License for a Crypto Exchange in Slovakia

Is This the Right Fit?

May Fit
You hold, exchange or manage crypto-assets for customers.

Needs Separate Review
Token issuance, financial instruments and payments have separate rules. Software, nonfungible token (NFT) and decentralized finance (DeFi) labels alone do not establish an exemption.

Not a CASP Activity
Buying or selling for yourself without providing a defined service requires no CASP permission. Customer-facing dealing has no automatic “own-account” exemption.

Choose the Authorization Route

Notify under Article 60 at least 40 working days before starting; incomplete notices prevent launch. Ordinary startups are ineligible. Sectoral rules and Article 60(10) exemptions, including from Article 67, apply. Article 65 gives no global access.

Services the Permission Can Cover

For Article 59 applicants, the highest service class sets the floor.

Class 1 • EUR 50,000

Executing customer orders, placing assets, transferring assets, receiving and transmitting orders, advising and managing portfolios require corresponding service policies.

Class 2 • EUR 125,000

Custody and administration, exchange for money and exchange for other crypto-assets require asset controls and applicable safeguarding. Lower-class services can also be authorized.

Class 3 • EUR 150,000

Trading-platform operation requires platform controls; lower-class services can also be authorized.

Under Article 67, maintain safeguards equal to the greater of the class floor and one-quarter of annual fixed overheads: recurring operating costs calculated under MiCA. Businesses operating for under a year use first-year projections. Eligible own funds, insurance, comparable guarantees or combinations cover liabilities. These differ from fees and incorporation capital; Article 60 exemptions apply.

What Gofaizen & Sherle Will Handle

• We assess activities and jurisdiction and advise on company formation and structure.
• Using your information, we prepare application documents and help answer NBS questions. You implement controls.
• We support anti-money laundering and counter-terrorist financing (AML/CFT), governance and agreed ongoing compliance. Technology and safeguarding are application topics; implementation, staffing and provider tasks require agreed scope.

Support Scope and Costs

Filing costs EUR 1,700 for Class 1, EUR 2,500 for custody or exchange, including lower-group combinations, or EUR 3,400 for platforms, alone or combined.

The 2026 annual contribution is 0.1% of assets calculated from prescribed accounts under NBS Decision 5/2025, section 2, minimum EUR 1,000. This is not turnover or arbitrary customer assets. First-year liability starts on the first day of the sixth calendar month after the authorization month, prorated for the applicable 2026 period. Operating costs and prudential resources remain separate.

What You Need to Prepare

For the application:

• Identify owners, major shareholders, ultimate beneficial owners and managers
• Describe services, markets, customers and transaction flows; demonstrate financial resources
• Provide governance, risk, AML, technology, continuity, safeguarding, complaints, outsourcing and service policies, with implementation evidence

Use NBS forms, checklist and digital-resilience questionnaire. Article 59 requires a home-state registered office with some services there, effective EU management and an EU-resident director. NBS requires physical premises, key people and functions, and accessible records in Slovakia; a virtual office is insufficient.

File in Slovak. Foreign annexes normally need certified Slovak translations; on written request, NBS may waive translation for certain annexes in Czech or customary financial languages, commonly English.

What Sets the Timeline

Rules That Shape the Business

MiCA governs authorization, governance and conduct. The Transfer of Funds Regulation (TFR) requires transfer information; the Digital Operational Resilience Act (DORA) governs technology resilience. Slovak Act 248/2024 implements MiCA; Act 297/2008 addresses AML/CFT. Financial instruments can fall outside MiCA.

Current Authorization Status

Keeping the Business Compliant

The CASP remains responsible, including when outsourcing.

AML/CFT
Monitor customers and transactions continuously and retain records.

Governance and Client Assets
Maintain staff, financial resources and segregated client assets, with ongoing control records.

Complaints, Conflicts and Outsourcing
Handle complaints, manage conflicts and oversee providers; retain policies, agreements and event records.

TFR and DORA
Maintain transfer data and technology continuity; document controls and report applicable incidents.

Reporting and Audit
Submit applicable periodic reports, change notifications and audited financial statements.

Regulatory Risk

Unauthorized services, misleading legacy VASP claims and control failures can trigger NBS information requests, inspections, suspension, prohibition or orders to stop services.

Banking and Payment Providers

Banks, electronic money institutions and payment service providers decide independently whether to open an account. CASP authorization does not guarantee acceptance or replace payment permissions.

Prepare:

• Ownership and source-of-funds documents
• Customer and transaction flows and AML controls
• Custody and safeguarding arrangements and authorization evidence

Assistance follows the agreed scope.

Company Taxes and VAT

For periods beginning from 1 January 2025, taxable revenue determines the corporate income tax rate: 10% up to EUR 100,000; 24% above EUR 5 million; otherwise ordinarily 21%. Apply it to the tax base after loss deduction, not turnover or marginal profit bands.

Standard value-added tax (VAT) is 23%; treatment depends on the service, token, transaction and place of supply. Payroll, withholding, permanent establishment, transfer pricing and accounting need individual analysis.

Compare EU Home Jurisdictions

In all five countries, Article 59 presence rules apply; eligible financial institutions can use Article 60. Assess local premises and staffing. Each authorization covers specified services; Article 65 notification enables EEA access within that scope.