Regulated activity

Exchange of crypto-assets for other crypto-assets

Swapping one crypto-asset for another out of the firm's own inventory needs a CASP authorisation under MiCA Article 3(1)(16)(d) and 3(1)(20). The licence travels with the firm across the EEA once granted. The same dealing activity falls under a VASP licence or a money services business framework once the firm operates outside Europe.

Last verified 2026-09-24Markdown · Data (CC BY 4.0)
Exchange of crypto-assets for other crypto-assets: regulated activityMiCA

Definition

Concluding contracts with clients to swap one crypto-asset for another using the provider's own capital.

Which licence you need

Licence families that typically permit this activity:

Where it can be licensed

Jurisdictions where exchange of crypto-assets for other crypto-assets can be licensedCyprusCzech RepublicEstoniaFranceGermanyIrelandItalyLatviaLithuaniaLuxembourgNetherlandsPolandSlovakiaSpainDubai (VARA)Malta
Licences in the Atlas that permit this activity
EU/EEA passportDomestic
Cyprus: Notification by financial entities providing crypto-asset services✓
Cyprus: Crypto-Asset Service Provider (CASP) authorisation✓
Czech Republic: Crypto-Asset Service Provider authorisation✓
Dubai (VARA): Virtual Asset Broker-Dealer Services Licence✓
Estonia: Authorisation to operate as a crypto-asset service provider✓
France: Crypto-asset service provider authorization✓
Germany: Crypto-asset service provider licence✓
Ireland: Crypto-Asset Service Provider Authorisation✓
Italy: Crypto-asset service provider (CASP) authorization✓
Latvia: Crypto-asset service provider licence✓
Lithuania: Crypto-asset service provider licence✓
Luxembourg: Crypto-asset service provider authorisation✓
Malta: Crypto-Asset Service Provider authorisation✓
Netherlands: Crypto-Asset Service Provider (CASP) authorisation✓
Poland: Crypto-Asset Service Provider authorization✓
Slovakia: Crypto-asset service provider licence✓
Spain: Crypto-asset service provider authorization✓

Frequently asked questions

Does an automated market maker or decentralised exchange protocol require a licence?

A protocol with no identifiable operator usually sits outside licensing regimes entirely. That changes as soon as a foundation or development team deploys the front end, holds admin keys, routes transactions or takes a fee. At that point regulators treat the enterprise as an exchange that needs authorisation.

Are crypto-to-crypto swaps subject to the FATF travel rule?

Yes. The FATF travel rule covers crypto-to-crypto swaps handled by a regulated provider, not just fiat conversions. Each qualifying transfer must carry originator and beneficiary information, held securely and passed to the counterparty institution, so the transaction stays traceable across networks and wallets.

Last verified 2026-09-24Author Danil Marmysh, Founder & CEO, ProtegraReviewed by Anastasia Sidorenkova, Head of Licensing, ProtegraReport an errorReference information, not legal advice.

Sources

  1. MiCA Art. 3(1)(16)(d) and 3(1)(20) · retrieved 2026-09-24

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