What a Cyprus CASP licence actually means.

MiCA is one rulebook, but the decision is never “get authorised or not” — it is where. This guide translates the Cyprus (CySEC) position into the four things a founder or board actually asks: what it takes to operate, what it costs, what it gives you competitively, and what keeps the licence alive. The law is identical across the Union; the cost, the clock and the supervisory texture are not.

PRIMARY SOURCES: MICA (EUR-LEX) ↗ · CYSEC AUTHORISED CASP REGISTER ↗ · MICA RADAR · FEE INSTRUMENT: CYSEC DIRECTIVE DI 73-2009-04 (CHARGES AND FEES, 2024) · LAST CHECKED 24 OCT 2026

1 · What it takes to operate

The legal standard is MiCA Title V: the home Member State — here Cyprus, through CySEC — authorises per service, and the licence names exactly which of the ten crypto-asset services the firm may provide (Art. 59–63). What this means in practice for a Cyprus filing:

RequirementPosition
Registered office & substanceRegistered office in Cyprus, effective management in the Union, and at least one director resident in the Union (Art. 59(2)). CySEC expects operational substance — a real office and management in the day-to-day, not a letterbox. Substance expectations are set in guidance, not by a published checklist; confirm with counsel on the current position.
Own fundsThe higher of the Annex IV class minimum (€50,000 class 1; €125,000 class 2; €150,000 class 3) or one quarter of the preceding year’s fixed overheads, held continuously (Art. 67). Article 67(4) allows qualifying insurance or a comparable guarantee to substitute for part of the requirement.
Governance & fit-and-properManagement and qualifying shareholders must meet fit-and-proper expectations; the application covers governance, conflicts of interest, complaints handling, custody and safeguarding policy, ICT and security arrangements aligned with DORA, and AML/CTF arrangements (Art. 62).
Client assetsSafeguarding duties and segregation of client crypto-assets, with custody policy and, where relevant, cold-storage expectations forming part of the file and of supervision.
Reporting infrastructureA CASP must be able to produce the evidence supervision asks for: transaction reporting hooks, audited financials that show crypto turnover separately, and the operational data behind the annual fee computation.

The clock (Art. 62–63): CySEC acknowledges receipt within 5 working days, assesses completeness within 25 working days, and decides within 40 working days of a complete file — the clock stops while answers are awaited. Statutory time is a floor, not a promise: a well-prepared Cypriot application is commonly reported at four to six months end-to-end, and the observed range depends on how complete the file is on first submission. We do not publish a single “typical” number because CySEC publishes no completion statistics; treat claims of guaranteed speed with caution.

Financial entities (Art. 60): a credit institution, investment firm, e-money institution or other listed financial entity already authorised in Cyprus can notify instead of applying afresh — a separate route with its own fee and a 40-working-day advance-notice period, keeping its existing own-funds regime rather than taking a MiCA one.

2 · What it costs

Cyprus is the only EU jurisdiction whose entire CASP charge schedule is fixed by an official instrument — CySEC Directive DI 73-2009-04 (Markets in Crypto-Assets, Charges and Fees, 2024) — with a separate row for each service. The application charge and the annual fee add up per service, so the licence scope decides the price. Figures below are from the directive as published; verify the current instrument before relying on them.

MiCA serviceApplication chargeAnnual fee (fixed)
Custody and administration (A)€10,000€10,000
Operating a trading platform (B)€30,000€20,000
Exchange — crypto for funds (C)€5,000€5,000
Exchange — crypto for crypto (D)€5,000€5,000
Execution of orders (E)€8,000€5,000
Placing (F)€8,000€5,000
Reception & transmission (G)€8,000€5,000
Advice (H)€8,000€8,000
Portfolio management (I)€8,000€8,000
Transfer services (J)€5,000€5,000

Turnover surcharge: on top of the annual fixed component, once crypto-service turnover exceeds €500,000: 1% from €500k to €1m; 0.4% from €1m to €5m; 0.3% from €5m to €10m; 0.1% above €10m — total annual fee capped at €500,000, payable within four months of the financial year-end (two months where operations cease), pro-rated for a part-year, and computed from audited statements that show crypto turnover separately. An Article 60 notification carries its own one-off charge of €10,000.

Two details that matter: an unpaid application charge means the application is treated as not submitted — the clock never starts; and the statutory fee is not the full cost. Budget realistically for professional work — legal and compliance advice, the AML programme, audit and reporting setup — which is not fixed by any regulator and is quoted per engagement. This page does not publish estimates for those because they are market prices, not rules; get them in writing before committing.

3 · What it gives you competitively

One authorisation, the whole Union (Art. 65): once authorised in Cyprus, a CASP notifies the Member States where it intends to provide services; cross-border provision may begin after the file is communicated, at the latest 15 calendar days after submitting the notification. A Cypriot licence passports to the EEA, and the passported countries appear in the register data.

Cyprus’ position in the field: Cyprus chose the full 18-month transitional window under Art. 143(3), and CySEC moved the legacy national-register firms onto MiCA authorisation (with a 27 February 2026 filing deadline for existing national-register CASPs). The live CySEC register and the MiCA Radar show the resulting field and its authorisation dates — check both, because the register changes weekly.

Tax framing is separate: the licence itself carries no tax advantage — a Cypriot CASP is an ordinary Cyprus company and faces the normal corporate tax and reporting regime. Treating “licence plus tax structure” as one decision is where jurisdictions get compared on something other than MiCA fees; that comparison belongs in a jurisdiction analysis, not in this guide.

The honest caveat: passporting is in the statute; the commercial reality of serving clients in another Member State includes local AML expectations, marketing rules and the possibility of host-state attention (Art. 65–66). A licence is market access, not market.

4 · What keeps the licence alive

Authorisation is a standing obligation, not an event. The continuing compliance load for a Cyprus CASP, from the fee instrument and MiCA:

ObligationDetail
Annual feeFixed per service plus turnover surcharge, payable within four months of each financial year-end; audited financials must show crypto turnover separately.
Continuous own fundsThe higher of class minimum or ¼ fixed overheads, at all times — not just at authorisation.
Ongoing governanceFit-and-proper is a standing condition; changes to management or qualifying shareholders notify the NCA rather than being a one-off.
DORA & ICTIncident reporting, resilience testing, third-party risk and, as relevant, information sharing apply to CASPs as financial entities under Regulation (EU) 2022/2554.
AML/CFT & travel ruleAML controls and the originator/beneficiary information duties of Regulation (EU) 2023/1113 apply with no de-minimis threshold — see the Travel Rule guide.
Supervision expectationsCySEC supervises CASPs with the same toolkit it applies to investment firms; enforcement and thematic attention are visible in its circulars (— see the CySEC circular library).

The transitional footnote: the Art. 143(3) grandfathering window closed on 1 July 2026. A national-registration-era firm without a MiCA authorisation (or an accepted Art. 60 route) has no grandfathered right to keep operating — a pending application is not permission. ESMA separately lists non-compliant entities reported by NCAs; the Radar reproduces that list with its source date.

Educational summary of public sources. Last checked 24 October 2026. This guide condenses the text of Regulation (EU) 2023/1114 (MiCA), Regulation (EU) 2023/1113 (TFR), Regulation (EU) 2022/2554 (DORA) and CySEC Directive DI 73-2009-04 (Charges and Fees, 2024) for general information. Fee figures are as published in the directive; verify the current instrument before relying on any amount. It is not legal advice; obligations depend on your specific facts. Verify against the official sources linked above before relying on any point.