including tokenized securities, digital currencies, and decentralized finance (DeFi) solutions that comply with established regulatory standards. The availability of a harmonized European market of over 400 million consumers provides innovators with an unparalleled level of scale and opportunity, thereby fostering an environment conducive to research, development, and cross-border collaboration.

At the same time, MiCA’s influence will extend to global regulatory cooperation. As crypto-assets continue to transcend national borders, international organizations such as the Financial Stability Board (FSB) and the International Organization of Securities Commissions (IOSCO) are expected to use MiCA as a reference when formulating cross-border guidelines. Aligning major jurisdictions around shared principles, such as transparency, custody safeguards, and consumer protection, could pave the way for a more integrated and stable global digital asset economy.

Despite these positive developments, the future of MiCA will involve challenges. Regulators must continuously adapt to new technologies and market practices to ensure the framework’s relevance in an evolving sector. Areas such as decentralized finance (DeFi), non-fungible tokens (NFTs), and algorithmic stablecoins pose complex regulatory questions that MiCA only partially addresses. Furthermore, uniformly applying the regulation across all member states will require close coordination among national authorities and the European Securities and Markets Authority (ESMA), especially to ensure consistent interpretation and enforcement.
In the long term, the global impact of MiCA is expected to extend beyond financial markets. It will contribute to the broader acceptance of blockchain technology as a foundation for trustworthy, regulated, and scalable digital infrastructure. By combining innovation with accountability, MiCA demonstrates how technology and law can evolve together — not in opposition, but in mutual reinforcement.

Ultimately, MiCA’s future lies in its ability to maintain this delicate balance. It must continue to promote innovation while preserving the principles of investor protection and market integrity that define the European regulatory tradition. If successful, MiCA will transform the European crypto landscape and serve as a cornerstone of the future global digital economy. It will demonstrate that, when applied thoughtfully, regulation can be a powerful enabler of progress rather than a barrier to it.

The implementation of the Markets in Crypto-Assets Regulation (MiCA) is a defining moment in the evolution of Europe’s financial landscape and the global digital economy. What began as a fragmented ecosystem of diverse national rules has matured into a unified, comprehensive regulatory framework that provides long-awaited legal certainty to one of the world’s most innovative yet volatile industries. MiCA represents years of policy work, dialogue, and collaboration between regulators, lawmakers, and the crypto community. They are all driven by a shared vision: to build a market balancing innovation with integrity, opportunity with oversight, and technology with trust.

For Europe, MiCA signifies a major step toward a single digital financial market where companies can operate seamlessly across borders under one harmonized legal regime. This harmonization is not merely a legal exercise; it is an economic catalyst. By enabling crypto-asset service providers (CASPs) to passport their licenses throughout the European Economic Area (EEA), MiCA eliminates the inefficiencies that once fragmented the European crypto sector. It empowers entrepreneurs to focus on growth and innovation rather than on navigating a patchwork of differing national laws. At the same time, MiCA gives regulators a powerful, standardized framework to monitor activity, detect risks, and ensure compliance across all 27 member states.

Perhaps MiCA’s greatest achievement is how it redefines trust in the digital asset ecosystem. By establishing clear obligations for issuers, custodians, and intermediaries, the regulation transforms a market once characterized by uncertainty into one governed by transparency, accountability, and consumer protection. Investors can now engage with licensed providers, confident that these entities meet stringent standards for security, capital adequacy, and operational reliability. This newfound confidence is expected to attract institutional capital and encourage mainstream participation, thereby expanding the role of digital assets within Europe’s broader financial system.

From a business perspective, MiCA introduces challenges and opportunities. The new licensing regime requires firms to invest in governance, compliance, and risk management structures similar to those in traditional finance. While this raises entry barriers, it also elevates the industry’s credibility overall, distinguishing sustainable projects from those that are speculative or noncompliant. Over time, the European crypto market is expected to consolidate around well-managed, well-capitalized, and fully compliant actors — a transformation that mirrors the maturation of other financial sectors throughout history.

Each member state’s regulator — whether the Bank of Lithuania, BaFin in Germany, the AMF in France, or the MFSA in Malta — contributes to this transformation through its national experience, expertise, and administrative culture. The diversity of these regulators’ approaches is a strength, not a weakness. It allows businesses to choose the regulatory environment that best aligns with their strategic goals while maintaining consistent legal rights across the EU. Together, Lithuania’s speed, Germany’s prestige, Malta’s experience, and Estonia’s rigor enrich the European regulatory mosaic, creating a competitive yet unified marketplace under MiCA’s umbrella.

The long-term impact of MiCA will extend beyond Europe. As other jurisdictions observe the European model, MiCA’s principles will likely influence global standards for crypto governance. Its framework of transparency, consumer protection, and cross-border cooperation provides a practical template for policymakers worldwide seeking to integrate digital assets into their financial systems responsibly. This will help bridge the gap between regions, fostering international dialogue and eventually leading toward a more coherent and interconnected global digital economy.

MiCA’s success ultimately rests on its ability to strike a balance between innovation and regulation, encouraging technological advancement while maintaining the safeguards necessary for a fair and stable market. MiCA acknowledges that regulation need not hinder progress, but rather, it can enable progress by providing clarity, legitimacy, and confidence. For businesses, investors, and regulators, MiCA represents a future in which cryptocurrencies are a recognized and integral part of Europe’s financial architecture, not a frontier of uncertainty.

MiCA is more than a regulatory framework; it’s a vision for the next generation of finance, where digital transformation is guided by the principles of trust, responsibility, and transparency. MiCA paves the way for a Europe that embraces and leads innovation, offering the world a compelling example of how regulation and technology can coexist to build a sustainable, inclusive, and forward-looking financial ecosystem.

At RUE, our deep understanding of European financial regulation and our extensive practical experience across multiple jurisdictions allow us to provide end-to-end assistance with the MiCA licensing process — from the initial consultation to successfully obtaining your Crypto-Asset Service Provider (CASP) license and beyond.
Over the past several years, our legal and compliance teams have been actively involved in preparing, submitting, and managing MiCA-related applications in nearly every EU member state. Our hands-on experience with regulatory authorities, including the Bank of Lithuania, the MFSA in Malta, the CSSF in Luxembourg, the BaFin in Germany, the CNB in the Czech Republic, the HCMC in Greece, and others, gives us a unique cross-border perspective. This allows us to tailor each licensing project to the specific procedural and cultural expectations of each jurisdiction.

Our MiCA licensing assistance covers every stage of the process:

• Initial strategy and jurisdiction selection: We analyze your business model, risk tolerance, and operational structure to determine the most suitable EU country for your MiCA authorization, balancing reputation, regulatory responsiveness, and time to market.
• Pre-application preparation: We prepare and structure all required documentation, including the Program of Operations, Internal Governance Framework, Anti-
• Money Laundering/Combating the Financing of Terrorism (AML/CTF) Policy, Safeguarding Procedures, and ICT/Operational Resilience Plan — aligning every aspect of your internal documentation with MiCA standards.
• Regulator engagement: We handle all communications with the competent authority, including pre-application meetings, responses to questions and clarifications, and follow-ups, ensuring your application progresses efficiently without unnecessary delays.
• Legal and corporate structuring: We assist with forming or adapting your EU legal entity and drafting corporate documents, shareholder resolutions, and governance policies that comply with national and EU regulatory requirements.

Capital and Compliance Readiness: We guide you through capital requirements, safeguarding models, and compliance testing to help your company demonstrate operational maturity and risk control from day one.

Post-licensing support: Our support continues even after your CASP license is issued. We continue to assist with passporting notifications, periodic reporting, internal audits, and ongoing compliance maintenance under the MiCA framework.

Whether you are a startup entering the EU market, an established exchange expanding operations, or a financial institution seeking regulatory alignment, RUE’s comprehensive support ensures that every step—from feasibility analysis to the final approval letter—is handled with precision, professionalism, and efficiency.
With our comprehensive MiCA licensing service, clients benefit from documentation and procedural support, as well as the strategic insight of a team that has successfully guided dozens of CASP applicants through the evolving EU regulatory landscape. Our objective is clear: to make your licensing journey faster, smoother, and fully compliant while safeguarding your long-term success under MiCA.