Services · Licences & special services

Estonia crypto exchange license (MiCA CASP authorisation)

MiCA CASP authorisation: real substance, real capital, open pricing.

What the Estonian crypto license is, and who it suits

An Estonia crypto license in 2026 means one thing: authorisation as a crypto-asset service provider (CASP) under the EU MiCA regulation, granted and supervised by the Estonian Financial Supervision Authority (Finantsinspektsioon). The old VASP regime run by the Financial Intelligence Unit is closed. Legacy registrations do not convert into a CASP authorisation, the transitional window is over, and new applicants go straight to a full CASP filing.

What the status actually buys you: the right to provide crypto-asset services in Estonia and, on a simple notification, across the EU and EEA without a separate licence in each country; workable relationships with banks and payment providers, who do not deal with unlicensed counterparties; and a legal perimeter that investors and partners can read.

Good fit. Exchanges and brokers, including crypto-to-fiat exchange; custody and wallet services; transfer platforms; firms receiving and transmitting client orders; teams with a working product, money for the capital requirement and a willingness to keep people and an office in Estonia.

Poor fit. Projects with no budget for recurring costs: capital, a local team, audit, ICT controls and AML tooling cost money every month, not once. Anyone shopping for a ready-made licence, since that market barely exists in Estonia. Structures unwilling to disclose ultimate beneficial owners. And token issuers, who need a different MiCA track altogether rather than a CASP authorisation. Our full breakdown of the regime is in the article Crypto licence in Estonia in 2026.

Requirements: capital, directors, office, compliance, documents

Own funds. MiCA sorts services into three classes and the minimum own funds follow the class: EUR 50,000 for reception and transmission of orders, advice, portfolio management, execution, placing and transfer services; EUR 125,000 for custody and administration of client crypto-assets and for exchange of crypto-assets for funds or for other crypto-assets; EUR 150,000 for operating a trading platform. You must hold the higher of the class floor or one quarter of the previous year's fixed overheads, and where you provide several services the highest floor applies. This is not a one-off deposit: the capital has to stay there, and if losses eat it, it must be rebuilt.

Substance. MiCA requires a registered office in a member state where at least part of the services are provided, the place of effective management in the EU and at least one director resident in the EU. In practice the Estonian regulator expects more: a working office in the country, at least one management board member who lives in Estonia and genuinely takes decisions, and a clear picture of who runs the business and from where. A nominee on paper plus a mail address does not pass.

People and functions. A management board with relevant experience and a clean record (fit and proper: CVs, qualifications, no criminal or problematic regulatory history), a compliance and AML function, and internal control and risk management procedures that actually work.

Compliance and ICT. AML and CFT policies, KYC and transaction monitoring, sanctions screening, Travel Rule implementation, client asset segregation, complaints handling, conflicts of interest policy, business continuity plan, and documentation of ICT systems, cybersecurity, key custody and disaster recovery.

Documents. Articles of association, a programme of operations describing every service applied for, business plan and financial model, proof of paid-in capital at a credit institution, questionnaires and personal documents for managers and beneficial owners, ownership structure, outsourcing and vendor arrangements. The pack is heavy, and its quality decides how many rounds of regulator questions you will go through.

The process step by step, and how long it takes

1. Project review, 1-2 weeks. We look at the model, fix the service class and the capital floor, and assess the team and the source of funds. If the project does not stand up, you hear it here, not after the state fee is paid.
2. OÜ incorporation and structure, 2-4 weeks. The Estonian company, articles drafted for a licensed activity, board appointments, registered address, office arrangement.
3. Capital and bank account, 2-6 weeks. Funds are paid into an EU credit institution and evidenced. The timing here belongs to the bank, not to the adviser.
4. Building the application pack, 4-8 weeks. Policies, programme of operations, ICT documentation, business plan, manager questionnaires, certificates, translations and apostilles.
5. Filing through the regulator's portal. The application is submitted electronically through the Financial Supervision Authority portal; paper and email filings are not accepted for this regime. The state application fee is paid at this point - a payment to the state, non-refundable if the application is refused.
6. Completeness check, up to 25 working days. The regulator confirms the pack is complete or asks for what is missing.
7. Substantive assessment, up to 40 working days. The clock pauses while you answer additional questions (up to 20 working days). In practice the exchange runs over several rounds, so the calendar is longer than the sum of the formal deadlines: budget six months or more from kick-off to decision.
8. Launch and passporting. Once authorised, you notify your home regulator of cross-border activity; it forwards the file to host authorities and services can start roughly two weeks after the notification, with no second licence and no second capital requirement. After that: ongoing reporting, audit and supervision.

How much an Estonian crypto license costs

Three different kinds of cost sit in the budget and should not be blended. First, our work. Second, payments to the state: the application fee is paid once and is not refunded if the regulator says no. Third, your own capital, which is not a cost at all but your money on the company's account - it simply has to be there and stay there. Plan the recurring items separately: local director, office, accounting, audit, AML software and transaction monitoring licences.

Prices are indicative and cover our work on a typical case. We confirm the exact quote in writing after a short call - you know the final number before we start. Government fees and bank tariffs are billed separately unless explicitly included.

Risks, pitfalls and the usual reasons applications fail

Refusals and endless correspondence come from a short list of recurring problems:

• Paper substance. A director who does not live in Estonia and does not manage anything, an office with nobody in it, every meaningful function outsourced. Before 2022 Estonia issued thousands of virtual currency permits and then cancelled most of them, largely for exactly this. The regulator remembers, and checks presence seriously.
• Opaque owners and source of funds. Long ownership chains, nominee holders, reluctance to name the ultimate beneficial owner end the conversation early.
• Template policies. Downloaded AML procedures that do not describe your real business are obvious on first reading.
• Weak ICT section. No clear account of key custody, access control, redundancy and recovery means no authorisation.
• Underestimated running costs. A licence obtained without the resources to maintain it leads to supervisory orders and then to withdrawal.

Two more things worth knowing upfront. The bar was raised deliberately, the number of authorised CASPs in Estonia is still small, and an offer to sell you a ready licence within a week is a reason to check the seller rather than to celebrate. And banking for a crypto business remains a separate project that no licence includes: the account is opened by a bank, not by the regulator, and nobody can guarantee it, ourselves included.

Tax and ongoing maintenance of the Estonian company

Estonia's profit tax model is still the jurisdiction's most practical advantage: retained profit is not taxed, tax arises on distribution, and the rate on distributed profit is 22/78 of the amount paid out. The planned increase to 24 percent and the separate corporate element of the security tax package did not come into force. The standard VAT rate has been 24 percent since 1 July 2025. Local payroll carries social tax, which is a material part of the substance budget and is routinely forgotten in planning.

The company keeps books under Estonian rules and files an annual report; an authorised CASP additionally reports to the regulator and is audited. We run this on an ongoing basis: accounting and reporting, keeping the office and presence alive, updating policies as the rules change, and handling routine regulator correspondence.

How we work

We start with an assessment, not a sales pitch. In the first stage we look at your model, budget and team and tell you plainly whether Estonia is worth it or whether the same goal is cheaper and faster elsewhere. Related routes we run: a Malta payment services provider licence, a BVI company with a VASP licence, a Cyprus company with a real office and other licensing services.

From there we work to a fixed written quote: you know the final number before we start. We do not guarantee the outcome - the regulator decides, and any adviser promising you a licence is promising something they do not control. What we are accountable for is the quality of the pack, the speed of our responses to the regulator and the fact that every cost and every weak spot in your file is visible to you in advance. The full list of our services and prices is in the services section.

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