CASP Authorization (MiCA)
MiCA-compliant CASP authorization through BaFin for crypto-asset services with EU-wide passporting, considered one of the highest-trust regulatory approvals in the EU.
MiCA Regulation (EU) 2023/1114, BaFin MiCA Implementation Guidelines
Capital Required
€50,000-150,000 per MiCA Annex IV class + 25% fixed overheads
Timeline
3-6 months
Fees
€5,000-50,000 BaFin application + €3,000-25,000 annual
Regulatory Body
Federal Financial Supervisory Authority (BaFin)
Legislative Framework
MiCA Regulation (EU) 2023/1114, German Banking Act (KWG), German Securities Trading Act (WpHG)
Last updated: August 2025
Key Requirements
Establish Germany-based legal entity subject to German law and BaFin supervision with EU passporting rights.
Maintain minimum capital per MiCA Annex IV based on crypto service class: €50,000 (Class 1), €125,000 (Class 2), or €150,000 (Class 3).
Implement governance structure with board-level oversight, compliance officer, and risk management functions per BaFin requirements.
Adopt customer asset safeguarding procedures with segregated custody arrangements and written safeguarding agreements.
Develop comprehensive AML/CFT compliance program per 5th EU Money Laundering Directive with transaction monitoring.
Implement operational resilience and business continuity procedures per DORA (Digital Operational Resilience Act).
Establish professional indemnity insurance covering minimum 25% of quarterly fixed overheads per MiCA requirements.
Application Process
Establish Germany-based company with articles of association, management documentation, and beneficial ownership structure.
Prepare comprehensive business plan including organizational structure, service offerings, AML/CFT procedures, and strategy.
Document capital adequacy per MiCA service class (€50,000-€150,000) with bank account evidence and financial documentation.
Prepare detailed operational procedures covering customer onboarding, AML/CFT compliance, and asset safeguarding arrangements.
Submit CASP authorization application to BaFin with business plan, governance documents, and compliance framework.
Provide evidence of professional indemnity insurance and custody/safeguarding arrangement documentation.
Engage with BaFin during assessment period (3-6 months) responding to information requests and compliance queries.
Receive BaFin authorization decision and register in BaFin register receiving EU-wide passporting notification.
Expected Total Timeline
3-6 months
Ongoing Obligations
After obtaining your CASP Authorization (MiCA), these are the continuing compliance requirements you must maintain.
Maintain minimum capital requirement per service class with quarterly capital calculations reported to BaFin.
Submit annual audited financial statements and governance reports to BaFin by statutory deadlines.
Report significant incidents or regulatory violations to BaFin within 24 hours of discovery.
Conduct annual internal governance review with board approval and submit documentation to BaFin.
Update AML/CFT compliance procedures annually addressing identified risks and regulatory guidance changes.
Maintain professional indemnity insurance continuously with coverage of minimum 25% quarterly fixed overheads.
Notify BaFin of material changes including shareholders, management, or service offerings within 30 days.
Cost Summary
Capital Requirement
€50,000-150,000 per MiCA Annex IV class + 25% fixed overheads
Application & Licensing Fees
€5,000-50,000 BaFin application + €3,000-25,000 annual
Jurisdiction Setup Cost
$30,000-$80,000
Annual: $20,000-$50,000
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