Regulation (EU) 2023/1114
MiCA licence requirements: what does MiCA require of you?
MiCA runs three separate regimes: authorisation as a crypto-asset service provider, authorisation as an issuer of asset-referenced tokens, and issuance of e-money tokens by a bank or e-money institution. Which one catches you depends on the activity, not on the label you use. Answer a few questions to see which articles apply.
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.
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Scope of this checker
- 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 independent information site operated by Ellul Solutions Ltd. 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.
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.
| Activity | Route | Key articles | Capital or own funds in the Regulation |
|---|---|---|---|
| Class 1 services: execution, placing, transfers, reception and transmission of orders, advice, portfolio management | Authorisation as a crypto-asset service provider | 59, 62, 63, 67, Annex IV | EUR 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-assets | Authorisation as a crypto-asset service provider | 59, 62, 63, 67, Annex IV | EUR 125,000, or a quarter of fixed overheads if higher |
| Class 3: any class 2 service plus operating a trading platform for crypto-assets | Authorisation as a crypto-asset service provider | 59, 62, 63, 67, Annex IV | EUR 150,000, or a quarter of fixed overheads if higher |
| Bank, investment firm, CSD, EMI, market operator, UCITS manager or AIFM providing equivalent services | Notification 40 working days before the first service | 60 | Set by the existing authorisation; Article 67 does not apply |
| Issuing an asset-referenced token, issuer is not a credit institution | Authorisation as an issuer of asset-referenced tokens | 16, 18, 20, 21, 35, 36 | Highest of EUR 350,000, 2% of the average reserve, a quarter of fixed overheads |
| Issuing an asset-referenced token, issuer is a credit institution | White paper approval plus notification 90 working days ahead | 17, 19 | Bank capital rules apply; Article 35 does not |
| Issuing an e-money token | Must already be a credit institution or an electronic money institution | 48, 49, 50, 51 | Set by the CRD or EMD authorisation |
| Offering another crypto-asset to the public or seeking admission to trading | No authorisation: white paper drawn up, notified and published | 4, 5, 6, 7, 8, 9, 14, 15 | None 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.
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.
- MiCA licensing requirements: what an application has to contain
MiCA application requirements under Article 62 and Delegated Regulation (EU) 2025/305: the 19 information items, the fit and proper proofs, and the statutory clock.
- MiCA grandfathering: the transitional period ended on 1 July 2026
Article 143(3) let existing providers trade on until 1 July 2026 at the latest, and states could shorten it. ESMA published the national periods: 6, 9, 12 or 18 months.
- MiCA licence register: how to check a firm is actually authorised
Article 109 requires ESMA to keep a public register of white papers, token issuers and authorised CASPs, plus a register of non-compliant entities under Article 110.
Common questions
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 custody and administration on behalf of clients, operation of a trading platform, exchange of crypto-assets for funds, exchange for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management, and transfer services on behalf of 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 figure and a quarter of the preceding year's fixed overheads, held as Common Equity Tier 1 items, an insurance policy meeting Article 67(5) and (6), or a combination.
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 provide crypto-asset services after a notification made at least 40 working days in advance, but 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
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), consolidated Official Journal text
- Commission Delegated Regulation (EU) 2025/305, RTS on the information in a CASP application
- ESMA, list of grandfathering periods under Article 143(3)
- ESMA, MiCA overview and Level 2 and Level 3 measures
- ESMA, databases and registers (MiCA register)
- EBA, asset-referenced and e-money tokens under MiCA
- ESMA statement on the end of the MiCA transitional period, June 2026 (via AMF)
Find out which MiCA regime you are in
Six questions, article references on every answer.
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