MiCA CASP authorisation: preparing your application to NBS

Crypto-asset services, from custody and exchange to transfers, are regulated throughout the EU under Regulation (EU) 2023/1114 (MiCA). In Slovakia, the National Bank of Slovakia (NBS) grants crypto-asset service provider (CASP) authorisation, supplemented by Act No. 248/2024 Z. z. on certain obligations and powers in crypto-assets. Anyone starting services today must be authorised before accepting the first client (selected financial institutions submit a notification instead, see below).

The transitional period has ended

Under § 12 of Act No. 248/2024 Z. z., persons who before 30 December 2024 were entitled to provide virtual currency exchange or wallet services (or other activities bearing the features of crypto-asset services) could continue no later than 30 December 2025. Slovakia therefore used a shorter transition than MiCA allowed, as Article 143(3) of MiCA permitted continuation until 1 July 2026 at the latest. After 30 December 2025, there is no old regime to rely on: crypto-asset services may not be provided without authorisation or a notification under Article 60 (Article 59(1) MiCA). NBS may impose corrective measures and fines under § 8 and order blocking of the online interface through which services are offered under § 10.

A legal entity or other undertaking wishing to provide crypto-asset services needs CASP authorisation and applies under Article 62 MiCA. Selected financial institutions, including banks, investment firms, electronic money institutions, management companies, market operators and central securities depositories, do not need a new authorisation and instead notify under Article 60 at least 40 working days before starting those services. Delegated Regulation (EU) 2025/303 defines the notification. This applies only to the services that Article 60 permits for the given type of institution: for example, an electronic money institution only custody and transfer services for the e-money tokens it issues, and a central securities depository only custody and administration of crypto-assets. See when is NBS authorisation required for lending? for other authorisation regimes.

What the application must contain

Delegated Regulation (EU) 2025/305 details Article 62 application requirements in seventeen articles. The core consists of:

• A three-year programme of operations (Article 2): services and crypto-asset types, target markets and clients, domains and applications, marketing plans and group membership.
• Prudential safeguards (Article 3): Article 67 MiCA safeguards through own funds or insurance, with calculations for the first three financial years and stress scenarios.
• Governance and internal policies (Articles 4 and 5): internal controls and business continuity.
• AML arrangements (Article 6): money laundering risk assessment and policies under domestic implementation of Directive (EU) 2015/849.
• People (Articles 7 and 8): management body members’ reputation, knowledge and time commitment, and qualifying shareholders’ details.
• ICT and cybersecurity (Article 9): technical system documentation and compliance with Regulation (EU) 2022/2554 (DORA), including critical functions, ICT supplier contracts and a cybersecurity audit with penetration testing.
• Service-specific modules (Articles 12–17): custody policy, trading platform rules, exchange, order execution, advice and transfer services, depending on the requested activities.

A Slovak requirement under § 7(5) of Act No. 248/2024 Z. z. adds that an applicant using a network and information system must submit a description of the cybersecurity audit with the application.

Form and timing: changes restart the assessment period

Implementing Regulation (EU) 2025/306 governs submission: the standard annex form is used, NBS publishes its contact point and acknowledges receipt with details of who handles the application.

Article 4 contains the key rule. Applicants must notify changes without undue delay, and the assessment period under Article 63(9) MiCA then starts anew when the updated information is received. NBS may also request additional information under Article 63(12). In practice, it is advisable to file only once the application is complete and internally consistent. A change to the information must, however, be distinguished from supplementation at NBS’s request: the completeness check follows Article 63(2)–(4) MiCA, while a request for additional information during assessment is governed by paragraph 12, which permits the assessment period to be suspended for no more than 20 working days. This does not automatically restart the entire process.

After authorisation: NBS reporting

Authorisation does not end the obligations. Under § 5 of Act No. 248/2024 Z. z. and NBS Measure No. 3/2025, effective from 1 July 2025, an authorised CASP submits eight reports through the Statistical Collection Portal. Quarterly reports cover the balance sheet and profit and loss account, own funds, services and fees, wallet addresses and complaints. The provider report is annual, AML/CFT reporting half-yearly, and management body changes are reported within five working days. Internal policies must therefore address reporting during application preparation: the system must produce the data NBS wants quarterly from day one.

How to prepare

Treat the application as a project: define service scope and the authorisation structure first, then prepare policies, ICT documentation and the AML programme, completing the form last. We assist throughout through MiCA CASP authorisation. AML for businesses covers AML arrangements, and public offer assessment addresses the boundaries if you also plan to offer crypto-assets publicly.