CASP (Crypto-Asset Service Provider)

CASP (Crypto-Asset Service Provider) is a legal person or other undertaking whose business is providing one or more crypto-asset services under the EU Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114). Since MiCA's transitional period ended on 1 July 2026, any firm serving EU clients with those services needs CASP authorisation from a national competent authority, and the authorisation names each permitted service, such as custody, exchange or advice. Article 67 sets minimum capital of €50,000, €125,000 or €150,000 by service class, or a quarter of fixed overheads if higher. One authorisation covers the whole EU. Acquiring a qualifying holding requires prior notification, and the authority has 60 working days to assess the buyer.

21 November 20252 min read

CASP (Crypto-Asset Service Provider) is a legal person or other undertaking whose business is providing one or more crypto-asset services under the EU Markets in Crypto-Assets Regulation (MiCA, Regulation (EU) 2023/1114). Since MiCA's transitional period ended on 1 July 2026, any firm serving EU clients with those services needs CASP authorisation from a national competent authority, and the authorisation names each permitted service, such as custody, exchange or advice. Article 67 sets minimum capital of €50,000, €125,000 or €150,000 by service class, or a quarter of fixed overheads if higher. One authorisation covers the whole EU. Acquiring a qualifying holding requires prior notification, and the authority has 60 working days to assess the buyer.

What services need CASP authorisation

MiCA lists the services: custody and administration of crypto-assets for clients, operating a trading platform, exchanging crypto-assets for funds, exchanging crypto-assets for other crypto-assets, executing orders, placing, reception and transmission of orders, advice, portfolio management, and transfer services. The authorisation names the specific services a firm may provide, so a licence for advice and order transmission does not cover custody.

CASP vs VASP

VASP is the FATF term, added to its glossary in October 2018 and used by national AML registration regimes. CASP is the MiCA term. The activities overlap heavily, but most pre-MiCA VASP regimes were AML registrations, while CASP authorisation is a full licence with capital, governance, conduct and safeguarding rules. A CASP authorised in one member state can serve clients across the EU on that home authorisation; non-EU firms may not serve EU clients except under reverse solicitation.

What are CASP capital requirements

Article 67 requires a CASP to hold the higher of two amounts: the permanent minimum capital for its service class, or one quarter of the previous year's fixed overheads, reviewed annually. The minimums are €50,000 for class 1 (order execution, placing, transfer, reception and transmission of orders, advice, portfolio management), €125,000 for class 2 (adds custody, and exchange for funds or other crypto-assets) and €150,000 for class 3 (adds operating a trading platform). The requirement can be met with Common Equity Tier 1 own funds, an insurance policy or comparable guarantee, or a mix.

Illustrative example: a class 2 exchange-and-custody CASP with €2.4 million of fixed overheads last year must hold €600,000, not €125,000, because a quarter of its overheads exceeds the class minimum. Doubling headcount after an acquisition raises the requirement for the following year.

Client funds other than e-money tokens must be placed with a credit institution or central bank by the end of the business day after receipt, in an account separately identifiable from the CASP's own (Article 70).

How the end of the transitional period changed the market

ESMA asked unauthorised firms to have operational wind-down plans and to transfer client assets before 1 July 2026, and tells consumers to check providers against its Interim MiCA Register. Firms that missed the date can no longer trade on a national registration, so an authorised CASP is now the only legal route into the EU market, applied for or bought.

Buying a CASP

Under Article 83, anyone proposing to acquire a qualifying holding in a CASP, or to increase it so it reaches or exceeds 20%, 30% or 50% of voting rights or capital, or so the CASP becomes its subsidiary, must notify the competent authority in writing first. The authority has 60 working days from acknowledging receipt to assess the acquirer. Due diligence should check which services the authorisation covers, whether capital still passes the overheads test under the buyer's plan, and how client assets are segregated on the DLT side.

See also: Crypto & Virtual Assets.

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