Payment Institutions (PIs) offering crypto-related services, such as issuing EMTs, providing crypto-asset services, or enabling crypto payments, need a separate MiCAR authorisation on top of their existing licence.

MiCAR imposes conduct-of-business, conflict-of-interest, and client asset segregation rules similar to MiFID II, plus white paper disclosure requirements for EMT issuers. The application process runs through four stages: pre-application engagement with the NCA; formal submission; assessment (including fit-and-proper checks); and ongoing post-authorisation supervision. The existing documentation will not satisfy MiCAR requirements without meaningful adaptation, though Malta’s MFSA reduces some duplication by cross-referencing existing PI documentation. PIs on a simplified ICT framework will also be pushed into the full DORA-aligned regime once crypto services are added.

Costs stack across four categories:

• White paper notification fees: €2,500-€8,000 (varies by entity/token type), plus €1,000 for amendments
• Application fees: €10,000-€25,000 by licence class
• Annual supervisory fees: €10,000-€50,000 by class (Class 3 supervisory fees double its application fee)
• Minimum capital requirements: €50,000-€150,000 by class, potentially exceeding existing PI thresholds and creating a standalone capital adequacy obligation.

Beyond these headline costs, PIs must budget for legal/advisory fees, an ongoing compliance function, and technology investment.

Thus, the MiCAR licence is a strategic commercial decision, not a compliance formality. The commercial upside should be weighed against the genuine scope of new obligations.