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The Crypto-Asset Service Provider (CASP) license is a mandatory authorization introduced by the EU’s Markets in Crypto-Assets (MiCA) regulation for companies providing crypto-asset services. This license covers activities such as crypto exchange operations, custodial wallet services, portfolio management, and advisory services in crypto-assets. Crucially, obtaining a CASP license allows a firm to operate across all 27 EU member states under a single regulatory framework, leveraging passporting rights similar to those in traditional finance. MiCA was adopted in 2023 to replace the previous patchwork of national VASP (Virtual Asset Service Provider) regimes with a unified EU-wide standard, ushering in a new era of transparency, security, and market integrity for digital assets.

MiCA Rollout and Transition: MiCA’s implementation is phased. The first phase (effective June 30, 2024) introduced rules for stablecoin issuers, while the second phase (effective December 30, 2024) brought into force the requirements for CASPs – i.e. crypto exchanges, brokers, custodians, and other service providers. Existing VASPs were granted a transition (grandfathering) period to continue operating under national registrations until they obtain a CASP license. In most EU countries this transition lasts until December 31, 2025, though some jurisdictions extend it up to July 1, 2026 (the maximum 18 months allowed). After this grace period, all crypto service providers must be fully MiCA-authorized CASPs to legally operate in the EU. In short, the CASP license has become the gateway to long-term legitimacy, customer trust, and cross-border expansion in Europe’s digital asset economy.

What to Do for Current VASP Holders in Europe?

For current holders of national VASP licenses in Europe, the advent of MiCA means preparing to transition to a CASP license. Existing VASPs can continue operating under their national authorization during the designated transition period, but they must secure a CASP license before this period ends to avoid disruption. The exact transition deadlines vary by country – many EU states chose a 12-month window ending late 2025, while others allow the full 18 months until mid-2026. It’s critical for VASPs to check their jurisdiction’s timeline and submit a CASP application by the required date (often by mid-to-late 2025) to benefit from the grandfathering period.

Key steps for a smooth VASP-to-CASP transition:

Capitalization: Ensure your company’s capital meets the new MiCA minimums (up to €150,000, depending on services). Existing VASPs should consider increasing capital in advance to required levels to expedite compliance and avoid last-minute issues.
AML Compliance & Internal Policies: Strengthen Anti-Money Laundering (AML) and Counter-Terrorist Financing (CTF) programs and overall internal controls. MiCA imposes more detailed requirements for risk management, customer due diligence, transaction monitoring, protection of client funds, and data security. VASPs should update or develop comprehensive policies covering these areas, conduct regular risk assessments, and ensure they align with MiCA’s stricter standards.
Local Presence: Establish a sufficient EU presence. Under MiCA, a CASP must have a physical office in an EU member state and “effective management” located in the EU. This means at least one qualified director or senior manager resident in the EU, as well as local AML compliance officers (e.g. a Money Laundering Reporting Officer). Regulators will expect “substance” – real operations and staff in the licensing country, rather than a shell setup.
Timeline Awareness: Begin the CASP licensing process early. MiCA license application portals opened in most countries by January 2025, and regulators are handling a high volume of applications. Given that formal review can take several months (or more) once submitted, current VASPs should not delay. Waiting too long risks missing the transition window, after which unlicensed operations must cease.

By proactively addressing these steps, VASP license holders can adapt to MiCA’s regime and position themselves for a successful CASP authorization. Early movers will benefit from uninterrupted service continuity, enhanced credibility with clients and banking partners, and the ability to passport services across the EU as a fully compliant CASP.

New Capital Requirements for CASP License

MiCA introduces tiered capital requirements for crypto-asset service providers, aligned to the scope of services and client risk. CASP licenses are split into three classes, each with a specified minimum paid-in capital.

CASP Class	Minimum paid-in capital	Covered services
Class 1	€50,000	— execution of orders on behalf of clients; — placing of crypto-assets; — providing transfer services for crypto-assets on behalf of clients; — reception and transmission of orders for crypto-assets on behalf of clients; — providing advice on crypto-assets; and/or — providing portfolio management on crypto-assets
Class 2	€125,000	Any Class 1 services plus — providing custody and administration of crypto-assets on behalf of clients; — exchange of crypto-assets for funds; and/or — exchange of crypto-assets for other crypto-assets.
Class 3	€150,000	Any Class 2 services and operation of a trading platform for crypto-assets.

How classification works. A company’s CASP class is determined by the most intensive service it provides. Minimum capital must be fully paid-in and available to safeguard solvency and protect customers against operational losses.

Additional financial requirements. All CASPs should maintain at least one EU-based account for handling funds. Regulators may also expect insurance or reserve provisions to cover liabilities such as cyber incidents or operational errors. Existing VASPs are encouraged to recapitalize early to meet the new thresholds and avoid any compliance gap as MiCA takes full effect.

Main Requirements for a CASP License

Transitioning from a VASP to a CASP under MiCA is not just a formality – it involves meeting a comprehensive set of legal and operational standards. Here are the main requirements a company must satisfy to obtain (and keep) a CASP license:

Incorporation and Legal Form: The business must be organized as a legal entity in an EU member state, with a clear corporate structure that protects clients’ interests and enables compliance with MiCA’s rules. Typically this means setting up a local company (e.g. an EU-based LLC or equivalent) with transparent ownership and governance.
EU Office and Management: The CASP must have a registered office in the licensing jurisdiction and conduct real operations there. Effective management must be in the EU, including at least one director resident in the EU on the management team. Many countries require that certain executives (CEO, compliance officer, etc.) be local to ensure accountability and local oversight.
Robust Internal Controls (AML/CFT): A licensed CASP needs to implement rigorous internal control and risk management systems. This encompasses strong AML/CFT measures: procedures to verify customers’ identities, monitor and report suspicious transactions, and assess risks of money laundering or terrorist financing. MiCA expects firms to have documented policies covering how they prevent illicit finance and manage operational, legal, and IT risks in their activities.
Customer Asset & Data Protection: CASPs are required to safeguard clients’ assets and personal data. This involves security measures such as segregating client funds from the company’s own assets, controlling access to sensitive data, encrypting information, and conducting regular security audits. The goal is to ensure confidentiality, integrity, and availability of client assets and information at all times.
Insurance and Financial Safeguards: Applicants must demonstrate financial safeguards against potential liabilities. MiCA doesn’t explicitly mandate an insurance policy, but it requires “sufficient insurance or reserves” to cover risks associated with breaches, operational errors, or client claims. Regulators will expect evidence of arrangements (capital buffers, insurance coverage, etc.) that can absorb such risks.
Business Continuity Planning: MiCA mandates a documented business continuity and disaster recovery plan. CASPs should be able to maintain or quickly resume critical operations in the event of disruptions (system failures, cyberattacks, etc.). This includes data backup procedures, contingency workflows, and crisis response strategies to ensure uninterrupted service.
Consumer Care and Disclosures: Licensed CASPs need clear procedures for handling customer complaints and resolving disputes. They must provide clients with information on how to lodge complaints and must address issues promptly and fairly. Additionally, MiCA elevates consumer protection standards – for instance, requiring transparent fee disclosures and risk warnings for products – so CASPs should embed these into their client communications.
Conflict of Interest Management: Firms must identify and manage conflicts of interest, both internal and external. This means if a CASP (or its staff) has any interest that could improperly influence its services (e.g. trading on its own account against clients, or preferential treatment of certain customers), it needs policies to mitigate and disclose those conflicts. Maintaining fair and transparent operations is crucial under the MiCA regime.
Complete and Truthful Authorization Application: Finally, to get licensed, a company must submit a thorough application to the regulator with full information about its activities, owners, management, and systems (details on this process in later sections). All statements must be truthful and complete. Once authorized, the CASP gains the ability to operate EU-wide without separate national licenses – but any changes (new services, new senior managers, etc.) generally require notifying or seeking approval from the authorities.

Meeting these requirements is a rigorous process by design – the EU is effectively holding crypto businesses to standards similar to traditional financial institutions. Aspiring CASPs should approach compliance holistically: it’s not just about documentation, but about embedding good governance and risk controls into the business’s DNA. Those that do so will not only satisfy regulators but also build greater trust with customers and partners.

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Record-keeping

Accurate and accessible recordkeeping is a fundamental obligation under MiCA. Crypto-asset service providers must keep detailed records of all their services, activities, orders, and transactions. The purpose is to ensure that regulators can supervise activities and enforce the rules effectively – if something goes wrong, there should be a paper trail (or rather, a data trail).

Key points on recordkeeping requirements:

Comprehensive Logs: CASPs should log every significant transaction and interaction: this includes trades executed, assets custodied, transfers made on behalf of clients, orders received and transmitted, etc. Essentially, any service provided or operation carried out should be recorded with sufficient detail to reconstruct what happened.
Special Format: MiCA, through ESMA guidelines, provides rules and formats on how firms maintain these records.For example, COMMISSION DELEGATED REGULATION (EU) 2025/1140 of 27 February 2025 supplementing Regulation (EU) 2023/1114 of the European Parliament and of the Council with regard to regulatory technical standards specifying records to be kept of all crypto-asset services, activities, orders and transactions undertaken.
Retention Period: Records must be kept for at least 5 years, and potentially longer for certain cases. If a national competent authority requests, records may need to be retained up to 7 years total. This extended retention typically would be invoked if an investigation or enforcement action is ongoing. CASPs should have data storage solutions that can securely retain historical records for several years and prevent tampering or loss.
Client Access: MiCA also implies that clients have a right to relevant information on request. In practice, a customer should be able to obtain records of their own transactions or account history. CASPs need to be capable of retrieving and providing such data to clients (within legal and privacy bounds).

Good recordkeeping is not just about compliance – it also helps in operational transparency and dispute resolution. By maintaining robust records, a CASP can more easily resolve customer inquiries, audit its own processes, and demonstrate compliance during regulator audits. Given the importance of this obligation, firms often invest in advanced IT systems and databases that automatically log activities and securely archive data, making compliance with recordkeeping relatively seamless.

Preparing to Apply for a MiCA CASP License

Timeline	Statutory ~3–4 months* Typical 6–9 months incl. preparation	Structure	Strong governance framework (qualified senior management, clear organisational structure, internal control systems)
State Fee	Depending on the country	Local staff	At least one EU-resident director and MLRO/Compliance Officer; effective management in the EU
Share Capital	€50,000–€150,000 by service class; if higher, ≥ one quarter of prior-year fixed overheads	Physical Office	Required in the licensing Member State
Corporate Tax	Depending on the country	Annual Fee	Depending on the country

* Statutory timeline under MiCA: completeness check within 25 working days; decision ~40 working days from a complete file (extendable). Real-world review commonly 3–6 months; with preparation, total project time often 6–9 months.

Securing a CASP license requires thorough preparation well before you file the official application. Companies should take the following steps in preparation for a MiCA authorization:

Study the MiCA Regulation and Guidelines: Begin by fully understanding MiCA’s requirements. Review the regulation text and any guidance from European authorities (ESMA, EBA) to grasp the categories of services, governance expectations, and technical standards. Being well-versed in what the law requires will inform all subsequent steps.
Determine Your CASP Category: Identify which category (or categories) of crypto-asset services your business will provide, as this dictates the license class and specific obligations. For example, are you an exchange, a custodial wallet provider, a broker (order reception/transmission), an advisor, an ICO/IDO platform, etc.? Each service type has tailored rules (and different capital classes). Pinpointing your scope of activities ensures you prepare the right documentation and meet the correct capital requirement.
Conduct an Internal Compliance Audit: Evaluate your current operations against MiCA’s standards. This gap analysis should check everything from governance structures and IT security to AML procedures and financial resilience. Identify any shortfalls – e.g., is your IT system capable of transaction tracing? Are your current KYC/AML checks up to the enhanced MiCA level? Do you have necessary internal roles filled (like a compliance officer, risk officer)? Addressing gaps early will make the formal application smoother.
Choose the Jurisdiction for Licensing: Although MiCA is uniform across the EU, each member state has its own regulator and may impose slight additional requirements or nuances in the application process. Factors to consider when picking a country for your CASP license include: regulatory reputation and supportiveness, processing timelines, administrative fees, required local substance (staffing expectations), taxation, and the presence of crypto-friendly infrastructure. For instance, some jurisdictions might have faster approval processes or a more established framework for fintech. Do research or consult experts to select the EU member state that best fits your company’s profile.
Prepare Documentation Diligently: Assemble all required documents for the application. This typically includes:
- A detailed programme of operations explaining your services and how you will generate revenue.
- Information on shareholders and beneficiaries, and identity documents for owners and directors (to perform fit-and-proper checks).
- Organizational structure charts and role descriptions (showing who will fulfill key functions like compliance, IT security, etc.).
- Comprehensive AML/CFT policies and procedures aligned with EU standards.
- A risk management framework document, covering how you handle various risks (market, liquidity, operational, cybersecurity, etc.).
- An IT/security architecture description, outlining systems used for handling crypto transactions, cybersecurity measures, data protection controls, and business continuity plans.
- Financial projections and proof of capital (e.g. bank statements or auditor confirmation of paid-in capital meeting the threshold).
- Any required insurance certificates or evidence of reserve funds for liabilities.
Preparing this dossier can be the most time-consuming part; it’s not unusual for the application package to run hundreds of pages long when complete.
Consult Professionals if Needed: Engaging experienced legal and compliance advisors can greatly improve your application quality. MiCA is a new framework, and experts (lawyers or consultants who specialize in fintech licensing) can help interpret requirements, review documents, and even liaise with regulators informally before submission. While not mandatory, this guidance can prevent costly mistakes – such as omissions or misstatements in the application – that could delay approval.

By following these preparation steps, a company will be in a strong position when it’s time to officially apply. Essentially, think of the pre-application phase as “getting your house in order.” Regulators will scrutinize everything from your financial soundness to your IT protocols, so investing the time and resources to polish these areas in advance is not just advisable but often essential for success.

CASP Licensing Process

The process of obtaining a CASP license under MiCA involves several stages, typically proceeding as follows (note that specific procedures can vary slightly by country):

Preparation of Documentation

(Stage 1) – First, compile the full set of required documentation as outlined above. This includes drafting the business plan, operational program, risk and compliance policies, AML/CFT procedures, IT security descriptions, and details on key personnel and shareholders. Every claim in the application should be backed by documented plans or policies. At this stage, it’s common to have multiple revisions of documents as you incorporate feedback from internal teams or advisors. Double-check that everything aligns with MiCA’s criteria (for example, ensure your risk management policy explicitly addresses all risks mentioned in MiCA, and your IT description covers data encryption, access controls, etc., as expected by regulators).

Selecting a Jurisdiction for Licensing

(Stage 2) – While preparing the docs, you should decide on the EU member state in which to submit your application. MiCA sets uniform standards, but some national regulators have additional local rules or differing documentation formats. For instance, one country might require a specific form or an extra document (like a fit-and-proper questionnaire for each director), whereas another might integrate that into the main application. Choose the jurisdiction that best fits your business model and timeline. Consider regulatory fees and capital taxes as well – some countries might have higher incorporation or supervision fees. Also, language can be a factor: will you need to translate documents into the national language, or will English be accepted? All these practical considerations feed into the jurisdiction decision. Many crypto companies have gravitated toward jurisdictions like Lithuania, Estonia, or other fintech-friendly states for their early readiness to handle CASP applications, but each case is unique.

Submitting an Application

(Stage 3) – Once your documentation is ready for prime time, you will submit the formal application to the National Competent Authority (NCA) of your chosen country. Typically, there’s an online portal or a defined process for this. The application will include all the documents prepared, as well as application forms where you provide summary information. Key information regulators ask for in the application includes:

Corporate details: The company’s name, legal form (e.g. LLC, PLC), registered address, and contact information.
Service scope: A clear outline of the types of crypto-asset services you intend to offer (exchange, custody, advice, etc.). This determines the license class and helps the regulator know which parts of MiCA apply to your firm.
AML/CFT programs: A description of your anti-money laundering and counter-terrorist financing systems and procedures. Many regulators require a summary or dedicated section explaining how you will meet AML obligations (customer onboarding, monitoring, reporting of suspicious activity, etc.).
Business continuity & security: Your plans for ensuring operational continuity, handling emergencies, and protecting data. This may include summarizing your IT security measures and back-up plans.
Risk management & internal controls: An overview of how you identify, assess, and mitigate risks, and what internal control frameworks you have (internal audit, compliance function, etc.).
Management and ownership info: Details on directors, key managers, and shareholders (often with attached CVs, criminal record certificates, and financial history declarations to assess their fitness and propriety).

Along with the application, a state fee might need to be paid (the amount varies by country). After submission, the NCA will usually acknowledge receipt and might indicate if any initial information is missing.

Audit and Verification of Documentation

(Stage 4) – In this phase, the regulator reviews and verifies the information in your application. They will scrutinize the documentation against MiCA requirements and their own checklists. Common aspects of this review include:

Checking that the firm’s policies and procedures meet the standards – e.g. does the AML policy fulfill all elements of EU AML directives and MiCA? Is the IT description adequate for cybersecurity expectations?
Evaluating the financial information – ensuring the minimum capital is in place (you may need to show proof of funds in a bank account), and that financial projections are reasonable.
Vetting the management and shareholders – all key persons typically undergo a fit-and-proper test. The regulator may perform background checks, looking for any criminal records, past bankruptcies, or regulatory sanctions. They assess whether the directors have the necessary experience and good repute to run a crypto financial firm.
Assessing organizational readiness – the NCA will consider if your company structure and staffing are sufficient to carry out what you propose. For instance, if you claim to operate a large exchange but have only two employees, they will likely raise questions. The presence of qualified compliance, risk, and IT security personnel is often verified.
Ensuring completeness – if any document or detail is missing or unclear, the regulator will usually send a request for additional information or clarification. It’s common to go through a round (or multiple rounds) of Q&A with the regulator during this stage. Responding promptly and thoroughly to any inquiries is important to keep the process on track.

This audit phase has statutory time limits under MiCA: Regulators have up to 25 business days to do an initial completeness check of the application and inform you if anything is missing. Once they deem the file complete, they aim to approve or refuse the license within 3 months. In practice, however, the back-and-forth of questions can extend timelines. Complex cases or heavy regulator workload can lead to the review stage taking 6+ months. Patience and careful attention to the authority’s requests are key during this period.

Obtaining a License and Providing Services

(Stage 5) – If the regulator is satisfied that all criteria are met, they will grant the CASP license formally. You become an authorized crypto-asset service provider! At this point, your company is typically added to a public register of licensed CASPs, and you receive a license certificate or decision letter from the authority.

Being a licensed CASP means you can immediately start (or continue) providing the crypto-asset services outlined in your application, across the entire EU single market. Thanks to MiCA’s passporting provision, a CASP licensed in one member state can offer services in all other member states without needing separate licenses. The process usually requires a notification to the other countries’ regulators – basically, you inform them “we are licensed in X country and intend to serve clients in your country” – and no further authorization is needed. This ability to passport is one of the biggest advantages of the CASP regime, as it opens up a continental customer base under one regulatory umbrella.

It’s worth noting that even after obtaining the license, some operational conditions might apply at the start. For example, a regulator could grant a license with certain restrictions or recommendations, or they might want a follow-up audit after 1 year. But generally, once licensed, the CASP can scale its business, launch products, and market services across the EU, as long as it stays within the scope of authorization and complies with ongoing rules.

(Regulatory timeline: Officially, the review and approval process should be around 3-4 months by law, as mentioned. However, early experiences suggest it could take longer to actually get the license in hand. Companies should plan for a potential licensing timeline of 6–9 months from submission to approval, factoring in preparation and review delays. In any case, successful applicants by end of 2024 or 2025 will be among the first CASPs, positioning themselves advantageously in the regulated market.)

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Compliance with Standing Requirements

(Stage 6) – Authorization is not the end of the journey – MiCA imposes a host of ongoing obligations on CASPs. Upon obtaining the license, a company enters the supervision regime, meaning regulators will continuously monitor compliance. Key ongoing requirements include:

Periodic Reports: CASPs will need to file regular reports to their NCA, such as annual (or more frequent) financial statements, possibly compliance reports, and notifications of key metrics. Some countries might ask for quarterly updates on volumes or client numbers, for example. Additionally, significant incidents (like security breaches or outages) often must be reported immediately.
AML/CTF Continuous Compliance: The AML obligations are continuous. Firms must keep customer due diligence information up to date, monitor transactions in real-time for suspicious activity, and file Suspicious Transaction Reports (STRs) to the Financial Intelligence Unit when necessary. Regulators may conduct periodic inspections or audits of your AML processes. Ongoing training of staff in AML and fraud prevention is also expected.
Recordkeeping and Data Protection: The requirement to maintain records (discussed earlier) is ongoing. Also, CASPs must ensure they comply with data protection laws (like GDPR) in handling client data. MiCA explicitly ties in with these protections – for example, ensuring privacy of customer data and secure processing. Regular IT security assessments and updates are part of staying compliant.
Capital and Prudential Standards: A CASP must maintain the required capital at all times. If the business grows or risks increase, regulators might require additional capital or liquidity buffers. Likewise, if there are any major changes (like big losses that eat into capital), the firm must inform the regulator and potentially take corrective action. Some CASPs might also be subject to audits or stress tests on their financials as the regulatory framework evolves.
Change Management: If a CASP wants to change its services (add a new service category), expand to new jurisdictions, or undergo corporate changes (e.g. new significant shareholders, new directors), these typically have to be notified to the regulator, and in some cases pre-approved. For instance, MiCA has provisions that if a new person acquires a qualifying holding in a CASP (say more than 10% ownership), they need regulatory clearance. Similarly, replacing a CEO or compliance officer might require the NCA to vet the new person. Staying on top of these obligations is crucial to avoid inadvertently breaching license terms.
General Conduct: MiCA also includes conduct requirements – treating clients fairly, managing conflicts of interest (as discussed), not engaging in market abuse, etc. Post-licensing, authorities will expect CASPs to uphold high standards of integrity. Any hint of misconduct (like insider trading on your platform, or misleading marketing) can trigger investigations or sanctions.

In summary, obtaining the CASP license is a significant achievement, but maintaining it demands continuous diligence. Compliance becomes an ongoing discipline: successful CASPs will integrate these regulatory practices into their daily operations. The payoff is the ability to operate in a stable, regulated environment and gain the trust of customers, who know the firm is under oversight and held to rigorous standards.

Provision of Crypto-Asset Services from Abroad

One question that arises is whether a company based outside the EU can service EU clients without a CASP license. MiCA does address this scenario through what is essentially a “reverse solicitation” exemption. According to MiCA, a service provider from abroad does not need to obtain a CASP license if the crypto-asset service is provided at the exclusive initiative of the client in the EU. In other words, if an EU customer on their own accord seeks out a foreign crypto service provider (without any solicitation or advertising targeting them), the foreign provider can serve that client without being licensed in the EU for that specific service.

However, this exemption is narrowly defined and comes with important caveats:

It cannot be used as a loophole for solicitation. If the client was prompted, encouraged, or advertised to by the provider (or its agent/affiliate), then the service is not considered at the client’s exclusive initiative. For example, if a non-EU exchange runs marketing campaigns in the EU or has an affiliate referring EU clients to them, they cannot claim the reverse solicitation exemption. Any “close links” or actions on behalf of the provider to get the client invalidate the exemption.
It only covers the specific service the client initiated. If an EU client reaches out to a foreign platform to, say, execute a one-time crypto trade, the platform can do that without an EU license. But if that same provider then wants to offer additional services to the client (for instance, moving the client’s assets into a custodial wallet or offering them staking services that the client didn’t explicitly request), those would not be covered by the exemption. Essentially, the provider can’t use an inbound request as a foot in the door to deliver new unsolicited services; each new service would require authorization if not explicitly initiated by the client.

This “provision of services from abroad” clause ensures that offshore companies can’t bypass MiCA by simply operating from outside the EU while actively targeting EU customers. It allows for genuine cases where an EU investor independently uses a foreign service (much like how an EU person might visit a foreign country’s website on their own initiative), but anything that looks like a coordinated offering into the EU market will bring regulatory scrutiny. From a practical standpoint, the exemption is not a basis for a scalable EU business strategy – a crypto firm with any serious intention to serve the European market will need to get a CASP license in the EU, or partner with someone who has one.

Official Sources & Primary Legislation (MiCA / CASP)

Primary EU Acts

ESMA — MiCA & CASPs

European Commission — MiCA Level-2 (examples)

EBA — MiCAR (ART/EMT Issuers)

MiCAR resources & Q&As for ART/EMT issuers

National Competent Authorities (Application Portals — examples)

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