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Malta’s MiCA CASP Licence Framework for Crypto Assets
As of 30 December 2024, Malta has fully implemented the EU’s Markets in Crypto-Assets Regulation (MiCAR) through its national Markets in Crypto‑Assets Act (Chapter 647). Malta was among the first EU Member States to align its legal framework and regulatory authorities, including the Malta Financial Services Authority (MFSA), with MiCA’s unified approach for crypto‑asset services. Having operated under the Virtual Financial Assets Act (VFA Act) since 2018, Malta now offers a robust licensing regime within a well-established regulatory framework for service providers seeking to offer cryptocurrency services from Malta, along with a clear transition path for existing Virtual Financial Asset (VFA) providers.
We can guide you through the MiCA‑compliant authorisation process, ensuring you meet MFSA expectations and operate legally within a robust and recognised regulatory environment.
Crypto-Asset Service Providers (CASP) Licence and A Virtual Asset Service Provider (VASP) Licence: What’s the Difference?
Crypto Asset Service Providers (CASPs), as defined under the EU’s MiCA Regulation, are sometimes referred to as Virtual Asset Service Providers (VASPs) in international regulatory discussions. The term VASP comes from the Financial Action Task Force (FATF), which uses it as part of its global framework to combat money laundering and terrorist financing. While the terminology differs, both CASPs and VASPs refer to businesses that provide services such as crypto exchange, custody, and transfer of virtual assets. In the EU, “CASP” is the official term used under MiCA. Outside the EU, particularly in FATF-aligned jurisdictions, “VASP” is more commonly used. If your cryptocurrency business operates across multiple jurisdictions, understanding both terms is essential for maintaining regulatory compliance and meeting global expectations.
Who Needs a CASP Licence to Offer Crypto Asset Services?
Under MiCA, a CASP is any legal person whose business or profession involves providing one or more crypto‑asset services to third parties on a professional basis. CASPs are defined under different categories, depending on the required for the crypto-asset services they intend to provide. These include:
Class 1
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execution of orders on behalf of clients;
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placing of crypto-assets;
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providing transfer services for crypto-assets on behalf of clients;
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reception and transmission of orders for crypto-assets on behalf of clients;
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providing advice on crypto-assets; and/or
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providing portfolio management on crypto-asset
Class 2
CASP authorised for any crypto-asset services under class 1 and:
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providing custody and administration of crypto-assets on behalf of clients;
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exchange of crypto-assets for funds; and/or
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exchange of crypto-assets for other crypto-assets.
Class 3
CASP authorised for any crypto-asset services under class 2 and:
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operation of a trading platform for crypto-assets.
To act as a CASP in Malta, a legal person or other undertaking must obtain a licence from the national competent authority, the Malta Financial Services Authority (MFSA). The MFSA not only authorises a CASP to offer its services to clients in Malta but also ensures that CASPs continuously meet their regulatory obligations.
Class 1
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execution of orders on behalf of clients;
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placing of crypto-assets;
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providing transfer services for crypto-assets on behalf of clients;
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reception and transmission of orders for crypto-assets on behalf of clients;
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providing advice on crypto-assets; and/or
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providing portfolio management on crypto-asset
Class 2
CASP authorised for any crypto-asset services under class 1 and:
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providing custody and administration of crypto-assets on behalf of clients;
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exchange of crypto-assets for funds; and/or
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exchange of crypto-assets for other crypto-assets.
Class 3
CASP authorised for any crypto-asset services under class 2 and:
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operation of a trading platform for crypto-assets.
To act as a CASP in Malta, a legal person or other undertaking must obtain a licence from the national competent authority, the Malta Financial Services Authority (MFSA). The MFSA not only authorises a CASP to offer its services to clients in Malta but also ensures that CASPs continuously meet their regulatory obligations.
Main Requirements to Apply for a CASP Licence Under MiCA
The Intention Stage
In this stage, a prospective applicant intending to apply for authorisation will be required to submit a statement of intent which will include preliminary details on the operations of the CASP, and a legal opinion issued from a Maltese warranted lawyer confirming that the proposed activities fall within the purview of MiCA. Upon submission of this statement, the MFSA will review this statement and subsequently request a meeting with all interested parties within 10 days from receipt of the statement (unless they have further comments/queries on the statement). If satisfied with the statement and the subsequent meeting, the MFSA will issue its no objection, allowing the applicant to formally begin the registration process leading to authorisation.
Pre-Authorisation Stage
Upon receiving the no objection from the MFSA, the application process begins, and all the necessary supporting documents must be submitted within 40 working days.
The application to seek authorisation must be submitted through the MFSA’s online portal and which would need to include the following:
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CASP Application Form, which shall include, amongst other corporate details on the applicant, statutory documents, a business plan outlining the business model, details on the management body, draft policies and procedures, and the ICT security arrangements in place.
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The licence requires the nomination of certain roles, in line with the proportionality principle, demonstrating independence, regulatory familiarity, policy oversight, and escalation protocols.
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Description and details of outsourced services
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Fit and Proper assessments are required for qualifying shareholders, board directors, senior managers, compliance officers, and money-laundering reporting officers.
Authorisation Stage
Should the MFSA be satisfied with all the application documents submitted, it will then proceed to issue an in-principal approval letter whereby it will state that certain requirements must be met prior to the granting of the official authorisation. These requirements must be met within a timeframe indicated in the letter.
Once the regulator, the MFSA is satisfied that the requests above have been met, it will issue the official authorisation to the applicant to provide the services applied for as a CASP. At this stage, the licence must meet specific conditions set out by the MFSA before the holder is permitted to commence business operations. Upon the completion of these conditions to the satisfaction of the MFSA, the licence holder can commence its business operations, concluding the formal licensing process.
The Intention Stage
In this stage, a prospective applicant intending to apply for authorisation will be required to submit a statement of intent which will include preliminary details on the operations of the CASP, and a legal opinion issued from a Maltese warranted lawyer confirming that the proposed activities fall within the purview of MiCA. Upon submission of this statement, the MFSA will review this statement and subsequently request a meeting with all interested parties within 10 days from receipt of the statement (unless they have further comments/queries on the statement). If satisfied with the statement and the subsequent meeting, the MFSA will issue its no objection, allowing the applicant to formally begin the registration process leading to authorisation.
Pre-Authorisation Stage
Upon receiving the no objection from the MFSA, the application process begins, and all the necessary supporting documents must be submitted within 40 working days.
The application to seek authorisation must be submitted through the MFSA’s online portal and which would need to include the following:
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CASP Application Form, which shall include, amongst other corporate details on the applicant, statutory documents, a business plan outlining the business model, details on the management body, draft policies and procedures, and the ICT security arrangements in place.
-
The licence requires the nomination of certain roles, in line with the proportionality principle, demonstrating independence, regulatory familiarity, policy oversight, and escalation protocols.
-
Description and details of outsourced services
-
Fit and Proper assessments are required for qualifying shareholders, board directors, senior managers, compliance officers, and money-laundering reporting officers.
Authorisation Stage
Should the MFSA be satisfied with all the application documents submitted, it will then proceed to issue an in-principal approval letter whereby it will state that certain requirements must be met prior to the granting of the official authorisation. These requirements must be met within a timeframe indicated in the letter.
Once the regulator, the MFSA is satisfied that the requests above have been met, it will issue the official authorisation to the applicant to provide the services applied for as a CASP. At this stage, the licence must meet specific conditions set out by the MFSA before the holder is permitted to commence business operations. Upon the completion of these conditions to the satisfaction of the MFSA, the licence holder can commence its business operations, concluding the formal licensing process.
Regulatory Requirements for CASP Licence Holders in Malta
Upon receipt of the official authorisation, the license holder will then be obliged to adhere to the submission of ongoing returns which the MFSA would require. Such obligations include submitting periodic returns, meeting prudential requirements, and ensuring compliance with regulatory frameworks applicable to CASPs under MiCA. CASPs must also ensure that their operations comply with other overlapping regulations which may apply to digital asset service providers, such as the Digital Operational Resilience Act (DORA) and the Payment Services Directive 2 (PSD2).
Fees and Capital Requirements for a CASP Licence in Malta
The following fees and capital requirements apply to applicants seeking a CASP licence in Malta:
- Class 1: Euro 10,000
- Class 2: Euro 20,000
- Class 3: Euro 25,000
Where an applicant intends to provide crypto-asset services falling under different classes, only the highest application fee applicable with respect to those crypto-assets services shall apply.
The ongoing applicable fees are as follows:
- Class 1: Euro 10,000
- Class 2: Euro 25,000
- Class 3: Euro 50,000
Other annual fees are the following:
- Euro 2,000 for every service being offered by the CASP
- 0.05% of the transaction volume of such person up to a maximum of Euro 250,000
For the minimum share capital, the following applies:
- Class 1: Euro 50,000
- Class 2: Euro 125,000
- Class 3: Euro 150,000
Our Services
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Initial eligibility and compliance assessment
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Preparation and submission of the licence application
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Drafting all documents relating to the authorisation with the MFSA
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KYC framework setup and risk management planning
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Ongoing regulatory support and licence maintenance
How A2CO Supports You Throughout the CASP Licensing Process
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Proven experience in CASP MFSA authorisation and working with EU regulatory bodies overseeing cryptocurrency and virtual asset compliance.
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In-depth understanding of anti-money laundering (AML), KYC, and MiCA compliance
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Tailored solutions for crypto businesses, startups, and established platforms
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Efficient, transparent application handling
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Ongoing advisory for evolving regulatory obligations
Frequently Asked Questions
A CASP in Malta can offer services such as cryptocurrency exchange, custody of crypto-assets, and execution of orders on behalf of clients. The specific services depend on the class of CASP licence obtained.
The authorisation process typically takes 3 to 6 months, depending on the completeness of the application and the MFSA’s review.
Applicants must submit a detailed application to the MFSA, including a business plan, governance arrangements, risk management policies, and proof of fitness and properness of key individuals.
To obtain a CASP licence in the European Union, you must apply for authorisation under the MiCA Regulation through the national competent authority of an EU Member State.
Once authorised in Malta, a CASP can passport its services across the EU under the MiCA regulation, subject to notification requirements.
