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Crypto License in Estonia

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MiCA CASP License Application in Estonia

Cryptocurrency and Wallet license in EstoniaEstonia continues to provide a reasonable legal environment for Crypto Asset Service Providers (CASPs) under the Markets in Crypto Assets (MiCA) regulation, aligning with EU-wide standards. Our lawyers and AML compliance professionals provide structured solutions for crypto exchange and wallet licenses setup under MiCA with corporate and AML compliance services support. MAXCORP is a member of the Estonian Crypto Association, the founding member of the Estonian Digital Assets Union and has navigated hundreds of companies to get licensed in Estonia since 2017.

Estonia has a clear and favorable legal and tax environment, including a 0% corporate income tax, making it an attractive licensing destination. Despite its small population of 1.3 million, Estonia is known as one of the world’s most digitally advanced nations. However, since 2022 the Financial Intelligence Unit (FIU, the previous regulator), adopted a restrictive approach toward virtual asset service providers (VASPs), creating a challenging regulatory environment for new entrants. The Estonian Financial Supervision Authority (FSA) assumed regulatory responsibilities (inc. licensing) for CASPs from January 2025, while the FIU will continue to manage existing VASPs until the Estonian transition period concludes on July 1st 2026.

Quick summary: CASP License in Estonia

Exchange + Wallet License
Setup in 4-8 months
Legal fees from 60.000 EUR
State fee 3000 EUR
Local substance required
Pricing >>
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Key points for Estonian MiCA CASP Crypto License Company structure

To apply for a CASP (Crypto Asset Service Provider) license under the Estonian MiCA framework, effective from 2025, a private limited liability company (OÜ) must first be established in Estonia. The minimum share capital required depends on the scope of activities.

The amount of the required share capital depends on the planned activities, most CASPs providing crypto exchange and/or wallet services fall under MiCA Class 2 (€125.000) or Class 3 (€150.000). Further, the capital amount may be required to be increased by the regulator, it is dependent on the projected operational costs of the CASP. The share capital must be fully paid in monetary form and held in a bank account within the European Economic Area (EEA). The company formation process can typically be carried out remotely, with no need to visit Estonia, and is completed within 10 business days after we receive all necessary documentation. Our service begins with analyzing the business model and the corporate structure to identify the appropriate license class and to determine the exact requirements for capital and documentation.

The license applicants have to comply with the local substance requirements such as on-site physical office, Estonian resident management board member(s) and local resident AML compliance officer (inc. MLRO), whom also have specific professional experience and fit-and-proper requirements. Further, the requirement to appoint an internal and external auditor is applied as well as FATF Travel Rule principle. We can provide on-going support with local substance (e.g. physical office setup) and AML compliance personnel sourcing such as professional background Estonian resident MLRO and CO roles to take care of reporting and to meet the regulatory requirements.

Once licensed, a CASP must maintain a comprehensive framework for Know Your Customer (KYC) and Know Your Transactions (KYT) processes, ensuring full compliance with Estonian and EU regulations. The Estonian Financial Supervision Authority (FSA) oversees all CASPs and may audit the company’s adherence to AML policies, request detailed reports on transactions, and evaluate compliance processes. The FSA may also conduct on-site visits to the company’s Estonian office to monitor operations and interview personnel. Our legal team is available to provide ongoing guidance, tailored to your specific needs, to ensure compliance with MiCA and AML requirements.

General requirements

  • At least 1 shareholder (natural person or corporate entity). No restrictions to citizenship or residence. For optimal setup structure please consult our legal team.
  • At least 2 management board member for MiCA Class 2 (one must be Estonian resident). Supervisory Board (3 members) requirement applies for MiCA Class 3.
  • Estonian resident AML compliance team inc. MLRO and CCO roles (professional experience required).
  • Physical office in Estonia required. Beneficial owners’ details are disclosed to the authorities.
  • Annual oversight fee: supervision fee consists of a fixed capital component and a variable component based on the entity’s assets. The exact rates are determined by the regulator annually.

Taxation

  • Virtual currencies (e.g. Bitcoin and altcoins) exchange services are not subject to VAT.
  • Services invoiced (e.g. sales invoices) in virtual currencies are subject to regular VAT rules.
  • Corporate profits are not taxed (CIT=0%) until the profits are distributed (as dividends). Income tax 22% is charged on gross dividends.

Company formation

Our lawyers support with a new company incorporation or we can provide an already prepared shelf company for a faster setup and license application submission. In our packages the company setup is already included. We also have availability for Estonian shelf companies with older registration dates and active VAT registrations. Usually the most time and cost efficient approach to register a company in Estonia is to purchase a new shelf company, because the founding process can be a challenge to non-residents due to some requirements (e.g. share capital deposit). Mostly non-residents opt for a new tailor-made shelf company to avoid bureaucracy as we have already taken care of all requirements. However, we do assist with new incorporations on request. We will help you to choose the best approach according to your objectives. For more information please refer to the Company Formation in Estonia page »

e-Residency

e-Residency is an optional digital identification card issued by the Republic of Estonia to non-Estonian citizens who do not permanently reside in Estonia, but would still like to take advantage of Estonia’s public e-services. e-Residency does not mean grant any form of citizenship, tax residency, residency right or right of entry to Estonia or the EU. It is not mandatory to obtain the e-Residency card for the company setup or licensing process, but we strongly recommend it as it simplifies the procedures and also the later administration of the company. For more information please refer to the Estonian e-Residency page »

Pricing for MiCA CASP Crypto License in Estonia

Setting up an Estonian private limited liability company (OÜ) and applying for the MiCA CASP crypto license in Estonia is straightforward as our lawyers take care of the full legal procedures on your behalf. We can also provide local substance building solutions per regulatory requirements. The company setup and license application submission can be completed remotely without travel, but an on-site interview with the regulator may be required in the final phase.
For more information please contact us for a tailor-made offer for your project >>

  • New LLC company in Estonia
  • Remote company setup
  • Lead time
  • Type of setup package
  • Official crypto license type
  • AML/KYC legal package
  • AML compliance consultation
  • Local substance consultation
  • Bank account opened
  • Registered share capital
  • Government fee (€3.000)
  • ASSESSMENT PACKAGE FOR CASP LICENSE Comprehensive preliminary assessment to identify potential compliance issues and deliver a detailed legal opinion.
  • € 15.000
  • 2 weeks
  • Legal opinion
  • Suitable CASP Class to be determined
  • Roadmap to be provided
  • Capital requirement to be determined
  • SEND ENQUIRY
  • LICENSE APPLICATION FOR CASP LICENSE Complete licensing package covering company, legal package, submission of the license application, and regulatory liaison.
  • € 60.000
  • 4-6 months
  • New License Appliaction
  • MiCA Class 2
  • Deposit €125.000+ required
  • SEND ENQUIRY
  • LICENSE APPLICATION FOR CASP LICENSE Complete licensing package covering company, legal package, submission of the license application, and regulatory liaison.
  • € 80.000
  • 4-8 months
  • New License Appliaction
  • MiCA Class 3
  • Deposit €150.000+ required
  • SEND ENQUIRY

* All orders are subject to our review and subject to our final confirmation; conditions may apply. All pricing is indicative and is subject to our final confirmation upon receiving order details. Prices shown excluding VAT. We reserve the right to change our individual and package prices at any time without notice. Additional fees may apply. Please contact us for a detailed offer specific to your project.

Legal Framework and Requirements in Estonia

The legal framework for Crypto Asset Service Providers (CASPs) in Estonia is governed by the Estonian MiCA Law, alongside the Money Laundering and Terrorist Financing Prevention Act (MLTFPA). These regulations establish comprehensive requirements for licensing, compliance, and operational standards, ensuring alignment with EU-wide practices. We can prepare all policy documentation according to the legal framework and manage the process to obtain a MiCA CASP crypto license in Estonia.

Documentation

For review and preparation of the licensing project we will ask for the following preliminary documentation:

  • Valid copy of passport from each country of citizenship
  • Power of Attorney (PoA)
  • Detailed business plan and financial forecasts
  • Resume (CV) listing employment and education background for all participants
  • Non-criminal certificate from the registry of convictions (not older than 3 months) for shareholder(s), board member(s), ultimate beneficiary owner(s)  *

All listed documentation has to be certified by notary public and confirmed with an apostille, in English (or sworn English translation). In the first stage we will gather all information and provide step by step process overview according to your case.

Procedures

Our legal compliance team will prepare comprehensive internal procedures and documentation to ensure your company meets the Anti-Money Laundering (AML), Know Your Customer (KYC), and Markets in Crypto-Assets Regulation (MiCA) requirements. Selected key components include:

Programme of Operations

  • A detailed description of the services and activities the company intends to provide, including the nature of crypto-asset transactions, custody, and trading operations.
  • Operational procedures for onboarding clients, managing transactions, and ensuring adherence to MiCA requirements.
  • Risk management systems to mitigate money laundering, terrorist financing, and other financial crime risks specific to crypto-assets.
Internal Security Measures
  • Assessment and management of risks associated with money laundering, terrorist financing, and vulnerabilities related to crypto-assets.
  • Implementation of secure processes for the collection, retention, and storage of transaction and customer records.
  • Reporting procedures for notifying the Financial Supervision Authority of any suspicious activities.
  • Internal control mechanisms to ensure compliance with MiCA and AML regulations.
Rules of Procedure
  • Clear definitions and protocols for low-risk and high-risk transactions, incorporating technological advancements and cross-border risks.
  • Processes for taking due diligence measures, including initial and ongoing KYC checks, as well as enhanced due diligence for high-risk customers.
  • Record-keeping requirements for all customer and transaction data to ensure compliance with MiCA and data protection regulations.
  • Detailed guidelines for monitoring transactions and applying the FATF Travel Rule in crypto-asset transfers.

Instructions and Guidelines
Practical steps to identify and manage:

  • Politically exposed persons (PEPs).
  • Entities based in jurisdictions with inadequate AML frameworks.
  • Persons suspected of involvement in money laundering or terrorist financing.
  • Individuals or entities subject to international sanctions.
  • Remote transactions or those carried out via digital communication channels.

Substance

We can provide several approach possibilities in regards to substance for meeting regulatory requirements in Estonia, e.g. we can support with setting up a local office and (out)sourcing highly qualified professionals of Chief Executive Officer (CEO), Chief Compliance Officer (CCO) and Money Laundering Reporting Officer (MLRO) roles, including support with on-going training, office and team management.

The duties of a Chief Compliance Officer (CCO) include, inter alia:

  • Main areas of work: internal controls; ensuring correct data keeping, reporting to the statistics agency, reporting to the data protection Agency, upkeep to any local regulatory deadlines to manage their compliance incl. AML, data breaches, fraud prevention, IT security and privacy procedures.

The duties of a Money Laundering Reporting Officer (MLRO) include, inter alia:

  • Main areas of work: supervision, monitoring and reporting functions, along with the communication with customers for EDD/CDD/ODD document collection and revision of any KYC/KYB/KYT reports, answering to the CEO/CCO.

We would also outline that the suggested local substance and employee count depends on your business model (inc. business plan) and trading volumes, we can provide our suggestions after completion of the preliminary analysis.

Revocation

The FSA is authorized to initiate revocation proceedings and may issue a warning or a remedial action plan before taking final action. Revocation typically includes a formal notice and an opportunity for the CASP to address deficiencies within a specified timeframe. Some of the legal grounds for revocation include:

  1. Non-Compliance with MiCA Requirements:
    • Failure to meet the minimum capital requirements for the licensed class (Class 1, 2, or 3).
    • Non-compliance with ongoing obligations, such as AML/KYC measures, FATF Travel Rule adherence, or regulatory reporting.
  2. Material Misrepresentation:
    • Providing false or misleading information during the licensing process or in subsequent regulatory filings.
  3. Operational Inactivity:
    • If the CASP fails to commence operations within 9 months of license issuance.
    • If the CASP ceases operations for a continuous period of 12 months without valid justification.
  4. Program of Operations Violations:
    • Significant deviations from the approved program of operations without prior approval from the Estonian Financial Supervision Authority (EFSA).
  5. Governance Failures:
    • Failure to maintain qualified and competent management board members or AML Compliance Officers (MLRO).
    • Breach of governance, internal control, or risk management requirements.
  6. Sanctions or Criminal Activity:
    • Involvement in money laundering, terrorist financing, or other illicit activities.
    • Non-compliance with international sanctions.
  7. Regulatory Non-Cooperation:
    • Ignoring requests for information or failing to cooperate with EFSA during audits, inspections, or other regulatory actions.
  8. Financial Insolvency:
    • Inability to demonstrate financial stability or meet obligations to clients or counterparties.
  9. Breach of EU or Estonian Laws:
    • Engaging in activities that contravene MiCA, AML, or other applicable EU or Estonian financial regulations.

Contact us for more information

We can provide a step by step overview with timeframes and budget break-down after gathering the preliminary project information. Our track-record in setting up crypto licenses in Estonia is backed by hundreds of licenses since 2017 as we follow a thorough checklist to confirm that all legal requirements are met. Please contact us through the contact form below and we will get back to you with further information.

    Contact details

    Please contact us to be connected with our crypto projects manager or to schedule a meeting.

    Tornimäe 5, Tallinn 10145, Estonia