Every crypto-asset service provider (CASP) authorised under the EU Markets in Crypto-Assets Regulation (MiCA) falls into one of three classes. The class follows from the services the provider is authorised for, and it decides the permanent minimum capital the company must hold. This guide explains the three classes service by service, how the capital requirement is calculated, what counts as capital, and the mistakes we see most often when a business plan meets the class table. Our prices for the application work are on the MiCA crypto licensing page.
All figures come from Regulation (EU) 2023/1114 (EUR-Lex): the classes and minimums from Annex IV, the calculation from Article 67. The guide is general information, not legal advice.
Why the class matters
The class is not a label the applicant chooses. It is the result of the list of crypto-asset services in the application. Add one service — for example exchange of crypto-assets for euros — and a Class 1 project becomes a Class 2 project, with a higher capital requirement, more policies and a different risk profile in the eyes of the authority. That is why we fix the service list before anything else, and why the class should be decided on the business model you will actually run in the first years, not on everything you might want to do one day.
Class 1 — minimum capital 50,000 euros
Annex IV places a provider in Class 1 when it is authorised for one or more of the following services:
- execution of orders for crypto-assets on behalf of clients;
- placing of crypto-assets;
- providing transfer services for crypto-assets on behalf of clients;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets;
- providing portfolio management on crypto-assets.
What these services have in common is that the provider does not hold clients' crypto-assets for them as a service and does not exchange crypto-assets against its own book. A broker that routes orders to other venues, an adviser, a portfolio manager or a placement agent typically fits here. Note that advice and portfolio management come with their own conduct obligations, including a suitability assessment of the client (Article 81).
Class 2 — minimum capital 125,000 euros
Class 2 covers a provider authorised for any Class 1 service and one or more of:
- providing custody and administration of crypto-assets on behalf of clients;
- exchange of crypto-assets for funds;
- exchange of crypto-assets for other crypto-assets.
This is where most consumer-facing businesses land: a wallet provider that holds keys for its clients, or an exchange service that buys and sells crypto-assets for euros. Custody is a Class 2 service, not a Class 3 service. The confusion is common because trading platforms usually offer custody too, but in the Annex IV table custody sits in Class 2. A provider that offers custody must also have a custody policy and keep clients' crypto-assets segregated from its own (Articles 70 and 75).
Class 3 — minimum capital 150,000 euros
Class 3 covers a provider authorised for any Class 2 service and the operation of a trading platform for crypto-assets. A trading platform brings together multiple third-party buying and selling interests in crypto-assets within one system, and it has its own requirements on operating rules, pre- and post-trade transparency and settlement (Article 76). A Class 3 provider may also provide the Class 1 and Class 2 services — including custody — under the same authorisation.
How the capital requirement is calculated
The Annex IV figure is a floor, not the whole answer. Article 67(1) requires a CASP to have in place, at all times, prudential safeguards equal to at least the higher of:
- (a) the permanent minimum capital requirement in Annex IV for its class; and
- (b) one quarter of its fixed overheads of the preceding year, reviewed annually.
A provider that has not been in business for a year uses the projected fixed overheads from the first 12 months of its business plan, as submitted with the application (Article 67(2)). Fixed overheads are calculated from the accounts by subtracting items such as profit-dependent staff bonuses from total expenses (Article 67(3)).
A simple example shows why this matters. A Class 2 provider with planned fixed overheads of 800,000 euros for its first year must hold at least 200,000 euros (one quarter of 800,000), not 125,000 euros — the overhead test gives the higher figure. A lean Class 2 business with fixed overheads of 300,000 euros meets the requirement with 125,000 euros, because one quarter of its overheads (75,000 euros) is lower than the Annex IV minimum. The business plan and the capital plan in the application must tell the same story.
What counts as prudential safeguards
Article 67(4) allows the safeguards to take the form of own funds (Common Equity Tier 1 items under the EU capital requirements rules), an insurance policy covering the territories where the services are provided, or a comparable guarantee, or a combination. An insurance policy must meet the conditions in Article 67(5) and (6) — among them an initial term of at least one year, a cancellation notice period of at least 90 days, an authorised third-party insurer and publication on the provider's website. In practice most start-up applicants use paid-in share capital, because it is simplest to evidence and does not depend on an insurer's appetite for crypto risk.
Whatever the form, the safeguards belong to the company and must stay available. They are not a payment to anyone, and they are never part of a service provider's fee — including ours.
Common mistakes
- Adding services "just in case". Every service in the application must be backed by procedures, people and systems. Listing exchange or custody without the capability to run it weakens the application.
- Assuming custody means Class 3. It does not; it means Class 2. Planning for Class 3 without a trading platform overstates the requirement.
- Ignoring the overhead test. A well-staffed business plan can push the requirement above the Annex IV minimum.
- Mixing capital and fees. The capital is the company's own money; the state and supervisory fees are separate; our price is our professional fee. Our guide to state fees and capital for EU licences sets them side by side.
Fees of the authority
In addition to the capital, the Estonian Financial Supervision Authority charges a procedural fee for a crypto-asset service provider's application: 3,000 euros in the wording of the Financial Supervision Authority Act in force on 29 September 2026 (§ 45³(2), Riigi Teataja). Adding services to an existing authorisation carries a fee of 1,500 euros under § 45⁴ of the same Act.
How we help
We start every MiCA project by fixing the service list, the class and the capital calculation, because every later document depends on them. Our fee for the application depends on the class — see the three class lines on the MiCA crypto licensing page — and add-ons such as a custody and administration policy or a security and key management procedure are priced separately. Our general guide to the MiCA CASP licence in Estonia describes the whole application.
Frequently asked questions
What are the minimum capital requirements for the three MiCA classes?
50,000 euros for Class 1, 125,000 euros for Class 2 and 150,000 euros for Class 3, under Annex IV of Regulation (EU) 2023/1114. The provider must hold the higher of that minimum and one quarter of its fixed overheads of the preceding year.
Does custody of crypto-assets require Class 3?
No. Custody and administration of crypto-assets on behalf of clients is a Class 2 service. Class 3 is reached by operating a trading platform.
Can the capital be provided by insurance?
Article 67(4) allows own funds, an insurance policy, a comparable guarantee or a combination; the insurance must meet the conditions in Article 67(5) and (6). Most new applicants use paid-in share capital.
Can a provider move to a higher class later?
Yes, by applying to extend its authorisation to additional services. It must then meet the capital requirement of the new class; the Financial Supervision Authority charges a procedural fee for extending the services.
Is the capital part of your fee?
No. The capital belongs to your company. Our price is our professional fee for the corporate and regulatory work.