CASP License Guide 2026
Step-by-step CASP license / MiCA licence guide for the EU: service classes, €50k–€150k capital, 3–12 month NCA timelines, document checklist, and 30-country comparison. Free scoping included.
Is MiCA CASP authorization mandatory for all crypto businesses in the EU?
Yes, for any firm providing crypto-asset services to clients in the EU on a professional basis. The only exemptions are: providing services exclusively between group entities (intra-group), firms below de-minimis thresholds (12 months, fewer than 40 distinct customers, total consideration under €100,000), and certain DeFi protocols with no identifiable central party. If you operate a regulated business serving the public, you need CASP authorization.
What is the difference between a CASP license and an e-money institution license?
An e-money institution (EMI) license under EMD2 covers fiat-denominated electronic money and payment services. A CASP authorization under MiCA covers crypto-asset services. They are separate regulatory frameworks. Stablecoin issuers may need both: an EMT/ART authorization under MiCA Title III/IV and a CASP authorization if they also provide exchange or custody services. Payment services involving fiat on/off-ramps may additionally require an EMI or payment institution license.
Can a startup without an operating history apply for a CASP license?
Yes. MiCA does not require a prior operating history. New entities can apply for CASP authorization from inception. You will need to demonstrate future capital adequacy through financial projections, provide a credible business plan, and have a management body with relevant professional experience. Many NCAs (Lithuania, Cyprus) are actively welcoming new crypto-native firms applying from scratch.
How does MiCA affect DeFi protocols?
MiCA explicitly exempts fully decentralised protocols where no central party provides crypto-asset services. However, 'fully decentralised' is a high bar. Many protocols have identifiable developers, foundations, or DAOs that could be deemed to be providing services. ESMA is expected to publish guidance on the DeFi boundary. For now: if your protocol has a legal entity, a front-end, or a foundation that exercises control, you likely need to assess CASP authorization.
What ongoing obligations does a CASP have after authorization?
Post-authorization obligations include: annual capital adequacy reporting, immediate notification of material changes (new services, ownership changes, governance changes), annual AML compliance report to the NCA, DORA-mandated ICT incident reporting, and ongoing supervision by your home NCA. Fees: most NCAs charge annual supervisory fees based on business volume, typically €5,000–€50,000/year.
Which jurisdiction is best for MiCA CASP authorization in 2026?
For most firms: Lithuania (Bank of Lithuania) is the first-choice jurisdiction. It offers the fastest authorization timeline (3–5 months), lowest NCA fees (€0–€5,000), a well-resourced supervisory team with deep crypto expertise, a digital application process, and the lowest local substance requirements in practice. Cyprus (CySEC) is the second-choice: no local CEO requirement, English-language process, and 3–5 month timeline. For firms targeting institutional counterparties who prioritize regulatory credibility: Netherlands (DNB) or Germany (BaFin).
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