Luxembourg
Overview
The Commission de Surveillance du Secteur Financier (CSSF) authorises and supervises CASPs in Luxembourg. The national Law of 6 February 2025 implements MiCA, repeals the old VASP registration route and sets the transitional measures. Existing VASPs registered before 30 December 2024 could continue until 1 July 2026 or until their CASP application was granted or refused, whichever came first.
Luxembourg is built for institutional and cross-border financial groups: funds, custody, tokenisation and bank-linked structures. The CSSF review is documentation-heavy, with a strong focus on governance, outsourcing and operational substance.
Regulatory framework
MiCA (Regulation (EU) 2023/1114) is directly applicable, supported by the Law of 6 February 2025. The CSSF is the CASP authorisation and supervisory authority; the VASP registration route is closed to new applicants. Financial instruments remain in the MiFID II perimeter.
Certain financial entities can use the Article 60 notification route. Third-country firms can use the Article 60 own-initiative route only where the client approaches them; reverse solicitation is narrow. A Luxembourg authorisation passports across the EEA after the Article 62 notification.
Licensing & authorisation
Route and clock. Apply to the CSSF (MiCA Arts 62–63). The authority acknowledges within 5 working days, assesses completeness within 25 working days and decides within 40 working days of a complete file; the clock stops for information requests. The statutory clock measures review of a complete file, not incorporation and preparation; market practice commonly runs 6–12 months end to end.
Charges. CSSF fees are set under its general fee framework. At the 24 October 2026 check we found no flat CASP application tariff; confirm the current fee basis with the CSSF before filing.
Own funds. MiCA Art 67 and Annex IV set the minimum at €50,000 (Class 1), €125,000 (Class 2) or €150,000 (Class 3), plus one quarter of the previous year’s fixed overheads, held continuously. The class follows the services authorised.
Substance and passport. MiCA Art 59 requires the registered office and head office in Luxembourg. Plan for a Luxembourg company (commonly an SA or SARL), local-resident management, a local AML officer and outsourcing/ICT arrangements that meet CSSF and DORA expectations. Once authorised, notify under Art 62 to passport into the EEA.
AML & Travel Rule
The EU Transfer of Funds Regulation (TFR, (EU) 2023/1113) has applied since 30 December 2024. CASP-to-CASP transfers must carry originator and beneficiary information from the first euro; transfers to or from self-hosted wallets above €1,000 require verification of the counterparty.
The CSSF supervises AML/CFT; the Cellule de Renseignement Financier (CRF) receives suspicious transaction reports. DORA has applied since 17 January 2025, and the EU AML Regulation (AMLR) applies from 10 July 2027.
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