The Markets in Crypto-Assets Regulation (MiCA), which took full effect on 30 December 2024, introduced a single, EU-wide rulebook for crypto-asset service providers (CASPs). For the first time, the industry has a harmonised legal foundation covering capital adequacy, corporate governance, the safekeeping of client funds, marketing communications, and the disclosure of risks. Once a CASP has been authorised in one Member State, that authorisation is recognised across all 27 jurisdictions of the Union via the passporting mechanism.
Even so, the actual license is not granted by Brussels – it is issued by the national competent authority (NCA) of the chosen Member State. It is the national regulator that examines the application, evaluates the business model, performs fit-and-proper checks on directors and shareholders, signs off on the AML framework, and ultimately decides whether to authorise the firm. For that reason, picking the right country of application is still a strategic decision in its own right: it influences how long approval takes, how much the project costs, the volume of paperwork involved, the demands placed on the local office and team, and the overall tone of communication with the supervisor over the entire life of the license.
As of May 2026, roughly 200 MiCA licenses have been issued across the EU. That sample is now large enough to compare jurisdictions on the basis of real outcomes – rather than marketing brochures – and to identify which regulators are actually moving applications forward and which ones leave files queued for months.
What to look at when picking a MiCA jurisdiction
Anyone preparing a MiCA filing should weigh up at least seven dimensions: the cost of company setup and ongoing maintenance; how clear and predictable the regulatory regime is; the NCA’s track record with fintech and crypto firms; the supply of qualified local AML, compliance, and risk officers; the corporate tax landscape; how quickly the regulator responds; and how well the jurisdiction is regarded by banks and payment partners.
The relative weight of each factor varies from one project to the next, and there is no single “correct” weighting. A consumer-facing exchange and an institutional custody provider will, quite reasonably, end up choosing different jurisdictions for different reasons.
Looking at sheer license output, the top tier consists of Germany (55 MiCA licenses), the Netherlands (25), Malta (12), and France (11). These are the heavyweights – large financial centres with experienced supervisors and, generally, higher price tags.
Germany, supervised by BaFin, applies the toughest standard in the EU: detailed beneficial-ownership scrutiny, demanding expectations for senior management, and rigorous requirements around IT security and operational resilience. The upside is that a BaFin authorisation effectively unlocks access to almost any European bank. Among the firms licensed in Germany are Bitpanda and BitGo.
In the Netherlands, supervision sits with AFM and DNB. The country is appreciated for the predictability of its procedures and its strong fintech ecosystem, making it a natural hub for businesses focused on Northern and Western Europe. Authorised firms include MoonPay, Bitvavo, Banxa, and One Trading.
Malta was an early mover in crypto regulation, well before MiCA arrived, and the MFSA has retained that institutional know-how. The jurisdiction continues to attract internationally structured groups, although its history makes a particularly thorough AML build-out advisable. The list of MiCA-authorised firms in Malta includes Crypto.com, OKX, Gemini, Blockchain.com, Gate.io, Bitpanda, Socios.com, BVNK, Payhound, Damex, ZBX, and Altarius Group.
France, with AMF and ACPR at the helm, offers a well-defined and structured process, though it places considerable weight on real local presence and on the use of French in dealings with the regulator. Currently authorised companies include CoinShares, CACEIS, Deblock, Fipto, Hexarq, Cometh, Bitstack, Goin, Finctek, and Metalgear.
Cost: gaps measured in orders of magnitude
Legal fees tend to track the local cost of living, but the state licensing fee is where the real divergence shows up – and it is striking.
By May 2026, the Czech Republic had issued 6 MiCA licenses, with the state fee set at just CZK 20,000 (about EUR 800). In Germany, the comparable charge sits at around EUR 100,000. Lithuania has also granted 6 licenses; there, the Bank of Lithuania’s administrative fee is EUR 2,425, payable when the authorisation is issued.
Put differently, the spread in state fees alone between the most expensive and the most accessible jurisdictions runs into the tens. And that is before adding in the rest of the bill: minimum share capital (anywhere from EUR 50,000 to EUR 150,000, depending on the CASP service category), rent for a genuine local office, salaries for a qualified MLRO and compliance officer, the mandatory annual audit, and outlays on IT and cybersecurity.
Taken end to end, launching a CASP in the Czech Republic or Lithuania – legal support, capital, and the first year of operations included – typically lands in the EUR 150,000–250,000 range. The same exercise in Germany or the Netherlands comfortably runs to EUR 400,000–700,000, and for projects with a broader range of authorised services the total can sail past one million euros.
So where should you apply in 2026?
There is no one-size-fits-all answer. The right choice depends on the business model, the mix of CASP services on offer (exchange, custody, order execution, placement, advice), the shareholder structure, the AML risk profile of the customer base, and how much capital the project has to deploy.
On balance, however, the most well-rounded options in 2026 for the majority of small and mid-sized crypto firms are the Czech Republic and Lithuania: reasonable state fees, realistic processing times (6–9 months on average, against 9–14 in the larger jurisdictions), constructive engagement with the regulator, and a workable pool of AML and compliance talent. Lithuania carries the additional advantage of a mature fintech scene and the Bank of Lithuania’s long experience supervising EMIs and PIs; the Czech Republic offers legal stability and a convenient location in the heart of Europe. Together they represent a sensible entry point into the EU market without an outsized upfront budget.
For larger or reputationally exposed projects – particularly those targeting institutional clients, contemplating a listing, or building bank integrations across Europe – Germany, the Netherlands, and Malta still make sense. Costs are higher and the requirements heavier, but the resulting level of trust from banks, investors, and counterparties is, on average, noticeably better. A BaFin or DNB license is more than a piece of paper: it is a meaningful reputational asset that directly shapes the terms on which bank accounts are opened, acquirer relationships are built, and Tier-1 custody services become available.
The guiding principle is not to default to whichever jurisdiction is the cheapest or the fastest. A MiCA license effectively defines, for the next five to seven years, which banks will partner with you, which customers you can onboard, and which products you can roll out. A wrong call at the jurisdiction stage tends to cost far more than any saving on state fees: switching jurisdictions after authorisation is, in practical terms, equivalent to going through the licensing process again from the beginning.
It is also worth bearing the EU passporting angle in mind. On paper, an authorisation from any Member State is good across the whole single market; in practice, certain regulators – BaFin and AMF among them – keep a close eye on firms doing significant business on their territory under a passport, and may insist on additional local reporting or even a local footprint.
How Regulated United Europe can support you
The Regulated United Europe team accompanies crypto businesses through every stage of the MiCA licensing process. We help identify the most appropriate jurisdiction in light of the actual business model and growth plan, assemble the complete CASP application file, draft internal policies and AML/CTF documentation calibrated to the specific NCA’s expectations, design a corporate structure with tax efficiency in mind, recruit a local MLRO and compliance team, and manage communication with European regulators end to end – from pre-application meetings through to the issuance of the license and the start of live operations.
If you are planning to launch or relocate a crypto business within the EU in 2026, we are happy to discuss your specific situation, sketch out a realistic budget and timeline, and recommend the jurisdiction best suited to your project.
