CASP license - re-licensing in accordance with MiCA

The Czech Republic has become an attractive destination for cryptocurrency companies due to its progressive approach to digital assets and strong governmental support for this sector. In recent years, the number of such companies operating in the country has steadily grown, driven by flexible regulations and favourable conditions for startups.

Under the new European Union regulations, as of 1 January 2025, all companies providing virtual asset services (VASP) in the Czech Republic must undergo a re-licensing process. This requirement is based on two key EU legislative acts that directly affect the operations of cryptocurrency businesses within the Union:

Markets in Crypto-Assets Regulation (MiCA)
Digital Operational Resilience Act (DORA).

These regulations have direct applicability in all EU member states. Specifically in the Czech Republic, the changes are reflected in the Digital Finance Act and the Act amending certain laws. Under the updated legal framework, the Czech National Bank (CNB) will act as the regulatory authority (National Competent Authority) responsible for overseeing the re-licensing process.

Advantages of obtaining a сrypto licence in the Czech Republic

Acquiring a cryptocurrency licence in the Czech Republic offers numerous significant advantages for companies operating in the crypto industry:

Access to EU markets: Licensed companies can operate freely across the European Economic Area (EEA), expanding their business opportunities within EU member states.
Flexible regulatory environment: The Czech Republic provides a straightforward regulatory framework for cryptocurrency companies, simplifying the licensing process and reducing bureaucratic hurdles.
Favourable tax conditions: Cryptocurrency companies benefit from attractive tax regimes, which enhance economic efficiency and help reduce operational costs.
Reliable legal support: Czech regulators, such as the Czech National Bank (CNB), ensure compliance with legal requirements and provide support throughout the licensing process.

Application submission deadlines

Registration as a licensed crypto-asset service provider (CASP) will become mandatory for all VASP companies wishing to continue their operations after 1 January 2025. All required documents and the re-licensing application must be submitted between 1 January and 31 July 2025.

Companies that comply with this requirement will be allowed to continue operating under their existing licence until a decision is made by the Czech National Bank, but no later than 1 July 2026. This transitional period provides cryptocurrency businesses with the necessary time to adapt to the new regulations and obtain the required licence to replace their expiring one.

Licence сategorisation

Under the new legislation, licences for crypto-asset service providers (CASP) are divided into three main categories:

Crypto-asset service provider (CASP):
A legal entity offering the following services, divided into three classes:
Class 1:
- Execution of purchase orders for crypto-assets (concluding agreements on behalf of clients to buy or sell crypto-assets).
- Placement of crypto-assets on the market (marketing crypto-assets to purchasers).
- Receiving and transmitting orders for crypto-assets (reception and transmission orders for execution).
- Providing crypto-asset advice (offering personalised recommendations to clients).
- Managing crypto-asset portfolios (investment management based on client mandates).
- Crypto-asset transfer services (transferring assets between addresses or accounts).
Class 2:

CASP authorised for any crypto-asset services under Class 1 and:
- Custody and management of crypto assets for clients (safekeeping of crypto-assets or of the means of access to such crypto-assets).
- Exchange of crypto-assets for fiat currencies or other crypto-assets.
Class 3:

CASP authorised for any crypto-asset services under Class 2 and:
- Operation of crypto-asset trading platforms (managing systems that connect buyers and sellers).

Issuer of asset-referenced tokens:
A legal entity issuing crypto-assets that maintain a stable value by referencing other assets or rights.

Issuer of electronic money tokens:
A legal entity issuing crypto-assets that maintain a stable value by referencing official currencies.

Note: The MiCA regulation does not apply to unique crypto-assets, such as NFTs.

Requirements for obtaining a CASP licence in the Czech Republic

To obtain a CASP licence, companies must meet the following key requirements:

Minimum capital:
- Class 1 — €50,000
- Class 2 — €125,000
- Class 3 — €150,000

Insurance policy (if minimum capital is insufficient):
The policy must include coverage against the particular list of risks, such as document loss or failure to meet legal obligations.

Management qualifications:
Company management must have sufficiently good repute, confirmed by a criminal record certificate, and at least three years of experience in crypto-assets and management positions.

Asset segregation:
Client assets and funds must be kept separate from the company’s own — in dedicated wallets and accounts.

These requirements ensure the reliability, transparency, and compliance of companies operating under the regulatory framework.

What is necessary to submit to CNB for a CASP licence

To apply for a CASP licence, the following documents must be submitted to the Czech National Bank (CNB):

Documents required for directors, executives, and shareholders:
- Identity documents (e.g., passport or ID card).
- Proof of residential address (e.g., utility bill).
- Bank statement for the last six months or tax returns.
- Completed KYC forms.
- CVs.
- Diplomas, certificates, or other relevant documents possess these persons’ knowledge, skills and experience.

Business and financial plan:
- A three-year activity programme outlining the services to be provided and marketing strategy.

Capital confirmation or insurance policy:
- Bank statement or a copy of the insurance policy proving compliance with minimum capital requirements.

Internal control and management documentation:
- Organisational structure and details of key personnel.
- Company policies, including money laundering and terrorist financing risk (AML) measures and risk management strategies.
- Business continuity plan.

Technical documentation:
- Cybersecurity audit.
- Description of DLT infrastructure and security measures.

Client asset segregation procedures:
- Segregation policies.
- Supporting documents, such as agreements with banks.

Additional documentation (if applicable):
- Policy for asset storage and management.
- Operating rules of the trading platform (Class 3).
- Commercial policy and pricing methodology (Class 2).
- Order execution policy for crypto-assets (Class 1).
- Knowledge and expertise confirmation of persons giving advice or managing portfolios (Class 1).
- Detailed information on asset transfer services (Class 1).
- White paper, if applicable.

Note: All documents must be submitted to the Czech National Bank in the Czech language.

CASP licensing process in the Czech Republic

We have developed a clear and efficient process for obtaining a CASP licence, ensuring full compliance with regulatory requirements while minimising client effort.

Initial case assessment
COREDO experts analyse the information provided to determine preparation timelines, the level of involvement required, and estimated costs. This stage typically takes about one week.
Preparation of application and documentation
Based on the specifics of your business, a list of required documents is compiled. The average preparation time is around two months, but this may vary depending on the completeness of the data provided.
Submission and application management
The application is submitted to the Czech National Bank, where COREDO specialists monitor its progress. If additional information is requested, it is provided promptly. In certain cases, active client participation may be required to address specific queries from the CNB.
CNB decision
The application review takes between 3 and 6 months (and no later than 1 July 2026). Upon approval, the relevant licence issuance will be recorded in the CNB register.

Service costs and scope

Our services are provided in two stages:

Initial case assessment
Cost: €5,000 + VAT.
What’s included:
- Providing detailed information on the requirements.
- Analysing the provided information and documentation — identifying problem areas and possible solutions.
- Drawing up an individual plan for the preparation of an application for a CASP licence.

Preparation of application and documentation, including interaction with the CNB
Cost: €29,000–€49,000 + VAT.
Factors influencing the final cost:
- Results of the initial case assessment — the level of involvement of COREDO specialists in preparing the application and developing the necessary documents.
- Necessary Classes of services within CASP.
The division of payments within this stage:
- Prepayment: 40% of the total cost of services. (Note: this payment must be made before the preparation of application and supporting documentation phase).
- Interim payment: 40% of the total cost of services (Note: this payment is made before the stage of submitting the application and interacting with the CNB, following the client’s approval of the prepared documents).
- Final payment: 20% of the total cost of services (this payment must be made after the CNB’s decision).

Trust COREDO experts to handle your company’s re-licensing process efficiently and professionally. With in-depth knowledge of Czech legislation and years of experience working with crypto companies, we ensure your business adapts seamlessly to new requirements. Our transparent, client-focused approach guarantees compliance with all regulatory standards, allowing you to focus on growing your business while we take care of the rest.

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