CASP License Estonia

Estonian FIU licences ended on 1 July 2026. Finantsinspektsioon now authorises CASPs. See the EUR 3,000 fee, capital by class, review timeline and AML duties.

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Crypto License in Estonia Under MiCA

Estonia’s virtual currency licences were issued by the Financial Intelligence Unit (FIU). The FIU announced that it would cancel the register data for those licences on 1 July 2026, the day the MiCA transition period ended. Since then, crypto-asset services in Estonia may only be provided by a company authorised by Finantsinspektsioon or by another EEA supervisor.

A company without an authorisation must not take new clients, open new accounts or actively market its services in the EEA. One that is still waiting for a decision must limit its activity until it arrives. Both must tell clients how the service will end or be limited and how to withdraw their assets or move them to an authorised provider.

What Is a CASP License in Estonia?

A CASP license is an authorisation to provide crypto-asset services under MiCA. In Estonia the authority is Finantsinspektsioon. The FIU’s remaining role is AML: authorised providers are obliged entities and report suspicious transactions to it. The FIU’s head said that AML documentation alone is not enough, and that safeguarding of client assets and cyber resilience also need supervision.

You need a CASP authorisation if your business provides services such as:

  • Crypto custody or wallet services
  • Trading platforms or exchanges
  • Fiat-to-crypto or crypto-to-crypto transactions
  • Executing orders on behalf of clients
  • Crypto transfer and payment services
  • Crypto-related investment advice or portfolio management

Capital Class by Service

Service Capital class Minimum capital
Execution of orders on behalf of clients Class 1 EUR 50,000
Transfer services for crypto-assets on behalf of clients Class 1 EUR 50,000
Investment advice and portfolio management for crypto-assets Class 1 EUR 50,000
Custody and administration of crypto-assets for clients Class 2 EUR 125,000
Exchange of crypto-assets for funds or for other crypto-assets Class 2 EUR 125,000
Operating a crypto trading platform Class 3 EUR 150,000

CASP License Timeline in Estonia

  • 30 December 2024: MiCA applies in full across the EU
  • 18 March 2026: Finantsinspektsioon opens its application portal for CASP licences
  • 23 March 2026: Finantsinspektsioon reports that it is processing 10 applications and asks applicants for a wind-down plan
  • 17 April 2026: ESMA states that the MiCA transitional period expires across the EU on 1 July 2026
  • 1 July 2026: the transition period ends and the FIU cancels the register data for the old virtual currency licences. Lightspark Payments Europe AS is the first standalone CASP authorised in Estonia

Banks and some other regulated firms can offer crypto-asset services after notifying their home supervisor under MiCA Article 60, at least 40 working days before they start. Cross-border providers authorised in other EEA countries can also serve Estonian clients, and the country-by-country CASP guide compares the routes. The register page read on 30 October 2026 listed one Estonia-based CASP, so check the live register before you rely on it.

CASP License Requirements in Estonia

To apply for and keep a CASP license in Estonia, you must meet these requirements:

  • Authorisation: apply to Finantsinspektsioon through its portal. The application is in Estonian, and supporting documents can be in English if the application says so
  • Substance: a registered office in a member state where you carry out part of your services, your place of effective management in the EU, and at least one director resident in the EU (MiCA Article 59). The Finantsinspektsioon licence page lists no separate Estonian residency rule
  • Capital: EUR 50,000, EUR 125,000 or EUR 150,000 depending on the service class, or one quarter of the previous year’s fixed overheads if higher
  • Management: board members need good repute and the knowledge, skills and experience to run the provider, shown through Finantsinspektsioon’s fit and proper form
  • AML and KYC: authorised CASPs are obliged entities under the Money Laundering and Terrorist Financing Prevention Act and report suspicious transactions to the FIU. Identity checks sit in your own KYC process
  • Travel Rule: Regulation (EU) 2023/1113 has applied since 30 December 2024, and the Travel Rule sets the data you must send with each transfer. For transfers above EUR 1,000 to a self-hosted address, the CASP must take adequate measures to assess whether its customer owns or controls that address (Article 14(5))
  • Transaction monitoring: ongoing transaction monitoring of customer activity for suspicious patterns

How Finantsinspektsioon Assesses a CASP Application

MiCA Article 63 sets the timetable, and the portal on the Finantsinspektsioon site is where the file goes in:

  1. Submit the application through the Finantsinspektsioon portal and pay the EUR 3,000 processing fee.
  2. Finantsinspektsioon checks completeness within 25 working days. If the file is incomplete, it sets a deadline for the missing information.
  3. Once the file is complete, it has 40 working days to decide.
  4. Requests for further information stop the clock until you answer, for up to 20 working days.
  5. Finantsinspektsioon notifies you of its decision within five working days of making it.

The file covers governance, internal controls, AML and counter-terrorist financing policies, ICT security, how client assets and funds are kept separate, and complaints handling. Custody, trading platforms, order execution, advice and transfer services each need extra documents. Since March 2026, Finantsinspektsioon has asked applicants to include a wind-down plan.

How Scorechain Helps You Stay MiCA-Compliant

Scorechain covers the screening and monitoring side of these duties. Your team keeps customer identification, Travel Rule decisions and reporting to the FIU.

Estonian CASP duty What it requires Where Scorechain helps What stays with you
Screen counterparties Assess risk before you accept or send funds Wallet screening shows exposure to sanctioned, illicit and high-risk counterparties with a risk score The decision to proceed
Monitor transactions Ongoing monitoring for suspicious patterns Transaction monitoring scenarios built from transaction direction, amount and triggered risk indicators, with real-time alerts across 25+ blockchains. Case Manager documents findings Reviewing alerts and escalating
Send Travel Rule data Originator and beneficiary data with transfers The Travel Rule API gives one endpoint to exchange the data through partner infrastructure Customer identification and self-hosted wallet checks. The API does not guarantee regulatory approval
Document unusual activity Clarify and record suspicious activity KYT and KYA reports with transaction details, risk scoring, entity attribution and red flags. KYA reports export as PDF or CSV Judging the activity and the decision
Check sanctions exposure Avoid dealing with sanctioned parties The free Sanctions Screening API checks addresses against OFAC, OFSI, MOFA and NBCTF lists, at 100 requests an hour Checking EU sanctions lists separately
Report suspicion Report suspicious transactions to the FIU Scorechain flags the risk, and case reports can be exported for your records Filing the report with the FIU

Prepare Your CASP License File in Estonia

Finantsinspektsioon had 10 applications in progress by March 2026 and the register lists one authorised Estonia-based CASP, so the file has to show how you will screen, monitor and document from the first day. Scorechain has supported 200+ organisations with AML compliance, blockchain analytics and regulatory risk management.

To see wallet screening and transaction monitoring on your own flows before you file, book a demo with the Scorechain team.

Frequently Asked Questions

Can I keep operating on my old FIU virtual currency licence?

No. The FIU announced that it would cancel the register data for the old licences on 1 July 2026, when the MiCA transition period ended. Since then, crypto-asset services in Estonia need an authorisation from Finantsinspektsioon or from another EEA supervisor. A firm still waiting for a decision must limit its activity until it arrives.

What does an Estonian CASP application need, and in what language?

The application goes through the Finantsinspektsioon portal, with a EUR 3,000 processing fee. It is in Estonian, and supporting documents can be in English if the application says so. The file covers governance, internal controls, AML and counter-terrorist financing policies, ICT security, how client assets and funds are kept separate, and complaints handling. Custody, trading platforms, order execution, advice and transfer services each need extra documents. Since March 2026, Finantsinspektsioon has asked applicants to include a wind-down plan.

How do I check whether a provider is authorised in Estonia?

Use the Finantsinspektsioon register of supervised entities. It lists Estonia-based CASPs and, separately, cross-border CASPs authorised in other EEA countries. The register page read on 30 October 2026 listed one Estonia-based CASP, Lightspark Payments Europe AS, so check the live register before relying on any list.

What happens to clients’ assets if a provider stops operating in Estonia?

Finantsinspektsioon expects the provider to protect clients and avoid unjustifiable financial harm. It must tell clients clearly and in good time how the service will end, the deadlines, and how to withdraw their assets or move them to an authorised provider. ESMA says offboarding can mean moving assets to an authorised CASP or to a self-hosted wallet.

Do Estonian banks need a CASP licence to offer crypto services?

Not a separate one. Credit institutions and some other regulated firms can offer crypto-asset services after notifying their home supervisor under MiCA Article 60, at least 40 working days before they start.

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