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LexorCorp Global Order

Guide

Cross-border crypto-asset services under MiCA (Article 65 notification)

A crypto-asset service provider (CASP) authorised in one EU Member State that intends to provide services in other Member States notifies its home authority, which passes the information on to the other states. This page explains that notification for a CASP authorised in Estonia, and briefly covers two related routes in the same regulation.

LexorCorp Global OÜ · published 11 November 2026

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Eesti

In short

A crypto-asset service provider (CASP) authorised in one EU Member State that intends to provide services in other Member States notifies its home authority 13 , which passes the information on to the other states 26 . This page explains that notification for a CASP authorised in Estonia, and briefly covers two related routes in the same regulation. Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) lists ten crypto-asset services, among them custody and administration of crypto-assets for clients, operating a trading platform, exchanging crypto-assets for funds or for other crypto-assets, executing and transmitting orders, placing, advice, portfolio management and transfer services 1 .

Order the application documents: Order

A crypto-asset service provider (CASP) authorised in one EU Member State that intends to provide services in other Member States notifies its home authority13, which passes the information on to the other states26. This page explains that notification for a CASP authorised in Estonia, and briefly covers two related routes in the same regulation.

Information as of 11 November 2026. Every numbered statement of this page was checked in the official text named below and re-checked by a second reviewer on 2026-11-11. The page is general information, not legal advice; the authority decides on every application.

What the activity is

Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) lists ten crypto-asset services, among them custody and administration of crypto-assets for clients, operating a trading platform, exchanging crypto-assets for funds or for other crypto-assets, executing and transmitting orders, placing, advice, portfolio management and transfer services1.

Cross-border provision means providing one or more of these services in a Member State other than the home Member State. For a CASP, the home Member State is the state of its registered office3. A host Member State is a state where the CASP provides crypto-asset services, if different from the home state4.

Article 65 sets a notification procedure13. A CASP that provides services cross-border does not need a physical presence in the host state2. What the notification does not cover: services the CASP is not authorised for (adding a service requires an extension of the authorisation5), and activity outside the European Economic Area (EEA), for which Estonian law requires a separate permit from Finantsinspektsioon6.

The legal act and the authority

  • Regulation (EU) 2023/1114 (MiCA), Article 65 "Cross-border provision of crypto-asset services". The regulation applies from 30 December 20247.
  • Krüptovaraturu seadus (Crypto-asset Market Act, KrüTS), which supplements MiCA in Estonia8.
  • Competent authority: Finantsinspektsioon (the Estonian Financial Supervision and Resolution Authority) grants and withdraws authorisations of crypto-asset market participants and supervises them9. For an Estonian CASP it is the home authority that receives the Article 65 notification10.
  • Register: the European Securities and Markets Authority (ESMA) keeps a public register of CASPs. For each CASP it shows, among other things, the list of host Member States in which the CASP intends to provide services and the starting date11. ESMA publishes the CASP register on its MiCA web page12.

Who must notify

Article 65 applies to a CASP that intends to provide crypto-asset services in more than one Member State13. The notifying entity is a legal person authorised as a CASP under Article 63 of MiCA14.

Article 60 (certain financial entities). Credit institutions, central securities depositories, investment firms, electronic money institutions, UCITS management companies, alternative investment fund managers and market operators that already hold their own sectoral authorisation may provide crypto-asset services if they notify their home authority15. Each notifies its home authority at least 40 working days before providing them for the first time15. The notification contains the information listed in Article 60(7)15. The authority checks within 20 working days whether it is complete, and the entity may not start while it is incomplete16. In Estonia, Finantsinspektsioon confirms the right of such an entity to act as a CASP by a decision17.

Article 61 (reverse solicitation). Where a client established or situated in the Union initiates, at its own exclusive initiative, a crypto-asset service by a third-country firm, the authorisation requirement does not apply to that service for that client18. If the third-country firm, or anyone acting on its behalf, solicits clients in the Union by any means, the service is not deemed to be at the client's own exclusive initiative, notwithstanding any contractual clause or disclaimer18. The client's initiative does not entitle the firm to market new types of crypto-assets or services to that client19.

Requirements for the notifying CASP

The points below concern the CASP's existing authorisation; whether further requirements apply is specified for the client's situation:

  • Authorisation and scope. The authorisation specifies the services the CASP may provide20. The notification can only cover services within that scope; new services require an extension of the authorisation5.
  • Continuing conditions. A CASP must at all times meet the conditions for its authorisation21.
  • Seat and management. The CASP must have its registered office in a Member State where it carries out at least part of its services. Its place of effective management must be in the Union, and at least one director must be resident in the Union22. For a CASP authorised in Estonia, the registered office must be in Estonia23.
  • No local presence. No physical presence in the host state is required for cross-border services2.

Whether host-state rules that are not harmonised by MiCA, such as local marketing or consumer law, apply is specified for the client's case.

Content of the notification

Article 65(1) lists four items13:

  1. the list of the Member States in which the CASP intends to provide crypto-asset services;
  2. the crypto-asset services it intends to provide on a cross-border basis;
  3. the starting date of the intended provision of those services;
  4. a list of all other activities it provides that are not covered by MiCA.

The same items appear in the register entry: host Member States, starting date (or intended starting date) and other services not covered by MiCA, with a reference to the applicable Union or national law11.

Fee and time limits

  • Fee: Finantsinspektsioon states that no processing fee is payable for the notification of cross-border provision of services24. (For comparison, the processing fee for a CASP authorisation application is EUR 3,00025.)
  • Home authority: within 10 working days of receiving the information, the home authority communicates it to the single points of contact of the host Member States, to ESMA and to the European Banking Authority (EBA)26. It then informs the CASP of that communication without delay27.
  • Start of services: the CASP may begin providing services in another Member State from the date it receives that communication, or at the latest from the 15th calendar day after it submitted the information28.

These time limits are set by the regulation; they are not a promise about a particular case.

What LexorCorp Global OÜ does and how to order

LexorCorp Global OÜ offers the service "Cross-border services notification (MiCA Article 65)" for CASPs that hold a MiCA authorisation. It prepares the notification to Finantsinspektsioon listing the Member States where the client intends to provide crypto-asset services. The service includes:

  • the notification under MiCA Article 65 with the list of host Member States and services;
  • the programme of operations for the cross-border services;
  • managing the procedure with Finantsinspektsioon on the notification.

Not included: review of local marketing or consumer law in each host state, and state and supervisory fees, which the client pays. LexorCorp Global OÜ prepares the documents and manages the process. It does not give legal, audit or tax advice, and it cannot promise any decision, communication or date of the authority.

The service is ordered on the crypto-asset licensing page: order form.

Sources

  1. Regulation (EU) 2023/1114 (MiCA), Art. 3(1)(16) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  2. Regulation (EU) 2023/1114 (MiCA), Art. 59(7) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  3. Regulation (EU) 2023/1114 (MiCA), Art. 3(1)(33)(f) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  4. Regulation (EU) 2023/1114 (MiCA), Art. 3(1)(34) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  5. Regulation (EU) 2023/1114 (MiCA), Art. 59(8) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  6. Krüptovaraturu seadus (KrüTS), § 10(1); § 4(3) (lepinguriik = EEA contracting state other than Estonia) — text in force from 01.07.2024 (RT I, 21.06.2024, 3; shown as 'hetkel kehtiv' on 11.11.2026)
  7. Regulation (EU) 2023/1114 (MiCA), Art. 149 — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  8. Krüptovaraturu seadus (KrüTS), § 1 — text in force from 01.07.2024 (RT I, 21.06.2024, 3; shown as 'hetkel kehtiv' on 11.11.2026)
  9. Krüptovaraturu seadus (KrüTS), § 5(2); § 26(1) — text in force from 01.07.2024 (RT I, 21.06.2024, 3; shown as 'hetkel kehtiv' on 11.11.2026)
  10. Finantsinspektsioon, 'The operating license in markets of crypto assets', section 'Cross-border provision of crypto-asset services'; MiCA Art. 65(1) — text in force from page last edited on 27/05/2026
  11. Regulation (EU) 2023/1114 (MiCA), Art. 109(1)(d), 109(5)(e)–(g) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  12. ESMA, Markets in Crypto-Assets Regulation (MiCA) page; file CASPS.csv — text in force from page 'Last update: 5 November 2026'
  13. Regulation (EU) 2023/1114 (MiCA), Art. 65(1) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  14. Regulation (EU) 2023/1114 (MiCA), Art. 59(1)(a) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  15. Regulation (EU) 2023/1114 (MiCA), Art. 60(1)–(7) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  16. Regulation (EU) 2023/1114 (MiCA), Art. 60(8) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  17. Krüptovaraturu seadus (KrüTS), § 6(1) — text in force from 01.07.2024 (RT I, 21.06.2024, 3; shown as 'hetkel kehtiv' on 11.11.2026)
  18. Regulation (EU) 2023/1114 (MiCA), Art. 61(1) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  19. Regulation (EU) 2023/1114 (MiCA), Art. 61(2) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  20. Regulation (EU) 2023/1114 (MiCA), Art. 59(6) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  21. Regulation (EU) 2023/1114 (MiCA), Art. 59(4) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  22. Regulation (EU) 2023/1114 (MiCA), Art. 59(2) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  23. Krüptovaraturu seadus (KrüTS), § 5(4) — text in force from 01.07.2024 (RT I, 21.06.2024, 3; shown as 'hetkel kehtiv' on 11.11.2026)
  24. Finantsinspektsioon, 'The operating license in markets of crypto assets' — text in force from page last edited on 27/05/2026
  25. Finantsinspektsioon, 'The operating license in markets of crypto assets', 'Processing fee' — text in force from page last edited on 27/05/2026
  26. Regulation (EU) 2023/1114 (MiCA), Art. 65(2) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  27. Regulation (EU) 2023/1114 (MiCA), Art. 65(3) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)
  28. Regulation (EU) 2023/1114 (MiCA), Art. 65(4) — text in force from consolidated version 02023R1114-20240109 (latest on EUR-Lex; incl. amendment by Reg. (EU) 2023/2869 and corrigendum of 2.5.2024)

Official sources

The laws this article names, each linked to its official text, as read on 9 October 2026. For the Estonian acts we read the English translation in Riigi Teataja; the legally binding text is the Estonian one.

Sources in the text are named without links; the official texts are linked under Official sources. To see which of our services your company needs, open the Business Navigator.

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We prepare the application documents and manage the process; the authority decides. Not legal advice.

Our fee: from €6,000; no VAT is added. State fees and the fees of the supervisory authority are not included in the price; you pay them yourself.

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