MiCA CASP License in Estonia (2026)
Estonia retired the old VASP register in early 2026. Existing VASPs migrate to a CASP authorisation under MiCA — and the Financial Supervision Authority is reviewing operating substance more strictly than at any point since 2019.
An Estonian MiCA CASP license is the authorisation issued by Finantsinspektsioon that lets a firm offer crypto-asset services from Estonia and passport them across the EU under a single supervisory regime.
Issued by Financial Supervision Authority (FSA) under Regulation (EU) 2023/1114 (MiCA), in force since 30 December 2024; Estonian Crypto-Asset Service Providers Act 2026. License types: CASP — full authorisation, CASP — VASP-to-CASP transition (until 1 July 2026). Built for mature crypto teams, projects needing track-record-backed counsel.
Quick Facts
| Parameter | Value |
|---|---|
| Regulator | Finantsinspektsioon (FSA) |
| Legal basis | MiCA Regulation + Estonian CASP Act 2026 |
| Minimum capital | €50,000 — €150,000 depending on services |
| Authorisation timeline | 5-7 months from complete application |
| Application fee | €3,300 base + €660 per additional service |
| Local substance | Resident director, registered office, locally-based MLRO |
| AML/CFT | Estonian Money Laundering Act compliance, internal MLRO mandatory |
Why has Estonia tightened its regime in 2026?
Estonia withdrew the lighter-touch VASP framework after a series of supervisory cases involving substance-light registrants in 2023-2024.
The Estonian VASP register, in force from 2017 to 2025, became a target of enforcement attention as supervisors observed firms using the registration as a marketing badge while operating substantively from outside Estonia. Several high-profile registration revocations in late 2024 made the political case for replacing the register with a full authorisation regime — which MiCA, fortuitously for the regulator, supplied.
The current FSA approach is uncompromising on local substance. They want to see the resident director give coherent answers about the operating model in interview. They want the MLRO based in Estonia. They want the registered office to be more than a brass plate.
How long does CASP authorisation take in Estonia?
Five to seven months from filing a complete application is realistic in 2026, longer than Lithuania's typical four to six.
The FSA is statutorily required to take an initial decision within 40 working days, but the clock pauses with each information request — and Estonia issues more requests on average than Lithuania does. Files where the substance story is solid clear in five months. Files where the regulator has follow-up questions about the resident director or the conflict-of-interest matrix run to seven or eight.
Pre-clearance with the FSA's authorisation team before submission shaves time off this. They will not give written pre-approval, but they will tell you informally whether the substance setup is in the right shape.
What capital is required for an Estonian CASP?
€50,000 to €150,000 in initial capital, in three tiers matching the MiCA service classification.
Class 1 (reception, transmission, advice): €50,000. Class 2 (exchange, execution, placement): €125,000. Class 3 (custody, trading platform, transfer): €150,000. Capital must be paid in to a credit institution or e-money institution licensed in the EEA before the FSA grants authorisation.
On top of initial capital, firms must hold professional indemnity insurance or additional own funds proportionate to assets under custody. The FSA published its supervisory expectations on this in February 2026 — they are stricter than the MiCA technical standards default and warrant a careful read before pricing the engagement.
Can my existing Estonian VASP transition straight to a CASP?
Yes, but the application is full-scope and must be filed before 1 July 2026 to use the transition window.
Existing VASPs can keep operating during FSA review if they file a CASP application before 1 July 2026. After that date, no transitional regime applies — the operating permission lapses and a new entrant pathway is required. The application itself is the same documentary set as for new entrants. The transition window saves time, not work.
What changed with the 2026 Estonian CASP Act
The Estonian Crypto-Asset Service Providers Act 2026, in force since 1 March, layered domestic detail on top of MiCA. The most material change: Estonia adopted gold-plating on local-substance requirements, going beyond what MiCA itself requires. Specifically, the FSA now publishes supervisory expectations that the MLRO be Estonian-based with at least 0.5 FTE allocation, and that board-level decisions on AML, ICT resilience, and conflict-of-interest matters be taken by directors physically present at meetings.
Working with us on an Estonian CASP file
We are based in Tallinn and have direct working relationships with the FSA’s authorisation desk. Engagements are partner-led. We do not subcontract drafting or supervisory liaison.
Frequently asked questions
Is Estonia harder than Lithuania for CASP authorisation?
Yes — slightly. Estonia takes 5-7 months on average versus 4-6 for Lithuania, with stricter substance review.
The trade-off is supervisory reputation. Estonia's FSA is regarded by EU peers as among the more rigorous supervisors, which can be useful when you later passport into more conservative member states.
Is a resident director enough for substance, or does the FSA want more?
The FSA expects the resident director to actually direct the business — not act as a nominee — and will probe this in interview.
We have seen authorisations refused where the resident director could not coherently describe the operating model. Set up the directorship around someone who is in the business decision loop, not someone purely available for signature.
Can the MLRO be outsourced offshore?
No. The MLRO function must be performed by a person based in Estonia with sufficient seniority and resources.
The Estonian AML Act explicitly contemplates a locally-based MLRO and the FSA has made clear in supervisory dialogue that a remote, part-time, non-Estonian MLRO will not be accepted on a CASP application.