Every provider quoting a MiCA CASP license leads with the same number: €50,000. It is technically true and practically useless, because €50,000 is the minimum own-funds requirement for the lightest service tier, not the cost of getting licensed. By the time you have paid for legal drafting, local substance, an AML build-out that survives a real regulator's review, and the first year of supervisory fees, the honest figure is many multiples of that headline.
This matters more now than it did eighteen months ago. Three weeks past the 1 July 2026 transitional backstop, roughly three-quarters of previously registered VASPs still have not converted, and a meaningful share of that backlog is businesses that budgeted against the €50,000 headline and then stalled when the real cost and timeline arrived. Getting this number right before you file, not after, is the difference between a project you can actually finish and one that runs out of runway halfway through.
This guide sets out the corrected capital tiers, the real all-in cost most businesses actually pay, the honest end-to-end timeline, and a detail almost no cost breakdown covers: the jurisdiction-by-jurisdiction swing in ongoing supervisory fees, which can matter more to your five-year cost than the initial application ever did.
Direct Answer
A MiCA CASP license costs roughly €300,000 to €700,000 all-in in year one, with €150,000 to €250,000 a year in recurring costs after that. Minimum capital is tiered: €50,000 for Class 1, €125,000 for Class 2, and €150,000 for Class 3. Realistic end-to-end timelines run four to twelve months.
Step 1: Confirm Your Capital Tier
The capital you must hold is not a choice; it is set by the services you actually provide, and getting this wrong at the outset skews every other budget line that follows. MiCA sets three tiers, and the numbering matters because it is easy to find outdated or garbled versions of this table elsewhere online.
| Tier | Minimum capital | Services covered |
|---|---|---|
| Class 1 | €50,000 | Reception and transmission of orders, execution of orders, placing of crypto-assets, transfer services, advice, portfolio management |
| Class 2 | €125,000 | Class 1 services, plus custody and administration, exchange of crypto for fiat, exchange of crypto for crypto |
| Class 3 | €150,000 | Class 2 services, plus operating a trading platform |
Class 1 is the lightest tier, built for advisory, brokerage, and non-custodial models. Class 2 is where most crypto-to-fiat exchanges and custodians actually sit, since custody and fiat conversion push you past the Class 1 threshold. Class 3 is the broadest tier, required the moment you operate a trading platform, and it absorbs every service in the two tiers below it.
What to Consider
- Map your actual service list against the table before assuming a tier. Adding custody or fiat exchange to a Class 1 model pushes the entire license into Class 2, with a materially higher capital requirement.
- The tier is a floor, not a target. Regulators can require additional capital based on your risk profile, transaction volumes, or business model, on top of the stated minimum.
- Do not under-scope your services to fit a lower tier. Under-declaring what you actually do to save on capital is a governance red flag that surfaces during review, not a real cost saving.
- Capital must be genuinely held, not just committed. Regulators expect to see the funds, not a shareholder letter promising them later.
Final Takeaway: Confirm your tier from your actual service list, not your budget. The tier drives the capital requirement; the capital requirement should never drive which tier you claim.
Step 2: Choose Your Jurisdiction, Cost and Speed Both
Because a CASP license passports across the entire EU and EEA, the jurisdiction you choose shapes cost and timeline far more than market access. Germany currently holds the most authorizations in the EU, but a large share of that count is traditional banks converting existing permissions, not new applicants, which is a different starting position than most crypto-native businesses have. Lithuania is worth a closer look for a different reason: it closed its own national deadline on 1 January 2026, six months ahead of the EU-wide backstop, and keeps applications open year-round rather than running a single filing window.
That fintech-friendly reputation is genuine on process and cost, but it is not the same as an easy approval. A compliance firm working the Lithuanian market reported helping more than 20 applicants prepare files by mid-2025, with only a single approval granted at that point, suggesting the Bank of Lithuania's substantive review is considerably more rigorous in practice than the marketing implies.
| Jurisdiction | Authority | Typical timeline | Cost profile |
|---|---|---|---|
| Lithuania | Bank of Lithuania | 4–6 months | Lower application and legal cost; year-round filing window |
| Estonia | FIU | 4–7 months | Structured, tech-forward process; moderate cost |
| Poland | KNF | 4–8 months | Affordable EU entry; requires local office and resident director |
| Malta | MFSA | 5–9 months | Higher cost; deep pre-MiCA crypto licensing track record |
| Cyprus | CySEC | 5–8 months | Moderate cost; strong for brokerage and advisory files |
| Germany | BaFin | 5–9+ months | Highest ongoing supervisory cost of the group; many authorizations are converting banks |
Part of the cost gap between jurisdictions is simply the local price of the same underlying work: legal drafting rates, translation requirements, the cost of a genuine local office, and director-residency rules all vary by member state independent of the regulator's own review rigor. A jurisdiction with a lower headline application cost is not necessarily cutting corners on the assessment; it may simply have a lower cost base for the same file.
What to Consider
- A jurisdiction's application cost and its ongoing cost are two separate numbers. A cheaper application in a jurisdiction with high recurring supervisory fees can cost more over five years than a pricier one with lower ongoing charges.
- "Fintech-friendly" describes process and cost, not approval odds. Lithuania's low first-approval rate among 2025 applicants is a genuine data point, not a reason to avoid the jurisdiction, but a reason to prepare the file properly.
- Local substance requirements vary and cost real money. A resident director, a genuine office, and local staff are recurring costs, not one-time filing fees.
- Match the jurisdiction to your service mix and target market, not just the cheapest sticker price.
Final Takeaway: Weigh application cost, ongoing supervisory fees, and realistic approval odds together. The cheapest jurisdiction on paper is not always the cheapest one over five years.
Step 3: Budget for the Real All-In Cost, Not the Capital Minimum
The €50,000 to €150,000 capital figure is the smallest line item in a real CASP budget, not the headline cost. Independently corroborated industry figures put the typical all-in year-one cost at €300,000 to €700,000, with application and legal fees alone commonly running €200,000 to €500,000. After year one, ongoing costs settle into a €150,000 to €250,000 a year range, covering compliance staff, audits, reporting, and supervisory fees.
| Cost category | Typical range |
|---|---|
| Minimum own-funds (capital, by tier) | €50,000 – €150,000 |
| Application, legal, and advisory fees | €200,000 – €500,000 |
| All-in year-one cost (capital plus setup) | €300,000 – €700,000 |
| Recurring annual cost after year one | €150,000 – €250,000 |
These figures are broadly consistent with our own crypto license cost calculator, which uses the same €300,000 to €700,000 baseline and lets you model your own service tier and jurisdiction against it rather than relying on a single averaged number.
Example
A composite crypto-to-fiat exchange targeting a Class 2 authorization budgeted €125,000 in required capital plus what it initially estimated at €80,000 in legal and setup costs, based on a provider's headline quote. By the time AML policy drafting, a resident director, local office costs, and a second round of regulator questions were factored in, the real pre-authorization spend landed closer to €340,000, still within the independently corroborated range, but nearly triple the original estimate.
What to Consider
- Treat any quote near the €50,000 minimum as a capital figure, not a total cost. Ask explicitly what the quote does and does not include.
- Budget legal and advisory fees as a range, not a fixed number. €200,000 to €500,000 is wide because file complexity, jurisdiction, and how many rounds of regulator questions you draw all move the real figure.
- Plan for recurring cost from day one, not just the application spend. A license that costs €300,000 to obtain and then folds under €200,000 a year in ongoing compliance cost has not actually solved your problem.
- Use a calculator or model against your specific service mix, not an industry-wide average, since Class 1, 2, and 3 files carry meaningfully different real costs.
Final Takeaway: Budget €300,000 to €700,000 for year one and €150,000 to €250,000 a year after that. Anyone quoting materially below that range is quoting the capital minimum, not the license.
Step 4: Build the Application File
A complete CASP file rests on the same pillars regardless of jurisdiction: an AML and KYC framework that survives real scrutiny, an EU/EEA-resident director with genuine fit-and-proper standing, an appointed Money Laundering Reporting Officer, and demonstrated operational resilience, cybersecurity, business continuity, and client-asset segregation among them. Weak governance and AML documentation are, consistently, the single biggest cause of delay across every jurisdiction covered in this guide.
Local substance requirements deserve particular attention because they are easy to underestimate from a cost perspective. Several member states expect a genuine physical office, not a registered address, and a resident director who can demonstrate real, ongoing involvement in governance decisions rather than a name on a filing.
What to Consider
- Front-load the AML and governance work. This is where files stall, and it is the one part of the budget where under-investing costs more time than it saves in fees.
- Confirm your local-substance obligations before signing a lease or a director agreement. Requirements differ by member state, and getting this wrong means redoing it later.
- Build the file to survive a second round of questions, not just the first submission. Regulators commonly request additional documentation once, and a thin initial file invites more of it.
- Keep the file internally consistent. A service description in the governance section that does not match your capital tier or your marketing materials is a common, avoidable red flag.
Final Takeaway: The application file, not the capital, is where most of the real cost and most of the real delay live. Invest there first.
Step 5: Plan for the Real Timeline, Not the Statutory Clock
MiCA's statutory clock gives the national competent authority roughly 25 working days to confirm your application is complete, followed by a further assessment window commonly cited at up to 40 working days from a complete file, often longer in practice. That clock only starts once your file is genuinely complete, and getting there, preparation, capital injection, and building local substance, is usually the longer part of the process.
Real end-to-end timelines, start to finish, commonly run four to twelve months. The businesses that land at the shorter end are the ones that arrive with a complete, internally consistent file on the first submission; the businesses at the longer end are almost always dealing with multiple rounds of regulator questions on AML or governance gaps that should have been resolved before filing.
Reality Check
The €50,000 capital headline exists because it is the smallest, most quotable number in the whole process, not because it reflects what a CASP license actually costs or how long it actually takes. The honest range is €300,000 to €700,000 in year one and four to twelve months end to end, and any provider or jurisdiction pitching a materially faster or cheaper path is usually describing an incomplete part of the process, not the whole thing.
What to Consider
- Build your internal timeline around 4 to 12 months, not the statutory 65 working days. The statutory clock only covers the assessment phase, not preparation.
- A complete first submission is the single biggest lever you control over your own timeline. Rushing to file early with gaps almost always costs more time than preparing properly first.
- If you are converting from a legacy VASP registration under time pressure, start now regardless of where you are in this guide. The gap between your remaining runway and a realistic timeline is the actual risk, not the deadline itself.
- Confirm your specific national competent authority's current review pace. Backlogs vary, and a jurisdiction's historical average timeline may not reflect its current queue.
Final Takeaway: Plan on four to twelve months and a six-figure budget from day one. Treating either number as smaller than that is the most common planning mistake in this process.
Step 6: Budget for Recurring Supervisory Fees by Jurisdiction
This is the detail most cost breakdowns skip entirely, and it is genuinely useful because the swing is large. Annual supervisory fees vary sharply by national competent authority: Germany's can reach €50,000 to €100,000 a year for a mid-sized CASP, while Lithuania's typically run to only a few thousand euros a year for a smaller operator. That gap alone can be larger than the entire application cost difference between the two jurisdictions.
This is not a reason to treat Germany as uncompetitive; its authorization count and, for many models, its banking relationships carry real weight. It is a reason to model your five-year total cost of ownership, not just your first-year application spend, before committing to a jurisdiction.
Example
A composite Class 2 applicant compared two jurisdictions on a five-year basis. Route A, a lower-cost jurisdiction similar to Lithuania, ran roughly €250,000 in application and legal fees plus €125,000 in capital, with supervisory fees near €5,000 a year, for a five-year total near €400,000. Route B, a higher-cost jurisdiction similar to Germany, ran a comparable €125,000 in capital but closer to €400,000 in application and legal fees, with supervisory fees near €75,000 a year, for a five-year total closer to €900,000. Neither route was wrong for every business; the point is that the gap only becomes visible when the ongoing fee line is modeled honestly rather than left out of the comparison.
What to Consider
- Ask every jurisdiction's advisor for the current annual supervisory fee schedule, in writing, not an estimate. This figure changes and is easy to understate.
- Model five years of ongoing cost, not one. A jurisdiction with a modestly higher application cost and a much lower annual fee often wins over a longer horizon.
- Weigh supervisory cost against banking and reputational access. A higher-fee jurisdiction like Germany can still be the right call if it materially improves your banking outcome.
- Revisit this line item annually. Supervisory fee schedules are set nationally and can change independent of your business.
Final Takeaway: Model five years of supervisory fees before you choose a jurisdiction. The gap between the cheapest and most expensive options can be larger than the entire application cost.
Conclusion
The €50,000 headline was never the real number, and three weeks past the MiCA transitional backstop, the businesses still stuck mid-file are disproportionately the ones that budgeted against it. The honest figures are €300,000 to €700,000 in year one, €150,000 to €250,000 a year after that, four to twelve months end to end, and a supervisory-fee swing between jurisdictions that can outweigh the entire application cost difference.
None of that makes a CASP license a bad investment; it makes it a project that deserves a real budget and a real timeline from the outset, built against your actual capital tier and a jurisdiction chosen on more than its reputation. Get those two decisions right early, and the regulatory process becomes predictable rather than a moving target.
How BankMyCapital Helps
We are not a bank, an EMI, or a law firm, and this guide is not legal or financial advice. What we do is help you confirm your real capital tier, compare jurisdictions on cost, timeline, and supervisory fees rather than reputation alone, and build the application file to survive a real regulator's review the first time. Full detail on the license itself lives on our CASP license page, part of the wider crypto licensing practice, and you can model your own numbers with our crypto license cost calculator.