Guide
What actually drives the cost of a crypto licence
Updated
Professional fees are usually larger than regulator fees and nobody publishes them. Rather than invent a range, here is what moves the number, and the questions that get you a real quote.
Why there is no price here
Legal and compliance fees for a MiCA authorisation are privately negotiated, vary by firm, member state, scope and how much of the file the applicant writes itself, and no regulator or trade body publishes them. Advisers who quote a single figure for a MiCA licence are quoting their own price list, not a market rate. We would rather say that than publish a number a reader could budget against and then miss by a factor of three.
The factors that move the bill
| Driver | Why it moves the price | What to ask for |
|---|---|---|
| Number and class of services | Each service adds a policy the application must contain under Article 62(2)(m) to (r), and class 2 or 3 adds custody, exchange or platform documentation | A fee per service, not a single project price, so you can drop scope |
| Whether a trading platform is in scope | Article 76 operating rules plus a market abuse detection system specified by Delegated Regulation (EU) 2025/885 is the single largest drafting block | A separate quote for the platform rules and market abuse system |
| Custody model | Article 75 requires a client agreement with seven prescribed contents, a register of positions and a custody policy; self-custody, sub-custody and hybrid models are priced very differently | Confirmation whether the adviser has taken the same custody model through the same authority |
| Substance in the member state | Article 59(2) requires effective management in the Union and a Union-resident director; recruitment, office and local directors are recurring, not one-off | A first-year running cost, separate from the application fee |
| Fit and proper population | Every director and qualifying shareholder needs the Article 62(3) evidence, and in the Netherlands each person carries a published AFM assessment fee | A per-person cost for due diligence packs, and who pays for repeats |
| ICT and operational resilience | Article 68(7) pulls in Regulation (EU) 2022/2554 (DORA), so ICT risk management, incident reporting and third-party registers are in scope | Whether DORA readiness is inside or outside the quoted scope |
| Regulator questions after submission | Article 63(12) allows further information requests; time answering them is the most common overrun | An hourly rate for post-submission work and an estimate of rounds |
| Audit and assurance | Prudential safeguards under Article 67 have to be evidenced, and the fixed-overheads limb is reviewed annually | Whether the auditor has signed comparable evidence before |
What you can budget with confidence
- The regulator fees, where published. Malta and France publish theirs in full; use our calculator.
- The capital. Annex IV sets EUR 50,000, EUR 125,000 or EUR 150,000, and Article 67 takes the higher of that and a quarter of fixed overheads, so the figure grows with the business.
- The insurance alternative, if you use it. Article 67(5) and (6) prescribe the policy terms, so a broker can quote against a defined specification rather than a vague brief.
- Time. The AFM says a licence application takes at least five months in a best case; the statutory clock alone is 25 working days for completeness and 40 from a complete file.
If you want a figure for professional fees, get three written quotes against the same scope: the services you will apply for, the custody model and the member state. That is a real comparison, which a published average would not be.