Business obligations, registers and licences · Czechia and Slovakia
MiCA authorisation for crypto-asset services (CASP)
The transitional periods have ended. An ordinary new crypto-asset service provider needs CASP authorisation under MiCA. Certain already regulated financial entities may, within the scope prescribed by law, use a complete and timely notification under Article 60 instead of obtaining a new authorisation. We guide you through the entire process: from assessing the relevant services and capital class through jurisdiction choice and the application file to proceedings before the National Bank of Slovakia or Czech National Bank. Passporting then allows one authorisation to open the entire EU market.
- Lawyer admitted to both the Czech and Slovak Bars
- Proceedings before NBS and ČNB
- Scope and price agreed for each stage in advance
What we'll do for you
We divide the project into separately priced stages, from an initial fixed-price assessment with a clear deliverable through to managing proceedings. Before each stage, you know what you receive and what it costs.
Select an item to see the details.
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Services and capital class assessment — phase 0
We map the MiCA services you actually provide, the capital class they trigger — €50,000, €125,000 or €150,000 according to the highest authorised service — and whether any flows fall under PSD2 payment regulation. The deliverable is a recommendation on whether to proceed.
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Jurisdiction choice and corporate structure
We compare NBS and ČNB proceedings for your operating model, form or adapt the company and prepare a management structure meeting the regulator's expectations of local substance.
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Authorisation file
A complete application under Article 62 MiCA and the delegated regulations, including a programme of operations, risk management, custody policy, exchange business policy and fit and proper materials for management and shareholders.
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AML, Travel Rule and market abuse
An obliged entity's internal AML programme, rules for crypto-asset transfers under the Travel Rule and market abuse prevention measures, including suspicious transaction reporting procedures.
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Regulatory proceedings
Filing, communication with NBS or ČNB and responses to requests and supplementary submissions through to a decision. The decision period starts only once the application is complete, making file quality decisive for timing.
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Operations after authorisation
Ongoing compliance, including notification of changes, annual obligations, DORA digital operational resilience requirements and planned changes to EU-level supervision.
Deliverablea complete authorisation file meeting MiCA and delegated regulation requirements, submitted to the regulator, with proceedings handled through to a decision
How it works
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- Initial assessmentthe first few weeks
Mapping services, identifying the capital class, assessing PSD2 applicability and recommending whether to proceed. A budget for subsequent stages is included.
- Formation and preparation
Corporate structure, management with real substance, funding sources and fit and proper documentation.
- File and submission
We prepare the authorisation documentation, complete the attachments and submit the application to the regulator.
- Proceedingsa matter of months
We manage regulatory communications and supplement the file. A realistic horizon for the entire project is 12–18 months.
- Passporting
After authorisation, we notify other Member States — one authorisation opens the entire EU market.
MiCA harmonised crypto-asset rules across the EU and ended the era of national registrations. An ordinary new provider needs CASP authorisation with prudential safeguards, effective management, risk management and an AML programme. For already regulated financial entities, we first assess whether notification under Article 60 MiCA is available.
We handle authorisation proceedings in Slovakia and the Czech Republic. We are a law firm, not a technology supplier or auditor. We understand both regulators’ requirements, speak their language and tell you what you may not want to hear: whether the project has a chance in its current form, what could undermine it and what it will actually cost.
No-obligation enquiry
Ready to start?
Send us an enquiry. We reply within 24 hours with a price confirmation and next steps. The first 30-minute consultation is free and commits you to nothing.
- 1Send your enquiry via this form
- 2Within 24 h you get a price confirmation and plan
- 3We start work only after your approval
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What clients ask
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What services does CASP authorisation cover?
MiCA distinguishes ten crypto-asset services, from custody and administration through exchange for funds or other crypto-assets to operating a trading platform or providing advice. Authorisation covers specifically listed services, so the first step is always to map precisely what you actually intend to do. Every additional service creates further requirements for the file.
What financial safeguards will I need?
The prudential safeguards under Article 67 MiCA must continuously equal at least the higher of the amount specified in Annex IV and one quarter of the fixed overheads for the preceding year. Annex IV specifies €50,000, €125,000 or €150,000 according to the most demanding service; the amounts are not added together. The safeguards may consist of qualifying own funds, compliant insurance or a comparable guarantee, or a combination of these. Insurance must satisfy the conditions in Article 67(5) and (6), including territorial coverage, duration and covered risks; the availability of a suitable product must be verified. We determine the precise scope when assessing the project.
Why can stablecoins also require a payment services licence?
Transfers of electronic money tokens (EMTs) on a client's behalf may constitute a payment service for which the CASP needs separate authorisation under payment regulation, or must route the transfers through a licensed provider. Crypto-asset exchange alone does not trigger payment regulation. We therefore map every EMT flow, from deposit to withdrawal, during the initial assessment before deciding the authorisation structure.
Slovakia or the Czech Republic — where should we apply?
MiCA requirements are the same across the EU and neither regulator is an easier route. Actual operations should determine the choice: where you can locate management, key functions and staff. NBS has a detailed guide and explicit local substance expectations, while ČNB has longer experience with a large number of applications. A comparison for your specific model forms part of the initial assessment, including regulatory fees, which differ significantly.
How long do proceedings take?
The statutory periods are short: the regulator assesses completeness within 25 working days and decides within 40 working days of a complete application. The difficulty lies in 'complete': rounds of supplementation before completeness are not limited, and this is where proceedings become prolonged. A realistic horizon from engagement to authorisation is 12–18 months. A well-prepared file does most to reduce it.
Does a transitional period still apply to me?
Probably not. Slovakia ended its transitional period on 30 December 2025. In the Czech Republic it ended on 1 July 2026 and applied only to entities already operating before MiCA became applicable that submitted an application on time. An ordinary new project must obtain authorisation before starting operations. We separately assess already regulated financial entities that Article 60 permits to provide specified services once the notification conditions have been met.
What should I budget for besides legal services?
Prudential safeguards under Article 67, the regulatory fee, compliance and AML staff salaries, custody technology and its security, Travel Rule and blockchain analytics software, audits and ongoing supervision costs. Phase 0 includes a realistic budget for the entire project, including items we do not supply but that you must allow for.
Legal Q&A
Common questions on this topic
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Who is a beneficial owner, and how are they identified?
A beneficial owner is always an individual, never a company. In a company, this particularly includes anyone with a direct or indirect interest of at least 25% in voting rights or registered capital, the right to appoint or remove statutory or supervisory bodies, control by other means, or entitlement to at least 25% of the economic benefit. If no such individual can be identified, senior management, meaning the statutory body, is treated as the beneficial owner.
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What happens if we are not registered in RPVS or miss annual verification?
The consequence is more than a fine. If beneficial owner verification is missing, the public-sector counterparty is not in default when it withholds performance for that reason, so it may lawfully withhold payment of your invoice. False or incomplete data can bring a company fine equal to the economic benefit obtained, or otherwise EUR 10,000–1,000,000, and EUR 10,000–100,000 for the statutory representative. The two-year re-registration ban arises in the sanction cases governed by Section 13a, not after every voluntary deletion.
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What must an RPVS verification document contain, and who prepares it?
Only an authorised person, a lawyer, notary, bank, auditor or tax adviser, prepares the document to evidence beneficial owner identification or verification. It must explain the information supporting the conclusion, state the partner's ownership and management structure and confirm that the facts match what was actually established. It must not contain a personal identification number or another generally applicable identifier.
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Further reading
MiCA CASP authorisation: preparing your application to NBS
Crypto-asset services in the EU require CASP authorisation, and Slovakia’s transitional period for former crypto trade licences ended on 30 December 2025. Delegated Regulation (EU) 2025/305 defines the NBS application requirements, and subsequent changes restart assessment.
Read more →
Stablecoins in business: when CASP authorisation is not enough and payment authorisation is needed
Electronic money tokens are funds for payment regulation purposes. Exchanging stablecoins is not a payment service, but transferring them for clients can be, including between the same client’s accounts. EBA’s approach defines where CASP ends and PSD2 begins.
Read more →
AML amendment: goAML registration by 30 November 2026 and stricter beneficial owner verification
AML amendment Act No. 73/2026 Z. z. has applied since 1 June 2026. Obliged entities must register in the Financial Intelligence Unit’s goAML system by 30 November 2026 and must not rely solely on the register of legal entities when verifying beneficial owners.
Read more →