A MiCA licence is an authorisation under the EU's Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114. There are three routes: crypto-asset service provider (CASP) authorisation for firms that serve clients, a separate authorisation for issuers of asset-referenced tokens (ARTs), and, for issuers of e-money tokens (EMTs), a bank or electronic money institution authorisation under other EU law plus a notified and published white paper.
Capital figures and statutory deadlines below are from the Regulation as adopted on 31 May 2023. Anvesan's EU regime page and Atlas track which companies hold CASP authorisations and issue EMTs, from ESMA's registers.
The MiCA regime in brief
MiCA lays down uniform requirements for offering and trading crypto-assets, for CASPs and for ART and EMT issuers (Article 1), and is directly applicable in all Member States. Its ART and EMT rules have applied since 30 June 2024, and the whole Regulation since 30 December 2024 (Article 149).
Each Member State designates the authorities that apply MiCA, and ESMA publishes the list (Article 93). ESMA's interim register of CASPs, token issuers and white papers was last updated on 24 September 2026. The European Banking Authority (EBA) supervises issuers of significant ARTs and, for parts of the rules, e-money institutions issuing significant EMTs (Article 117). The EBA classes a token as significant when at least three of seven criteria are met, such as more than 10 million holders (Articles 43 and 56).
Who needs MiCA authorisation
Three activities in the EU require an authorisation:
- Crypto-asset services. MiCA lists ten, from custody and trading platforms to advice and portfolio management (Article 3(1)(16)). They take CASP authorisation or, for banks and some other authorised financial firms, a notification (Articles 59 and 60).
- E-money tokens. An EMT claims to keep a stable value by referencing one official currency (Article 3(1)(7)). Its issuer must be a credit institution or an electronic money institution and must notify and publish a white paper; others offering it need the issuer's written consent (Article 48, which also sets some exemptions).
- Asset-referenced tokens. An ART is a token, other than an EMT, that claims to keep a stable value by referencing another value or right, or a combination, including one or more official currencies (Article 3(1)(6)). The issuer must be authorised, or be a credit institution that follows Article 17; others need its written consent (Article 16(1)).
An ART issuer needs no authorisation, though it still notifies a white paper, if the token's average outstanding value never exceeds EUR 5,000,000 over 12 months and the issuer is not linked to a network of other exempt issuers, or if the offer is solely to qualified investors who alone can hold it (Article 16(2)). Offerors of other crypto-assets need a notified white paper instead, with some exemptions (Article 4). Financial instruments, deposits and unique, non-fungible crypto-assets fall outside MiCA (Article 2). A third-country firm serving an EU client at that client's own exclusive initiative needs no authorisation, but soliciting EU clients by any means ends that exception (Article 61).
The three license routes
CASP authorisation
A firm applies to the competent authority of its home Member State (Article 62). It needs a registered office in a Member State where it provides at least part of its services, its place of effective management in the EU and at least one director resident in the EU (Article 59(2)). Financial firms that notify instead do so at least 40 working days ahead, within limits Article 60 sets for each type.
E-money token issuers
EMTs are deemed to be electronic money, and Titles II and III of the Electronic Money Directive (Directive 2009/110/EC) apply to them unless MiCA's e-money token rules say otherwise (Article 48). The EBA's response to the Commission's consultation on the MiCA review counted 39 EMTs issued under MiCA as at 1 September 2026, 36 of them by electronic money institutions.
Asset-referenced token issuers
An issuer that is not a credit institution must be a legal person or other undertaking established in the EU (Article 16). Its authority sends a draft decision to the EBA, ESMA and the European Central Bank (ECB), and must refuse if the ECB, or where applicable the national central bank, gives a negative opinion citing risks to payment systems, monetary policy transmission or monetary sovereignty (Articles 20 and 21). A credit institution instead needs an approved white paper and notifies its authority at least 90 working days before first issuing (Article 17). The EBA reported that no ART had been authorised as at 1 September 2026.
Capital and other requirements at headline level
CASPs hold prudential safeguards of at least the higher of the Annex IV minimum or a quarter of the preceding year's fixed overheads, as own funds, an insurance policy or a comparable guarantee, or a mix (Article 67).
| Class | Services (Annex IV) | Minimum capital |
|---|---|---|
| 1 | Order execution, placing, transfers, reception and transmission of orders, advice, portfolio management | EUR 50,000 |
| 2 | Class 1 services plus custody, or exchange for funds or other crypto-assets | EUR 125,000 |
| 3 | Class 2 services plus operating a trading platform | EUR 150,000 |
ART issuers hold own funds of at least the highest of EUR 350,000, 2% of the average reserve of assets, or a quarter of the preceding year's fixed overheads (Article 35(1)). Their authority can require up to 20% more than the reserve-based amount where it finds a higher degree of risk, and must require 20% to 40% more in certain circumstances after stress tests (Article 35(3) and (5)). For significant ARTs the 2% reserve-based rate becomes 3% (Article 45(5)). E-money institutions that issue significant EMTs follow MiCA's reserve rules and parts of Articles 35 and 45 instead of the Electronic Money Directive's Articles 5 and 7 (Article 58).
A CASP application also covers management, shareholders, governance, anti-money laundering controls, ICT systems, client asset segregation and complaints handling (Article 62(2)).
Passporting: the MiCA passport
A CASP may provide services throughout the EU, through a branch or across borders, and serving across borders needs no physical presence in the host state (Article 59(7)). It sends its home authority details including the Member States, services and start date it plans. The authority forwards this to the host states, ESMA and the EBA within 10 working days, and the CASP may start once informed, or at the latest from the 15th calendar day after submitting (Article 65). ART authorisations and approved ART white papers are also valid for the entire Union (Article 16).
Application process and timelines
For CASPs, Article 63 sets the clock:
| Step | Deadline |
|---|---|
| Acknowledge receipt | 5 working days |
| Check completeness | 25 working days from receipt |
| Decide | 40 working days from a complete application |
| Notify the decision | 5 working days from deciding |
The authority can ask for more information until the 20th working day of the assessment, which pauses the clock for up to 20 working days.
For ART issuers, the steps are 25 working days for completeness, 60 for a draft decision, 20 for opinions from the ECB (or, where applicable, the national central bank) and, on request, the EBA and ESMA, and 25 for the decision (Articles 20 and 21). EMT issuers notify their authority at least 40 working days before an offer or admission to trading (Article 48(6)), and notify the white paper at least 20 working days before publishing it (Article 51(11)).
Transitional periods
CASPs that served clients under national law before 30 December 2024 could continue until 1 July 2026, or until authorised or refused if sooner, and Member States could shorten or skip that period where they considered their previous national rules less strict than MiCA (Article 143(3)). ESMA's list shows national periods from 6 months (for example the Netherlands) to 18 months (for example France), and notes that some may not yet have been written into national law. As 1 July 2026 was the latest possible end date, every Member State's period has ended.
One transitional deadline is still ahead: for other crypto-assets admitted to trading before 30 December 2024, trading platform operators have until 31 December 2027 to ensure that a white paper, where MiCA requires one, is drawn up, notified and published (Article 143(2)).
Recent changes
- 2 March 2026: the transition period under the EBA's No Action letter on PSD2 and MiCA ended. The EBA had advised authorities to require PSD2 authorisation for a subset of CASP services with EMTs only after that date. Its opinion of 12 February 2026 says more than 100 CASPs had approached authorities or applied for payment authorisation since June 2025.
- 20 May 2026: the European Commission opened a targeted consultation on the review of MiCA. The EBA responded on 24 September 2026.
For each requirement on a path, dated and sourced, see Sherpa's Pathfinder; its coverage varies by jurisdiction and product. To compare MiCA with other regimes, see all regimes. This guide is planning information from official sources, not legal advice.