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: the capital the regulation requires, what regulators charge, and implementation and operating costs.
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 for fiat, crypto for 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
MiCA leaves authority fees to national law. The table shows the CASP fees that we could verify in official fee rules or on the authority’s own website, checked on 14 October 2026. Each row links to its legal basis.
| Home state | Application fee | Annual or supervisory fee | Legal basis |
|---|---|---|---|
| Malta (MFSA) | €10,000, €20,000 or €25,000 by highest service class | €10,000, €25,000 or €50,000 by class, plus €2,000 per authorised service and 0.05% of transaction volume, capped at €250,000 | S.L. 647.01 (L.N. 295 of 2024) |
| Cyprus (CySEC) | Charged per service and added together, from €5,000 to €30,000 each. Custody costs €10,000 and a trading platform €30,000. | A fixed amount per service (€5,000 to €20,000), plus a charge on crypto-service turnover above €500,000, capped at €500,000 in total | CySEC Directive DI 73-2009-04 (December 2024) |
| Czechia (CNB) | CZK 20,000 | None found in the fee act | Act No. 634/2004 Coll., Annex item 65(4)(g) |
| Germany (BaFin) | Charged by time spent, and due even if the application is withdrawn or refused | An annual cost levy based on balance-sheet total, with a minimum of €6,500 | FinDAGebV item 32.1.2 and FinDAG section 16g |
| Netherlands (AFM) | €200 per hour, up to €100,000, plus fit and proper tests per person | The 2026 AFM levy is €8,000 plus a charge per €1,000 of turnover and a fixed amount per service. DNB charges a separate levy. | AFM cost page and Staatscourant 2026, 20792 |
| Ireland (Central Bank) | Not found | A flat levy of €30,000 for a full year of authorisation (2026 funding regulations) | Guide to the 2026 Industry Funding Regulations |
| Luxembourg (CSSF) | €30,000, or €15,000 for an entity already authorised by the CSSF | €40,000, or €25,000 for an entity already authorised by the CSSF, plus €25,000 per trading platform | Grand-Ducal Regulation of 8 January 2026 |
| France (AMF) | No separate application fee | An annual contribution of €10,000, plus a charge on assets in custody with a minimum of €1,500 | Monetary and Financial Code, Articles L621-5-3 and D621-29 |
| Lithuania (Bank of Lithuania) | Not verified | 0.7% of annual revenue, with a minimum of €3,000 (2026 rate) | Bank of Lithuania 2026 contribution rates |
What drives the total cost
Authority fees are a small share of the budget. These cost lines set the total.
- Capital. The Annex IV floor is €50,000, €125,000 or €150,000 by service class, or one quarter of fixed overheads if that is higher (Article 67).
- Compliance staff. Management, compliance, AML and risk functions, with effective management in the EU (Article 59(2)).
- Legal work. The application file, internal policies, client terms and the disclosures that the services need.
- IT and security. Custody or trading systems, ICT risk controls under DORA, monitoring and Travel Rule tools.
- Audit. External audit of the accounts and assurance work on controls.
- Insurance. A policy, if the firm uses insurance to meet part of its prudential requirement under Article 67.
Published estimates vary widely. According to Crassula, a software vendor, a realistic first year for a credible Class 2 or Class 3 CASP costs €350,000 to €900,000, of which €125,000 to €150,000 is locked capital (guide updated 22 April 2026). The 2020 impact assessment by the European Commission estimated one-off compliance costs of €2.8 million to €16.5 million across the whole sector, depending on the number of entities seeking authorisation. Both figures are estimates by their authors and do not replace a quote for a specific firm.
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
- Outside the clockPreparation and remediation
- 25 working daysCompleteness check
- 40 working daysAssessment of a complete file
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. 365 current legal-entity entries appear in the snapshot as of 6 October 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.
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
- Regulation (EU) 2023/1114, Articles 59, 63 and 67 and Annex IV, for capital classes and establishment requirementseur-lex.europa.eu
- Markets in Crypto-Assets Act (Fees) Regulations, S.L. 647.01 (L.N. 295 of 2024), for Malta feeslegislation.mt
- CySEC Directive DI 73-2009-04 on Markets in Crypto-Assets (Fees and Subscriptions)cysec.gov.cy
- Czech Act No. 634/2004 Coll. on administrative feeszakonyprolidi.cz
- German FinDAG, section 16ggesetze-im-internet.de
- German FinDAGebV, item 32.1.2gesetze-im-internet.de
- Dutch supervision levy tariffs for 2026, Staatscourant 2026, 20792zoek.officielebekendmakingen.nl
- Luxembourg Grand-Ducal Regulation of 8 January 2026 on CSSF feeslegilux.public.lu
- French Monetary and Financial Code, Article L621-5-3legifrance.gouv.fr
- Crassula: MiCA CASP licence guide (22 April 2026)crassula.io
- European Commission, SWD(2020) 381, executive summary of the MiCA impact assessmenteur-lex.europa.eu
Reviewed 14 October 2026. ESMA register data through 6 October 2026. The page gives general information and does not provide legal, tax or licensing advice.