Crypto-asset service providers (CASPs) need permission to serve clients.
New Norwegian applicants seek Finanstilsynet authorization under the Markets in Crypto-Assets Regulation (MiCA). The former VASP registration transition has ended.
Preparation and assessment, individually calculated support fee
Norway Business Fit
Fit Consider Norway if you will provide crypto-asset services to clients and operate there.
Limits Token issuance, including asset-referenced and e-money tokens, payments and financial instruments require separate classification.
Choose Your Regulatory Route
Norway belongs to the European Economic Area (EEA).
Applicant
Route
Permission Boundary
New Norwegian applicant
Article 63 application to Finanstilsynet
Authorization covers approved services
Eligible licensed financial entity
Article 60 notification
Only eligible services within existing or equivalent permissions
Authorized EEA CASP
Article 65 notification to its home regulator
Cross-border provision of authorized services
For an electronic money institution (EMI), Article 60 covers custody and transfers only of its own e-money tokens (EMTs).
Under Article 65, the home regulator forwards information within 10 working days. Services may start when the home regulator confirms transmission, or no later than the 15th calendar day after submission.
Regulated Crypto-Asset Services
Custody: holding and administering clients’ crypto-assets.
Trading platforms: operating a crypto-asset trading platform.
Exchange for funds: buying or selling crypto-assets for money.
Crypto-to-crypto exchange: exchanging one crypto-asset for another.
Execution: executing clients’ orders.
Placing: marketing crypto-assets to buyers for an offeror or related party.
Reception and transmission: receiving orders and passing them to another executor.
Transfers: transferring crypto-assets for clients.
Application Support From Gofaizen & Sherle
Gofaizen & Sherle can help you:
Identify which planned services need regulatory permission
Prepare application documents and governance policies
Develop controls against money laundering and terrorist financing (AML/CFT)
Respond to the regulator’s questions
You provide the information and put controls into practice. An authorized filer submits the application through Altinn, Norway’s filing portal. Third parties supply their own documents. Finanstilsynet makes the decision.
Ongoing compliance and corporate services are included only if agreed in the contract.
Scope and Costs
Category
Basis
Professional support
Individual calculation for agreed scope, no fixed price
Official charges
Potential processing fee and annual supervisory levy: confirm CASP applicability and tariff with Finanstilsynet before filing
Third-party costs
Not automatically included in the support fee
Prudential safeguards
Financial protection for business risks, rather than a regulatory payment
Application Process
Step1Agree on the route and services. You provide information and implement controls.
Step2Gofaizen & Sherle prepares documents. An authorized filer submits through Altinn.
Step3Finanstilsynet checks completeness. We help answer requests, incomplete files may be rejected.
Step4Finanstilsynet assesses the complete application and approves or refuses authorization.
Information and Documents You Need
Documents
Use Finanstilsynet’s current form and checklist, referencing:
Founding documents, LEI and operating plan
Evidence of owners’ and managers’ suitability
Policies for governance, AML, complaints, outsourcing, technology security, business continuity, client assets and your specific services
Business Presence
Maintain a Norwegian registered office and provide some services there. Effective management must be in the EEA, with at least one EEA-resident director.
Financial Safeguards
Article 63 applicants use the highest applicable threshold, without adding amounts together:
Services
Minimum
Execution, placing, transfers, order reception/transmission, advice, portfolio management
€50,000
Custody or either exchange service
€125,000
Trading platform
€150,000
Maintain the higher of this threshold or one-quarter of annual fixed overheads. Use the previous year’s overheads, or projected first-year overheads for a new business.
Eligible own funds, insurance, a comparable guarantee or a combination must meet Article 67 conditions. These additional safeguards do not apply to Article 60 financial entities.
Review Times and Delays
Article 63 Authorization
Finanstilsynet follows these review stages:
Acknowledges receipt within 5 working days
Checks completeness within 25 working days of receipt
Assesses a complete application within 40 working days
Notifies you within 5 working days after its decision
If information is missing, Finanstilsynet sets a response deadline. Norwegian guidance allows 5–20 working days.
A written request made by the 20th working day of assessment pauses the review until you respond, for up to 20 working days. Later requests do not pause it again.
Article 60 Notification
Eligible financial entities must notify Finanstilsynet at least 40 working days before starting services.
Finanstilsynet checks completeness within 20 working days
If information is missing, it sets a deadline of no more than 20 working days
The 40-working-day period pauses until that deadline expires. Later requests cause no further pause
Services cannot start while the information remains incomplete.
Business setup, application preparation, funding, technology and bank review take additional time. These regulatory deadlines do not guarantee a launch date.
Norway’s Regulatory Framework
Norway’s Crypto Assets Act implemented MiCA on July 1, 2025, supervised by Finanstilsynet. MiCA governs permission and conduct. AML/CFT rules require applicable risk-based checks and reporting, the Transfer of Funds Regulation (TFR) requires sender and recipient information for covered transfers.
The Digital Operational Resilience Act (DORA), effective in Norway from July 1, 2025, addresses technology resilience.
Providing advice alone does not trigger AML coverage under the CASP definition. MiCA and other possible AML grounds still apply.
Current Authorization Status
Position
Consequence
Article 63 authorization or eligible Article 60 notification
Check the current status and permitted services in the register
Former VASP registration
Transition ended July 1, 2026, a pending application does not extend it
No right to continue
Stop onboarding, retain only services strictly necessary for orderly wind-down
Duties After Authorization
Management Keep governance, complaints and conflict controls, with records. Remain responsible for outsourced work.
Compliance Where AML applies, verify customers and ultimate owners, monitor transactions and report suspicions. Meet TFR requirements for covered transfers. Transfers involving wallets outside a service provider need a risk assessment and at least one suitable extra safeguard.
Operations Protect client assets and funds. Maintain applicable DORA controls and reporting.
Finance Maintain required financial safeguards and meet crypto-asset tax-reporting duties where applicable.
Risks of Unauthorized Operations
An expired registration does not allow you to accept new clients. Finanstilsynet must withdraw Article 63 authorization for serious MiCA breaches or ineffective AML/CFT controls. Other grounds may also justify withdrawal. Article 60 follows different rules.
Weak security or poor asset protection can cause clients to lose money.
Banking and Payment Arrangements
CASP authorization does not guarantee a bank account or allow you to provide payment services. Each bank or payment provider decides whether to accept your business. Prepare:
Details of ultimate owners and sources of funds
Expected transaction flows
Evidence of your regulatory permissions
An ordinary corporate account does not replace the client-fund safeguards required under Article 70. Payment services need a separate permission.
Business Taxation
Ordinary corporate net income is taxed at 22% in 2026. Businesses liable for financial activity tax face 25% income tax plus an additional 5% payroll tax, subject to activity thresholds and exceptions.
VAT depends on the service and token function. Exchange/payment exemptions require an asset accepted as alternative payment with no other purpose. CASP fees are not all automatically exempt.
Assess payroll, reporting, withholding, tax residence and permanent establishment. Foreign customers alone do not make income tax-free.
Norway and Alternative Jurisdictions
Norway offers an EEA route under MiCA. The alternatives below do not grant MiCA passporting.
Home State and Regulator
EEA Access
Operational Substance
Application Readiness
Limitation
Norway • Finanstilsynet
Article 65 notification for authorized CASPs
Norwegian office and services. EEA management and at least one EEA-resident director
Altinn application, policies and financial safeguards
Only approved services, cross-border notification required
Montana, USA • FinCEN at federal level
No MiCA passport
Local registered agent for a Montana company
Check federal registration and target-state rules
Federal and other states’ rules still apply
Canada • FINTRAC and securities regulators
No MiCA passport
Foreign MSBs need a Canadian service representative
Registration details and compliance controls
Trading platforms may need additional registration
Switzerland • FINMA and recognized AML supervisory bodies
No MiCA passport
Swiss office and operations for a FinTech license
Identify the required license or supervision
Services and custody determine requirements
El Salvador • CNAD, separate Bitcoin-provider route
No MiCA passport
Compliance staff and operating controls for digital-asset providers
Business plan, AML, custody and security documents
The transition ended July 1, 2026. Pending applications grant no extension. Without permission, stop onboarding and restrict services to necessary orderly wind-down.
How long does the application take?
Regulatory working-day clocks depend on completeness and permitted pauses. Preparation and launch take additional time.
What must an applicant prepare?
Evidence of ownership, management, activities, controls and financial safeguards, with policies for the proposed services.
What does application support cost?
The professional fee is calculated individually. Official charges, third-party costs and safeguards are distinct. Confirm the applicable official tariff before filing.
Does authorization guarantee a bank account?
No. The provider decides after review. CASP authorization does not grant payment permission.
Does authorization guarantee a bank account?
Maintain applicable governance, asset protection, technology controls, monitoring, records and reporting.
Which business taxes apply?
Ordinary corporate tax and, where applicable, financial activity tax. VAT depends on the service and asset’s payment function, 22% is not universal.
We at Invity and SatoshiLabs as a whole were extremely pleased with the legal support provided by Gofaizen & Sherle in establishing our virtual assets business in Lithuania. Their expertise and thorough understanding of the virtual assets landscape were invaluable, ensuring that every aspect of our setup was compliant and robust. The team's professionalism and dedication made the entire process seamless and stress-free. We highly recommend Gofaizen & Sherle for their legal services in the virtual assets sector.
Services Provided: Full turnkey VASP formation in Lithuania, including transfer of a ready-made entity, AML/CTF framework development, MiCA readiness, corporate structuring, and ongoing compliance and regulatory support.
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