VASP Registration in Estonia: Updated 2026 Guide (Now CASP Under MiCA)
Estonia's legacy VASP licences end 1 July 2026, replaced by MiCA CASP authorisation from Finantsinspektsioon, no auto-conversion. See capital and substance.
VASP registration in Estonia no longer works the way it did. A legacy Estonian VASP authorisation was a national licence granted under the Money Laundering and Terrorist Financing Prevention Act and supervised by the Financial Intelligence Unit. On 1 July 2026 that authorisation ceased to be valid: the crypto-asset service it covered now requires a MiCA CASP authorisation from Finantsinspektsioon.
If you searched for an Estonian VASP licence, you are really searching for what replaces it. This guide explains the sunset, the successor CASP regime under the EU Markets in Crypto-Assets Regulation, the capital classes, the substance and compliance rules, and the migration path from a closed legacy licence to a passportable EU authorisation. We separate the two regimes carefully, because blending them is where most outdated guidance goes wrong.
Is an Estonian VASP licence still valid in 2026?
A legacy Estonian VASP authorisation was valid only until 1 July 2026. It has ceased to be valid, and crypto-asset services in or from Estonia require either a Finantsinspektsioon MiCA CASP authorisation or an equivalent EU CASP authorisation passported into Estonia. There is no automatic conversion of the old licence.
This is the answer that matters most for any founder or compliance officer auditing an Estonian structure in 2026. The window comes from MiCA itself, then was confirmed for Estonia by the national regulator.
The short answer: legacy VASP cover ended 1 July 2026
MiCA's CASP rules in Title V applied from 30 December 2024, and Article 143(3) gave providers who lawfully operated under national law before that date a transitional, grandfathering window. The maximum transitional period was 18 months, running to 1 July 2026, or until the firm's MiCA authorisation was granted or refused, whichever came first (MiCA Art. 143(3)). Member States were allowed to shorten that window or not apply it at all, and Estonia took the full backstop date as a hard cut-off.
What you must hold instead from 1 July 2026
On 23 March 2026 Finantsinspektsioon confirmed that the transition would end in summer 2026, and that after 1 July 2026 only firms holding a Finantsinspektsioon MiCA authorisation, or an equivalent EU CASP authorisation obtained elsewhere and passported in, may lawfully provide crypto-asset services in or from Estonia (Finantsinspektsioon statement). A legacy VASP holder must apply afresh. Nothing migrates by default.
What replaced the VASP licence: CASP authorisation under MiCA
The successor to the Estonian VASP licence is the Crypto-Asset Service Provider authorisation under MiCA, Regulation (EU) 2023/1114. It is an EU-harmonised, prudential authorisation rather than a national, AML-only registration, and its operating rules have applied across the Union since 30 December 2024 (MiCA Title V).
The shift is not cosmetic. A national VASP licence was bounded by Estonian law and Estonian supervision. A CASP authorisation is recognised across the EU and EEA, comes with capital, governance, and prudential obligations defined at EU level, and is the only forward-looking route for a crypto business in Estonia.
Why MiCA superseded the national MLTFPA regime
Before MiCA, Estonia authorised virtual asset service providers under the national Money Laundering and Terrorist Financing Prevention Act (MLTFPA), with the Financial Intelligence Unit acting as the AML supervisor. That framework treated crypto licensing primarily as an anti-money-laundering matter. MiCA replaces this patchwork of national regimes with a single, prudential authorisation standard so that one set of rules governs CASPs everywhere in the EU, closing the regulatory arbitrage that the older national licences created.
What a CASP authorisation lets you do (service scope)
A MiCA CASP authorisation can cover custody and administration of crypto-assets, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, operation of a trading platform, execution of orders, placing of crypto-assets, transfer services, reception and transmission of orders, advice on crypto-assets, and portfolio management on crypto-assets (MiCA Annex IV). Which of these you can offer determines your capital class, covered in the capital section below.
Who regulates crypto in Estonia now: Finantsinspektsioon vs the FIU
The single most common confusion in outdated Estonian guidance is the regulator. Authorisation today is granted by Finantsinspektsioon under MiCA. The Financial Intelligence Unit historically handled AML supervision under the MLTFPA, but the licensing authority is now the Financial Supervision Authority, not the FIU (Finantsinspektsioon). Some older pages even named an ambiguous "Estonian Financial Supervision Authority (FSA)" and quoted a "120 business days" review figure; the correct authority is Finantsinspektsioon, and the legacy day-count should not be relied on for the MiCA process.
Finantsinspektsioon: the live licensing authority
Finantsinspektsioon is Estonia's prudential financial regulator. Under MiCA it is the competent authority that receives, assesses, and decides CASP authorisation applications, and it supervises authorised CASPs on an ongoing prudential basis (MiCA Title V). A 2026 application goes to Finantsinspektsioon, governed by the EU rules, not to the FIU under the national act.
The FIU/MLTFPA legacy AML role (closed)
The FIU (Rahapesu Andmebüroo) supervised legacy VASPs for AML and counter-terrorist-financing compliance under the MLTFPA. That was the licensing and oversight door for the national VASP regime (Financial Intelligence Unit). With the legacy authorisations ceasing on 1 July 2026, that route has closed.
How much capital do you need for an Estonian CASP? (MiCA Annex IV)
Capital for an Estonian CASP is set by MiCA Annex IV, which fixes a permanent minimum by service class, and by Article 67, which adds an ongoing own-funds test. The minimum is EUR 50,000 for Class 1, EUR 125,000 for Class 2, and EUR 150,000 for Class 3 (MiCA Annex IV). These are the figures that govern a 2026 application; the old MLTFPA numbers no longer apply.
Capital by CASP class (Class 1 / 2 / 3)
| CASP class | Permanent minimum capital | Indicative service scope |
|---|---|---|
| Class 1 | EUR 50,000 | Execution of orders; placing; transfer services; reception and transmission of orders; advice; portfolio management |
| Class 2 | EUR 125,000 | All Class 1 services plus custody and administration; exchange crypto-for-funds; exchange crypto-for-crypto |
| Class 3 | EUR 150,000 | All Class 2 services plus operation of a trading platform |
The class is driven by the broadest service you intend to provide, so a firm running an exchange or a trading platform lands in the higher classes (MiCA Annex IV).
The Article 67 own-funds and fixed-overheads test
The permanent minimum is a floor, not the whole requirement. Under Article 67 a CASP must hold own funds at all times equal to the higher of (a) the Annex IV permanent minimum capital for its class, or (b) one quarter of the preceding year's fixed overheads, reviewed annually. Eligible safeguards are own funds in the form of Common Equity Tier 1 capital under Regulation (EU) 575/2013 and/or a qualifying insurance policy (MiCA Art. 67). A larger operation may therefore need to hold more than the headline class minimum.
Legacy MLTFPA figures (EUR 100,000 / 250,000) no longer apply
Older Estonian guidance cites EUR 100,000 of share capital for standard virtual-currency services and EUR 250,000 for transfer services. These are legacy national MLTFPA thresholds, not MiCA figures (2022 MLTFPA amendments). They expired with the regime that created them and should never be presented as the requirement for a new 2026 authorisation. For any forward-looking plan, the MiCA Annex IV figures of EUR 50,000 / 125,000 / 150,000 are the governing numbers.
Substance, fit-and-proper and compliance requirements
A CASP authorisation is not a paper exercise. Finantsinspektsioon expects genuine local substance, a clean and competent management body, a full AML and KYC stack, and operational resilience. These requirements draw on MiCA and, on the AML side, on the obligations carried over from the legacy framework (MiCA Title V).
Local substance and EU effective management
MiCA requires effective management from within the EU, meaning a place of effective management in the Union, at least one director resident in the Union and a registered office in a Member State where it carries out at least part of its services (Article 59(2)). The legacy Estonian regime had already required local management and an Estonian registered office as a reaction to past letterbox abuse (2022 MLTFPA amendments).
AML/CFT, KYC and ongoing monitoring
A CASP must operate mandatory AML/CFT, KYC, transaction-monitoring, and suspicious-activity-reporting frameworks. The management body and qualifying shareholders must pass good-repute and suitability, the fit-and-proper tests, including criminal-record checks (Finantsinspektsioon). These controls are assessed at authorisation and supervised on an ongoing basis, so they need to be real and operational, not just documented.
DORA, ICT resilience and audited accounts
A CASP must align its ICT systems with the Digital Operational Resilience Act (DORA), maintaining operational and cyber resilience. Annual audited financial statements were required under the legacy Estonian regime, and MiCA CASPs face ongoing prudential and reporting obligations (MiCA).
How to apply: from OÜ incorporation to Finantsinspektsioon authorisation
The application path runs from incorporating an Estonian company through building a compliant operation to filing with Finantsinspektsioon under the ESMA technical standards. The package is governed by Commission Delegated Regulation (EU) 2025/305, the ESMA regulatory technical standards on CASP authorisation (Delegated Regulation (EU) 2025/305). Below is the route in six steps.
Step 1-2: Incorporate the OÜ and build the compliance stack
First, incorporate an Estonian entity, typically an OÜ (private limited company), with a registered office and genuine local substance. Then build the compliance stack: AML/CFT policies, KYC procedures, risk management, governance arrangements, DORA-aligned ICT resilience, and a business plan with financial forecasts (MiCA Title V). This stage determines whether the later assessment goes smoothly.
Step 3-4: Appoint management and file with Finantsinspektsioon
Next, appoint local management and a compliance officer who can evidence good repute and a clean criminal record. Then file the MiCA CASP authorisation application with Finantsinspektsioon, not the FIU, structured to the ESMA RTS in Regulation (EU) 2025/305 (Delegated Regulation (EU) 2025/305). The legacy FIU route closed on 1 July 2026.
Step 5-6: Completeness, substance assessment, ESMA register and passporting
Finantsinspektsioon first checks the application for completeness, then assesses substance against the MiCA standards. Once authorised, the CASP is entered in the ESMA register of CASPs, and the authorisation can be passported across the EU and EEA (MiCA Title V). Under Article 63, completeness is checked within 25 working days of receipt and the decision follows within 40 working days of a complete application, with the clock paused for up to 20 working days while information is requested.
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How long does authorisation take, and what is the deadline?
There is one fixed date and one variable. The fixed date was the 1 July 2026 backstop, when legacy VASP cover ended. The variable is how long Finantsinspektsioon takes to grant a CASP authorisation, which depends on the completeness of your application and the volume of regulator queries, not on a single advertised figure (MiCA Title V).
The hard backstop: 1 July 2026
Since 1 July 2026, legacy Estonian VASP authorisations are no longer valid, and only a Finantsinspektsioon MiCA authorisation or an equivalent passported EU CASP authorisation permits lawful crypto-asset services in or from Estonia (MiCA Art. 143(3)).
Why a single timeframe figure is misleading
You will see "6 to 8 months" quoted in older guidance, and Article 63 sets statutory time limits. Both are easy to misread. Real elapsed time is driven by application completeness and the back-and-forth of regulator queries, so a single headline figure can mislead more than it helps (MiCA Title V). Plan around the quality of your submission.
Migrating from a legacy VASP licence to a CASP authorisation
If you already hold a legacy Estonian VASP licence, the central fact is that it does not roll over. There is no automatic conversion: an existing VASP holder must submit a fresh CASP application to Finantsinspektsioon, and the legacy authorisation expired on 1 July 2026 regardless of where that application stood (Financial Intelligence Unit statement). The transitional window ran from the 30 December 2024 MiCA start to the 1 July 2026 cut-off (MiCA Art. 143(3)).
No automatic conversion: what an existing VASP holder must do
A legacy holder should treat migration as a fresh authorisation project: re-paper the compliance stack to MiCA standards, confirm capital against Annex IV and Article 67, evidence EU effective management, and file with Finantsinspektsioon under the ESMA RTS (Financial Intelligence Unit statement). A firm whose application is still pending must cease or limit its activities until Finantsinspektsioon decides.
Equivalent EU authorisation and passporting as an alternative route
Estonia is not the only path to operating there. A CASP authorisation granted by another EU or EEA competent authority can be passported into Estonia, and that is an equally lawful basis for serving Estonian clients after the sunset (passporting). For groups already authorised elsewhere in the EU, passporting may be faster than a fresh Estonian application.
A note on fees and outdated cost figures
Outdated Estonian guidance often quotes a "EUR 10,000 application fee". That was the state fee for an FIU virtual currency licence, repealed from 30 December 2024; the processing fee Finantsinspektsioon publishes for a MiCA authorisation application is EUR 3,000 (Finantsinspektsioon).
Why the old "EUR 10,000 fee" no longer applies
Because the legacy regime is retired, its fee schedule does not carry into the MiCA process. Finantsinspektsioon charges a processing fee of EUR 3,000 on an application for authorisation as a crypto-asset service provider, which is the figure to budget for the application itself.
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Limitations and scope
This page covers the transition from Estonia's legacy VASP licence to MiCA CASP authorisation, the Annex IV capital classes, and the Finantsinspektsioon application route. It does not cover the CASP process in other Member States; for comparison, see Lithuania's CASP transition.
- The EUR 10,000 application fee quoted in older guidance was the repealed FIU licence state fee, not a Finantsinspektsioon cost.
- Real elapsed time depends on application quality and regulator queries, not only on the Article 63 statutory day-counts.
Frequently asked questions
Is the old Estonian VASP licence still valid in 2026?
No. Legacy Estonian VASP authorisations ceased to be valid on 1 July 2026. Since then you must hold a Finantsinspektsioon MiCA CASP authorisation, or an equivalent EU CASP authorisation passported into Estonia, to lawfully provide crypto-asset services in or from the country.
What replaced the VASP licence in Estonia?
The CASP authorisation under MiCA, Regulation (EU) 2023/1114, issued by Finantsinspektsioon, replaces the national VASP licence. It is an EU-harmonised, prudential authorisation rather than a national AML-only registration, and its operating rules have applied across the Union since 30 December 2024.
Who regulates crypto in Estonia now, the FIU or Finantsinspektsioon?
Authorisation is now granted by Finantsinspektsioon under MiCA. AML supervision was historically handled by the Financial Intelligence Unit (Rahapesu Andmebüroo) under the national MLTFPA, but the licensing authority for a 2026 crypto application is the Financial Supervision Authority, not the FIU.
How much capital do I need for a CASP in Estonia?
MiCA Annex IV sets EUR 50,000, 125,000 or 150,000 depending on the CASP class, plus the Article 67 own-funds test. Under that test you must hold the higher of the Annex IV minimum for your class or one quarter of the preceding year's fixed overheads, reviewed annually.
Which services fall in Class 1, Class 2 and Class 3?
Class 1 covers execution, placing, transfer, reception and transmission of orders, advice and portfolio management. Class 2 adds custody and administration plus the two exchange services. Class 3 adds operating a trading platform. The broadest service you offer sets your class and minimum capital.
Does my old VASP licence convert automatically to a CASP authorisation?
No. There is no automatic conversion. An existing VASP holder must submit a fresh CASP application to Finantsinspektsioon, and the legacy authorisation expired on 1 July 2026 regardless of how far the new application had progressed; a firm still waiting for its decision must cease or limit its activities until the decision is made.
Can a non-EU founder still get an Estonian crypto authorisation?
Yes, but the company must be Estonian-incorporated with EU and local substance and effective management, including a registered office in Estonia and EU-based management. MiCA requires a place of effective management in a Member State and at least one EU-resident director.
Can an Estonian CASP authorisation be used across the EU?
Yes. A MiCA CASP authorisation can be passported across the EU and EEA, so one Estonian authorisation lets you serve clients in other Member States. Equally, a CASP authorisation granted in another EU state can be passported into Estonia after the legacy sunset.
What was the difference between the old EUR 100,000 / 250,000 capital and the new figures?
The EUR 100,000 and 250,000 figures were legacy MLTFPA national thresholds, EUR 100,000 for standard virtual-currency services and EUR 250,000 for transfer services, and they no longer apply. The governing MiCA Annex IV figures are now EUR 50,000, 125,000 and 150,000 by class.
What was the deadline to be MiCA-compliant in Estonia?
1 July 2026 was the hard backstop ending the transitional period. Since then, only a Finantsinspektsioon MiCA CASP authorisation, or an equivalent passported EU authorisation, is lawful for crypto-asset services in or from Estonia. Legacy VASP authorisations ceased to be valid on that date.
What services are covered by a MiCA CASP authorisation?
Custody and administration, exchange of crypto for funds and crypto for crypto, operation of a trading platform, execution of orders, placing, transfer services, reception and transmission of orders, advice on crypto-assets and portfolio management. The combination you offer determines your Annex IV capital class.
Do I still need a local office and resident compliance officer?
A registered office in Estonia and EU effective management, meaning a place of effective management plus an EU-based director, are required. MiCA Article 59(2) requires at least one director resident in the Union; it sets no residence rule for the compliance officer.