For an Article 63 CASP applicant, MiCA sets three minimum prudential amounts: €50,000, €125,000 or €150,000 depending on the services (Annex IV). Everything else, including regulator fees, compliance staff, local operations and audits, varies by country and operating model. The budget has three cost layers.
Layer 1: capital the regulation requires
| Class | Annex IV amount | 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 |
The amounts in the table apply to Article 63 CASP applicants. Article 60(10) disapplies Article 67 to eligible Article 60 financial entities. Eligible Article 60 entities remain under their existing sectoral prudential regime and route-specific MiCA requirements. For an Article 63 applicant, Article 67 sets the requirement at the higher of the Annex IV amount or one quarter of fixed overheads. A firm that has operated for at least a year uses the previous year. A newer applicant uses projected fixed overheads for the first 12 months under Article 67(2). Fixed overheads can raise an operating exchange’s requirement above €150,000. Article 67 allows eligible own funds, an insurance policy or a combination. Eligible own funds remain a balance-sheet requirement. An insurance policy has a premium and must meet the coverage conditions.
Layer 2: what regulators charge
| Regulator | Application fee | Ongoing |
|---|---|---|
| MFSA (Malta) | €10,000 / €20,000 / €25,000 by highest service class | €10,000 / €25,000 / €50,000 fixed by class, plus €2,000 per authorised service and 0.05% of transaction volume (capped at €250,000) |
| Other EEA home states | Set by national law, not MiCA | Confirm the current application, variation and supervision schedule with the competent authority |
Malta is shown because its official fee regulations publish a complete CASP schedule. National charges can change and may use different bases, so obtain a written calculation from the authority before approving a budget. The country guide identifies the correct authority for every EEA home state.
Layer 3: implementation and operating costs
The budget must cover the firm described in the application. Include staff responsible for compliance, AML, risk, security and internal control. Also include legal and regulatory drafting, DORA-aligned resilience and testing, custody or trading infrastructure, external audit and assurance, and insurance used for prudential safeguards. Budget for data, monitoring and Travel Rule vendors, and for premises that support real management activity. Article 59(2) requires a registered office in the home state and at least part of the services there. Article 59(2) also requires effective management in the EU and an EU-resident director.
Build a 24-month cash model with four separate columns: prudential safeguards, one-off implementation, recurring operating cost and regulatory charges. Add a documented contingency for regulator questions and remediation. Separate columns are useful because a custody platform, an advisory firm and an exchange need different controls and teams.
How long it takes
MiCA provides 25 working days for the completeness check and 40 working days for the assessment of a complete file. The authority may request further information and suspend the assessment clock within the limits in Article 63. Preparation, governance hiring, corporate work and control testing are outside those statutory periods. The periods also exclude the time needed to complete a deficient application. Base the launch plan on evidence readiness and allow time for work outside the statutory review.
Current authorisation footprint
The ESMA register shows the current register footprint. 328 current legal-entity entries appear in the snapshot as of 20 August 2026. The data includes Article 63 authorisations and eligible Article 60 notification routes. The CASP licence guide explains what the authorisation covers. The MiCA licence by country comparison shows all 30 EEA home-state routes. The Spain guide explains the CNMV process. The deadline page shows how each country ran its transition.
Turn the estimate into a licensing plan
Start with service scope and home-state operations. The service scope and home-state operations determine the capital, regulator process, staffing and evidence that you need to budget.
Common questions
What is the minimum capital for a MiCA licence?
For an Article 63 applicant, Annex IV sets three minimum amounts. The minimum is €50,000 for order execution, transfers, advice and similar services. Annex IV sets €125,000 for custody and exchange services and €150,000 for operating a trading platform. Article 67 requires the higher of the Annex IV amount or one quarter of fixed overheads. A firm without a full year of business uses projected fixed overheads for its first 12 months. Article 60 financial entities follow their existing sectoral prudential regime and route-specific requirements.
Why do MiCA licence cost estimates vary so much?
Estimates measure different things. A filing or drafting quote can exclude regulatory capital, authority fees, compliance staff, and ICT and DORA work. The quote can also exclude audit, insurance, office and ongoing supervision. Ask every provider for an itemised scope and its assumptions before comparing figures. No universal all-in estimate applies to every CASP.
How long does authorisation take?
MiCA gives the authority 25 working days to check completeness and 40 working days to assess a complete file. The statutory periods do not include preparation. The authority can suspend the assessment period when it requests more information. The periods do not promise an end-to-end project date.
Can I just pick the cheapest, fastest country?
No. Article 65 provides a notification route for authorised services in other EEA states. The applicant still needs a real registered office and activity in its home state. The applicant also needs effective management in the EU and at least one EU-resident director. Regulator fees are one small part of a home-state decision.
Sources: capital classes and establishment requirements from Regulation (EU) 2023/1114 (Articles 59, 63 and 67, and Annex IV). Malta fees come from the official Markets in Crypto-Assets Act (Fees) Regulations. Reviewed 2 September 2026. ESMA register data through 20 August 2026. The page gives general information and does not provide legal, tax or licensing advice.