Crypto licence in EstoniaOverview
For several years Estonia was the most popular EU base for crypto start-ups, with more than 600 FIU virtual-currency licences in force in 2021. Successive tightening of the AML regime reduced that number to 36 valid licences at the start of 2026. With the Act on Markets in Crypto-Assets, adopted in June 2024 to implement MiCA, licensing and prudential supervision moved from the FIU to Finantsinspektsioon.
Estonia applied the maximum MiCA transitional period. FIU-licensed providers could continue until 1 July 2026, without any simplified procedure for conversion. On that date the FIU cancelled the register data for the old licences, and unauthorised providers were required to stop accepting new clients, stop marketing to EEA clients, and give clients clear instructions for withdrawing or transferring their assets. Applicants that file now must include a wind-down plan with their application.
Finantsinspektsioon is a prudential regulator with a banking-supervision culture, and it assesses crypto applicants with the same rigour. Applicants should expect detailed scrutiny of the management body, the AML risk assessment, IT security and custody arrangements, and the economic substance of the Estonian entity. The regime emphasises genuine local management rather than a nominee-based presence, which marks a clear break from the earlier FIU era.
Estonia remains attractive for digitally native businesses because of its e-government infrastructure and efficient company administration. Founders who held an FIU licence should treat MiCA authorisation as a new application rather than a renewal.
Key benefits
- Fully digital corporate administration and e-residency ecosystem
- Prudential regulator whose authorisation carries weight with banks and partners
- Single EU licence passportable to all Member States
- English widely used in the financial and technology sectors
- Competitive operating costs compared with larger EU financial centres
- Clean post-transition market, with unlicensed providers having exited
Requirements
- Estonian legal person with place of effective management in the EU and at least one EU-resident director
- Management board of at least two members, usually complemented by a supervisory board of three, all meeting fit-and-proper standards
- Minimum capital or prudential safeguards per MiCA Article 67
- Qualifying shareholder assessment and transparent source of funds
- AML/CFT framework under the Money Laundering and Terrorist Financing Prevention Act, with a designated compliance officer
- Travel Rule compliance under Regulation (EU) 2023/1113
- Client-asset segregation and custody policy for Class 2 and Class 3 services
- ICT security and operational resilience consistent with DORA
- Wind-down plan, which Finantsinspektsioon now expects in every application
Licence options & capital
Class 1 CASP
EUR 50,000 minimum capital
Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice and portfolio management. Often chosen by brokerage and transfer-only business models.
Class 2 CASP
EUR 125,000 minimum capital
Any Class 1 service plus custody and administration of crypto-assets for clients and exchange of crypto-assets for funds or for other crypto-assets.
Class 3 CASP
EUR 150,000 minimum capital
Any Class 2 service plus operation of a trading platform for crypto-assets. Prudential safeguards must equal the higher of the fixed amount or one quarter of the previous year's fixed overheads.
Step-by-step process
- 1
Feasibility review
Assess the business model, ownership and team against Finantsinspektsioon's expectations, including whether a former FIU licence holder can realistically meet MiCA standards.
- 2
Corporate set-up
Establish or restructure the Estonian company, appoint the management and supervisory boards and secure local premises and staff.
- 3
Application file
Prepare the programme of operations, policies, financial projections and the wind-down plan.
- 4
Filing and completeness
Submit to Finantsinspektsioon, which checks completeness within 25 working days.
- 5
Assessment
The complete application is assessed within 40 working days, with one possible suspension of up to 20 working days for additional information.
- 6
Authorisation and launch
Begin operations, register for ongoing reporting and notify passporting to other Member States.
Typical documents
- Articles of association and commercial register extract
- Programme of operations and business plan with three-year projections
- Evidence of capital or insurance-based prudential safeguards
- Fit-and-proper questionnaires, CVs and criminal record extracts for board members
- Shareholder structure, ultimate beneficial owner information and source-of-funds evidence
- AML/CFT risk assessment and internal rules
- IT security, business continuity and outsourcing policies
- Custody and safeguarding policy
- Wind-down plan and complaints procedure
How Legal Wealth helps
Legal Wealth helps founders decide whether Estonia remains the right home for their EU licence and, where it does, builds an application that reflects Finantsinspektsioon's prudential standards. We support board composition, local substance, the AML framework and the wind-down plan, and we coordinate the project discreetly alongside the shareholders' broader structuring and succession planning.
Enquire with Legal WealthFrequently asked questions
Is my Estonian FIU crypto licence still valid?
No. The transitional period ended on 1 July 2026 and the FIU cancelled the register data for virtual-currency licences on that date. Providing crypto-asset services now requires MiCA authorisation.
Is there a simplified procedure for former FIU licensees?
No. Estonia did not adopt a simplified conversion route, so former licensees must submit a full MiCA application.
How many board members are required?
A management board of at least two members is required, and in practice a supervisory board of three is usually expected as well, giving around five management body members. All must pass Finantsinspektsioon's fit-and-proper assessment.
Can I serve clients while my application is pending?
Not if you are unauthorised. After 1 July 2026 firms still awaiting a decision must not provide crypto-asset services in Estonia or onboard new clients until authorised.
Can an Estonian CASP serve other EU countries?
Yes. Once authorised, it may notify Finantsinspektsioon of the Member States it intends to serve and passport its services under MiCA.
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
- Finantsinspektsioon – The transition period for crypto companies ends in summer
- Financial Intelligence Unit – The transitional period for providers of crypto asset services is ending
- Ellex – Act for Markets in Crypto-Assets clarifies the changes
- ESMA – Interactive Single Rulebook, MiCA minimum capital requirements
