Estonia crypto licence in 2026: the MiCA route after FIU licences ended

28 September 2026 · Business blog · Estonia, MiCA

An Estonia crypto licence in 2026 means a MiCA CASP authorisation from Finantsinspektsioon, the Estonian Financial Supervision Authority. The virtual currency licences issued by the Financial Intelligence Unit (FIU) stopped giving the right to operate on 1 July 2026; Finantsinspektsioon announced that the FIU would cancel their register data that day. A new provider files through Finantsinspektsioon’s portal and pays a EUR 3,000 processing fee; MiCA sets minimum capital at EUR 50,000–150,000 by service class, and the regulator has 25 working days to confirm the file is complete and 40 working days to decide. The authorisation can then be passported to every EEA state by notification.

What happened to Estonian crypto licences on 1 July 2026

Since 1 July 2026, crypto-asset services in Estonia may only be provided by companies authorised under MiCA by Finantsinspektsioon or by the supervisor of another EEA state. Finantsinspektsioon announced that the FIU would cancel the register data of the virtual currency service provider licences on that day. Estonia had used the full 18-month grandfathering period allowed by Article 143(3) of MiCA (ESMA list of grandfathering periods).

The numbers show how far the market has shrunk. According to the head of the FIU, there were 641 valid licences in mid-2021 and 36 at the start of 2026. Finantsinspektsioon had granted one CASP authorisation by 30 June 2026, to Lightspark Payments Europe AS, while AS LHV Pank and Lightyear Europe AS may also provide crypto-asset services; other providers serve Estonia cross-border on authorisations from other EEA states (Finantsinspektsioon, 30 June 2026; register of crypto-asset service providers).

For firms without an authorisation, ESMA’s public statement of 23 June 2026 sets the expectations: stop onboarding EU clients and all marketing, limit services to what clients need to sell, transfer or close positions, and keep custody only for the period strictly necessary for an orderly exit (ESMA public statement). Finantsinspektsioon adds that firms still waiting for a decision must limit their activity until the final decision.

MiCA allowed member states a simplified procedure for holders of national licences only for applications filed by 1 July 2026 (Article 143(6)). A former FIU licence holder filing today goes through the standard procedure of Articles 62 and 63.

How to get CASP authorisation from Finantsinspektsioon: step by step

A CASP authorisation in Estonia is granted by Finantsinspektsioon on an application under Article 62 of MiCA, filed on the form in Annex VI of the ESMA technical standards through the Finantsinspektsioon application portal, which has been mandatory since 18 March 2026 (Finantsinspektsioon authorisation page).

1. Define the services. Custody, exchange, trading platform, order execution, reception and transmission, placement, transfer, advice and portfolio management each carry different documentation and a different capital class.
2. Set up the company and substance. Article 59(2) of MiCA requires a registered office in a member state where at least part of the services is provided, the place of effective management in the EU and at least one director resident in the EU. Managers go through Finantsinspektsioon’s fit and proper assessment form.
3. Write the file. Programme of operations, including where and how services will be marketed; proof of prudential safeguards; governance; repute and competence of managers and qualifying shareholders; internal controls, AML/CFT risk management and business continuity; ICT technical documentation with a non-technical description; segregation of client assets; complaints handling. Custody, trading platforms, exchange, execution, advice and transfer services each add their own policy.
4. Add a wind-down plan. In March 2026 Finantsinspektsioon told applicants to include a plan for winding up operations with their application (Finantsinspektsioon, 23 March 2026).
5. File and pay. The application is filed in Estonian; supporting documents may be in English if the application says so. The processing fee is EUR 3,000.
6. Answer the regulator. Finantsinspektsioon may request more information whenever it is not convinced the applicant has adequate arrangements.

Capital, fees and substance: the numbers

The cost of an Estonian CASP licence has three regulatory parts: the processing fee, minimum capital set by MiCA, and the substance MiCA requires in the EU. The first two have fixed floors.

Sources: Finantsinspektsioon; Regulation (EU) 2023/1114 on EUR-Lex.

Prudential safeguards may be held as own funds, an insurance policy or a combination of both (Art. 67(4) MiCA). Our own fee is quoted in writing after a free review of the model, because an advice-only licence and a custody-and-exchange platform differ several times in workload.

Timeline: how long an Estonian CASP licence takes

The statutory clock is 25 working days for the completeness check and 40 working days for the decision, with the clock paused for up to 20 working days while the applicant answers questions. Preparation comes before that clock starts: in our practice, assembling a fileable application usually takes three to six months, and hiring EU-resident senior staff often takes longer than writing policies.

The Blocons regime board on our home page shows 6–9 months for Estonia from start to authorisation. Treat it as a planning range: the result depends on how complete the file is on day one and on Finantsinspektsioon’s workload. In March 2026 the regulator reported 10 CASP applications in processing and warned that new applicants were unlikely to receive a decision before the 1 July deadline.

Estonia vs Lithuania vs Malta

Under MiCA the rulebook, capital classes and statutory clock are the same in all three countries; the differences are the regulator, the practicalities of working with it and the cost of local substance.

Grandfathering periods: ESMA list under Art. 143(3) MiCA. Fees: Finantsinspektsioon.

Choose the home state on four practical points: how many CASP files the regulator has actually decided, the language you will correspond in for years, whether you also need payment or e-money permissions, and the cost of resident management and staff. Our pages on the crypto licence in Malta and the Lithuanian route go through each regulator in detail.

Passporting an Estonian licence across the EU

An Estonian CASP authorisation covers the whole EEA through a notification under Article 65 of MiCA. The provider sends Finantsinspektsioon the list of member states, the services, the start date and any activities outside MiCA. The regulator forwards it within 10 working days, and the provider may start from the date it is told the information was passed on, or at the latest from the 15th calendar day after its notification.

The passport works only for authorised EU providers. ESMA reminds firms established outside the EU that they may not provide MiCA services to EU clients or solicit them, including business-to-business, apart from the narrow reverse solicitation exception, and that custody may not be outsourced to an entity that is not itself a CASP (ESMA statement of 17 April 2026).

What goes into a Blocons jurisdiction plan

A jurisdiction plan is a written document that maps your business model onto the regimes open today and states the cost and timeline before you pay for licence work. For an Estonian CASP it covers:

• your services mapped to MiCA classes and the resulting own-funds amount;
• whether Estonia, Malta or Lithuania fits your model better, and why;
• the substance plan: office, management, EU-resident director, MLRO and staff;
• the document list for the Article 62 file, including the wind-down plan;
• a timeline from first call to filing and to the regulator’s decision;
• the UK, US or Canadian permissions you need if clients sit outside the EEA.

Why teams bring this work to us: we cover 12 jurisdictions, have 5 years in crypto licensing, work in 6 languages, review the model for free and put the plan in writing before any payment. More on the service: licensing of crypto activities and our page on the crypto licence in Estonia.