Crypto licence in CyprusOverview
Cyprus introduced a national registration regime for crypto-asset service providers under its AML legislation in 2021, focused mainly on anti-money laundering supervision. With MiCA's application on 30 December 2024, CySEC stopped accepting new national registrations (from 17 October 2024 for local applicants) and became the competent authority for MiCA authorisations, assessing governance, prudential resources, safeguarding of client assets, internal controls, outsourcing and operational resilience.
Cyprus chose the maximum transitional period. Registered providers could continue until 1 July 2026 or until their MiCA application was decided, whichever came first, provided they applied by 27 February 2026; those that did not were required to submit wind-down plans. CySEC made clear that a pending application would not extend the transition. Since 1 July 2026, a Cypriot national registration on its own does not allow any crypto-asset services, and unauthorised firms must have stopped regulated activity and settled or transferred client assets.
MiCA offers two routes in Cyprus. A new or existing company can apply for full CASP authorisation in one of the three classes. Alternatively, entities already authorised as Cyprus investment firms, credit institutions, e-money institutions or similar may notify CySEC under Article 60 of MiCA of the crypto-asset services they intend to provide, within the scope of their existing licence. This is particularly relevant for the many brokerage and forex groups already supervised by CySEC.
Cyprus combines an experienced financial-services supervisor, an English-speaking legal environment based on common law, a eurozone economy and a deep pool of compliance, risk and back-office professionals. CySEC expects real substance on the island: directors who direct, staff who perform key functions and systems that can be inspected. A Cyprus CASP can then passport its services across the EU and EEA.
Key benefits
- Experienced supervisor with long practice in investment-firm and brokerage regulation
- Article 60 notification route for existing CySEC-licensed firms adding crypto services
- English-language, common-law-based legal environment
- Eurozone jurisdiction with full EU and EEA passporting
- Established ecosystem of compliance, risk, audit and fund administration providers
- Natural fit for groups combining forex, investment and crypto services under one supervisor
Requirements
- Cypriot company with registered office and place of effective management in Cyprus
- At least one EU-resident director and a management body meeting CySEC fit-and-proper standards
- Own funds of EUR 50,000, 125,000 or 150,000 by class, or one quarter of prior-year fixed overheads if higher
- Local substance: office, key function holders and decision-making in Cyprus
- Qualifying shareholders with documented source of funds and transparent group structure
- AML/CFT framework, travel-rule procedures and sanctions screening
- DORA-compliant ICT risk management, incident reporting and business continuity
- Segregation and safeguarding of client crypto-assets and funds
- Complaints-handling, conflicts-of-interest and outsourcing policies
Licence options & capital
Class 1 CASP
EUR 50,000 minimum own funds
Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, providing transfer services, advice on crypto-assets and portfolio management. Suited to brokerage, advisory and introducing models that never hold client assets.
Class 2 CASP
EUR 125,000 minimum own funds
All Class 1 services plus custody and administration of crypto-assets on behalf of clients and exchange of crypto-assets for funds or for other crypto-assets. This is the usual tier for custodial wallets, brokers that hold client assets and exchange desks.
Class 3 CASP
EUR 150,000 minimum own funds
All Class 2 services plus operation of a trading platform for crypto-assets. Expect the most intensive review of market-abuse surveillance, rulebooks, matching systems and conflict management.
Article 60 notification
Within existing licence capital
For Cyprus investment firms, credit institutions, e-money institutions and other eligible entities already authorised in Cyprus, providing crypto-asset services equivalent to their existing permissions after notifying CySEC.
Step-by-step process
- 1
Route selection
We determine whether full authorisation or an Article 60 notification fits, and which CASP class covers the intended services.
- 2
Corporate set-up and substance
Incorporation or adaptation of the existing Cypriot entity, capital, office, and appointment of directors and key function holders.
- 3
Application preparation
Programme of operations, policies, ICT and DORA documentation and fit-and-proper files in the form set by the MiCA technical standards.
- 4
Submission to CySEC
Filing with the applicable fee and a completeness check of up to 25 working days.
- 5
Assessment and information requests
A 40 working day assessment after completeness, with clock stops for CySEC questions.
- 6
Authorisation and passporting
Entry in the CySEC and ESMA registers, followed by cross-border notifications and launch.
Typical documents
- Memorandum and articles of association and Registrar of Companies certificates
- Programme of operations and business plan with financial projections
- Evidence of own funds and capital adequacy calculations
- Fit-and-proper questionnaires, CVs and criminal record certificates
- Source-of-funds evidence and group structure chart
- AML/CFT manual, risk assessment and travel-rule procedures
- ICT security policy, DORA documentation and business continuity plan
- Custody, safeguarding and client-asset policies
- Lease or proof of local premises and organisational chart
How Legal Wealth helps
Legal Wealth helps clients decide between a new Cyprus CASP and an Article 60 notification within an existing CySEC-licensed group, then coordinates Cypriot counsel, auditors and technology specialists to prepare a file that reflects the business as it is actually run. We are attentive to substance, governance and the documentation of ownership and wealth, handled with discretion. Because many of our clients also consider Cyprus residence or hold assets through Cypriot structures, we can align the licensed entity with their wider personal, tax-residence and succession planning.
Enquire with Legal WealthFrequently asked questions
Can I still operate under a CySEC national CASP registration?
No. The transition ended on 1 July 2026. A national registration alone no longer permits crypto-asset services, and a pending application does not extend the transitional period.
Does a Cyprus investment firm need a separate CASP licence?
Not necessarily. Under Article 60 of MiCA, a CIF can notify CySEC and provide crypto-asset services equivalent to its existing investment services, without a separate authorisation.
What capital does a Cyprus CASP need?
EUR 50,000 for Class 1 services, EUR 125,000 for Class 2 and EUR 150,000 for Class 3, or one quarter of prior-year fixed overheads if that is higher.
What fees does CySEC charge?
CySEC's fees for MiCA applications, notifications and annual supervision are set in Policy Statement PS-03-2024 and vary with the services and business volume. We confirm the current amounts at the start of each engagement.
How much substance is needed in Cyprus?
CySEC expects the company to be managed and controlled from Cyprus, with an office, key function holders and decision-making on the island, and with any outsourcing kept under effective control.
Can a Cyprus CASP serve clients across the EU?
Yes. After authorisation it notifies CySEC of the Member States and services concerned and can then operate on a cross-border basis.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
Sources
- Harneys - CySEC updates on transitional measures for crypto-asset providers
- AGP Law - MiCA's transition ends on 1 July 2026
- Harris Kyriakides - MiCA: a new era for crypto-assets
- ESMA - List of MiCA grandfathering periods under Article 143(3)
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA), EUR-Lex