Built on Relationships, Developed on Trust

MiCA CASP Licences

MK Fintech Partners is a specialised regulatory consultancy focused on Financial Services, Fintech, Cryptocurrencies, and Investment Services operating under the Michael Kyprianou Group, a globally recognised Top Tier law firm acknowledged by Legal 500 and Global Law Experts. Our core proposition is bridging the legal and technological gap for clients operating in complex, fast-evolving regulatory environments.

Cryptocurrencies and Digital Asset Services in Malta

MiCA CASP Licences

Malta was among the first EU member states to introduce a dedicated regulatory framework for virtual assets, and with the full application of the Markets in Crypto-Assets Regulation (MiCA) across the EU, the jurisdiction remains at the forefront of crypto-asset regulation in Europe. For operators seeking a Crypto-Asset Service Provider (CASP) authorisation, Malta offers a mature ecosystem: the MFSA has accumulated years of supervisory experience in the digital assets space through the Virtual Financial Assets Act, giving it a depth of institutional knowledge that few EU regulators can match. A MiCA CASP licence granted in Malta provides full passporting rights across the EEA, enabling firms to offer services such as custody, exchange, execution, transfer, advisory, and portfolio management of crypto-assets from a single EU base.

Our end-to-end support covers every stage of the CASP licensing journey: from pre-application strategy, MFSA engagement, to the preparation of all submission application documents such as the Programme of Operations, policies and procedures, and financial projections all the way to licence approval and post-licensing compliance. 

Our client portfolio spans both emerging fintechs and established financial institutions, including Damex, Phemex, CoinGateway, Paytently, XNT, PXP Financial, Relm, Paydo, and Suncontract, reflecting the breadth and credibility of our practice.

CASP Licence Classes at a Glance

Built on Relationships, Developed on Trust | LICENSING OVERVIEW

Under MiCA, there are three CASP licence classes available in Malta, each permitting a different scope of crypto-asset services. The table below summarises the key differences:
License ClassMFSA Application FeeType of ActivitiesType of Service ProviderMin. Share Capital
Class 1€10,000Reception & transmission of orders, investment advice, execution of orders, placing of crypto-assetsIntroducer, Investment Advisor, Broker (without dealing or custody), Token Marketing€50,000 or €25,000 with professional indemnity insurance
Class 2€20,000All Class 1 services, plus custody & administration of crypto-assets, exchange of crypto-assets for fiat, exchange of crypto-assets for other crypto-assetsCustodian, Broker (with custody and/or dealing), Liquidity Provider, Dealer€125,000
Class 3€25,000All Class 2 services, plus operation of a trading platform for crypto-assetsTrading Venue€150,000
License ClassMFSA Application FeeType of ActivitiesType of Service ProviderMin. Share Capital
Class 1€10,000Reception & transmission of orders, investment advice, execution of orders, placing of crypto-assetsIntroducer, Investment Advisor, Broker (without dealing or custody), Token Marketing€50,000 or €25,000 with professional indemnity insurance
Class 2€20,000All Class 1 services, plus custody & administration of crypto-assets, exchange of crypto-assets for fiat, exchange of crypto-assets for other crypto-assetsCustodian, Broker (with custody and/or dealing), Liquidity Provider, Dealer€125,000
Class 3€25,000All Class 2 services, plus operation of a trading platform for crypto-assetsTrading Venue€150,000
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What You Need to Qualify

Key Requirements

The MFSA’s main licensing requirements are fourfold. Understanding these early ensures your application is well-prepared and avoids unnecessary delays:

  1. Programme of Operations
  2. Various Policies & procedures
  3. Fit and Proper Tests
  4. Company Incorporation and Local Substance
  5. Application Form and ancillary supporting MFSA forms (such as outsourcing forms and corporate questionnaires)
  6. Financial Projections
  7. Other Submission Documents

Passporting Rights

EU MARKET ACCESS

A CASP licensed in Malta can passport its services across the EU/EEA under a single licence, subject to notification to the relevant national authorities, enabling access to the entire European market.

Application Process

GETTING STARTED

The MFSA’s CASP authorisation process follows three structured phases. Understanding what is expected at each stage helps applicants plan ahead and avoid delays.

Preparatory and Licence Application

Phase 1

  1. Before submitting a formal application, the MFSA encourages promoters to arrange a preliminary meeting with its representatives to discuss the proposed business model. The applicant is responsible for formulating the proposal and preparing the application documents, although the MFSA will provide guidance on regulatory requirements. A comprehensive written description of the proposed activity must be submitted in advance of this meeting.

  2. Following the preliminary meeting, the promoters submit the completed application form together with all required supporting documentation.

  3. The MFSA reviews the application and supporting materials, and provides structured feedback through “Comments Letters”. The Authority may request additional information or clarification at any stage. Fit and proper checks on key individuals commence at this point. All new applications are handled by the Authorisation Unit.

Licensing: Approval in Principle

Phase 2

  1. After a thorough review of the draft application, the Director of the Authorisation Unit assesses whether the business proposal and due diligence documentation meet applicable regulatory standards. If satisfied, the Authorisation Unit recommends issuance of the licence to the Supervisory Board Members for formal approval.

  2. Upon approval by the Supervision Council, the MFSA issues its “in principle” approval for the licence.

  3. The applicant must then finalise any outstanding matters  such as company incorporation and submission of signed final-form application documents  and address any remaining issues raised during the review process.

  4. The licence is formally issued once all pre-licensing conditions have been satisfied.

Post-Licensing / Pre-Commencement of Business

Phase 3

  1. The MFSA may impose certain post-licensing obligations that must be fulfilled before the entity commences operations. The applicant must satisfy all pre-commencement requirements before formally launching its activities.
  2. Once the MFSA confirms that all conditions have been met, the entity is authorised to begin operating as a licensed CASP.

Key Contact

Dr Justine Scerri Herrera

Founder & managing partner

Matteo Alessandro Fintech Crypto MK Fintech Partners Ltd.

Key Contact

Dr. Matteo Alessandro

Senior Associate