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.
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.
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Request demoWhat 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). 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
- 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.
- Incorporation. Register Estonian OÜ, open a capital account, pay in EUR 100k to 250k depending on class.
- File preparation (3 to 5 months). Programme of operations, business plan, governance, AML/CFT, ICT/DORA, outsourcing, safeguarding, fit-and-proper.
- Submission and completeness check. 25 working days per MiCA Article 62.
- Substantive assessment. 40 working days statutory, extendable by 20. Real-world 4 to 8 months.
- Conditions precedent. Capital paid up, safeguarding live, AML and Travel Rule operational.
- 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 for the full regulatory context.
FAQ
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.
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.
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).
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.
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.
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.
