CASP Licence Cost in 2026: Fees, Capital and Timelines

Ask three consultants what a CASP licence costs and you will get three answers, all of them incomplete. The application fee is the smallest line on the invoice. What actually determines your budget is minimum capital, the people you must hire before you can file, and how long your regulator takes to come back with questions.

This guide breaks the cost into the four buckets that matter, using the figures firms are working with in 2026.

1. Minimum capital: set by what you do, not where you are

MiCA fixes prudential requirements by service class, and they are the same in every member state. This is the one number you cannot negotiate down by picking a friendlier jurisdiction.

• Class 1 — EUR 50,000. Reception and transmission of orders, execution on behalf of clients, placing, advice, portfolio management, transfer services.
• Class 2 — EUR 125,000. Custody and administration of crypto-assets on behalf of clients, plus exchange of crypto-assets for funds or for other crypto-assets.
• Class 3 — EUR 150,000. Operation of a trading platform.

You hold the higher of your class minimum or one quarter of the prior year's fixed overheads. For a firm running real headcount, that overheads test usually bites first — a team burning EUR 1.2m a year needs EUR 300,000 held, not the EUR 125,000 headline.

2. Application and supervisory fees

These are set nationally and vary far more than the capital requirement. Application fees across member states generally land between EUR 5,000 and EUR 25,000, with annual supervisory fees on top, often scaled to your turnover or client assets.

The fee is rarely the deciding factor. Regulator throughput and the quality of pre-application engagement matter more, which is why the same paperwork can take four months in one country and eleven in another. We compare that directly in where to get a CASP licence.

3. The people you must hire before you file

This is the bucket that surprises people. A CASP application is assessed on substance, and substance means named individuals resident in the authorising member state.

• Two executive directors with relevant experience, effectively running the business from the jurisdiction
• A compliance officer — in practice a full-time hire, not a shared service
• An MLRO responsible for AML/CFT, sometimes combinable with compliance at smaller firms
• A risk function proportionate to the services offered
• An IT/security lead who can answer to the DORA obligations that arrive alongside MiCA

Budget EUR 300,000 to EUR 600,000 a year for a credible minimum team before you write a line of the application. Regulators reject shell structures with non-resident directors, and they have become notably better at spotting them.

4. The compliance stack

You cannot file without describing the systems that will do the work. Auditors will ask for them, and "we will procure this post-authorisation" is a weak answer.

• Identity verification for onboarding — see the best crypto KYC providers
• Business verification if you onboard corporates — covered in best KYB software for crypto
• Sanctions and watchlist screening at onboarding and continuously — see best sanctions screening software
• Transaction monitoring with documented rules and alert handling — see best crypto transaction monitoring software
• Travel Rule messaging for transfers between providers — see Travel Rule compliance for VASPs

Realistic annual spend for a mid-size firm sits between EUR 60,000 and EUR 200,000 depending on volume and how many vendors you consolidate.

Putting it together

A first-time applicant offering custody and exchange — Class 2 — should plan for roughly:

• EUR 125,000+ held as regulatory capital (not spent, but locked)
• EUR 10,000–25,000 in application fees
• EUR 60,000–150,000 in legal and advisory support to prepare the file
• EUR 300,000–600,000 in annual staffing
• EUR 60,000–200,000 in compliance tooling

Call it EUR 450,000 to EUR 1m of first-year cost before a single client is onboarded, with capital locked on top. Firms that budget only for the application fee are the ones that stall halfway through.

Timelines

MiCA gives regulators 40 working days to assess completeness and a further 40 to decide. In practice the clock stops every time they request information, and most applications go through two or three rounds. Six to nine months from first submission to authorisation is a realistic planning assumption; firms with weak pre-application engagement have taken longer.

Where DORA fits

MiCA is not the only regime landing at once. DORA imposes ICT risk management, incident reporting and third-party oversight obligations on the same firms, and regulators increasingly review both together. Budgeting for MiCA alone leaves a gap — we set out the overlap in MiCA and DORA and in our DORA compliance guide.

Before you commit

The cheapest licence is the one you do not need. If your model can operate as a decentralised protocol without custody or an operated trading venue, MiCA may not apply to you at all — a distinction we explore in MiCA-compliant crypto platforms and top blockchains for Europe under MiCA.

If you do need one, pick the jurisdiction on regulator throughput and talent availability rather than headline fees. The difference between a six-month and a fourteen-month authorisation is worth far more than a EUR 15,000 saving on the application.