| Czech Republic |
Czech legal entity (typically an s.r.o. / a.s.) acting as a CASP applicant under MiCA or certain already regulated entities (with MiCA notification route for some services). |
MiCA (CASP authorisation) |
Case-by-case. In the EU, crypto exchange transactions (fiat ↔ bitcoin) are generally treated as VAT-exempt under the Hedqvist ruling of the Court of the EU, but not every crypto service is automatically exempt, so the service mix must be reviewed. |
Company formation: Czech commercial register entry has a general court deadline of 5 working days.
Licence: MiCA statutory process is staged (receipt, completeness, assessment), with 25 working days for completeness and 40 working days for assessment once complete (plus info requests). CNB is actively processing applications and has already issued first MiCA authorisations in Feb 2026. |
EUR 50,000 / 125,000 / 150,000 depending on CASP service category. The service category depends on the exact services provided. |
You need an EU legal-entity setup, registered office and effective head office in the EU, and at least one EU-resident director/manager. Also prepare a complete application package (ownership, governance, AML/compliance, business model) to avoid delays at completeness check. |
| Czech Republic |
Czech legal entity acting as a Section 15 manager (often used for a sub-threshold AIF / “mini-fund” style setup). |
Alternative Investment Fund |
Management of special investment funds is generally an EU VAT exemption category (Article 135(1)(g) of the VAT Directive), but supporting/administrative services may still be taxable. |
Company formation: commercial register generally 5 working days.
CNB list entry: the AMCIF provides a 5 working day deadline for entry in the relevant list after a proper application (applies to the CNB list route used for this regime). |
No fixed minimum for the Art. 15 sub-threshold registration route itself; the key gate is staying within the AUM thresholds. |
Sub-threshold regime: this route is only available if AUM stays within the statutory limits (EUR 100m leveraged / EUR 500m unleveraged closed-ended, with conditions). The client must bring a clear investment strategy, governance setup, and documentation for CNB list registration and ongoing reporting. |
| Canada |
Canadian corporation or foreign MSB with Canadian nexus |
MSB registration (FINTRAC) (note: FINTRAC registration is not a “licence”) |
Under CRA rules, financial services are generally GST/HST-exempt, but many services supplied by financial institutions can still be taxable, so scope mapping is required. |
Company formation (federal):online incorporation is typically 1 business day.
MSB: must be registered with FINTRAC before operating; FINTRAC processes requests in order received, but does not publish a fixed service standard for new MSB approvals on the registry page. |
No minimum capital stated for FINTRAC MSB registration (registration-based regime, not prudential licensing). |
AML registration regime, not a prudential licence. The client must be ready for FINTRAC registration before launch, and if acting as a foreign MSB, must appoint a representative resident in Canada to receive notices. A complete AML/compliance package is essential. |
| Poland |
Polish legal entity (commonly sp. z o.o.) used as CASP applicant or certain already regulated entities (with MiCA notification route for some services). |
MiCA CASP authorisation (EU MiCA regime) |
Case-by-case. In the EU, crypto exchange transactions (fiat ↔ bitcoin) are generally treated as VAT-exempt under the Hedqvist ruling of the Court of the EU, but not every crypto service is automatically exempt, so the service mix must be reviewed. |
Company formation: KRS filing is examined within 7 days, or 1 day via S24 template registration.
Licence: MiCA statutory clock applies (25 working days completeness + 40 working days assessment once complete, subject to requests for information). |
EUR 50,000 / 125,000 / 150,000 depending on CASP service category. The service category depends on the exact services provided. |
You need an EU legal-entity setup, registered office and effective head office in the EU, and at least one EU-resident director/manager. Also prepare a complete application package (ownership, governance, AML/compliance, business model) to avoid delays at completeness check. |
| Poland |
ASI + ZASI structure (internal or external manager); licensed ZASI applicant is a capital company |
AIF / ASI route: either registered ZASI (sub-threshold, no licence) or licensed ZASI (full KNF permit) |
Management of special investment funds is generally an EU VAT exemption category (Article 135(1)(g) of the VAT Directive), but supporting/administrative services may still be taxable. |
Company formation: KRS filing is examined within 7 days, or 1 day via S24 template registration.
KNF: for the licensed route, KNF indicates a 3-month decision timeline from receipt of the application or its supplementation; the registered route is lighter but timing still depends heavily on completeness of the filing. |
Licensed ZASI: EUR 125,000 (external manager) or EUR 300,000 (internal manager), in PLN equivalent. Registered/sub-threshold route: lighter entry regime (threshold-based). |
The key caveat is choosing the right route (registered vs licensed) based on AUM and model. For the licensed route, KNF expects a substantial file: company documents, management qualifications and criminal record extracts, shareholder/funding-source information, business plan, operational/IT setup, and AIF/ASI documentation. |
| Germany |
German legal entity (typically GmbH) or certain already regulated entities (with MiCA notification route for some services). |
MiCA CASP authorisation |
Case-by-case. In the EU, crypto exchange transactions (fiat ↔ bitcoin) are generally treated as VAT-exempt under the Hedqvist ruling of the Court of the EU, but not every crypto service is automatically exempt, so the service mix must be reviewed. |
Company: GmbH incorporation typically a few weeks including notary and register.
Licence: authorities indicate review may take up to ~4 months once the file is complete, often longer if information requests are issued.
|
EUR 50,000 / 125,000 / 150,000 depending on CASP service category. The service category depends on the exact services provided. |
Requires German or EU establishment, qualified management vetted by BaFin, robust AML/KYC framework, business plan, and proof of capital. Real local substance is expected; purely remote setups face scrutiny. |
| France |
French legal entity (SAS/SA commonly) acting as AIFM or sub-threshold manager. |
Alternative Investment Fund (AIFM or registered regime) |
Management of special investment funds is generally an EU VAT exemption category (Article 135(1)(g) of the VAT Directive), but supporting/administrative services may still be taxable |
Company: typically a few days to a few weeks depending on the filing route.
AMF: full authorisation procedures commonly several months; sub-threshold registration faster but still file-dependent. |
AIFM: typically EUR 125k (external) or EUR 300k (internally managed AIF) under AIFMD framework. |
Must demonstrate professional management, risk management framework, depositary arrangements where required, and full AMF-ready documentation. Management must meet fit-and-proper standards and maintain EU substance. |