You do not need a new authorisation from the Czech National Bank. A CASP authorisation granted by the National Bank of Slovakia permits you to provide services throughout the Union, but before starting services in Czechia you must notify NBS of the list of Member States, the services, the intended start date and your other activities. NBS forwards the information to the Czech single point of contact within 10 working days, and you may start on the day it notifies you of that transmission, and at the latest on the 15th calendar day after submitting the notification. You may provide only the services covered by your authorisation.
One of the principal advantages of Regulation (EU) 2023/1114 (MiCA) is that an authorisation as a crypto-asset service provider (CASP) granted in one Member State is valid throughout the Union. For a Slovak provider wishing to serve Czech clients as well, and for a Czech provider looking to Slovakia, that means a straightforward procedure, which nevertheless must not be skipped and which does not widen the scope of the authorisation.
One authorisation for the whole Union
Crypto-asset service providers may provide services throughout the Union under the right of establishment, including through a branch, or under the freedom to provide services, and cross-border provision may not be made subject to a physical presence in the host State (Article 59(7)). The home Member State is the State of the provider’s registered office (Article 3(1)(33)(f)), and in Slovakia the National Bank of Slovakia grants the authorisation and exercises supervision (Section 7(1) of Act No. 248/2024 Coll.). Czechia is the host Member State in this case (Article 3(1)(34)), and the Czech competent authority is the Czech National Bank (Section 9 of Act No. 31/2025 Sb., on the digitalisation of the financial market).
The procedure under Article 65
Before starting services in another State, the provider submits to the competent authority of the home State the list of Member States in which it intends to operate, the services it intends to provide there, the intended start date and a list of other activities to which MiCA does not apply (Article 65(1)). Within 10 working days, the home authority communicates that information to the single points of contact of the host States and to ESMA and EBA (Article 65(2)), and notifies the provider of it without delay (Article 65(3)). When you may start is governed by paragraph 4:
A crypto-asset service provider may start to provide crypto-asset services in a Member State other than its home Member State from the date of receipt of the communication referred to in paragraph 3 or at the latest from the 15th calendar day after having submitted the information referred to in paragraph 1.
A Czech company authorised by the CNB that wishes to operate in Slovakia proceeds in the same way; it submits the notification to the CNB, which forwards it to Slovakia.
What passporting does not solve
Cross-border provision covers only the services listed in the authorisation (Article 59(6)). If you wish to offer a service in Czechia that your authorisation does not cover, you must first ask NBS to extend it (Article 59(8)); a notification under Article 65 does not suffice for that. The authorisation also presupposes a genuine link with the home State: the provider must have its registered office in a State in which it carries out at least part of its business, its place of effective management in the Union, and at least one director resident in the Union (Article 59(2)). A company with nothing but a registered office in Slovakia, running its entire operation from Czechia, would not meet that condition. Whether the activity in the host State triggers duties outside MiCA, for instance in tax or consumer protection, must be assessed separately.
A third-country provider without an authorisation in the Union cannot rely on passporting. The exemption for a service provided at the client’s exclusive initiative is narrow: it does not apply where the firm solicits clients in the Union in any way, and it does not permit new types of crypto-assets or services to be offered to the client (Article 61(1) and (2)). The transitional periods for providers operating under the former national rules ended in Slovakia on 30 December 2025 (Section 12 of Act No. 248/2024 Coll.) and in Czechia on 1 July 2026, that is, on the latest date permitted by Article 143(3) MiCA.
How to proceed
Before notifying, check that the services planned for Czechia are covered by the authorisation, and prepare the list of other activities together with a realistic start date. We prepare the notification to NBS or the CNB, any extension of the authorisation and the cross-border operating arrangements through our MiCA licence for crypto-asset services service. If you are still applying for the authorisation, we set out the contents of the application in CASP authorisation under MiCA.
This answer provides general information on the law as at 12 September 2026. It does not constitute legal services or replace an assessment of an individual case. The details of your situation may differ. Book a consultation to discuss them.
