Crypto License 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

Applicant	Home Regulator	Authorization	Slovakia Access	Limitation
Slovak applicant	NBS	Article 59 application	Approved services	Operational readiness required
European Economic Area (EEA) CASP	Home authority	Existing authorization	Home authority notifies NBS under Article 65	Permitted services; local rules remain
Eligible financial institution	Sectoral authority	Article 60 notification	Eligible equivalent services	Existing sectoral permissions govern

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.

Support Scope and Costs

Package	Deliverables	Exclusions	Professional Fee	Official Fees	Third-Party Costs
Individual proposal	Agreed advisory, application, corporate and compliance work	Specified in proposal	Individually quoted	Below	Provider quotes

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

Owner and Stage	Review Clock	Condition
Adviser, client and providers prepare	Project-specific	Preparation, implementation, responses and provider reviews fall outside NBS clocks
NBS checks completeness	25 working days from receipt	Missing information requires a response and recheck
NBS assesses the application	40 working days from receipt of a complete application	Information requests may pause this period for up to 20 working days; refusal remains possible

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

Current Status	Confirmed	Requires Project-Specific Verification
Transition	Slovakia ended 30 December 2025, before MiCA’s 1 July 2026 maximum	Legacy registration gives no current right
Providers	NBS reported six Slovakia-based CASPs on 29 July 2026	Check current entity permissions and services in the register; six is a historical count

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.

Jurisdiction	Regulator	Substance	Service Scope	Application Readiness	Passporting	Key Limitation
Slovakia	NBS	Local premises and functions	Authorized services	NBS checklist	Article 65	Virtual office insufficient
Estonia	Finantsinspektsioon	Assess local functions	Authorized services	Current application portal	Article 65	Legacy permissions expired 1 July 2026
Germany	BaFin	Assess local functions	Authorized services	Confirm filing procedure	Article 65	Check premises and staffing
Portugal	Banco de Portugal; CMVM	Assess local functions	Authorized services	File with Banco de Portugal; CMVM consultation	Article 65	Check authorities’ responsibilities
Lithuania	Bank of Lithuania	Assess local functions	Authorized services	Prepare licensing evidence	Article 65	Director rule concerns EU residence