European Union (MiCA)
One authorisation, twenty-seven markets. The transitional period closes 1 July 2026 and MiCA moves into full application.
Who regulates this
National Competent Authorities, coordinated by ESMA and the EBANCA / ESMA
Regulation (EU) 2023/1114. You are authorised by one member state's regulator and supervised primarily by it.
Licences and permissions
CASP authorisation
Custody, operation of a trading platform, exchange for funds or other crypto-assets, execution, placement, reception and transmission of orders, advice, portfolio management and transfer services.
A single authorisation covering whichever subset you apply for, with passporting rights across all member states.
ART / EMT issuance
Asset-referenced and e-money tokens.
A separate and substantially heavier regime, with reserve and redemption obligations.
What it takes
Capital
Tiered by service class — broadly €50,000, €125,000 or €150,000 of minimum own funds, or a quarter of the prior year's fixed overheads if higher.
Timeline
The NCA has a defined assessment window once a file is complete, but "complete" is doing the heavy lifting; six to twelve months end-to-end is a realistic plan.
Substance
Real management in the authorising member state. Letterbox entities are an explicit supervisory concern and ESMA has said so directly.
Where a software vendor sits
MiCA authorises persons providing crypto-asset services, and software supply is not one of them. But Article-level outsourcing obligations bind the CASP: it must retain full responsibility, ensure continuity, and give its regulator access. Practically, your customer will need contractual audit rights and a documented exit plan from you.
What catches people out
There is no third-country equivalence. A Dubai, Singapore or UK licence buys you nothing under MiCA. Serving EU clients means an EU authorisation, full stop — and reverse solicitation is a narrow doctrine that regulators have warned against relying on.
Verify this yourself
We would rather you checked. These are the primary and authoritative secondary sources behind the summary above.