Does MiCA cover every crypto-asset?

No. Crypto-assets that qualify as financial instruments, deposits or other instruments already covered by Union financial services law fall outside MiCA and are governed by those frameworks instead. Establishing which side of that line a token sits on is a perimeter question, not a formality.

Do we need a separate authorisation to issue a stablecoin?

Issuance is a separate route from service provision. Offering an asset-referenced token to the public requires its own authorisation, and an e-money token may be offered to the public only by an issuer authorised as a credit institution or as an electronic money institution. A crypto-asset service provider authorisation does not carry either.

Crypto-assets authorisation in the EU

Direct answer

Providing crypto-asset services in the Union, such as custody, exchange, operating a trading platform, transfer or advice, requires authorisation as a crypto-asset service provider, and the applicant must have a registered office in a Member State with its effective management in the Union.1 5 Issuing tokens is a separate question with a separate answer: offering an asset-referenced token needs its own authorisation, and an e-money token may be offered only by a credit institution or an electronic money institution.3 4 The transitional arrangement for firms operating under national law before 30 December 2024 ran until 1 July 2026 at the latest and is no longer available.9 10

Who this applies to

Crypto exchanges and trading platforms
Custodial wallet and custody providers
Issuers of asset-referenced tokens and e-money tokens, under a separate route3 4
Non-EU crypto firms that need an established EU entity to serve EU users1 5

Regulated activities

Custody and administration of crypto-assets1 5
Operation of a trading platform for crypto-assets1 5
Exchange of crypto-assets for funds or other crypto-assets1 5
Transfer, placing, reception and transmission of orders, and advice1 5

Routes to market

Own CASP authorisation

A crypto-asset service provider authorisation from one Member State, extended to others through the cross-border notification procedure.1 5 7

Notification by an already authorised firm

Some entities that already hold a Union authorisation, including credit institutions, investment firms and electronic money institutions, may provide specified crypto-asset services on notification instead of a separate authorisation.6

Acquisition

Acquire an authorised provider. The transitional route through a firm still operating under a national regime has closed, so the target needs a MiCA authorisation.9 10

Capital and substance

Own funds of at least the higher of the permanent minimum capital requirement for your class of services and one quarter of the fixed overheads of the preceding year.8
The permanent minimum by class is EUR 50 000, EUR 125 000 or EUR 150 000 depending on which services are provided.8
Registered office in a Member State, effective management in the Union, and custody segregation, complaints and conflicts frameworks.1 5 11 14
Authorised providers and issuers of asset-referenced tokens are financial entities under DORA, so ICT risk management applies to them directly once authorised.12 13

Authorisation stages

1
Classification
Map the services to MiCA categories, and check separately whether any token issuance engages the asset-referenced or e-money token route.1 3 4 5
2
Pre-application
Prepare governance, custody, prudential and ICT evidence.8
3
Submission and review
File with the competent authority and manage questions.
4
Cross-border notification and launch
Notify host states and complete operational readiness.7

Where applications commonly fail

Reading the class minimum as the whole capital requirement and ignoring the fixed-overheads limb8
Collapsing token issuance into the service authorisation3 4
Assuming a transitional national registration still supports EU activity9 10
Weak custody segregation and safeguarding controls
Treating ICT resilience as a task that follows authorisation12 13

Frequently asked questions

Yes. The transitional arrangement for providers operating under national law before 30 December 2024 ran until 1 July 2026 at the latest. Member States could shorten it or decline to apply it at all, so it ended earlier in some of them, but it is no longer an available route anywhere.

Primary sources for this page

14 citations, each to the article or section the statement rests on. The numbers beside a statement point to the citation behind it. Always confirm against the current official text.

Last updated 2026-08-21. 3 min read, calculated from 605 words.

Crypto-assets: MiCA