Crypto licence in the Czech RepublicOverview
Before MiCA, Czech crypto businesses operated under a free trade licence for services related to virtual assets, supervised mainly for AML purposes. Act No. 31/2025 Coll. on the implementation of EU rules on the digitalisation of the financial market, together with Act No. 32/2025 Coll., took effect on 15 February 2025 and made the CNB responsible for MiCA authorisations, notifications and supervision of CASPs and token issuers.
The Czech Republic kept the maximum eighteen-month transitional period, but only for firms that held the relevant trade licence on 29 December 2024 and filed a CASP application by 31 July 2025. In June 2026 the CNB warned that most former providers could not continue because they did not meet those conditions, and on 1 July 2026 unauthorised firms had to stop serving clients, transfer client assets to authorised providers or self-hosted wallets and keep complying with AML rules until wind-down. Unauthorised provision can be fined above CZK 100 million.
The CNB has been candid about the quality of applications. It received the highest number of MiCA filings in the EU, yet many were incomplete, came from entities with no verifiable history or a virtual address, or aimed to operate mainly abroad. Only a small share demonstrated a transparent business model, ownership and financing. Applicants should therefore expect detailed scrutiny of real substance in Prague or elsewhere in the country, of the management body's experience and of the economic rationale for the Czech base.
For groups that do meet the standard, the Czech Republic offers a sophisticated financial supervisor, a strong technology workforce and a central position in Europe. The CNB publishes separate lists of authorised CASPs, notified financial institutions and foreign CASPs, and applies the MiCA technical standards and ESMA's supervisory briefing on CASP authorisation as its methodological reference.
Key benefits
- Authorisation from a well-regarded central bank supervisor
- Full EU and EEA passporting from a single Czech licence
- Deep technology and fintech talent pool in Prague and Brno
- Capital tiers aligned with the services actually offered
- Clear CNB published lists that make status easy for counterparties to verify
- Strong regulatory credibility for banking, investor and partner due diligence
Requirements
- Czech legal person with registered office and effective management in the Czech Republic
- At least one EU-resident director and a management body that is reputable, competent and has sufficient time
- Own funds of EUR 50,000, 125,000 or 150,000 by class, or one quarter of prior-year fixed overheads if higher
- Transparent ownership structure and a documented, verifiable source of funds
- Real operational presence: physical office, staff and decision-making in the country, not a virtual address
- AML/CFT framework, travel-rule procedures and sanctions screening
- DORA-compliant ICT risk management, incident reporting and business continuity
- Safeguarding and segregation arrangements for 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.
Step-by-step process
- 1
Readiness assessment
We test the business model, ownership and funding against the CNB's published concerns before committing to a Czech application.
- 2
Incorporation and substance
Company formation, capital contribution, office, recruitment of directors and key function holders, and bank account opening.
- 3
Application file
Preparation of the Article 62 MiCA application using the forms in Implementing Regulation (EU) 2025/306, with all policies and fit-and-proper files.
- 4
Submission to the CNB
Filing through the CNB contact point and the completeness check of up to 25 working days.
- 5
Assessment
A 40 working day assessment once complete, with clock stops for information requests. Several rounds of questions are common.
- 6
Authorisation and registration
Publication in the CNB register once the decision becomes final, entry in the ESMA register and passporting notifications.
Typical documents
- Memorandum or articles of association and Commercial Register extract
- Programme of operations, business plan and financial projections
- Own-funds evidence and prudential calculations
- Fit-and-proper documentation and criminal record extracts for directors and qualifying shareholders
- Source-of-funds and source-of-wealth evidence
- AML/CFT manual and business-wide risk assessment
- ICT security, DORA and business continuity documentation
- Custody and safeguarding policy
- Proof of local premises and staffing plan
How Legal Wealth helps
Legal Wealth works with clients to decide whether the Czech Republic is the right home state, and if it is, to build a file that addresses the CNB's stated concerns from the outset: substance, governance, transparent ownership and a credible business model. We coordinate Czech counsel, auditors and IT security specialists, manage sensitive shareholder information discreetly and keep the founder's personal residence and succession goals in view when designing the group structure. After authorisation we can support passporting, reporting and future restructuring.
Enquire with Legal WealthFrequently asked questions
Can I still operate under a Czech trade licence for virtual assets?
No. The MiCA transition ended on 1 July 2026 and covered only firms that applied by 31 July 2025. Crypto-asset services now require CNB authorisation, an Article 60 notification by a qualifying financial institution, or a passport from another EU state.
How many CASPs has the CNB authorised?
On 1 July 2026 the CNB reported 11 authorisations after assessing 251 applications and notifications. The list of authorised firms is published once decisions become final.
Which law governs crypto licensing in the Czech Republic?
MiCA applies directly. Act No. 31/2025 Coll. and Act No. 32/2025 Coll., in force since 15 February 2025, designate the CNB and adjust Czech law accordingly.
What does the CNB look for in an application?
A real business model, transparent ownership and financing, competent management physically present in the country, and complete documentation. The CNB has publicly criticised files from entities with virtual addresses and no track record.
What happens if a firm operates without authorisation?
It breaches MiCA and can face CNB measures including fines with an upper limit above CZK 100 million, as well as orders to cease activity and settle client positions.
Last reviewed: 2026-10. Requirements, fees and timelines change. Information is general, reviewed on the date shown, and is not legal or tax advice.
