Guide
MiCA licence cost: which regulators publish a fee, and what it is
Updated
There is no MiCA fee. The Regulation harmonised the rules and left the money to member states, which is why the same authorisation costs a published EUR 51,000 in one country and an unpublished number in the next.
What MiCA itself sets, and what it does not
Regulation (EU) 2023/1114 sets capital, not fees. Annex IV fixes permanent minimum capital at EUR 50,000, EUR 125,000 or EUR 150,000 by class of service, and Article 67 requires the higher of that and one quarter of the preceding year's fixed overheads. Application and supervisory fees are set by each member state, usually in a national instrument, and Article 137 deals only with the fees the EBA charges issuers of significant tokens it supervises directly.
Malta: a fee for every step, written down
The Markets in Crypto-Assets Act (Fees) Regulations, subsidiary legislation 647.01 made by Legal Notice 295 of 2024, is unusually complete. Regulation 6 sets the CASP fees; regulations 3 to 5 set fees for white papers and token issuers.
| Fee | Amount |
|---|---|
| CASP application, class 1 services | EUR 10,000 |
| CASP application, class 2 services | EUR 20,000 |
| CASP application, class 3 service | EUR 25,000 |
| Adding services to an existing authorisation | The application fee above, reduced by 25% |
| Removing a service from an authorisation | EUR 1,000 modification fee |
| Annual supervisory fee, by class | EUR 10,000, EUR 25,000 or EUR 50,000 |
| Annual supervisory fee, per authorised service | EUR 2,000 each |
| Annual supervisory fee, transaction element | 0.05% of transaction volume, capped at EUR 250,000 |
| White paper notification, other crypto-assets | EUR 2,500 (EUR 1,000 to notify a modification) |
| White paper notification, e-money token | EUR 3,000 |
| Asset-referenced token application, not a credit institution | EUR 8,000 |
Where a firm provides services in more than one class, regulation 6(1) charges only the highest applicable application fee. The regulations also state that fees are not refundable and, apart from the first supervisory payment, not prorated.
France: one number, and it recurs
The AMF's guide to fees and contributions sets the crypto-asset service provider contribution at EUR 10,000 on authorisation and EUR 10,000 annually while the firm remains authorised, plus 0.0094 per thousand of assets under custody with a EUR 1,500 minimum for firms authorised for custody. Notifying a crypto-asset white paper is a separate fixed fee of EUR 3,000. The contribution is due on the date of authorisation and payable within six months, then by 30 June each year.
The three that publish no fixed fee
- Netherlands, AFM
- No fixed licence fee. Processing a CASP licence application is charged at EUR 200 an hour up to EUR 100,000, and a notification at EUR 200 an hour up to EUR 50,000, with EUR 700 per person for a properness assessment and EUR 2,900 per person for a suitability assessment, reduced to EUR 1,500 or EUR 500 where DNB has already assessed that individual (AFM). The AFM also says a licence application takes at least five months in a best case.
- Germany, BaFin
- MiCAR authorisation applications are chargeable, the amount depends on the time spent, the instrument is the Finanzdienstleistungsaufsichtsgebührenverordnung, and the fee is due even if the application is withdrawn or refused (BaFin). No fixed figure is published.
- Ireland, Central Bank of Ireland
- The Central Bank publishes detailed MiCAR authorisation guidance and forms, but no application fee (MiCAR FAQ). Authorised firms pay an annual industry funding levy calculated by levy category, published each year in the Industry Funding Regulations.
"No published fee" does not mean free. It means the number is only obtainable by asking the authority, and you should ask in writing before committing to a jurisdiction on cost grounds.