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MiCA CASP licensing in Estonia and the EU
We take crypto-asset businesses through authorisation as a crypto-asset service provider (CASP) under Regulation (EU) 2023/1114, the Markets in Crypto-Assets Regulation, from the first perimeter question to the supervisor's decision and the passporting notifications that follow. Estonia is our home jurisdiction, and the same file structure stands up in front of any EEA supervisor.
Three numbers shape every project. The own-funds classes are EUR 50,000, EUR 125,000 and EUR 150,000, or 25% of the previous year's fixed overheads where that is higher. The review clock at Finantsinspektsioon is 25 working days to confirm that a file is complete and 40 working days to decide on a complete application, and the assessment can be paused for up to 20 working days while the supervisor waits for information. The processing fee is EUR 3,000.
Since 1 July 2026 the old route into the Estonian market is closed. Every virtual-currency service licence issued by the Financial Intelligence Unit lost validity on that date and the register entries were cancelled, so only firms authorised under MiCA by Finantsinspektsioon or by another EEA supervisor may provide crypto-asset services in Estonia. As at 11 August 2026 exactly one Estonian CASP authorisation had been granted, to Lightspark Payments Europe AS.
How a CASP authorisation runs:
01
Perimeter and class scoping
We map the product against MiCA's closed list of crypto-asset services, settle which services you are actually applying for, and fix the own-funds class that follows from them. Where an activity sits outside the perimeter, or belongs to a different regime, we say so in writing before any drafting starts.
02
Entity, own funds and substance
The applicant company, its governance, the directors and key function holders the supervisor will assess, and evidence of own funds at the class minimum or 25% of the previous year's fixed overheads, whichever is higher.
03
The Article 62(2) file
MiCA Article 62(2) sets out the 18 categories of information an application must contain: the programme of operations, governance arrangements, the AML/CFT framework, safeguarding and segregation of client assets, ICT and security policies, complaints handling, conflicts of interest and the rest. We draft them as one coherent set, not as 18 unrelated annexes.
04
Filing and the supervisor's clock
Applications go to Finantsinspektsioon through its portal, in Estonian or English with a signed declaration, against a EUR 3,000 processing fee. The supervisor has 25 working days to confirm completeness and 40 working days to decide on a complete application, and may pause the assessment for up to 20 working days while it waits for information from you.
05
Passporting and life after the licence
An authorised CASP reaches the rest of the EEA on a home-to-host notification rather than a fresh application. We handle those notifications, and the reporting, outsourcing and change-of-control obligations that start on the first day of the licence.
The class you apply in is set by the services, not by the size of the business. Class 1, at EUR 50,000, covers reception and transmission of orders, advice, portfolio management, transfer services, placing, and execution of orders. Class 2, at EUR 125,000, adds custody and administration of crypto-assets on behalf of clients and the exchange of crypto-assets for funds or for other crypto-assets. Class 3, at EUR 150,000, adds operating a trading platform. A firm that spans classes holds the highest applicable minimum, and in every class the requirement is the higher of that figure and 25% of the previous year's fixed overheads.
Those minimums are a floor, not a budget. What the supervisor assesses is whether the business can be run safely: working capital beyond the minimum, named people with the time and the record to do the jobs the file describes, and operational arrangements that exist rather than being promised.
If you held an Estonian virtual-currency licence that stopped authorising anything on 1 July 2026, the position is different again, and it is time-sensitive. A firm whose application was already with Finantsinspektsioon on that date must limit its active operations until the decision arrives. A firm with no application on file is outside the regime altogether, and chooses between applying here, applying through another EEA supervisor, or winding the EU-facing business down in an orderly way.
Services we provide in MiCA CASP licensing:
- Perimeter and token-classification opinions: whether MiCA applies, and in what capacity
- CASP class selection and own-funds planning across Classes 1, 2 and 3
- Applicant company formation, governance and local substance in Estonia
- Fit-and-proper files for directors, shareholders and key function holders
- The full MiCA Article 62(2) application file, drafted end to end
- AML/CFT programme, business risk assessment and the compliance officer function
- Safeguarding and segregation arrangements for client crypto-assets and funds
- ICT, security, business-continuity, outsourcing and complaints-handling policies
- Filing with Finantsinspektsioon and the dialogue through to the decision
- Passporting notifications across the EEA and post-authorisation obligations
- Remediation after a refusal, and orderly wind-down where authorisation is not the answer
Frequently asked questions
We are ready to take on non-standard projects
Averium runs CASP authorisations end to end in Estonia and across the EEA, and will tell you in the first conversation whether the licence you are asking about is the one you actually need.
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