Slovakia’s crypto licensing framework has undergone a complete overhaul. The former simple Virtual Asset Service Provider (VASP) trade license no longer applies and has been replaced by a full financial services regime under the EU Markets in Crypto-Assets (MiCA) Regulation.
All existing providers must obtain a MiCA license from the National Bank of Slovakia (NBS) or another EU competent authority with passporting into Slovakia by December 30, 2025.
Although requirements are now stricter, Slovakia aims to become a practical and cost-efficient MiCA hub within the EU. This guide outlines how to select the right license, meet the key requirements, and navigate the NBS application process.
TL;DR:
- Slovakia’s framework is fully aligned with MiCA, with a transitional deadline of December 30, 2025, for existing providers.
- Full EU passporting is available under one Slovak CASP license, giving market access across all 27 member states.
- From January 1, 2026, licensed CASPs will fall under the EU’s DAC8 tax reporting obligations.
- Early engagement with the NBS and a strong compliance foundation are key to securing approval.
How Slovakia Regulates Crypto
Slovakia's current regulatory framework consists of EU and national laws, with MiCA at its core.
As the primary law, MiCA is directly applicable in Slovakia. It sets the rules for authorization, governance, consumer protection, and market abuse. The NBS acts as the sole competent authority responsible for supervising and enforcing applicable rules for Crypto Asset Service Providers (CASPs).
Other regulations in Slovakia’s crypto licensing compliance stack include:
- Transfer of Funds Regulation (TFR): This is the EU's implementation of the Financial Action Task Force (FATF)’s “Travel Rule," which runs alongside MiCA and requires CASPs to collect and exchange originator/beneficiary information for all crypto transfers.
- Digital Operational Resilience Act (DORA): As newly regulated financial entities, all CASPs must comply with this comprehensive IT and cybersecurity framework. It mandates ICT risk management, incident reporting, and business continuity planning.
- Slovak AML Act: The national anti-money laundering law (Act No. 297/2008) also applies, requiring comprehensive Know-Your-Customer (KYC) and customer due diligence (CDD) procedures, transaction monitoring, and reporting of suspicious transactions to the Financial Intelligence Unit (FIU).
- Directive on Administrative Cooperation (DAC8): This is a tax transparency directive that extends automatic exchange of information reporting obligations to crypto-asset transactions across the EU.
Timeline of Key Compliance Changes in Slovakia
How Tokens Are Classified Under MiCA
In Slovakia, regulatory obligations for CASPs are determined by the type of tokens dealt with, based on their economic substance, not their name. MiCA creates three main classifications:
- E-Money tokens (EMTs): These are crypto-assets that aim to maintain a stable value by referencing one official fiat currency (e.g., a "Digital Euro" or "Digital Dollar").
- Asset-Referenced tokens (ARTs): These are crypto-assets that aim for a stable value by referencing a basket of assets. This can include multiple fiat currencies, commodities, or other crypto-assets.
- Utility tokens: A utility token is defined by its sole purpose: to provide access to a good or service offered by its issuer. This category includes assets like ETH.
Choosing a Slovakian Crypto License
Slovakian law requires a CASP license for any legal person whose business is the professional provision of one or more crypto-asset services to third-party clients.
The NBS officially lists 10 services that require authorization :
- Providing custody and administration of crypto-assets.
- Operating a trading platform for crypto-assets.
- Exchanging crypto-assets for funds (fiat).
- Exchanging crypto-assets for other crypto-assets.
- Executing orders for crypto-assets.
- Placing of crypto-assets.
- Reception and transmission of orders for crypto-assets.
- Providing advice on crypto-assets.
- Providing portfolio management on crypto-assets.
- Providing transfer services for crypto-assets.
Proprietary trading is the key exception under Slovakia’s MiCA regime. Companies that buy or sell crypto only for their own account do not need authorization from the NBS and are not considered to be CASPs.
This exemption applies strictly to self-directed trading. Businesses that operate platforms or match trades for third parties are providing a regulated service and must obtain a license.
MiCA categorizes these regulated business activities into three classes, adjusting startup capital requirements in line with the level of risk.
Key Licensing Requirements
- Corporate setup: Register a Slovak legal entity, typically a limited liability company (s.r.o.), with a legal address in Slovakia. A registered local business address in Slovakia is mandatory, and the level of physical presence is assessed on a case-by-case basis.
- Minimum capital: This is a two-step process.
- Step 1: Incorporate an s.r.o. with the standard €5,000 share capital.
- Step 2: Before applying for a CASP license, deposit the prudential capital required by MiCA according to the class of license that applies. Applicants must also document the source of these funds for AML verification.
- Governance and personnel:
- All directors and qualifying shareholders must pass the “fit and proper” assessment administered by the NBS, providing clean criminal records, relevant CVs, and proof of good repute.
- Applicants must appoint an AML officer. The officer may be based in any EU country, though appointing one in Slovakia is recommended to ensure smooth communication with regulators.
- At least one director must be a Slovak or EU citizen. The NBS allows role cumulation, meaning one qualified person may carry out multiple duties if they can prove their capacity and expertise.
- Documentation: All of the following documents must be submitted in Slovak.
- A complete application form
- Program of activities with a three-year business and financial plan
- AML/CFT and KYC policy
- DORA-compliant ICT and cybersecurity
- Business continuity and disaster recovery plan
- Client asset and fund safeguarding policy
- Conflicts of interest policy
- Complaints handling procedure
- Internal control and risk management framework, including comprehensive monitoring and analytical tools
Application Process
Corporate & Operational Setup
Applicants must first complete corporate registration as a Slovak s.r.o., secure a legal address, deposit the initial €5,000 share capital, appoint a qualified EU-resident director and AML officer before engaging with the regulator.
Pre-Licensing Dialogue
The NBS encourages applicants to hold a pre-licensing meeting before formal submission. This discussion helps confirm the appropriate license class, clarify requirements, and prevent delays. Early engagement with the regulator is strongly advised. Interested applicants should email the NBS with a detailed description of their business model, including the proposed type of crypto-asset service.
Prepare Compliance Dossier
- Increase capital to the MiCA-required prudential minimum.
- Prepare all documentation outlined above.
- Translate all materials into Slovak. A waiver for English-language IT documents may be requested, but is not guaranteed.
NBS Submission and Review
Applications are first filed in paper form, after which applicants may email the NBS with a request to create an electronic submission portal.
The NBS has 25 working days to assess if an application dossier is complete, and may request additional information with new deadlines as it deems appropriate.
Within 40 days after an application is deemed complete, the NBS will issue a decision on whether to grant or refuse a license. This period may be extended by an additional 20 working days if the NBS requests additional information from the applicant.
Post- Licensing Duties
Obtaining a license marks the beginning of ongoing regulatory supervision. Licensed CASPs operate as financial institutions and must meet continuous obligations across financial, compliance, and tax areas.
Financial and reporting duties
- All licensed CASPs must have annual financial statements audited by an independent auditor approved by the NBS.
- The required minimum capital must be maintained at all times.
- Client funds and crypto-assets must be fully separated from company assets.
- Regular reports must be filed with the NBS.
Compliance and Operational Duties
- Ongoing transaction surveillance, KYC/CDD procedures for all clients, and filing of suspicious transaction reports with the FIU are mandatory.
- ICT systems, cybersecurity, and business continuity plans must be maintained, tested, and updated regularly.
- All client identification and transaction records must be retained for at least 5 years.
Tax and Accounting Duties
Under Slovak accounting rules, cryptocurrencies are classified as short-term financial assets, not intangible assets as under the International Financial Reporting Standards (IFRS). Crypto-to-crypto exchanges are considered taxable transactions, while income from staking or mining is taxed only upon disposal of the asset. Slovakia applies a progressive corporate income tax rate:
- 10% on income up to €100,000
- 21% on income from €100,000 to €5,000,000
- 24% on income above €5,000,000
Conclusion
Slovakia’s crypto regulation framework is maturing. What was once a simple registration process is now a structured licensing regime aligned with EU financial standards. For serious operators, this brings both higher expectations and stronger credibility within the European market.
The National Bank of Slovakia is taking a practical but firm approach. Applicants who prepare early, engage directly with the regulator, and build compliance into their foundation will be well-positioned to continue their operations. Those who delay risk exclusion from the market.
With MiCA now active, Slovakia offers an efficient route to full EU market access under one license. For businesses ready to meet the standard, Slovakia offers an opportunity to operate under clear rules and gain long-term regulatory stability.
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