Crypto License in Czech Republic

Last Update: 14.10.2026

Gofaizen & Sherle helps businesses assess their model, establish an entity and prepare an application. A “crypto license” means authorization as a crypto-asset service provider (CASP) under the Markets in Crypto-Assets Regulation (MiCA). The Czech National Bank (CNB) assesses the application and decides which services to authorize.

Service Snapshot

Regulator

CNB
Regime

MiCA
Permission

Authorization, or notification for eligible institutions
Services

Only the permitted scope
Financial Safeguards

Depend on services and overheads
Establishment

EU office and management requirements
EU Passporting

Cross-border notification required
Current Status

Previous transitional permission has expired
Timing

Preparation and regulatory review differ

Is This Route Right for Your Business

Suitable: businesses serving customers through exchange, custody or other regulated services.

Separate assessment: token issuance, including asset-referenced and electronic-money tokens, and payment services need their own assessment. Issuance grants no CASP permission.

Outside this scope: tokens qualifying as financial instruments fall under securities rules, including the Markets in Financial Instruments Directive (MiFID).

Choose the Regulatory Route

Activity	Legal Route	Authority	Output	Limitation
Independent services	Articles 59/63	CNB	Authorization	Approved services only
Eligible regulated institution	Article 60	Home regulator	Notification	Eligible institution/service combinations only
Token issuance	Issuer rules	Relevant regulator	Issuer outcome	Separate permission
Financial instruments	MiFID	Relevant regulator	Securities assessment	Outside MiCA

Article 60 requires notification at least 40 working days before starting; it is unavailable to ordinary startups.

Regulated Crypto Asset Services

Each service needs the corresponding permission:

Custody: Safekeeping customer assets requires asset protection.

Exchange: Exchange for funds and exchange for crypto-assets are distinct services; safeguards depend on assets handled.

Trading platforms: Operating a marketplace requires platform rules and asset-handling controls.

Orders and placing: Execution carries out orders; reception/transmission passes them onward; placing markets assets for an issuer. Safeguards depend on handling.

Advice and portfolio management: Recommendations and managed investments require suitability checks; any asset handling needs separate assessment.

Transfers: Moving assets for customers requires transfer permission and applicable sender/recipient information.

What Gofaizen & Sherle Will Handle

Assess activities and jurisdiction using your business model.
Support company formation and prepare agreed governance, anti-money-laundering (AML) and customer-identification (KYC) documentation.
Prepare application materials and support regulator communication; you provide evidence, funding and working controls.

Scope and Costs

Choose the support you need; professional fees are agreed individually.

Support	Deliverables	Exclusions	Professional Fee	Official and Other Costs	Financial Safeguards
Assessment	Model and route review	Application submission	Agreed individually	Third parties separate	Calculate required protection
Application support	Agreed documents and communication	Operating the business	Agreed individually	CZK 20,000 receipt fee; third-party/ongoing costs separate	Demonstrate financial protection

Recheck the official payment requirements before filing.

For Article 63 applicants, Article 67 requires ongoing financial safeguards equal to the greater of the service-class floor or one quarter of prior-year fixed overheads. New businesses use forecasts for their first 12 months.

Floors are €50,000 for orders, placing, transfers, advice and portfolio management; €125,000 for custody/exchanges; €150,000 for platforms. Use the highest applicable class, without adding floors. Protection can use company funds meeting MiCA capital rules, insurance or comparable guarantees meeting Article 67, or a combination. Evidence accompanies the application. These resources are neither fees nor merely nominal company capital. Article 67 does not apply to eligible Article 60 institutions.

Expert Contact

Maksim Gasanbekov

Partner, Head of Sales (Crypto and Blockchain)

+65 3159 3338 maksim@gofaizen-sherle.com

How the Application Process Works

Step 1 Assess: you and Gofaizen & Sherle define services and entity readiness.

Step 2 Prepare: Gofaizen & Sherle assembles agreed documents, you implement controls and resolve evidence gaps.

Step 3 Submit: CNB checks completeness, requests information and assesses the application. It may authorize specified services or refuse.

Step 4 Launch: start only permitted services once operationally ready.

To offer services across the EU through passporting under Article 65, notify the home regulator of destination countries, services, start date and other activities. It forwards this information within 10 working days. Cross-border services can begin upon notice of that communication or, at latest, the 15th calendar day after submitting the information.

What We Need From You

For the application: identity, corporate, ownership and management records identify the business, alongside its Legal Entity Identifier (LEI), a unique organizational code. Plans, forecasts and safeguard evidence demonstrate financial readiness.

For operations: governance, risk/AML, technology and continuity, outsourcing, safeguarding, complaints and service-specific policies explain how controls work. Article 62 requires a full application tailored to your services.

Review Stages and Timing

Step 1 Acknowledgment within 5 working days of receipt

Step 2 Completeness assessment 25 working days

Step 3 Decision 40 working days from a complete application

Step 4 Decision notification within 5 working days afterward

An information request by substantive-review day 20 may suspend review for up to 20 working days; further requests do not suspend it. Preparation, missing documents and third-party onboarding have separate timelines.

MiCA and Czech Regulation

Regulation (EU) 2023/1114 sets the MiCA framework. Czech Act No. 31/2025 Coll. establishes CNB competence. Commission Delegated Regulation (EU) 2025/305 specifies application information; Commission Implementing Regulation (EU) 2025/306 supplies forms and procedures. Czech anti-money-laundering and counter-terrorist-financing rules and transfer-information rules apply separately.

Current Authorization Status

Status Item	Current Position
Route and authority	CNB authorization or eligible Article 60 route
Transition	Ended July 1, 2026
Register	Match identity, dates, services and withdrawals in CNB JERRS and European Securities and Markets Authority (ESMA) records; clarify discrepancies with the home regulator
Limitation	Legacy VASP registration is not current permission; registers can lag

Ongoing Compliance

MiCA
Management maintains governance, safeguards, customer-asset protection, conflict controls, complaints handling, outsourcing oversight and records. Keep policies and control records throughout operations.

Money Laundering and Terrorist Financing
Compliance staff perform customer checks, monitor activity, report suspicions and train staff as required by Czech rules and Financial Analytical Office (FAU) guidance. Retain checks and reports.

Transfer Information
The transfer operator collects, retains and shares sender/recipient data for each covered transfer under Regulation 2023/1113 (TFR).

Digital Resilience
Management and technology staff manage technology risks, incidents, testing and suppliers under the Digital Operational Resilience Act (DORA). Authorized CASPs must keep ongoing and incident-related records.

Bank Terms
Operations staff maintain onboarding and transaction records required by the account provider’s contract.

You remain responsible for implementing controls; ongoing advisory support requires a separate agreement.

Enforcement and Launch Risk

Unauthorized providers must stop onboarding and inform customers about winding down. CNB may take enforcement measures. Legacy claims provide no protection.

Banking and Payment Readiness

Account providers decide whether to accept your business. Prepare details of ultimate owners, funding sources, customer transactions, markets and AML controls.

Article 70 prohibits using customer assets or money for your own business. Customer money, excluding electronic-money tokens, must reach separately identifiable accounts at a bank or central bank by the end of the following business day. An ordinary electronic-money account does not meet this requirement.

Article 70 exempts credit, payment and electronic-money institutions from paragraphs 2–3, which govern customer funds. Payment services still require appropriate authorization, held by you or a third party.

Tax and Accounting

Standard corporate income tax is 21% of taxable profit. Fiat/bitcoin exchange has a VAT exemption without input-tax deduction; other fees need separate assessment. Review accounting, payroll, transfer pricing and tax residence as applicable.

Compare EU Jurisdictions

For Article 63 applicants, Article 59 requires an EU registered office where some services occur, effective EU management and at least one EU-resident director. These establishment rules apply across the comparison. Budget separately for Article 67 safeguards, official fees and professional support.

Jurisdiction	Regulator	EU Establishment	Application Practice	Banking	Cost Check	Key Limitation
Czech Republic	CNB	Required	2025/306 forms	Provider-specific	CZK 20,000 filing fee	Approved scope
Germany	BaFin	Required	Authorization/notification	Provider-specific	Request current fees	Filing channel needs verification
Malta	MFSA	Required	LH Portal; prior personal questionnaires	Provider-specific	Request current fees	Old VFA permission insufficient
Lithuania	Bank of Lithuania	Required	CASP procedure	Provider-specific	Request current fees	Old VASP insufficient
Netherlands	AFM; DNB financial checks	Required	Separate route forms	Provider-specific	Request current fees	Local application assessment
Poland	Designation unresolved	If route applies	Domestic filing availability unresolved	Provider-specific	Request current fees	Draft legislation is insufficient
Slovakia	NBS	Required	Corporate-form/application guidance	Provider-specific	Request current fees	Eligible entity needed

Official Sources

Last reviewed 14.10.2026

Frequently Asked Questions

Who needs CASP authorization from the CNB?

Businesses providing regulated crypto-asset services to clients from Czechia generally need authorization from the Czech National Bank (CNB) before starting. This includes exchanges, custodians and other crypto-asset service providers (CASPs). Certain already regulated financial institutions can use the notification route under Article 60 of MiCA instead.

How do Article 59 and Article 60 differ?

Article 59 establishes who can legally provide crypto-asset services under MiCA. An independent provider normally applies for authorization through the assessment process in Article 63. Article 60 allows certain already regulated financial institutions to provide specified services after notifying their regulator. It is not a general shortcut for new crypto businesses.

Which services can an authorization cover?

Authorization can cover custody, operating a trading platform, exchanging crypto-assets for money or other crypto-assets, executing orders, placing crypto-assets, receiving and transmitting orders, advice, portfolio management and transfers. A provider may offer only the services covered by its authorization. Token issuance and payment services may involve separate requirements.

What financial safeguards must an applicant maintain?

An ordinary CASP applicant must maintain safeguards equal to the higher of its service-based minimum—€50,000, €125,000 or €150,000—or one quarter of its annual fixed overheads. New businesses use projected overheads for their first 12 months. These safeguards can consist of qualifying own funds, compliant insurance or a comparable guarantee, or a combination. They are separate from application fees.

What information is needed for the application process?

The application must explain the business model, intended services, ownership, management and financial resources. It also needs supporting policies covering governance, anti-money laundering, technology, business continuity, complaints and relevant customer protections. The documents must describe how the business will actually operate. The precise requirements depend on the services requested.

How long can CNB review take?

MiCA provides 25 working days for the completeness assessment and 40 working days for the substantive review once the application is complete. Requests for missing information can increase the elapsed time. These periods do not include preparing the application or making operational changes, so they should not be treated as a guaranteed launch schedule.

When can authorized services expand across the EU?

An authorized CASP must first notify its home regulator of the intended countries, services and start date. Services can begin once the regulator confirms that it has forwarded the information, or at the latest on the 15th calendar day after submission. Expansion remains limited to the services covered by the authorization.

Does a legacy VASP registration still permit operation?

No. The Czech transitional period ended on July 1, 2026. A legacy virtual asset service provider (VASP) registration alone no longer permits a business to provide services regulated by MiCA. The business needs the relevant MiCA authorization or must qualify for the Article 60 notification route.

Does authorization guarantee a bank account?

No. Banks and payment providers make their own onboarding decisions. They may assess the company’s owners, source of funds, customers, transaction flows and anti-money laundering controls. CASP authorization does not replace those checks or guarantee that an account will be opened.

Which AML and ongoing compliance duties remain?

Providers must continue checking customers, monitoring transactions, reporting suspicious activity, keeping records and training staff. They must also maintain financial safeguards, governance, complaints procedures and applicable protections for customer assets. Requirements concerning information accompanying crypto transfers and digital operational resilience also apply where relevant.

How are corporate income tax and VAT assessed?

The standard Czech corporate income tax rate is 21% of taxable profit. VAT depends on the service provided. Exchanging bitcoin for traditional currency can qualify for VAT exemption without the right to deduct related input VAT. This does not make every crypto service VAT-exempt; other activities require a separate assessment.