--- title: "Estonia CASP License 2026 | VASP Migration, FSA | Crassula" description: "Estonia CASP licence for 2026: Crypto Asset Market Act, Finantsinspektsioon authorisation, VASP to CASP by 1 July 2026, EUR 100k-250k capital, timelines." url: "https://crassula.io/guides/licenses/estonia-vasp/" lang: "en" last_updated: "2026-04-22" image: "https://crassula.io/static/images/guides/estonia-vasp/tallinn-tower-1440.4fd669ba6aa0.jpg" alternates: "en": "https://crassula.io/guides/licenses/estonia-vasp/" "de": "https://crassula.io/de/guides/licenses/estonia-vasp/" "es": "https://crassula.io/es/guides/licenses/estonia-vasp/" "fr": "https://crassula.io/fr/guides/licenses/estonia-vasp/" "x-default": "https://crassula.io/guides/licenses/estonia-vasp/" index: "https://crassula.io/llms.txt" --- # Estonia VASP to CASP License in 2026: The Complete Guide A 2026 deep dive into Estonia's crypto-asset service provider regime: Crypto Asset Market Act, Finantsinspektsioon authorisation, VASP-to-CASP migration by 1 July 2026, EUR 100k-250k capital, governance and the end of the old FIU-licensed VASP regime. ![Estonia VASP to CASP License in 2026: The Complete Guide](https://crassula.io/static/images/guides/estonia-vasp/tallinn-tower-960.895157351acb.jpg) - Author: [Kate Drozd](https://www.linkedin.com/in/kate-drozd-1b2bb8191/) - With the Expertise of: [Ivan Sharov](https://www.linkedin.com/in/ivansharov/) - Last edited April 22, 2026, 12 min read ## From FIU-licensed VASP to FSA-authorised CASP Estonia used to be the default low-cost crypto jurisdiction in Europe. Between 2017 and 2021, the Financial Intelligence Unit (FIU) issued more than 2,000 virtual-asset service provider licences under an AML-centred regime. By 2022 the regime had been tightened significantly and most licences were revoked for lack of substance. In 2024 Estonia overhauled the framework entirely. The **Crypto Asset Market Act (CMA)** entered into force on **1 July 2024**, designating the **Finantsinspektsioon (FSA, Financial Supervision and Resolution Authority)** as the single authority responsible for granting, refusing, revoking and supervising CASP authorisations. An FSA CASP authorisation is MiCA-compliant and carries the full EEA passport. The old FIU-issued VASP regime is AML-only and national. Existing FIU-licensed VASPs may continue operating until **1 July 2026**, but must file a new CASP application with the FSA to continue beyond that date. There is **no automatic conversion** between the FIU VASP licence and the FSA CASP authorisation. ### Building a business on this licence? See what the platform covers for it: the regulator's IT questions, rails, providers and the technical part of your application. - [Crypto banking for CASPs authorised by Finantsinspektsioon](https://crassula.io/solutions/crypto-banking/estonia-casp/) [Request demo](https://crassula.io/request-demo/) ![Policy document prepared for a licence application](https://crassula.io/static/images/landings/compliance_assistant/hero/01.525dcb1578e9.webp) ## What the Estonian CASP regime covers Estonia transposes MiCA directly. The ten services and three capital classes are the same as anywhere else in the EU (see the [MiCA CASP guide](https://crassula.io/guides/licenses/mica-casp/)). Estonian specifics: - **Legal entity.** Estonian OÜ (private limited company) with a registered office in Estonia. - **Capital.** Paid-up share capital of EUR 100,000 to EUR 250,000 depending on MiCA class, consistent with Annex IV. Method-of-payment restrictions: cash, not in-kind. - **Substance.** Management board with at least one Estonian-resident director, local compliance function, real office in Estonia. The FIU VASP standard of a single local manager was explicitly rejected as insufficient. - **Procedure.** Phased application process; documentation in Estonian or English on formal request. - **Ongoing own funds.** MiCA-standard: the higher of the class floor or one quarter of the previous year's fixed overheads. The CMA includes specific Estonian adaptations on outsourcing, ICT risk and market-abuse surveillance for trading platforms, aligned with DORA and MiCA RTS. --- ## What FSA supervision actually looks like Finantsinspektsioon has supervised banks, investment firms, insurance and payment institutions for decades. CASP supervision is layered on top of that experience. - **Full financial supervision.** Unlike the FIU regime, FSA oversight covers governance, safeguarding, prudential capital, complaints handling, outsourcing, ICT resilience, conduct, and market abuse - not just AML. - **Substantive fit-and-proper.** Management board, key function holders and every qualifying shareholder assessed individually. Revoked FIU licences often had board members with overlapping mandates; FSA is closing that door. - **Inspections.** Regular onsite thematic inspections; AML-focus remains high given Estonia's history. - **Public register.** Granted CASPs appear on the FSA register and on the consolidated ESMA interim register (weekly CSV until mid-2026). --- ## Process and timeline 1. **Pre-application engagement.** FSA expects a pre-submission meeting. Bring a one-pager business model, MiCA-class scope, capital plan, custody architecture and AML approach. 2. **Incorporation.** Register Estonian OÜ, open a capital account, pay in EUR 100k to 250k depending on class. 3. **File preparation (3 to 5 months).** Programme of operations, business plan, governance, AML/CFT, ICT/DORA, outsourcing, safeguarding, fit-and-proper. 4. **Submission and completeness check.** 25 working days per MiCA Article 62. 5. **Substantive assessment.** 40 working days statutory, extendable by 20. Real-world 4 to 8 months. 6. **Conditions precedent.** Capital paid up, safeguarding live, AML and Travel Rule operational. 7. **Passporting.** Notifications to host NCAs; services start 15 calendar days later. End-to-end for a well-prepared file: **6 to 10 months**. FIU-licensed VASPs migrating to CASP get no automatic credit: the file has to be built from scratch to MiCA standards. --- ## Transition decisions for FIU-licensed VASPs Three paths for the firms that held a FIU VASP licence as of 30 December 2024. #### Migrate to Estonian CASP File a fresh MiCA application with the FSA. Budget 6 to 10 months. Plan capital uplift, substance, governance, DORA, market-abuse and custody work. #### Relocate to another Member State Apply in a jurisdiction where timelines, language or cost fit better. Malta, Lithuania, Cyprus and France are common destinations. #### Wind down EU activity Controlled migration of client assets to a licensed CASP, orderly customer communication, Estonian FIU deregistration. Operating past 1 July 2026 without an FSA CASP authorisation (and without being out of scope) is a criminal offence in Estonia. --- ## Ship an Estonian CASP product with Crassula A CASP authorisation is the legal layer. The product layer is the crypto platform itself. Crassula delivers it as a MiCA-ready white-label core tuned to FSA expectations: custody with MPC or multi-sig, matching or RFQ, Travel Rule, market-abuse surveillance, DORA-aligned ICT and regulator-ready reporting. See the [MiCA CASP guide](https://crassula.io/guides/licenses/mica-casp/) for the full regulatory context. --- ## FAQ ### What is the Crypto Asset Market Act? Estonia's national law that entered into force on 1 July 2024 to transpose MiCA. It makes the Finantsinspektsioon (FSA) the single authority for CASP authorisation and supervision, replacing the Financial Intelligence Unit's pre-MiCA VASP regime. ### When does the old FIU VASP licence expire? 1 July 2026 is the hard backstop. Existing FIU-licensed VASPs may operate until that date but must file a fresh CASP application with the FSA. There is no automatic conversion. ### What capital does an Estonian CASP need? Paid-up share capital of EUR 100,000 to EUR 250,000 depending on MiCA class, consistent with Annex IV of MiCA (EUR 50k Class 1, EUR 125k Class 2, EUR 150k Class 3; Estonia aligns with these floors and requires the full paid-up amount in a local account). ### Is FSA supervision different from the old FIU supervision? Yes. The FIU VASP regime was AML-only. The FSA CASP regime covers governance, safeguarding, capital, complaints, outsourcing, ICT, conduct and market abuse - full financial supervision. ### How long does Estonian CASP authorisation take? 6 to 10 months for a well-prepared file. Statutory 25 working days for completeness plus 40 working days for decision (extendable by 20), plus pre-application and conditions-precedent periods. ### How does Crassula help? Crassula provides the MiCA-ready white-label core: custody with MPC or multi-sig, matching or RFQ engine, KYC and Travel Rule, market-abuse surveillance, DORA-aligned ICT and FSA-ready reporting. ## Create a digital bank in a matter of days [Request demo](https://crassula.io/request-demo/) ![Companies using Crassula](https://crassula.io/static/images/home/cta/logos.d2974e5bd7da.png) **150+** companies already with us