The regulation itself sets one hard number: minimum own funds of €50,000, €125,000 or €150,000 depending on the services (Annex IV). Everything else — regulator fees, compliance staff, local substance, audits — varies by country and by how honestly it is counted. Three cost layers matter.
Layer 1: capital the regulation requires
| Class | Minimum own funds | Covers |
|---|---|---|
| 1 | €50,000 | Execution, placing, order handling, transfers, advice, portfolio management |
| 2 | €125,000 | Class 1 + custody and exchange (crypto↔fiat, crypto↔crypto) |
| 3 | €150,000 | Class 2 + operating a trading platform |
Two things the summaries skip: Article 67 makes the requirement the higher of the Annex IV amount or one quarter of the previous year’s fixed overheads — a running exchange quickly needs more than €150,000. And capital is held, not spent: it is a balance-sheet requirement, which is exactly why cheap quotes can exclude it without technically lying.
Layer 2: what regulators charge
| Regulator | Application fee | Ongoing |
|---|---|---|
| MFSA (Malta) | €10,000 / €25,000 / €50,000 by class | Same scale annually + €2,000 per service + 0.05% of volume (capped €250k/yr) |
| CySEC (Cyprus)* | Per service, cumulative: ~€5,000–8,000 typical, €10,000 custody, €30,000 trading platform | Year 1 free, then ~€5,000–20,000 per service + turnover component |
| BaFin (Germany) | No flat fee — billed by time spent, payable even if the application is withdrawn or rejected | Time-based supervision fees |
| Bank of Lithuania* | ~€1,500–2,500 state fee (sources conflict) | Annual supervision from ~€3,000 |
*Cyprus and Lithuania figures per intermediary sources — the regulators’ own fee pages were unreachable at review time; confirm directly before budgeting. AMF (France) and FMA (Austria) fees could not be verified and are deliberately omitted.
Layer 3: the costs the low quotes leave out
The gap between “from €8,500” and “€700,000” is scope, not dishonesty. The low end is a consultancy’s drafting fee in Lithuania or Estonia. The high end is a first-year run-rate that includes what the regulation actually forces you to build: legal work (€40,000–200,000 depending on jurisdiction), a compliance officer and an MLRO (roughly €70,000–120,000 a year each), DORA-grade ICT resilience (€30,000–80,000 to stand up), external audit, compliance tooling, and a real office — because Article 59(2) requires an EU registered office, effective management in the EU and at least one EU-resident director. Substance is in the regulation, not in the consultant’s upsell. Treat every all-in figure as a market estimate; the honest planning range for a serious CASP is mid-six-figures in year one.
How long it takes
On paper: 25 working days for completeness plus 40 for assessment. In reality the clock stops with every question round, and 2025–26 practice looked like this: Malta and Lithuania around 4–6 months, France 3–5 months for firms already registered under the old PACTE regime (6–10 for new entrants), Cyprus 6–12, and Germany and Ireland 9–18 months. One caution about the fast lanes: ESMA’s July 2025 peer review found Malta’s MFSA only “partially met expectations” on a CASP authorisation — quick approvals are attracting exactly the scrutiny you would expect.
Who has actually done it
The answer to “is it worth it” is in the register: 293 firms have been authorised as of 18 July 2026 — from two-person fintechs to Commerzbank. The CASP licence guide explains what the authorisation covers, and the deadline page shows how each country ran its transition.
Common questions
What is the minimum capital for a MiCA licence?
Annex IV of the regulation sets three classes of minimum own funds: €50,000 (order execution, transfers, advice and similar), €125,000 (custody and exchange services) and €150,000 (operating a trading platform). Article 67 adds a catch: the requirement is the higher of that amount or one quarter of the previous year’s fixed overheads — so an operating exchange usually needs more than the flat minimum.
Why do cost estimates vary from under €10,000 to €700,000?
They measure different things. The low quotes are a consultant’s fee for drafting the application in a cheap jurisdiction — excluding capital, mandatory compliance staff, ICT/DORA infrastructure, audit and office. The high quotes are the all-in first-year operating cost of actually running an authorised CASP. Both can be simultaneously true.
How long does authorisation take?
The statutory clock is 25 working days for a completeness check plus 40 for assessment — but it pauses every time the regulator asks questions. In practice, 2025 authorisations ran roughly 4–6 months in Malta and Lithuania, 6–12 in Cyprus and France, and 9–18 months in Germany and Ireland.
Can I just pick the cheapest, fastest country?
Passporting makes the licence EEA-wide wherever it is granted, so jurisdiction shopping is real — but not free of consequences. The regulation itself requires genuine substance (EU office, effective management in the EU, an EU-resident director), and ESMA’s 2025 peer review openly criticised one fast-track authorisation, so scrutiny of quick approvals is rising.
Sources: capital classes and substance from Regulation (EU) 2023/1114 (Art. 59, 63, 67, Annex IV); Malta fees from the MiCA Act Fees Regulations summary; BaFin from its MiCAR pages; year-one cost breakdown attributed to ItisPay’s market estimate; peer review from ESMA. Informational only — not legal, tax or licensing advice.