Is Estonia Still Crypto-Friendly? From the AML Act Licence to MiCA

Alena Mach

09.05.2022 | 6 min read

Updated: 15.10.2026

Estonia and crypto: from the FIU licence to MiCA

For years, the route into the Estonian crypto market was a national licence for virtual currency service providers issued by the Financial Intelligence Unit (FIU). Since 1 July 2026, crypto-asset services in Estonia require an authorisation under the EU Markets in Crypto-Assets Regulation (MiCA).

The FIU licence was issued under the Money Laundering and Terrorist Financing Prevention Act (MLTFPA). The FIU itself has said that checking anti-money laundering documents alone cannot manage the risks of the sector. Supervision of how client assets are safeguarded and of cyber resilience is also needed.

The FIU's own figures show how the market shrank. There were 641 valid licences when the FIU started to clean up the sector in mid-2021. At the start of 2026, there were 36.

The EU then replaced national crypto licences with a single regime. The MiCA rules for crypto-asset service providers, Regulation (EU) 2023/1114, have applied since 30 December 2024. Estonia added its national rules in the Crypto-Asset Market Act (krüptovaraturu seadus).

This act entered into force on 1 July 2024. It brought participants in the crypto-asset market under the supervision of Finantsinspektsioon, the Estonian Financial Supervision Authority.

What changed on 1 July 2026

MiCA let firms that provided crypto services under national law before 30 December 2024 continue during a transitional period. The period lasted until 1 July 2026 at the latest, or until the firm was granted or refused a MiCA authorisation, whichever came sooner.

Member States could shorten this period. Estonia did not: its law uses the same end date, 1 July 2026.

The Estonian rules sit in two acts. Under the Crypto-Asset Market Act, holders of the FIU licence had to bring their activity into line with the new requirements by 1 July 2026.

Under the MLTFPA, no new FIU licence could be applied for from 30 December 2024. An existing licence lapsed when its holder received a MiCA authorisation from Finantsinspektsioon, or on 1 July 2026 at the latest.

From 1 July 2026, crypto-asset services in Estonia may only be provided with an authorisation from Finantsinspektsioon or from the supervisor of another EEA state. The FIU announced that on the same day it would cancel the register data of the old virtual currency service licences.

How existing Estonian crypto companies made the transition

The FIU licence did not turn into a MiCA authorisation. The law describes three situations for a former licence holder:

1. Authorisation received. The FIU licence lapsed once the company received its MiCA authorisation from Finantsinspektsioon. From then on, the company works under MiCA and the Crypto-Asset Market Act.
2. Application still pending on 1 July 2026. If the company applied before that date and has no decision yet, its activity is not treated as unauthorised activity under the Penal Code. Until the decision, it may not conclude new client contracts.
3. No crypto services from 1 July 2026. A provider set up and operating before 30 December 2024 that stops crypto-asset services does not need to apply. It must tell clients that the service is ending and return their assets within a reasonable time. The same applies after a refusal by Finantsinspektsioon.

For companies without an authorisation, the FIU adds practical limits. From 1 July 2026, they may not accept new clients, open new accounts or actively market their services to clients in the EEA.

The FIU keeps a role in the crypto sector. Authorised crypto-asset service providers are obliged entities under the MLTFPA and must report suspicious transactions to the FIU. The FIU no longer issues licences for crypto services.

The FIU and Finantsinspektsioon advise clients to check whether their provider holds an EEA authorisation. Authorised providers can be checked in the Finantsinspektsioon register of market participants.

What a CASP authorisation requires

A crypto-asset service provider (CASP) applies to the competent authority of its home Member State, in Estonia Finantsinspektsioon. A participant authorised in Estonia must have its registered office in Estonia. The core conditions come from MiCA itself:

• Substance in the EU. The place of effective management must be in the Union, and at least one director must be resident in the Union.
• Management and shareholders. Members of the management body need sufficiently good repute and appropriate knowledge, skills and experience. Shareholders with qualifying holdings must also be of good repute.
• Prudential safeguards. The provider's safeguards must equal at least the higher of the minimum capital in Annex IV and one quarter of the previous year's fixed overheads. Own funds, an insurance policy or a comparable guarantee may be used, alone or combined.
• Minimum capital by class. Class 1, for example order execution, advice or transfer services: EUR 50,000. Class 2, which adds custody and the exchange of crypto-assets for funds or other crypto-assets: EUR 125,000. Class 3, which adds a trading platform: EUR 150,000.
• Operational resilience. Since 17 January 2025, crypto-asset service providers must meet the digital operational resilience requirements of Regulation (EU) 2022/2554 (DORA).

The application also describes governance, internal controls, money laundering risk management, ICT systems and the segregation of client assets. Some documents depend on the services, such as a custody policy or the operating rules of a trading platform.

Application, timelines and fees at Finantsinspektsioon

Finantsinspektsioon describes its procedure for crypto-asset service providers as follows. Deadlines and fees below are those stated by the regulator:

1. The application uses the form in Annex VI to the ESMA technical standards. Since 18 March 2026, it is submitted through the Finantsinspektsioon application portal.
2. The application is written in Estonian. Documents may be in English if the application says so clearly.
3. Finantsinspektsioon checks within 25 working days whether the application is complete.
4. It then assesses a complete application within 40 working days. A request for further information can pause this period for up to 20 working days.
5. The processing fee for a crypto-asset service provider's application is EUR 3,000.
6. To serve other EU states, the provider notifies Finantsinspektsioon. It may start there once the host authority has received the notification, or 15 calendar days after submission at the latest. This notification carries no processing fee.

So, is Estonia still crypto-friendly? Estonia is no longer a light-touch national regime. It no longer issues national crypto licences and applies the same MiCA rules as the rest of the EU.

What Estonia offers is an EU authorisation with passporting. A provider authorised in Estonia can serve other Member States after notification. For a project built for the European market, that is a real advantage. For a project that wanted a quick national licence, Estonia is no longer that option.

If you are assessing Estonia or another EU jurisdiction for a CASP authorisation, the team at Coredo can review your business model and help prepare the application documents.