On 1 July 2026, the transitional period under the Markets in Crypto-Assets Regulation (MiCA) officially came to an end. From that date onwards, any company wishing to provide regulated crypto-asset services across the European Union generally needs authorisation as a Crypto-Asset Service Provider (CASP).
For many entrepreneurs, obtaining a CASP licence has become almost synonymous with launching a blockchain project.
That assumption is often wrong.
In reality, most token issuance projects do not need to become CASPs at all. And for those that do, the real cost is significantly higher than many founders initially expect.
The great MiCA filter
Before MiCA, thousands of companies operated across Europe under different national registration regimes.
When the transitional period expired, only a fraction had successfully obtained CASP authorisation.
This should not be interpreted as regulatory failure.
Quite the opposite.
The regulatory filter is working exactly as designed: becoming a CASP requires a substantial financial, organisational and compliance commitment that many business models simply cannot sustain.
The question should therefore not be:
“Can we obtain a CASP licence?”
but rather:
“Does our business actually require one?”
That distinction can save a project hundreds of thousands of euros.
The visible costs
The first costs are relatively easy to calculate.
MiCA establishes different prudential capital requirements depending on the services provided.
Broadly speaking:
- EUR 50,000 for advisory services and reception/transmission of orders.
- EUR 125,000 for custody and exchange services.
- EUR 150,000 for operating a crypto-asset trading platform.
Beyond regulatory capital, preparing an application normally requires extensive legal and compliance work, including:
- Programme of operations.
- Corporate governance framework.
- AML/CFT policies.
- Custody procedures.
- Business continuity planning.
- Internal controls.
- Risk management framework.
- Fit and proper assessments of directors and senior management.
Depending on the jurisdiction and complexity of the project, legal and consultancy costs alone may easily range between EUR 100,000 and EUR 250,000, excluding regulatory filing fees and internal preparation costs.
For many founders, these figures already appear substantial.
They are not the real problem.
The hidden cost: maintaining a CASP
The application is only the beginning.
The true financial burden comes after authorisation.
European supervisors increasingly expect CASPs to have genuine operational substance within the Member State where they are established.
In practice this often requires:
- Local effective management.
- Independent governance arrangements.
- A dedicated Compliance Officer.
- A Money Laundering Reporting Officer (MLRO) or AML Officer.
- Internal audit functions where appropriate.
- Ongoing prudential monitoring.
- Transaction monitoring systems.
- Cybersecurity controls.
- Regular reporting obligations.
- Continuous regulatory updates.
For smaller businesses, these recurring operational costs frequently exceed EUR 150,000–300,000 annually, even before considering commercial staff or technology development.
That recurring expenditure—not the initial legal bill—is what ultimately determines whether a CASP business model is economically viable.
Time is another cost
Official regulatory timelines often suggest that authorisation may be granted within a few months.
Reality tends to be different.
Preparing documentation, responding to supervisory questions, revising governance structures and completing remediation rounds frequently turns the process into a 12–18 month project.
For startups seeking investment or preparing a token launch, this delay represents an additional commercial cost that is rarely reflected in financial forecasts.
Launching a business and obtaining a CASP licence are often two separate projects running in parallel.
The solution many advisers never mention
The most important legal point is also the simplest.
Issuing a token does not automatically require becoming a CASP.
Under Title II MiCA, many ordinary crypto-asset offerings are carried out through the publication and notification of a compliant crypto-asset white paper, rather than through obtaining a CASP authorisation.
The regulated activities are different from the issuance itself.
Services such as:
- custody,
- exchange,
- trading,
- execution of orders,
- or fiat on/off ramps,
can be provided by already authorised CASPs.
This creates a far more efficient structure.
The project focuses on:
- developing the protocol,
- building its community,
- designing tokenomics,
- and creating value.
Meanwhile, regulated service providers deliver the activities that legally require authorisation.
Instead of replicating an expensive compliance infrastructure, projects leverage providers that have already invested in obtaining regulatory approval.
For many startups, this architecture reduces regulatory costs dramatically while remaining fully compatible with MiCA.
When does obtaining a CASP licence make sense?
There are situations where becoming a CASP is entirely justified.
For example, when the business model itself consists of providing regulated crypto services, such as:
- custody platforms;
- exchanges;
- brokerage;
- execution services;
- trading venues;
- or institutional crypto infrastructure.
In those cases, controlling the complete customer experience may justify the investment.
However, if the objective is simply to issue a token linked to a protocol, a platform or a digital ecosystem, obtaining a CASP licence may be unnecessary—and economically inefficient.
The licence should follow the business model.
Not the other way around.
Operating without authorisation is no longer an option
Since the end of the MiCA transitional regime, providing regulated crypto-asset services in the European Union without the required authorisation is no longer a regulatory grey area.
Projects exposing themselves to regulated activities without authorisation may face supervisory intervention, cease-and-desist measures, administrative sanctions and potential civil liability towards users.
Legal compliance therefore begins long before launch.
It begins with correctly classifying the token, identifying which activities are regulated and designing the appropriate legal structure from the outset.
Beyond licensing: legal infrastructure also matters
Regulatory compliance should not end with obtaining authorisations.
Token projects increasingly operate across multiple jurisdictions, interact through smart contracts and involve decentralised governance.
Disputes are inevitable.
Founder disagreements, tokenholder conflicts, governance disputes and service provider claims all require predictable resolution mechanisms.
For that reason, projects should also consider incorporating specialised dispute resolution frameworks into their legal architecture, including arbitration clauses specifically designed for blockchain ecosystems.
At Blockchain Arbitration & Commerce Society (BACS), we believe legal infrastructure should evolve alongside technological infrastructure.
Compliance is only one layer.
Governance, enforcement and dispute resolution complete the architecture.
Conclusion
A CASP licence is one of the most demanding regulatory authorisations introduced under MiCA.
For businesses whose core activity is providing regulated crypto services, it may be indispensable.
For many token issuers, however, it is neither legally required nor commercially sensible.
The smartest regulatory strategy is not always obtaining more licences.
It is understanding which licences are actually necessary.
This article is provided for general informational purposes only and does not constitute legal advice. Every token project requires an individual legal assessment before launch.
