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Markets in Crypto-Assets Regulation (MiCA) – CASP License in EU

MiCA CASP LICENSE
WE'VE GOT YOU COVERED

Complium simplifies MiCA compliance for existing VASPs and new CASPs,
guiding you through the EU licensing process with confidence.

What’s the MiCA CASP license?

The new MiCA (Markets in Crypto-Assets) regulation introduces unified EU-wide requirements  for crypto businesses. A Mica CASP license is recognised across all EU member states and it covers operations in any EU state (e.g. same as for an EMI license).

Under MiCA, companies currently classified as VASPs (Virtual Asset Service Providers) will be reclassified as CASPs (Crypto-Asset Service Providers) and must obtain the new license to operate legally in the EU. Expected to start on January 1st, 2025 (though the exact date might vary by jurisdiction), all existing VASPs must apply to secure their MiCA CASP license.

Who needs a MiCA CASP license?

  • Current VASP (virtual service provider) license holders
  • New crypto businesses who wish to operate in the EU
  • Companies providing crypto-asset services

At Complium, we simplify the MiCA CASP licensing process. Leveraging our strong connections, extensive experience, and proven success with EMI, PI, and crowdfunding licenses, we are well-equipped to navigate the new MiCA CASP regulations. Our expertise ensures a smooth transition for VASPs to achieve a pan-European MiCA CASP license.

How to get started

While MiCA CASP license applications are expected to officially open on January 1, 2025 (though the exact date might vary by jurisdiction), the transition to this new regulatory framework is complex and time-consuming. Existing VASPs will face a limited transition period, which varies depending on the jurisdiction. If a VASP does not apply for the CASP license within this transition period, their current VASP license will expire after six months. Additionally, the regulatory authority overseeing applications will change in our specialized areas.

To ensure a smooth transition, we recommend starting preparations now:

  • Draft necessary policy documents
  • Set up a local office
  • Assemble a team of experienced AML professionals

Thorough and timely preparation is crucial for a successful transition to MiCA compliance.

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READY-STEADY-GO

MiCA license key points and requirements
for existing and new CASPs

Existing VASP
holders

To ensure a seamless transition, current VASPs should align their operations with the MiCA regulations to prepare for the upcoming regulatory changes. For VASP license holders, we highlight three essential areas to focus on for a successful MiCA CASP license application:
Capital Requirements

MiCA mandates increased capital requirements, up to €150k, to ensure financial stability, protect customer interests, and establish market entry thresholds. We assist with capital injection procedures and provide banking advisory services for setting up an EU credit institution account.

AML Compliance and Internal Policies

MiCA necessitates robust internal policies for control mechanisms, risk assessment, confidentiality, and fund protection. Our expert lawyers are available to review and prepare all necessary legal documentation.

Local Presence

MiCA requires a physical office, EU-based management with at least one EU-resident director, and senior AML compliance roles such as CCO and MLRO. Regulatory expectations vary by jurisdiction. We offer team staffing and local management solutions to meet these requirements.

New CASP license
capital requirements

The MiCA regulation specifies different share capital class requirements depending on the type of CASP activities. To prevent administrative delays and issues, we strongly advise increasing your VASP company’s capital in the registry now.
Class 1 CASP

Requires €50,000 capital for crypto-asset  services including:

  • Reception and transmission of orders on behalf of third parties; and/or
  • Providing advice on crypto-assets; and/or
  • Execution of orders for third parties; and/or
  • Placement of crypto-assets
Class 2 CASP

Requires EUR 125.000 capital for any crypto-asset services under Class 1 and:

  • exchange of crypto-assets for fiat currency that is legal tender;
  • exchange of crypto-assets for other crypto-assets;
  • operation of a trading platform for crypto-assets.
Class 3 CASP

Requires EUR 150.000 capital for any crypto-asset services under Class 2 and:

  • custody and administration of crypto-assets on behalf of third parties.

Please note: CASPs should also maintain at least one bank account with an EU-based credit institution (an EMI bank account does not qualify).

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READY FOR TRANSITIONMiCA License application
process and timeline


The MiCA will come into effect for crypto exchanges in December 2024, and license applications expected to open on January 1, 2025. The EU Member States have the option to offer currently licensed VASPs an additional “transitional period” of up to 18 months, allowing them to continue operations without a MiCA license (“grandfathering clause”). This means existing VASPs could potentially operate until as late as July 1, 2026, although the exact deadline may vary depending on how each Member State’s jurisdiction applies these optional transitional measures under Article 143(3) of MiCA.

  • CCO/MLRO Requirement
  • MiCA license application
  • MiCa policy documentation
  • Notes

We offer various solutions to meet regulatory substance requirements. For example, we can assist with establishing a local physical office and recruiting highly qualified professionals for key roles such as Chief Executive Officer (CEO), Chief Compliance Officer (CCO), and Money Laundering Reporting Officer (MLRO). Our services also include ongoing training and support with office and team management.

The responsibilities of a Chief Compliance Officer (CCO) include, but are not limited to:

  • Overseeing internal controls and ensuring proper data management.
  • Reporting to relevant agencies such as the statistics and data protection agencies.
  • Meeting local regulatory deadlines, including compliance with AML requirements, data protection, fraud prevention, IT security, and privacy procedures.

The duties of a Money Laundering Reporting Officer (MLRO) include, among others:

  • Supervising and monitoring compliance functions and handling reporting duties.
  • Managing customer communications for Enhanced Due Diligence (EDD), Customer Due Diligence (CDD), and Other Due Diligence (ODD) document collection.
  • Reviewing KYC (Know Your Customer), KYB (Know Your Business), and KYT (Know Your Transaction) reports and reporting to the CEO/CCO and to the authorities.

The required local substance and staffing levels will depend on your business model (inc. business plan) and trading volumes. We can provide tailored recommendations following a preliminary analysis.

For a CASP license application, we start with a detailed legal assessment of your business model, shareholding structure, policy documents, and AML compliance systems. From there, we create a tailored plan and manage every step of the licensing process. Below are some key requirements outlined in MiCA Article for the necessary application documentation.

  • Programme of Operations: This plan details the crypto-asset services the applicant aims to provide, including their marketing strategies and geographic reach. It includes a comprehensive three-year roadmap for both regulated and unregulated activities, outlines the target client demographics, and describes the outsourcing policy, covering intra-group arrangements and external service providers. Additionally, it provides financial forecasts and outlines plans for exchanges and other key activities.
  • Business Continuity Policy: This includes a disaster recovery plan, internal control mechanisms, and robust procedures for risk assessment. It outlines systems and protocols to protect the security, integrity, and confidentiality of information. CASPs must also implement systems to monitor and detect market abuse. Additionally, the policy must address outsourcing requirements and establish effective measures to prevent, identify, manage, and disclose conflicts of interest.
  • CASPs must establish strong measures to protect their clients’ assets, especially in case of insolvency, and to prevent the misuse of client funds for their own purposes. Client funds should be held in segregated accounts at an EU credit institution. Additionally, CASPs must secure adequate insurance coverage to protect against theft or loss of assets.

Below is a comprehensive list of the essential documentation, policies, and regulations required for the CASP license, each of which needs to be customized for the individual applicant. At Complium, we manage every aspect of the licensing process, ensuring a seamless and efficient application experience.Rest assured, we are here to support you every step of the way, so you can focus on your business while we handle the complexities of obtaining your CASP license.

  1. Programme of Operations – article 17(1)(b)(i) of MiCA
  2. Client Information and Best Interest Policy – Article 66 of MiCA
  3. Insurance Policy – Article 67(4)(b) of MiCA
  4. ICT Systems Security Policy – Article 68(7) of MiCA
  5. Market Abuse Monitoring and Reporting Policy – Article 62 (2)(n) and 92 of MiCA
  6. Client Crypto-Asset Safeguarding Policy – Article 70 of MiCA of MiCA
  7. Client Complaint Handling Policy – Article 71 of MiCA
  8. Conflict of Interest Policy – Article 72 of MiCA
  9. The Outsourcing Management Policy – Article 73 of MiCA
  10. Custody Policy – Article 75 of MiCA
  11. Trading Platform Operating Rules – Article 76 of MiCA
  12. Non-Discriminatory Commercial Policy – Article 60(7)(g) of MiCA
  13. Order Execution Policy (if applicable) – Article 70 of MiCA
  14. Governance Arrangements – Article 34(1) and 68 of MiCA
  15. Internal Control Policy – Article 34(10) of MiCA
  16. Business Continuity Policy – Article 34(9) and 62(2)(i) of MiCA
  17. IT Systems and Security Arrangements Policy – Article 34(9) and 62(2)(j) of MiCA
  18. Proof of Meeting Prudential Safeguards Documentation Policy – Article 62(2)(e) of MiCA
  19. Client’s Crypto-Assets and Funds Segregation Procedures Policy – Article 37(6)(d) and 62(2)(k) of MiCA
  20. Subsidiary Relationship Information Documentation – Article 55(4) of MiCA
  21. Compliance Assessment Documentation – Article 55(5) of MiCA
  22. Cross-Border Service Provision Information Documentation – Article 65 of MiCA
  23. Notification of Cross-Border Activities Documentation – Article 65 of MiCA
  24. AML Policy
  25. Whistleblowing Policy

For the complete MiCA regulation, please visit: Regulation (EU) 2023/1114 of the European Parliament and of the Council of 31 May 2023 on markets in crypto-assets, and amending Regulations (EU) No 1093/2010 and (EU) No 1095/2010 and Directives 2013/36/EU and (EU) 2019/1937 (Text with EEA relevance)

The MiCA CASP license may be terminated by the regulator for several reasons beyond just regulatory non-compliance. This includes situations where licensed activities have not started within 12 months of the license being granted or if crypto-asset services have not been provided for a span of 9 months.

Furthermore, MiCA outlines financial penalties that range from 3% to 12.5% of the entity’s total annual turnover, along with the option for periodic fines. The regulator also has the authority to suspend or withdraw the license and to prohibit individuals from holding managerial positions.

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How long does it take to get the MiCA CASP license?

The MiCA license application process involves submitting the application to the regulator, who has up to 25 business days to review its completeness, providing a deadline if additional information is required. Once accepted, the regulator will evaluate the CASP license applicant’s compliance with the requirements within 3 months and issue a reasoned decision, notifying the applicant within 3 business days. Although the expected timeframe for licensing is about 4 months, based on prior experience with crowdfunding and EMI licenses, we anticipate the process may take twice as long.

STEP-BY-STEP GUIDE

Get ready for the MiCA CASP license
we’ve got you

With a proven track record of managing over 500 VASP licenses since the onset of EU crypto regulations and a team of more than 30 seasoned AML professionals and lawyers, we are ideally positioned to support your VASP company. Our expertise will ensure a successful MiCA CASP license application and thorough handling of all related legal documentation.

Obtaining MiCA CASP license
with Complium

For existing VASP license holders, we strongly advise a phased approach to MiCA compliance. This will help you secure top-tier specialists and manage their availability effectively as the deadline approaches.
Initial assessment

Stage 1

Enterprise Wide Risk Assessment (EWRA)

Objective: Thorough evaluation of your business plan, AML procedures, and IT infrastructure and your website.

Outcome: Comprehensive legal report identifying necessary improvements for MiCA licensing.

Budget: Approximately 50 hours of legal work

Documentation and preparation

Stage 2

MiCA Required Policy Documentation

Objective: Address and resolve any deficiencies identified in the EWRA analysis.

Outcome: Complete set of policies, procedures, and rules necessary for MiCA compliance.

Budget: Legal fees will be provided after Stage 1

MiCA CASP License

Stage 3

MiCA CASP License Application

Objective: Prepare and submit the CASP license application, including all necessary correspondence with the regulator.

Outcome: Obtain the MiCA CASP license to operate across the European Union.

Budget: Estimated legal work of 80 hours

The hourly rate for MiCA licensing includes both our partner attorney-at-law and a senior AML compliance specialist. All quotes are preliminary and subject to review and final confirmation; conditions may apply. Pricing for packages is indicative and will be finalized based on additional details provided. Additional fees may be incurred. We reserve the right to adjust pricing and package details at any time without prior notice. For a detailed, project-specific quote, please contact us directly.

On-Going Support

On-Going Support for VASPs (future CASPs)

At Complium, we don’t just help you obtain your MiCA CASP license—we provide comprehensive, ongoing support to ensure your business remains fully compliant with evolving regulations. Our services include:

Quarterly Statistical Reports: We assist in preparing and submitting required quarterly reports to regulatory authorities, keeping your business compliant at all times.
Over Threshold & Suspicious Transaction Reporting: We handle reporting on Suspicious Activity Reports (SARs) and high-value transactions over €15,000, ensuring transparency and adherence to AML requirements.
Expert Advisory Services: Our team of AML and regulatory specialists is available to provide ongoing guidance, helping you navigate any challenges or regulatory updates that may arise.

This allows you to focus on growing your business, knowing your compliance needs are taken care of.
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WHY COMPLIUM? Get expert guidance
on MiCA CASP licensing

Complium operates in multiple European jurisdictions, giving us deep insight into the regulatory landscape across countries. With experience working in Poland, Lithuania, and other EU regions, we can compare laws and regulations to find the best solutions for your specific needs. We also have strong relationships with law enforcement and governmental authorities, ensuring smooth cooperation and compliance in any jurisdiction.

MiCA CASP
License Application
Quarterly Compliance
Reports
Local Presence
Support
AML Compliance &
Reporting
Transaction
Reporting
Ongoing Advisory
Services

CONTACT FORMBook your
FREE 30-min consultation

Our team will get back to you shortly!
Let our experts guide you through the process.

    On our Clients’ request, through our network of trusted partners, we can offer additional services such as GDPR compliance and accounting, providing a complete package of services. With everything handled through one entity, there’s no need for clients to seek out multiple advisors—Complium covers all your needs under one roof.

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    KEY FACTS

    MiCA CASP License FAQs

    MiCA is expected to come into effect for crypto exchanges in December 2024, with license applications expected to open on January 1, 2025
    Is MiCA compliance mandatory for all existing VASPs in the EU?

    Yes, MiCA compliance is mandatory for all existing Virtual Asset Service Providers (VASPs) operating in the European Union. Under MiCA, VASPs will be reclassified as Crypto-Asset Service Providers (CASPs) and must obtain the new license to operate legally in the EU.

    Who are exempt from MiCA legislation?

    Some entities are exempt from MiCA, including the European Central Bank, national central banks, and public authorities. Public international organizations and persons who provide crypto-asset services exclusively for their parent companies, for their own subsidiaries or for other subsidiaries of their parent companies

    When do VASPs need to be compliant with MiCA?

    MiCA is expected to come into effect for crypto exchanges in December 2024, with license applications expected to open on January 1, 2025 (though this may vary by jurisdiction). Existing VASPs will have a limited transition period, which also varies depending on the jurisdiction. If a VASP doesn’t apply for the CASP license within this period, their current VASP license will expire after six months.

    What are the key requirements under MiCA for existing VASPs?

    Under MiCA, existing Virtual Asset Service Providers (VASPs) must meet several key requirements to continue operating legally within the EU:

    • Reclassification: Existing VASPs must transition to Crypto-Asset Service Providers (CASPs) by obtaining the MiCA CASP license.
    • AML Compliance: VASPs need to maintain robust Anti-Money Laundering (AML) procedures and internal control systems to meet the new standards.
    • Capital Requirements: VASPs must meet updated capital thresholds based on their services.
    • Reporting & Transparency: Enhanced transparency, record-keeping, and reporting obligations must be adhered to, particularly for customer information and financial data.
    • Local Presence: VASPs are required to establish a physical presence in the EU, including local management and compliance officers.
    • Consumer Protection: There are new measures to ensure better protection for customers and secure handling of assets.
    What are the key capital requirements for new CASPs?

    MiCA outlines different capital requirements for new CASPs (Crypto-Asset Service Providers) based on the services they provide:

    • Class 1 CASP: Requires €50,000 in capital for services like advising on and executing crypto-asset orders.
    • Class 2 CASP: Requires €125,000 for additional services, including exchanging crypto-assets for fiat or other crypto-assets, and operating a trading platform.
    • Class 3 CASP: Requires €150,000 for services that involve custody and administration of crypto-assets on behalf of third parties.

    Additionally, CASPs must maintain at least one bank account with an EU-based credit institution, ensuring proper financial oversight and stability.

    How can Complium help my business obtain a MiCA license?

    Complium provides comprehensive legal and compliance services to assist businesses in obtaining and maintaining MiCA CASP licenses. Our services include:

    Initial Assessment: We conduct a thorough evaluation of your current operations to identify areas requiring attention for MiCA compliance.

    Documentation Preparation: Our legal team prepares all necessary documentation, including policy papers and procedural guidelines, tailored to your specific business model.

    License Application Support: We manage the entire application process, handling all communications with regulatory authorities to ensure an efficient licensing procedure.

    Ongoing Compliance Assistance: We provide continuous support to help maintain compliance as regulations evolve.

    AML Expertise: Our AML specialists develop robust policies and procedures to ensure your operations meet all anti-money laundering requirements.

    Staffing and Local Presence Solutions: We assist in recruiting qualified professionals for key roles and help establish the necessary local presence to meet regulatory requirements.

    With extensive experience in crypto regulations, Complium is well-positioned to guide your business through the MiCA compliance process efficiently and effectively.

    What happens if my business doesn’t comply with MiCA?

    If your business does not comply with the MiCA regulation, it may face several consequences, including:

    • Fines and Penalties: Non-compliance can result in financial penalties ranging from 3% to 12.5% of your business’s annual turnover, depending on the severity of the breach.
    • License Revocation: Failure to comply with MiCA requirements may lead to the suspension or revocation of your CASP license, preventing your business from operating within the EU.
    • Reputational Damage: Non-compliance can harm your business’s reputation, reducing trust from customers and investors.
    • Ban from Management Positions: Individuals in managerial positions may be banned from holding similar roles if found responsible for significant non-compliance issues.
    • Restricted Operations: Without proper compliance, your business may be restricted from offering certain services or expanding within the EU market.

    Ensuring compliance with MiCA is critical to avoid these risks and continue operating within the EU’s regulatory framework.

    How long does the MiCA licensing process take?

    The MiCA licensing process typically takes around 4 months, although it may take longer depending on the complexity of the application and the jurisdiction. After submitting the application, the regulator has 25 business days to review its completeness. Once the application is deemed complete, the regulator has 3 months to issue a decision.

    What documentation is required for the MiCA license application?

    Some of the most important documentation includes (see above to see the full list of documents needed):

    • Programme of Operations (detailing services and operations)
    • AML and risk management policies
    • Business continuity and internal control policies
    • Proof of capital requirements
    • IT and data security policies
    • Client asset safeguarding and insurance policies
    • Outsourcing policies, if applicable
    • Corporate governance and management structure documentation Each document must align with MiCA regulations and be tailored to your specific business operations.
    Will my business need to update its compliance policies to meet MiCA requirements?

    Yes, most businesses will need to update their compliance policies. MiCA requires enhanced AML procedures, robust risk management, secure IT systems, and comprehensive client asset protection measures. Additionally, businesses must align their governance structures with MiCA requirements, including having EU-based management and compliance officers.

    What are the benefits of being MiCA-compliant?

    Being MiCA-compliant offers several advantages:

    • Pan-EU operations: A MiCA CASP license allows you to operate legally across all EU member states.
    • Increased market trust: Compliance with unified regulations builds trust among clients and investors.
    • Operational clarity: MiCA provides clear rules for crypto businesses, reducing uncertainty.
    • Regulatory alignment: MiCA compliance ensures that your business meets stringent AML and security standards, protecting against penalties and legal risks.
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    MICA CASP LICENSE
    WE'VE GOT YOU COVERED

    Don’t worry about your MiCA license! Together we get it done.
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    OFFICE DETAILSOffice

    Poland office: +48 222 085 280
    Estonian office: +372 5874 6380
    office@complium.eu

    COMPANY DETAILSCOMPLIUM LLC

    Registry code: 14996517
    VAT number: EE102267505
    Office: Tornimäe 3//5//7, Tallinn, 10145, Estonia

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