MiCA CASP authorisation in Estonia (Finantsinspektsioon)

Why teams look at Estonia

Estonia is a digital-first state with e-Residency and a strong technology base. It once ran one of the world’s most permissive crypto-licensing regimes, which it then tightened sharply, with large numbers of registrations withdrawn as substance and anti-money-laundering rules were raised. Under MiCA’s crypto-asset service provider regime, applying from 30 December 2024, the Finantsinspektsioon (Estonian Financial Supervision Authority) is the authorising authority. Treat Estonia as digital-friendly but no longer light-touch.

This page is informational and does not replace legal, regulatory, or tax advice. Confirm current requirements, forms, fees, and timelines directly with the Finantsinspektsioon before acting.

The authorisation route

A firm that is not already an EU-authorised financial entity applies to the Finantsinspektsioon for authorisation as a CASP under Article 62. A firm already authorised under EU financial law can use the lighter Article 60 notification.

Under Article 63 the authority has 25 working days to confirm completeness and then 40 working days to decide once the file is complete.

What the Finantsinspektsioon expects

Local substance

A registered office in Estonia and management effectively based there under Article 59(2). After the tightening of the old regime, genuine local presence is closely tested.

AML and controls

Estonia raised anti-money-laundering expectations sharply. Expect close attention to AML, sanctions, and transaction-monitoring controls.

Custody and client assets

Segregation, reconciliation, a custody policy, and strict liability for loss under Article 75 where you hold client crypto-assets or the means of access.

Prudential safeguards

Own funds, an insurance policy, a comparable guarantee, or a mix under Article 67, at the higher of the class minimum or one quarter of fixed overheads.

Capital and the Article 67 question

The minimum is 50,000 euro, 125,000 euro, or 150,000 euro depending on the services you are authorised for, or one quarter of the previous year’s fixed overheads if higher. If you are weighing insurance against capital, build the evidence first: see the CASP insurance evidence pack and own funds vs insurance.

Coming from a VASP registration

Estonia’s earlier crypto registrations do not convert automatically to a MiCA authorisation, and the substance bar is far higher than it once was. Firms transition through a process the Finantsinspektsioon manages within a national transitional window. Confirm the current cut-off date and the exact transition steps with the authority.

Transitional dates have moved at the member-state level. Confirm any date against current Finantsinspektsioon guidance before planning around it.

FAQ

Is an Estonia CASP licence valid across the EU?

Yes. A CASP authorisation passports to all 27 member states under Article 65. You authorise in Estonia and notify the host states before providing services there.

Is Estonia still the cheap, easy crypto licence?

No. The permissive era ended when Estonia raised substance and AML requirements and withdrew many registrations. It remains digital-friendly, but MiCA authorisation is a substantive process.