An Estonia crypto license issued by the Financial Intelligence Unit (FIU) no longer provides a right to operate. On 1 July 2026, Estonia's transitional period for virtual asset service providers (VASPs) ended. The FIU cancelled the register data for its former virtual currency service licences, and only companies authorised under the EU's Markets in Crypto-Assets Regulation (MiCA) could continue providing crypto-asset services in Estonia.
The FIU reported that one company, Lightspark Payments Europe AS, had received a standalone crypto-asset service provider (CASP) authorisation from Estonia's financial supervisor, Finantsinspektsioon, by the transition deadline. Other businesses could provide services under existing authorisations, including those held by a bank, an investment firm, or providers licensed in another European Economic Area (EEA) country. Read the FIU's transition announcement.
If your business held an FIU VASP licence, the old registration no longer provides a basis for operating. If you are entering the Estonian market now, an Estonia cryptocurrency license application must follow the MiCA authorisation framework.
This guide explains what changed, how the Estonian licensing process works, and what businesses need to prepare for Finantsinspektsioon.
TL;DR
- The FIU licensing route has ended. On 1 July 2026, Estonia cancelled the register data associated with its former virtual currency service licences. The FIU no longer issues these licences.
- Finantsinspektsioon is the national licensing authority. New CASP applications are submitted under MiCA and Estonia's Crypto Markets Act (CMA). Businesses may also provide services in Estonia under a qualifying authorisation from another EEA supervisory authority.
- The transition deadline was 1 July 2026. Estonia selected the maximum 18-month grandfathering period allowed under MiCA Article 143(3). The transitional regime has now ended.
- MiCA sets the minimum own-funds requirements. The applicable minimum is €50,000 for Class 1, €125,000 for Class 2, and €150,000 for Class 3 services. The required amount depends on the services offered.
- The application processing fee is €3,000. Finantsinspektsioon assesses application completeness within 25 working days and, for complete applications, carries out the substantive assessment within a further 40 working days. The period may be paused for up to 20 working days.
- An authorised CASP can passport services across the EU. Passporting requires notification through the home-state authority and compliance with applicable MiCA requirements.
What Changed on 1 July 2026?
MiCA allowed EU states to give existing crypto businesses up to 18 months to transition from national licences to MiCA authorisations. Estonia chose the full period, which ended on 1 July 2026.
The FIU confirmed that its old VASP licences were no longer valid. From that date, businesses needed a MiCA authorisation from Finantsinspektsioon or an authorisation from another EEA regulator that allowed them to operate in Estonia.
The numbers show how little of the old market transitioned. Estonia had 641 valid virtual currency service licences in 2021. Of the 36 that remained at the start of 2026, the FIU identified just one company, Lightspark Payments Europe AS, as having obtained a standalone CASP authorisation from Finantsinspektsioon by the deadline. LHV Pank and Lightyear Europe provided services under existing authorisations, while other firms operated through licences issued elsewhere in the EEA.
This was the position at the transition deadline, not a complete count of Estonia's current authorised providers.
If You Held an FIU VASP Licence
An FIU VASP licence no longer gives you the right to operate. Estonia cancelled the old licence register on 1 July 2026, when the transition to MiCA authorisations ended. There was no automatic conversion to a CASP licence.
What you can do now depends on whether you applied for a new authorisation before the deadline.
If you did not apply, you cannot continue providing services under the old registration. The FIU's transition guidance required businesses to stop taking new clients, opening accounts, and marketing their services in the EEA. They must instead manage the wind-down and protect existing clients, including arrangements for returning or transferring assets.
If you applied and are still waiting for a decision, submitting the application does not grant a full MiCA authorisation. You must follow the applicable restrictions while Finantsinspektsioon reviews your application.
If you received authorisation, you can operate under the scope of your MiCA licence.
To verify a provider's current status, check the Finantsinspektsioon register of market participants. But it’s important to note that an old FIU registration is no longer evidence of authorisation.
Applying for an Estonia Crypto License Under MiCA
A new applicant must seek authorisation under MiCA and Estonia's CMA. The national authority is Finantsinspektsioon, which supervises CASPs operating under the Estonian framework.
MiCA Article 59(2) requires a CASP to have its registered office in a member state, its effective management in the Union, and at least one director resident in the Union.
The application process is based on MiCA's requirements and the information specified in the relevant regulatory technical standards. Estonia's CMA provides the national legal framework for the authorisation and supervision of crypto-asset market participants.
Minimum Own Funds for MiCA
MiCA establishes minimum own-funds requirements based on the class of crypto-asset services provided.
Source: ESMA Interactive Single Rulebook: Minimum capital requirements .
These are EU-wide MiCA minimums, not Estonia-specific capital requirements. The applicable amount depends on the services included in the application. Applicants must also budget for staffing, technology, compliance, security, and ongoing operations.
Corporate Structure and Management
The applicant must meet MiCA's requirements for its registered office, effective management, and management personnel.
Its governance framework should define:
- Management and decision-making responsibilities.
- Ownership and organisational structure.
- Key functions, internal controls, and risk management.
- The suitability and experience of relevant personnel.
Finantsinspektsioon may request additional information to assess whether the arrangements meet the applicable requirements.
AML/CFT and Customer Due Diligence
CASPs must maintain risk-based anti-money laundering and counter-terrorist financing (AML/CFT) controls. The framework should cover customer due diligence, risk assessments, transaction monitoring, suspicious activity reporting, and applicable Travel Rule obligations.
The FIU remains responsible for receiving suspicious transaction reports from relevant obliged entities under Estonia's AML framework.
Read more about the crypto Travel Rule and the compliance controls required for digital asset businesses.
Operational Resilience and Data Protection
Applicants must demonstrate that their technology and operational arrangements support the services they intend to provide.
The framework should address ICT security, operational risk, business continuity, incident management, client asset protection, and GDPR compliance.
The Digital Operational Resilience Act (DORA) applies to in-scope financial entities, including relevant crypto-asset service providers. The exact requirements depend on the entity's classification and operating model.
Financial Reporting and Audits
Applicants must establish appropriate arrangements for financial reporting, internal controls, risk management, and applicable audit requirements.
The application must contain the information required by MiCA Article 62 and relevant technical standards. Finantsinspektsioon may request further documentation during its review.
Application Process
Finantsinspektsioon began accepting CASP applications through its application portal on 18 March 2026. Applicants should prepare the required documentation before filing.
Step 1: Define the Operating Model
Identify the crypto-asset services you will provide — operating a crypto exchange, custody and administration, transfer services, advice — and the CASP class that covers them.
That class sets your own-funds requirement and the scope of the application.
Step 2: Establish the Corporate and Governance Framework
Set up the applicant's legal structure and assign management and key functions. Ensure the governance arrangements meet MiCA requirements.
Step 3: Prepare Financial Arrangements
Secure the required own funds and prepare evidence of the financial resources needed for your operating model, including proof of origin of funds where required.
Step 4: Compile the Application Dossier
Prepare the information required under MiCA Article 62 and the relevant technical standards, including:
- Business model, planned services, and operating structure.
- Governance, ownership, and management information.
- AML/CFT and risk management documentation.
- ICT security and operational resilience arrangements.
- Client asset protection measures.
- Financial information and supporting evidence.
Finantsinspektsioon may request additional documents or clarification during its assessment.
Step 5: Submit the Application
Submit the application through the Finantsinspektsioon application portal.
Heads up: the regulator's guidance states that applications are submitted in Estonian, but supporting documents may be submitted in English if this is clearly indicated in the application.
You should also be aware that the MiCA application processing fee is €3,000.
Step 6: Finantsinspektsioon Review
Finantsinspektsioon assesses applications in two stages:
- Completeness assessment: Within 25 working days.
- Substantive assessment: Within a further 40 working days after the application is considered complete.
The substantive assessment period may be extended by up to 20 working days. Also, keep in mind that the regulator may request additional information or documents.
These statutory periods do not guarantee an authorisation timeline, as preparation time and follow-up requests can extend the overall process.
How Hacken Supports MiCA and DORA Compliance
Preparing a CASP application involves coordinating legal, governance, compliance, technology, and operational documentation.
Hacken's compliance services support businesses preparing their security and compliance frameworks for regulatory requirements.
For businesses entering the Estonian market after the MiCA transition, the focus is on establishing a complete, evidence-based application and the operational controls needed to support ongoing compliance.
Conclusion
Estonia's former FIU VASP licensing route ended on 1 July 2026. Businesses that want to provide crypto-asset services in Estonia now need a MiCA authorisation from Finantsinspektsioon or an appropriate authorisation from another EEA supervisory authority.
The MiCA framework establishes minimum own-funds requirements of €50,000, €125,000, or €150,000, depending on the CASP class. Applications submitted to Finantsinspektsioon carry a €3,000 processing fee and are subject to completeness and substantive assessments.
The licensing process requires more than corporate registration and AML documentation. Applicants must prepare governance arrangements, financial information, ICT security documentation, operational resilience controls, and other materials required by MiCA and Estonia's CMA.
An Estonian MiCA authorisation can provide access to the EU market through passporting. The decision to establish operations in Estonia should account for the intended services, regulatory requirements, operating costs, and the resources needed to maintain compliance after authorisation.
