CASP License

Quick Facts

Item	Position
Regime	MiCA, with approval by the home national competent authority (NCA)
Establishment	EU registered office and effective management requirements
Service scope	Permissions cover specified activities
Prudential safeguards	Article 59 route: higher of €50,000/125,000/150,000 floor and one-quarter of fixed overheads
Review	Separate completeness and substantive assessment stages
Passporting	Article 65 notification for cross-border services
Service price	Starting from €35,000

Is This the Right Fit?

This route suits client-facing crypto businesses prepared to establish genuine EU operations. Under Article 59, the registered office must be in a Member State where some services are conducted, effective management must be in the EU, and at least one director must reside there.

Pure technology suppliers may fall outside the service perimeter. Decentralized finance (DeFi), tokenization, stablecoin issuance, securities and payment models need individual classification.

Which Regulatory Route Applies?

Applicant	Route and limitation
New crypto business	Article 59 authorisation through the home NCA
Credit institution	Article 60 notification to its home competent authority
Investment firm, UCITS manager or AIFM	Article 60 only for permitted equivalent services
Market operator	Article 60 for trading-platform operation
Central securities depository	Article 60 for custody and administration
Electronic money institution	Article 60 for custody and transfers of its own e-money tokens

Article 60 requires notification at least 40 working days before starting. It is not a blanket exemption for regulated firms.

Which Activities Are Covered?

The ten statutory crypto-asset services are:

1. Custody and administration on behalf of clients.
2. Operating a trading platform.
3. Exchange for funds.
4. Exchange for other crypto-assets.
5. Executing client orders.
6. Placing crypto-assets.
7. Receiving and transmitting client orders.
8. Providing advice.
9. Portfolio management.
10. Transfers on behalf of clients.

Token issuance alone is not one of these services. ART/EMT issuance, financial instruments and fund structures require separate analysis under the MiCA framework.

What Determines the Total Cost?

The cost of Gofaizen & Sherle application support depends on the services you plan to offer, your chosen EU country and how much preparation your business needs. Key factors include:

• Service scope: custody, exchange and trading-platform models require different policies, controls and supporting evidence.
• Existing setup: an established company with suitable management and documented procedures needs different support from a business starting from scratch.
• Operational complexity: outsourcing, technology providers, transaction flows and target markets affect the documentation required.
• Application readiness: missing evidence, policy revisions and responses to regulator questions influence the work involved.

The proposal should distinguish Gofaizen & Sherle professional fees from incorporation costs, regulatory fees, staffing, insurance, audit and technology expenses, identifying what is included and what is paid separately. Ongoing operating and compliance costs also need a separate budget.

Resources required to meet prudential safeguards are additional to the service budget. They are not fees paid to Gofaizen & Sherle or the regulator.

What Information Is Needed?

Initially, provide:

• the ownership/UBO structure
• qualifying holdings
• management profiles
• intended services
• clients
• markets
• transaction flows
• custody model
• ICT vendors
• outsourcing
• forecasts
• existing policies.

Identify your current entity, preferred home state, capital budget and target launch date.

These inputs define the engagement. The complete Article 62 dossier requires supporting evidence and service-specific policies.

How Long Does Review Take?

Article 63 provides 25 working days to check completeness and 40 working days to assess a complete application. An initial information request can suspend the assessment for up to 20 working days. Decision notification follows within five working days.

Preparation, missing documents, national pre-filing discussions and launch readiness add time. These statutory periods are not an end-to-end delivery promise.

What Are the Capital and Financial Safeguard Requirements?

Under Annex IV to MiCA (Regulation (EU) 2023/1114), the minimum capital threshold is €50,000 for execution, placing, transfers, order transmission, advice or portfolio management. Custody or exchange raises it to €125,000. Trading-platform operation requires €150,000.

Article 67 requires the higher of that floor and one-quarter of preceding-year fixed overheads, reviewed annually. New firms use first-year projections. Qualifying own funds, insurance or comparable guarantees, or a combination, may provide the safeguards. Article 60 entities follow their applicable sectoral prudential rules.

Has the Transition From National Rules to MiCA Ended?

Yes. The maximum EU transitional period ended on 1 July 2026. It allowed eligible existing crypto businesses to continue temporarily under national rules while moving to MiCA authorisation. Some Member States ended this arrangement earlier. A pending application does not extend permission to operate.

Position checked: 18 September 2026

What Has Changed?	What Does It Mean for Your Business?
National transitional arrangements have expired	A former national registration alone no longer permits continued provision of services requiring MiCA authorisation. ESMA requires unauthorised providers to stop onboarding new EU clients and wind down affected activities while protecting client assets.
Authorisation must cover the operating entity and its services	Check the exact company and permitted activities in the ESMA Interim MiCA Register, which also lists non-compliant entities.
Applications must meet current implementation requirements	Use applicable technical standards and supervisory guidance. Confirm filing procedures, fees and local requirements with the competent authority in the chosen EU country.

What Should You Check Before Choosing an EU Country?

MiCA provides a common authorisation framework, but national procedures and local operating conditions affect where your business can establish and operate effectively.

What to Check	Why It Matters for Your Project
Application language, regulatory fees and pre-filing procedures	Determine translation costs, the filing budget and whether preliminary discussions with the regulator are needed.
Company law, management, staffing and local presence requirements	Confirm the permitted legal structure, corporate obligations, staffing and decision-making arrangements needed for your operating model.
National AML/CFT rules and the responsible supervisor	Identify the local requirements your policies, reporting procedures and compliance responsibilities must address.
Tax, employment and ongoing reporting obligations	Estimate recurring costs and the resources needed to maintain the company after authorisation.

Assess these factors against your planned services, team and target markets before choosing where to apply.

What Continues After Approval?

Maintain governance, conduct standards, safeguarding, complaints handling, conflict controls, outsourcing oversight and regulatory reporting. Assess ownership and management changes before implementation.

Article 68 requires records for five years, extended up to seven at the authority’s timely request. Apply national AML/CFT rules, Travel Rule requirements and DORA according to their scope and proportionality provisions.

What Are the Regulatory Risks?

Unauthorised operations can trigger cessation orders and sanctions. Serious breaches can lead to withdrawal of authorisation. Do not market a pending application as approved status.

How Do Banking and Payments Fit?

Business Need	What Is Required	Supporting Evidence	G&S Support
Company bank account	Bank approval	Owners, funding sources, transaction flows	Prepare application documents
Holding clients’ fiat money	Safeguarding arrangements	Separate client accounts	Assess safeguarding requirements
Holding clients’ crypto-assets	Custody authorisation	Asset segregation controls	Prepare custody policies
Providing payment services	Payment authorisation or authorised provider	Payment flows, countries served	Assess required permissions

CASP authorisation neither guarantees a bank account nor replaces payment permissions. Article 70 addresses these distinctions. Payments involving e-money tokens need separate assessment.

How Is the Business Taxed?

MiCA sets no common corporate tax rate. Review residence, permanent establishments, VAT, transfer pricing, payroll and withholding locally. DAC8 covers reportable transactions from 2026, with first reporting in 2027 under domestic deadlines. Assess CARF implementation separately where relevant.

Which Other Permissions Might Apply?

Business model	Additional or alternative framework
Securities or investment services	MiFID and relevant investment permissions
Payments or e-money	PI/EMI rules
Non-EU crypto operations	Relevant national VASP regime