Regulation (EU) 2023/1114

MiCA licence requirements: who needs MiCA authorisation

MiCA runs three regimes: crypto-asset service provider authorisation, asset-referenced token issuer authorisation, and e-money token issuance by a bank or e-money institution. The activity decides which catches you, not the label you use.

Question 1

Which of these describes what you do, or plan to do, with crypto-assets?

MiCA classifies by activity. Pick the one that carries the most weight in your business model; you can run the checker again for a second activity.

Scope of this checker

The 6 things it checks
  • Crypto-asset service provider authorisation (Articles 59, 62, 63 and Annex IV)
  • The notification route for banks, investment firms, EMIs, CSDs, market operators, UCITS managers and AIFMs (Article 60)
  • Asset-referenced token authorisation (Articles 16 to 21 and 35)
  • E-money token issuance (Articles 48 to 51)
  • White paper duties for other crypto-assets and the Article 4 exemptions
  • The transitional position under Article 143, which expired on 1 July 2026

MiCA Requirements is an information site. We are not a law firm, we are not authorised or registered by any regulator, and we are not affiliated with or endorsed by ESMA, the EBA, the European Commission or any national competent authority. Nothing here is legal or regulatory advice: MiCA classification and authorisation turn on facts a questionnaire cannot see, so confirm your position with a qualified adviser or your competent authority before acting.

MiCA requirements by activity: route, articles and capital

Last updated

Every activity MiCA regulates, the authorisation or notification route it takes, the articles that create the duty, and the capital the Regulation itself specifies. Read from the Official Journal text of Regulation (EU) 2023/1114.

MiCA requirements by activity: route, articles and capital
ActivityRouteKey articlesCapital or own funds in the Regulation
Class 1 services: execution, placing, transfers, reception and transmission of orders, advice, portfolio managementAuthorisation as a crypto-asset service provider59, 62, 63, 67, Annex IVEUR 50,000, or a quarter of fixed overheads if higher
Class 2 services: any class 1 service plus custody and administration, or exchange for funds or other crypto-assetsAuthorisation as a crypto-asset service provider59, 62, 63, 67, Annex IVEUR 125,000, or a quarter of fixed overheads if higher
Class 3: any class 2 service plus operating a trading platform for crypto-assetsAuthorisation as a crypto-asset service provider59, 62, 63, 67, Annex IVEUR 150,000, or a quarter of fixed overheads if higher
Bank, investment firm, CSD, EMI, market operator, UCITS manager or AIFM providing equivalent servicesNotification 40 working days before the first service60Set by the existing authorisation; Article 67 does not apply
Issuing an asset-referenced token, issuer is not a credit institutionAuthorisation as an issuer of asset-referenced tokens16, 18, 20, 21, 35, 36Highest of EUR 350,000, 2% of the average reserve, a quarter of fixed overheads
Issuing an asset-referenced token, issuer is a credit institutionWhite paper approval plus notification 90 working days ahead17, 19Bank capital rules apply; Article 35 does not
Issuing an e-money tokenMust already be a credit institution or an electronic money institution48, 49, 50, 51Set by the CRD or EMD authorisation
Offering another crypto-asset to the public or seeking admission to tradingNo authorisation: white paper drawn up, notified and published4, 5, 6, 7, 8, 9, 14, 15None specified
  • MiCA regulates ten crypto-asset services, listed in Article 3(1)(16): custody and administration, operating a trading platform, exchange for funds, exchange for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management and transfer services.
  • Permanent minimum capital for a crypto-asset service provider is EUR 50,000, EUR 125,000 or EUR 150,000 depending on the class of services in Annex IV, or one quarter of the preceding year's fixed overheads if that is higher (Article 67).
  • The MiCA transitional regime in Article 143(3) ran out on 1 July 2026 at the latest, and member states were free to shorten it: ESMA's published list records national periods of 6, 9, 12 and 18 months from 30 December 2024.
How this was compiled, and how to cite it

Compiled from Regulation (EU) 2023/1114 as published in the Official Journal, read on 15 August 2026: Titles II to V and Annex IV. Capital figures are the Regulation's own minimums, not estimates. Application fees are set nationally and are not in the Regulation; they vary by member state.

Cite this page

“MiCA requirements by activity: route, articles and capital”, MiCA Requirements, https://micarequirements.com/ (updated 2026-08-15). Compiled from Regulation (EU) 2023/1114 as published in the Official Journal, read on 15 August 2026: Titles II to V and Annex IV. Capital figures are the Regulation's own minimums, not estimates. Application fees are set nationally and are not in the Regulation; they vary by member state.

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Related guides

Sourced, dated, kept current.

Common questions

What is MiCA authorisation, and who grants it?

Article 59(1) requires it to provide crypto-asset services in the Union, unless the Article 60 notification route applies. The home competent authority grants it under Article 63, on an application with Article 62(2)'s 19 items. It has 25 working days for completeness and 40 to decide. Article 59(7) then allows Union-wide service, and ESMA lists the firm (Article 109). (Regulation (EU) 2023/1114, EUR-Lex)

Is a MiCA licence the same thing as MiCA authorisation?

Yes, though the regulation never says licence. Article 59(1) requires Article 63 crypto-asset service provider authorisation, or an Article 60 notification by a bank, investment firm or similar. A MiCA licence, or license in American spelling, means that authorisation. Asset-referenced token issuers are authorised under Article 21; e-money tokens come only from credit or electronic money institutions (Article 48). (Regulation (EU) 2023/1114, EUR-Lex)

Do crypto brokers need MiCA authorisation?

Yes, if they serve Union clients. Passing orders on is reception and transmission of orders (Article 3(1)(23)); concluding trades for clients is executing orders (Article 3(1)(21)). Both are crypto-asset services, so MiCA for brokers means Article 59(1) authorisation in Annex IV class 1, with EUR 50,000 permanent minimum capital. A MiFID II investment firm can notify under Article 60 instead. (Regulation (EU) 2023/1114, EUR-Lex)

Who has to comply with MiCA?

Anyone issuing, offering to the public or seeking admission to trading of crypto-assets in the EU, and anyone providing crypto-asset services there. Article 2 carves out unique non-fungible tokens, anything that qualifies as a financial instrument, deposit, insurance or pension product, and services provided exclusively within a corporate group.

What are the ten crypto-asset services under MiCA?

Article 3(1)(16) lists ten. Custody and administration for clients; operating a trading platform; exchange for funds; exchange for other crypto-assets; execution of orders. Then placing; reception and transmission of orders; advice; portfolio management; and transfer services for clients.

How much capital does a MiCA licence require?

Annex IV sets a permanent minimum of EUR 50,000 for class 1 services, EUR 125,000 for class 2 and EUR 150,000 for class 3. Article 67 requires the higher of that and a quarter of last year's fixed overheads. It is held as Common Equity Tier 1 items, an insurance policy meeting Article 67(5) and (6), or both.

Is the MiCA transitional period still running?

No. Article 143(3) capped it at 1 July 2026, and many member states set shorter national periods of 6, 9 or 12 months from 30 December 2024. A provider serving EU clients today needs an authorisation under Article 63 or a notification under Article 60.

Do banks and investment firms need a separate MiCA licence?

No, they notify instead. Article 60 lets credit institutions, investment firms, market operators, CSDs, e-money institutions, UCITS management companies and AIFMs notify at least 40 working days ahead. They may then provide only services equivalent to those their existing authorisation covers.

Can a non-EU firm serve EU clients under MiCA?

Not as a matter of course. MiCA has no third-country equivalence regime, and Article 59(2) requires a registered office in a member state, effective management in the Union and a Union-resident director. Article 61 permits service at the client's own exclusive initiative, but any solicitation, promotion or advertising in the Union defeats it.

Sources

This site's own dataset, every figure quoted from its source and dated:

  • The MiCA Authorisation Requirements carries 7 published figures read from 3 sources' own pages; the 6 published figures given by requirement run from 3 to 12 month, read 11 November 2026.
  1. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), consolidated Official Journal text
  2. Commission Delegated Regulation (EU) 2025/305, RTS on the information in a CASP application
  3. ESMA, list of grandfathering periods under Article 143(3)
  4. ESMA, MiCA overview and Level 2 and Level 3 measures
  5. ESMA, databases and registers (MiCA register)
  6. EBA, asset-referenced and e-money tokens under MiCA
  7. ESMA statement on the end of the MiCA transitional period, June 2026 (via AMF)

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