Crypto license in Estonia

What Are the Requirements for Obtaining a CASP License in Estonia?

According to Finantsinspektsioon, to obtain a CASP license in Estonia, a CASP application must comply with Article 62 MiCA, meeting the following requirements specified in Annex V of the ESMA regulatory technical standards:

• a legal entity must be established in the required legal form;
• articles of association must be developed and submitted;
• a business plan must include a detailed programme of operations with details of how those services will be marketed and delivered;
• adequate prudential safeguards must be offered;
• an organisational and management structure must be prepared, with clearly defined responsibilities;
• proper managers and a director must be appointed and have a good reputation and required skills and experience;
• adequate systems and security procedures must be demonstrated;
• AML/CFT policies must be drafted.

The list of documentation can be expanded. To get detailed information, you can reach out to the SBSB team of fintech lawyers for consultation. 

What Are the Capital and AML/KYC Requirements for CASPs in Estonia?

The capital requirements for CASPs are set out in Annex IV of MiCA and apply to all EU member states. The minimum capital depends on the service class in the following way:

• Class 1 – €50,000;
• Class 2 – €125,000;
• Class 3 – €150,000. 

Estonian CASPs are subject to the Money Laundering and Terrorist Financing Prevention Act (MLTFPA) together with the applicable EU AML framework and MiCA requirements. They must identify and verify customers, verify the beneficial owners for corporate customers, monitor transactions, and report suspected money laundering or terrorist financing to the competent Estonian authorities in accordance with the MLTFPA. Additional measures must be taken where a customer or transaction presents a higher level of AML/CFT risk. 

How Does the CASP Licensing Process Work in Estonia?

Since March 2026, CASP licence applications have been submitted through a dedicated digital portal. The application review typically lasts up to 8 months, with a detailed check and communication between the applicant and the regulator. 

What Are the Steps to Apply for a CASP License in Estonia?

When obtaining a CASP license in Estonia, a registered entity meeting the above requirements must:

1. Prepare the application with required documents. 
2. Submit the application package online through the Finantsinspektsioon Application Portal.
3. Pay the application fee that is €3,000.
4. Wait until the regulator checks competences within 25 working days.
5. Provide missing documents where required.
6. Wait until the regulator reviews an application and assesses it within 40 working days. 
7. Receive the regulator’s decision within the applicable MiCA procedure.

The assessment period may be suspended for up to 20 working days, where additional information is required.

How Is a CASP Company Incorporated in Estonia?

A business applying for a CASP licence in Estonia must first establish an Estonian legal entity. In practice, an OÜ (osaühing), the Estonian private limited company, is typically preferred. The company must choose and reserve its name, determine activities, and prepare the founding documents. Then the management board is appointed, and the local office is registered. Once the applicable capital contribution requirements are met, the incorporation application is submitted to the Estonian Commercial Register. Upon registration, a company receives a registry code and can start preparing documents for a CASP licence.