Crypto-Asset Service Provider authorisation under MiCA and Act No. 31/2025 Coll. (Czech Republic)

At a glance

What it lets you do, and where

What does a Czech CASP licence allow and where can you serve clients?

A Czech CASP authorisation covers the crypto-asset services defined in MiCA Article 3(1)(16). To serve clients in another Member State, the CASP submits the information required under MiCA Article 65 to ČNB. The regulator prescribes no form for this.⁸

Activities it covers

Where it is valid

Do you need it, and is Czech Republic the right choice?

What is a Czech MiCA CASP licence and do you need one?

Yes, if you provide crypto-asset services as a legal person. A Czech MiCA CASP licence is the authorisation the Czech National Bank (ČNB) grants under EU Regulation 2023/1114 (MiCA) and Act No. 31/2025 Coll., and MiCA Article 59 requires it. Operators on the old trade-licence regime could continue only until their application was decided, and no later than 1 July 2026.²³

Is Czechia the right jurisdiction for your CASP model and what are the alternatives?

Czechia is a selective jurisdiction: by early July 2026 ČNB had assessed 251 applications and granted only 11 licences. It turned away applicants with virtual addresses, no verifiable history or a mainly foreign focus. Credit institutions and investment firms can instead use the MiCA Article 60 notification route.²⁰²

Yes. Under MiCA Article 65 a Czech CASP licence lets you provide services across all EU/EEA states without host-state licensing. The competent authority of the home Member State communicates the notification to the host states' single points of contact, ESMA and EBA within 10 working days of receipt under Article 65(2). Reverse solicitation is strictly interpreted under ESMA guidelines (ESMA35-1872330276-1899).¹⁰²²¹

Not always. Under MiCA Article 48, an e-money token may be offered to the public or admitted to trading only if the person is its issuer and is authorised as a credit institution or an electronic money institution. Existing credit institutions and investment firms use simplified notification under MiCA Article 60. Crypto derivatives that qualify as financial instruments are investment services under MiFID2, and MiCA does not apply to them.¹⁰²

No. ČNB approved only 11 of 251 applications by 1 July 2026, and initial grants took over 12 months. By comparison, ESMA launched a fast-track peer review of the MFSA's authorisation of a CASP in April 2025. The report is dated 10 July 2025 and names neither the firm nor a 4-day timeline.²²²³

It depends on the activity. The decentralised finance exemption under MiCA Recital 22 applies only where services are fully decentralised without intermediaries. Crypto advice requires professional competence under Act No. 31/2025 Coll. § 7. Under Act No. 31/2025 Coll. § 17, ČNB keeps an electronic list of white papers notified under MiCA Article 8.²³

Yes, in part. Entrusted client assets are immune from execution and excluded from the bankruptcy estate under Act No. 31/2025 Coll. § 4. MiCA Article 75(8) covers custodian liability for lost client crypto-assets or private keys. ESMA's Second Consultation Paper says there is no legal basis to treat a permissionless DLT used by a CASP as an outsourcing provider.³²⁴

What it really takes

Who do you have to hire for a Czech CASP licence and must they be local?

You must appoint a Compliance Officer / MLRO under Czech AML Act No. 253/2008 Coll. A combined MLRO and compliance role is a planning assumption of €55,000 to €80,000 per year. Under MiCA Article 59(2), the firm needs a place of effective management in the Union, a registered office in an EU Member State and at least one director resident in the Union. ČNB has rejected applicants with virtual-address registered offices or those operating mainly abroad.^2202519

In which language must a Czech CASP application be filed?

File in Czech; Slovak is also accepted as the official language of proceedings under Act No. 500/2004 Coll. § 16(1). Your application and supporting documents must therefore be in Czech or Slovak. Any foreign-language documents need a certified Czech translation under § 16(2) of the same Act.²⁶

Application content is defined by Commission Delegated Regulation (EU) 2025/305 under MiCA Article 62(5). Standard templates and forms are set by Commission Implementing Regulation (EU) 2025/306. ČNB requires a standardised submission through its designated contact point.²⁷²⁸²⁹

Requirements

The legal framework

The procedure under the law

How long it takes

How long does getting a Czech MiCA CASP licence really take?

On paper, 25 working days to assess completeness and 40 working days for the decision, under MiCA Article 63(2) and 63(9), which apply directly in Czechia. In practice the first 6 Czech CASP licences were granted on 11 February 2026 after lengthy reviews.³⁰³¹

MiCA sets the deadlines: 25 working days for the completeness check (Article 63(2)) and 40 working days from receipt of a complete application to assess it (Article 63(9)). Further information may be requested no later than the 20th working day of that period (Article 63(12)).²

Statutory: 40 working days from complete application under MiCA Art. 63(9) (plus 25 working days completeness check)². Observed: not published. The statutory clock usually starts only when the regulator treats the application as complete, and pauses while it waits for answers to its questions.

What it costs

What is the total cost of obtaining and maintaining a Czech CASP licence?

ČNB charges an administrative fee of CZK 20,000 under Act No. 634/2004 Coll., Item 65(4)(g). CASPs providing custody must also have an auditor verify their client-asset safeguarding at least once a year (Act No. 31/2025 Coll. § 5).⁴³

Approval odds and who can own it

What are the real approval odds for a Czech CASP licence and why do applications fail?

Approval odds are roughly 4.4%: by early July 2026 ČNB had assessed 251 applications and granted only 11 licences (holders include Altlift, Coinmate, GG Digital, Ilavo Group, Invity Finance and Simple Coin). By 31 October 2025 it had terminated 81 proceedings and suspended 213. ČNB said some applications lacked key information and others came from entities with no verifiable history, a virtual-address seat or a mainly foreign focus.²⁰³²

Who can own and run a Czech crypto company under MiCA?

The suitability of the management body and qualifying-holding shareholders is assessed under the joint EBA/ESMA guidelines (MiCA Art. 63(11)); CDR 2025/305 covers application content. Vetting checks reliability (spolehlivost) and a transparent source of wealth. Acquiring 20%, 30% or 50% holdings requires prior notification and a 60-day assessment under MiCA Articles 83-84.⁸³³²

How many CASP licences has the Czech National Bank granted?

By early July 2026 ČNB had granted 11 CASP licences out of 251 assessed applications. The first 6 were granted on 11 February 2026. Holders include Altlift, Coinmate, GG Digital, Ilavo Group, Invity Finance and Simple Coin. By 31 October 2025 ČNB had terminated 81 proceedings and suspended 213.²⁰³⁰³²

After you get the licence

What other licences and regulatory regimes do you need alongside a Czech CASP?

Alongside a CASP, Act 31/2025 §9 makes the CNB the competent authority for both DORA and MiCA, and §12 gives the CNB DORA supervisory powers. Transfer services trigger Travel Rule duties under Regulation (EU) 2023/1113, enforced through Czech AML Act § 49. Issuing e-money tokens additionally requires authorisation as a credit institution or electronic money institution under MiCA Article 48.³²⁵¹⁰

Will a Czech bank open an account for your MiCA CASP?

No bank account is guaranteed. After the Equa bank merger, Raiffeisenbank terminated crypto firms' accounts (e.g. Coinmate) as of end of May; SatoshiLabs held no Equa accounts. Oberbank closed WBTCB's account and Česká spořitelna refused to open one (reported March 2025). The law gives licensed crypto-asset providers a right to open a bank account, but banks may refuse under set conditions.³⁴³⁵³⁶

What ongoing duties are required to maintain a Czech CASP licence?

Every CASP must submit audited financial statements and the auditor's report to ČNB within 4 months of year-end under Act No. 31/2025 Coll. § 6. ČNB may revoke a licence unused for 12 months or dormant for 9 consecutive months under MiCA Article 64(1). Share acquisitions require a ČNB qualifying-holding assessment within 60 working days under MiCA Articles 83-84. Duties covering custody and administration apply only to CASPs providing those services.³²

Can you appeal a ČNB refusal of a CASP licence?

Yes. A refusal can be challenged by a rozklad to the ČNB Bank Board within 15 calendar days under Act No. 500/2004 Coll. § 152(5) and § 83(1); ČNB published decisions confirm this deadline. An action may then be filed within 2 months of notification under § 72(1) of Act No. 150/2002.²⁶³⁷¹⁵

The licence has indefinite validity under MiCA Title V, with no statutory expiration date. Changes of qualifying holding require prior notification and are assessed within 60 working days of written acknowledgement of receipt under MiCA Articles 83-84. Changes to the management body need notification, not approval, before new members act under MiCA Article 69.²

Is an old Czech crypto trade licence (živnost) still valid after 1 July 2026?

No. The transitional period expired on 1 July 2026 under Act No. 31/2025 Coll. § 26. Legacy operators had to file by 31 July 2025 to benefit from the transition. An article of 29 September 2025 cited nearly 30,000 entities operating on free trade licences in 2024. Only 11 entities were granted CASP licences by 1 July 2026.³³⁸²⁰

Buying a company that already holds it

The authorisation is granted to the specific corporate entity and cannot be assigned, sold, or transferred to another undertaking. Any acquisition of the regulated business must be carried out as a corporate share deal (transfer of shares or ownership interests in the licensed company), subject to prior notification to the CNB and the qualifying holding assessment under MiCA Articles 83-84 and Act No. 31/2025 Coll. An asset deal requires the acquiring entity to apply for and obtain its own separate CASP authorisation.²

Prior notification with an objection period. Under MiCA Article 83 and Act No. 31/2025 Coll., any natural or legal person proposing to acquire or increase a qualifying holding in a Czech CASP reaching or exceeding 20%, 30%, or 50% of voting rights or capital, or make the CASP a subsidiary, must give prior written notification to the Czech National Bank. The CNB acknowledges receipt within 2 working days and conducts an assessment within a statutory 60-working-day window (interruptible once by up to 20 working days for supplementary details, or 30 working days for non-EU acquirers) under MiCA Article 84. If the CNB does not issue a written objection before the assessment period expires, the acquisition is deemed approved. Acquiring or increasing a qualifying holding without notification or over regulatory objection constitutes an administrative offence subject to a fine of up to CZK 10,000,000 under Section 20(1)(d) and (5) of Act No. 31/2025 Coll.²

Ready-made companies holding this licence: see verified positions.

CASP in other countries

Values come from each licence's page, where every figure has its source.

Laws behind it

• Markets in Crypto-Assets Regulation: Regulation (EU) 2023/1114

Getting this licence

Protegra handles this licence end to end: CASP license in the Czech Republic: process, timeline and our fee.