Starting in 2025, the cryptocurrency market in the Czech Republic will enter a phase of significant transformation. The pan-European MiCA (Markets in Crypto-Assets) regulation will come into force, establishing unified legal standards for all industry participants. This marks the end of legal uncertainty and the beginning of crypto companies operating under clear and predictable rules that apply across the entire European Union.
In this overview, we will explore the key provisions of MiCA, the new requirements for crypto businesses, and the steps needed to ensure compliance with the law.
What is MiCA regulation, exactly?
MiCA is a pan-European regulation that sets common rules for the cryptocurrency market in all EU member states.
Before MiCA, regulation was fragmented. Each country had its own set of requirements. Some enforced strict laws, while others barely monitored crypto companies.
This created legal uncertainty. A company could operate legally in one jurisdiction but be in violation of the law in another. The rules were vague. It wasn’t clear who needed a license, which tokens were regulated, or how clients should be verified.
As a result, bad actors began to emerge. Some launched “exchanges” without reliable custody systems. Others offered investments in tokens with no real value. Companies raised funds and then disappeared.
Honest market participants suffered. Users lost money. The market lost trust. Regulators couldn’t keep up.
MiCA aims to change all of this. It introduces clear rules on who is allowed to operate, under what conditions, and with what responsibilities. This protects clients, closes loopholes, and levels the playing field for everyone in the industry.
Who is affected by MiCA and who needs to obtain a license
MiCA applies to anyone operating with crypto-assets in the Czech Republic and across the European Union. Whether you are a large exchange, a small wallet provider, or a new fintech startup, the regulation concerns you.
MiCA covers companies that:
- issue tokens, including stablecoins,
- manage crypto wallets or hold client assets,
- provide exchange or trading services,
- offer investment advice related to cryptocurrencies,
- transmit orders to buy or sell tokens.
If you are already engaged in such activities in the Czech Republic, you must apply for a CASP (Crypto-Asset Service Provider) license by July 31, 2025. New companies must meet these requirements from day one.
Operating without a license will be prohibited. Violations will lead to fines, market access restrictions, and the loss of the right to serve clients within the EU.
It is important to note that certain crypto-related activities are not covered by MiCA. For example, the regulation does not apply to staking services or crypto-backed lending. These services may be subject to other EU legal frameworks or national legislation.
What will happen to the VASP license in the Czech Republic
Before MiCA came into effect, the Czech Republic operated under the VASP (Virtual Asset Service Provider) license. It was issued by the Czech Trade Register and allowed companies to work with crypto-assets—providing exchange, custody, and client order transmission services.
Starting in 2025, the situation will change. MiCA introduces a unified EU-wide licensing model, and the VASP license will no longer be sufficient for legal operation within the European Union.
All companies registered as VASPs must undergo relicensing and obtain a CASP (Crypto-Asset Service Provider) license. Without it, they will not be allowed to continue operating after the transition period.
For existing VASP license holders, the deadline to apply for a CASP license is July 31, 2025. After submitting the application, they may continue operations while awaiting a decision from the regulator—but no later than July 1, 2026.
Obtaining a CASP license not only ensures continued operation in the Czech Republic but also provides full access to the EU crypto market under a single regulatory framework.
Types of CASP Licenses and Capital Requirements
A CASP (Crypto-Asset Service Provider) license grants permission to provide crypto-asset services within the European Union. Depending on the nature of their business, companies must choose the appropriate license class.
MiCA defines three levels:
Class 1 – Basic Services
This includes the transmission and execution of client orders, token placement, investment advice, portfolio management, and the transfer of digital assets. Companies under this class do not hold client assets or perform exchange operations.
Minimum capital: €50,000
Class 2 – Custody and Exchange
Includes all services from Class 1, plus custody of client assets and crypto-to-fiat exchange (e.g., euro or USD).
Minimum capital: €125,000
Class 3 – Trading Platforms
This applies to exchanges and trading platform operators that provide the infrastructure for peer-to-peer transactions. These companies face the highest requirements in terms of capital, internal processes, and regulatory control.
Minimum capital: €150,000
A separate category covers issuers of electronic money and stablecoins.
This license is required for companies issuing tokens that function as a means of payment—such as stablecoins pegged to fiat currencies. These tokens are regulated similarly to electronic money.
Minimum capital: €350,000
This license is comparable to an EMI (Electronic Money Institution) license, reflecting the higher level of responsibility and oversight involved.
The choice of license class depends on the services offered. If a company plans to engage in multiple activities, it must meet the requirements for all applicable classes.
What is required to apply for a CASP license
To obtain a CASP license, a company must submit a complete set of documents and undergo an assessment for compliance with the MiCA regulation. The evaluation covers not only the legal structure but also business reputation, internal processes, financial model, and compliance systems.
Directors and shareholders
The regulator thoroughly reviews the management team and key business owners.
Directors must demonstrate relevant experience, professional competence, and an impeccable reputation. At least one director must have permanent residency within the EU.
Criminal records related to money laundering, financial fraud, or other trust-related offenses are strictly prohibited.
The same applies to shareholders with significant holdings. They must verify the source of their funds, undergo a fit and proper assessment, and disclose any potential conflicts of interest. If any of the owners are politically exposed persons (PEPs), enhanced scrutiny will be applied.
The regulator has the authority to limit the influence of such shareholders if deemed necessary for sound governance.
Core documentation package
Companies must provide:
- Articles of association and ownership structure,
- A description of the business model and list of crypto services,
- A three-year business plan including financial projections and growth strategy,
- A financial plan with forecasts for revenue, clients, and transactions,
- Proof of meeting minimum capital requirements,
- Agreements with banks, payment solution providers, and counterparties.
If token issuance is planned, a White Paper and a compliance notification with MiCA must be included.
AML, internal control, and risk management
Special attention is given to anti-money laundering (AML) measures. The following are required:
- An AML and CFT policy,
- Appointment of an AML officer and MLRO (Money Laundering Reporting Officer),
- Internal risk assessment and mitigation plan,
- Client identification and verification system (KYC),
- Transaction monitoring procedures.
This is not a formality—all measures must be documented, implemented, and actively functioning in practice.
Information security and IT systems
MiCA and DORA require a high level of digital resilience. Companies must provide descriptions of:
- IT system architecture and data protection measures,
- Backup and recovery processes,
- Incident response and cyberattack plans,
- Regular security audits and testing,
- Storage and safeguarding of keys to crypto-assets.
Additionally, it must be confirmed that client assets are segregated from the company’s own funds.
What happens if you fail to comply with MiCA requirements
Non-compliance with MiCA rules leads to serious consequences. Companies that do not obtain a CASP license within the established deadlines will lose the right to operate with clients in the Czech Republic and other EU member states.
Operating without a license carries significant penalties. Fines can reach up to €15 million or 15% of the company’s annual turnover—whichever amount is higher.
Additionally, the regulator has the authority to:
- suspend operations,
- restrict access to client funds,
- block the operation of a platform or website,
- revoke licenses from those who obtained them but breached the conditions.
Particular attention is given to violations related to AML compliance and information security. Companies that fail to verify clients properly or handle data insecurely may be classified as high-risk. In such cases, they can lose access to banking and payment services, and their activities may be placed under heightened regulatory scrutiny.
Regulators also have the right to impose daily fines until the identified issues are resolved.
How to prepare for MiCA licensing
MiCA is changing the game for crypto companies in the Czech Republic. To maintain access to the market and obtain a CASP license, businesses need to prepare documentation in advance, establish internal procedures, and undergo a compliance review. It’s a demanding process, but with the right professional support, it can be completed with confidence.
The DoMyTax team supports clients at every stage — from the first consultation to submitting the complete application to the Czech National Bank. We also offer a turnkey crypto license service in the Czech Republic under the MiCA framework.
If you plan to operate legally within the new regulatory system for crypto business — we’re here to help you do it right.
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