MiCA license

Own funds and the three service classes

A CASP must hold permanent minimum capital of €50,000, €125,000 or €150,000, depending on the services it provides (Annex IV of Regulation (EU) 2023/1114). Reception and transmission of orders, advice, execution, placing, transfer services and portfolio management sit in Class 1. Custody and the exchange of crypto-assets for funds or for other crypto-assets move a firm into Class 2; operating a trading platform means Class 3.

The class figure is a floor. Article 67 asks for the higher of that amount and one quarter of the previous year’s fixed overheads, and a new firm uses projected overheads for its first 12 months. A business plan with a large team therefore raises the own-funds requirement before the first client is onboarded.

Transitional periods: one parameter, nine answers

Every national transitional period for CASPs is now over: MiCA capped them at 1 July 2026 and let member states choose shorter ones. Malta, Spain and France took the full 18 months. Ireland and Lithuania chose 12 months; the Netherlands and Latvia allowed 6, which ended on 30 June 2025.

Germany closed its window on 31 December 2025 under § 50 KMAG. Italy let firms that had applied by 30 December 2025 continue until 30 June 2026. For Portugal the end date is not verified in a primary source, so we do not state one.

A firm that relied on a national registration in any of these countries now needs its own MiCA authorisation or a passport from a CASP authorised elsewhere in the EU. In its statement of 4 December 2025, ESMA expects firms without authorisation to carry out an orderly wind-down.

Why most applications do not end in a license

On 1 July 2026 the Czech National Bank reported 11 CASP licences after assessing 251 applications, 204 of them filed during the transitional period. The bank did not publish a breakdown of reasons, and we do not guess at one.

Article 63 of MiCA sets the grounds on which an authority refuses: a management body that threatens sound and prudent management or business continuity, managers who lack good repute, knowledge or experience, shareholders with qualifying holdings who fail the suitability test, or an applicant that does not meet the requirements of Title V.

Article 62 lists what the application must contain, and each refusal ground points to one part of it: the fit-and-proper questionnaires, the shareholder chart with source of funds, the programme of operations or the policy set. A gap in one of them is enough.

How long the authority takes

The AFM in the Netherlands publishes 5 to 8 months for a CASP licence. MiCA itself fixes only the first stage: the authority acknowledges receipt within 5 working days and decides whether the file is complete within 25 working days.

BaFin publishes no processing time and refers applicants to the MiCA deadlines. Our part, the application pack, takes the working days shown in the price table; the authority’s clock starts only once the file is complete.

Passporting from one authorisation

Since 1 July 2026 only MiCA-authorised or passported CASPs may serve clients in Spain, and the same now holds in every member state. A passport is a notification to the home authority under Article 65, not a second license: the home authority forwards it to the host states within 10 working days, and services may start no later than the 15th calendar day after the notification was submitted.

The home country therefore matters more than the target market. MiCA requires a registered office in a member state where the firm provides at least part of its services, effective management in the Union and at least one director resident in the Union. A group serving Spain and Italy can hold one authorisation in Cyprus, where CySEC stopped taking national registrations on 17 October 2024, provided that management really sits there.