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The European Markets in Crypto-Assets regulation, or MiCA law, which took full effect at the end of 2024, now requires that all crypto firms, classified as crypto asset service providers (CASPs) operating within the EU, need an authorization.
Firms without a proper CASP license can no longer serve across Europe, regardless of their home base, if it is outside the 27 EU member states. In practice, this means exchanges, custodians, and brokers must obtain prior approval if they want to retain access to this highly lucrative market.
Hoping to still accept customers from the EU through the “reverse solicitation” principle – registering a crypto business abroad and accepting clients who approach voluntarily – is no longer a viable strategy. Regulators are gradually tightening this loophole; obtaining a valid CASP license to ensure uninterrupted operations is of importance for crypto companies targeting Europe.
Reverse Solicitation Door Is Getting Closed: Who Needs a CASP License?
The reverse solicitation doctrine had previously allowed crypto firms outside the EU to service clients in the EU, as long as those clients contacted them directly. Yet, in February 2025, ESMA issued its final guidance, effective from April 2025, that has significantly limited this route.
ESMA’s guidelines broadly define what counts as “soliciting” clients, including online advertising, representatives, affiliates, sponsorships, and even simple “education materials.” The restrictions would mean European crypto exchanges, brokers, and other firms without the MiCA license could no longer rely on this exemption to solicit EU customers.
National regulators like AMF of France, FMA of Austria, and Consob of Italy have gone further in calling for restrictions on reverse solicitation “as far as possible,” mandating EU or equivalent trading venues, and increasing direct oversight by ESMA. Namely, France threatened legal action over supposedly lighter “passporting” procedures in other EU member states, mandating more rigid and harmonized regulation of crypto assets across Europe.
“Under MiCA, this approach is no longer a reliable workaround: reverse solicitation is strictly limited, and most crypto-asset service providers must now obtain authorisation within the EU to serve its market. As a result, MiCA compliance has become essential for any business wishing to work with clients in the EU market,” said Elena Sadovskaya, Managing Partner of Inteliumlaw, in the interview with TechBullion.
For companies seeking to operate legally in the EU, obtaining a CASP license has become the only long-term option. Whether issuing a stablecoin, conducting crypto broker activities, or any other type of crypto business in Europe, full licensure under MiCA is imperative. In other words, reverse solicitation is expected to become a thing of the past in the near future; compliance via appropriate licensing is the only feasible path going forward for the European digital asset ecosystem.
European Crypto Market: Immense Potential for Crypto Companies
A crypto license in one of the EU member states is absolutely worth getting for serious crypto businesses – and the figures confirm this statement well. Here are the key reasons to obtain a MiCA crypto license:
- European Market Access. A CASP license equals access to all 27 EU countries thanks to a harmonized MiCA regulation. In 2024, the European cryptocurrency market crossed the $7 billion mark in size and is expected to reach $22.87 billion by the end of 2033, growing at a CAGR of 13.94% and offering an unparalleled opportunity.
- Low Crypto Ownership Rate: Although the global crypto ownership rate sits at a 6.9% average, the average ownership rate in Europe is 9%, which means the European residents are more willing to invest in crypto.
- Progressive Legislation: Europe leads in VASP crypto licensing globally, with 2,747 registrations against 2,521 in North America, partly since the region’s MiCA encourages innovative projects such as the digital euro and property tokenization with clear and transparent legislation.
- Developed Economy and High GDP: With a strong GDP, good spending potential, and a Gen Z population keen on digital assets, the European crypto market appears to be one of the most attractive for international scaling.
- Highly Reputable Banking: Having a crypto license in Europe opens up the path to prestigious financial institutions and organizational funds while minimizing “debanking” risks.
Most significantly, however, the crypto market in Europe could become largely underserved as soon as grandfathering periods end across all member states. According to CoinCub, 75% of the current EU VASPs could lose compliance status post-grandfathering, while less than 100 crypto licenses have been granted so far. For those looking to obtain a MiCA license and enter the European market, there is no greater opportunity than now.
Source: Market Data Forecast
Requirements to Get a CASP License to Operate Across the EU
Obtaining a crypto license in Lithuania, Bulgaria, Poland, the Czech Republic, Cyprus, or another EU country within the new licensing structure of MiCA is important if a business aims to operate legally throughout Europe. Although certain specific requirements vary between member states, generally, many of the wider standards stay the same across Europe.
- Capital Requirements: The minimum capital requirement to get the EU crypto license under Annex IV of MiCA ranges from €50,000 to €150,000, based on the type of activity. When annual fixed costs exceed these thresholds, 25% of this amount must be reserved as paid share capital.
- Organizational Requirements: Crypto firms applying to get a CASP license must have a home base within the EU, at least one European resident board member, an appointed CCO and MLRO, and adequate AML/CFT policies for successfully getting a MiCA authorization.
- Official Submissions: A two-year business plan, AML/KYC procedures, backup strategies, and a mechanism for handling complaints are essential for submission to get a CASP license.
- Key Personnel Requirements. CASPs are expected to demonstrate a strong reputation and adequate expertise, transparent and resilient operations, consistent compliance with regulatory requirements, appropriate data protection controls, and accurate maintenance of required documentation for effective supervision.
- Consumer Protection: MiCAR obliges firms to establish security baselines, including access controls, encryption, and regular independent audits.
Despite higher compliance requirements and rising costs, securing a European crypto license still pays off 10 times in the long term, offering substantial potential that far exceeds the initial investment.
Step-by-Step Guide to Get a CASP License in Europe
A common misconception is that moving from a VASP license to a CASP license is optional rather than mandatory. Quite contrary, however, the fact of non-compliance with MiCA can lead to multiple severe risks.
Below is a summary of the key risks of ignoring the grandfathering period to obtain the MiCA license:
- Immediate suspension of crypto-related activity in the EU. Ignoring MiCA’s grandfathering period can lead to an immediate EU-wide halt of crypto services, forcing one to suspend all crypto-related activity until properly authorized.
- Administrative fines. In cases of significant non-compliance, regulators can impose fines of up to €5 million or 12.5% of annual turnover.
- Debanking. Once suspended from operating across all 27 EU member states, a crypto firm may be delisted from licensed trading venues and lose access to banking, payment gateways, and fiat on/off-ramps.
- Reputation damage. Over time, disclosure in regulatory registers may trigger lasting reputational harm and increased friction in subsequent licensing applications.
In turn, however, with guidance from a specialized firm such as Inteliumlaw, a CASP license can be secured smoothly through a few simple steps:
- Choose the Jurisdiction. Select a jurisdiction among EU members, determine the business activity, and choose between the company types to determine the CASP license type to apply for.
- Preparation of Documents. Prepare all corporate documents, AML/CFT policies and processes, KYC mechanisms, and a business plan.
- Submit Application: The MiCA license application will be lodged with the national competent authority (NCA). The relevant body will then take time to review the application, which may take from a couple of weeks to over half a year, depending on the complexity and the regulator.
- Maintain Compliance: Once the crypto license is granted, a business can start offering services across Europe yet needs to ensure lasting compliance with all MiCA requirements, including reporting.
How Inteliumlaw Can Assist with Getting a CASP License
A MiCA license offers broad access across the EU, but obtaining it requires substantial preparation and careful execution; obtaining a crypto license in Europe is going to be quite a complex procedure. When it comes to securing a CASP license, this process can be made much more efficient with the help of qualified advisors like Inteliumlaw, who help crypto firms translate MiCA requirements into practical steps and enter the EU market smoothly and compliantly.
Contact Inteliumlaw now to obtain your MiCA license and enter the EU market on a solid legal footing.
