Head of International Corporate Law and Fintech Practice
Expert in fintech, crypto, and international corporate law with over 20 years of experience. Specializes in crypto licensing (VASP/CASP), iGaming business support, and international structuring, asset protection, and OSINT analytics for risk assessment and due diligence.
OBTAINING A CRYPTO LICENSE IN ESTONIA
Estonia remains one of the most attractive EU jurisdictions for crypto projects, but since 2025 the regulatory regime has been significantly tightened and aligned with the MiCA Regulation.
New market entrants must immediately obtain a Crypto-Asset Service Provider (CASP) license under the supervision of the Financial Supervision Authority (Finantsinspektsioon), while existing Virtual Asset Service Providers (VASPs) must undergo re-licensing by 1 July 2026.
Which services require a crypto license in Estonia
Under MiCA and the Estonian implementing framework, a CASP license is required for, in particular, the following activities:
- exchange of crypto-assets for fiat currencies and crypto-to-crypto (crypto exchange);
- custodial services for safeguarding crypto-assets and private keys (custody/wallet);
- execution and reception of client orders in crypto-assets (brokerage, dealing on behalf of clients);
- operation of trading platforms for crypto-assets;
- placement of crypto-assets, including public offerings.
Regardless of whether the company serves retail or institutional clients, providing these services without a CASP license after the transition period will constitute a MiCA violation.
Key requirements for crypto companies in Estonia
Estonia has effectively brought serious crypto businesses to the level of traditional financial institutions: requirements for capital, real substance, corporate governance, compliance, and IT infrastructure have significantly increased.
Corporate substance
To obtain a crypto license, the applicant must establish an Estonian company (most commonly an OÜ) or set up a branch with real economic presence in Estonia.
Capital requirements
Since 2025, minimum share capital thresholds have increased significantly and typically range from approximately EUR 50,000 to EUR 150,000 depending on the business model.
For models involving transfers, large-scale custody, or higher risk exposure, the threshold may reach EUR 100,000–250,000+.
The capital must be fully paid up prior to application, and the company must maintain adequate own funds. The regulator separately assesses the capital buffer based on fixed overheads or turnover.
AML/CFT requirements
Applicants are expected to implement a comprehensive AML/CFT framework, including a risk-based approach, KYC/KYB procedures, sanctions screening, transaction monitoring, and suspicious activity reporting mechanisms.
Appointment of a qualified MLRO with real authority and relevant experience is mandatory.
The company must also implement operational and compliance risk management policies, a business continuity plan, and incident response procedures.
Failure to meet AML requirements may result in substantial fines or license revocation.
Audit and ongoing control
The company must undergo mandatory annual financial audit, and the external auditor must be designated already at the application stage.
IT infrastructure
IT expectations are close to banking standards. The company must ensure robust architecture, secure client asset storage, proper asset segregation, backup systems, and adequate personal data protection.
Process of obtaining a crypto license in Estonia
Project structuring and company registration
At the initial stage, the business model, scope of services, and corporate structure are defined.
The legal form (most often OÜ) is selected, shareholders and governing bodies are structured, and a capital contribution account is opened.
The company is then registered in the Estonian Commercial Register — either via a local notary or using e-Residency tools.
It is advisable to align the structure with MiCA requirements already at this stage to avoid costly restructuring in 2025–2026.
Preparation of the licensing package
The Finantsinspektsioon application package includes a detailed 2–3 year business plan with financial projections, description of services, target markets, client types, revenue model, and risk profile.
AML/CFT policies, risk management procedures, business continuity framework, sanctions screening, and internal compliance rules must be prepared.
Corporate governance, organizational chart, compliance and internal control functions must be clearly described.
A detailed IT systems and security description is also required.
The applicant must submit documentation on beneficial owners and management (CVs, proof of education and experience, criminal record certificates, fit & proper declarations).
At this stage, alignment with regulator expectations on depth and structure of documentation is critical.
Application submission and review
The CASP license application is filed with Finantsinspektsioon together with the full supporting package and proof of state fee payment.
While statutory timelines apply, in practice the full structuring and licensing cycle for a new business typically takes four to six months.
During the review, the regulator may request additional information, written explanations, or meetings with management to clarify the business model, risk management, and compliance framework.
For existing Estonian VASPs transitioning to CASP status, some elements may be simplified, but substantive requirements on governance, capital, AML, and IT remain high.
Post-licensing obligations
After obtaining the CASP license, the company enters ongoing supervision.
It must regularly submit statistical and regulatory reports, undergo annual audit, and continuously review and update risk assessments and internal policies.
Ongoing customer and transaction monitoring, KYC updates, suspicious transaction blocking and reporting become part of daily operations.
Any material changes in ownership, management, IT infrastructure, or scope of services must be promptly reported to the regulator.
Failure to comply may result in activity restrictions, fines, or license revocation.
How Prikhodko & Partners assists with obtaining a crypto license in Estonia
Prikhodko & Partners supports clients at every stage of the Estonian crypto licensing process — from selecting the optimal model (exchange, custody, brokerage and other CASP services) and structuring the business in line with MiCA requirements to incorporating the Estonian entity and preparing the full licensing package, including the business plan, AML/CFT framework, internal procedures, IT architecture description, and organizational structure.
We assist with building corporate governance, selecting and approving management and MLRO candidates, managing communication with the Estonian regulator, and promptly responding to regulatory queries.
After licensing, the firm continues to support clients in the post-licensing phase: advising on reporting, policy updates, MiCA alignment, and national regulatory changes to ensure the crypto business remains fully compliant and operationally stable.
Contact us today — and we will support your crypto business ambitions in Estonia.
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