Insights · Crypto

MiCA licence in Luxembourg or the Netherlands: the CASP guide for 2026

The MiCA transition is over: since 1 July 2026 every crypto-asset service provider in the EU needs an authorisation. Capital classes, CSSF or AFM, what the file needs, how long it takes and what DAC8 adds, with a readiness check.
Check my readiness ↓

Reading time7 minutes
TopicMiCA and crypto
Rules as ofOctober 2026
AuthorAlexander Baranov
The short version

Every crypto-asset service provider serving EU clients now needs a MiCA authorisation: the Dutch transition ended in June 2025 and all others by 1 July 2026. Capital is EUR 50,000, 125,000 or 150,000 by service class. The firm needs an EU registered office, effective management in the EU and an EU-resident director. The AFM licensed the first CASPs in Europe and suits retail; Luxembourg's CSSF suits institutional and custody business. Plan six to twelve months.

01 · The rule

MiCA in 2026: no licence, no business

The Markets in Crypto-Assets Regulation applies in full since 30 December 2024. The transitional periods that let existing firms keep operating under national registrations have now ended everywhere: the Netherlands closed its window on 30 June 2025, Luxembourg and the rest of the EU by 1 July 2026. A crypto business serving EU clients today either holds a CASP authorisation or is out of the market.

Passport

One licence, 27 countries

An authorisation in one member state lets you serve clients across the EU.

Substance

Real EU presence

Registered office, effective management and a resident director in the EU.

Capital

EUR 50,000 to 150,000

By class of service, or a quarter of fixed overheads.

Tax data

DAC8 from 2026

Client transactions reported to tax authorities from 2027.

02 · Classes

Services and capital classes

ClassServicesMinimum capital
Class 1Advice, receiving and transmitting orders, executing orders, placing, transfers, portfolio managementEUR 50,000
Class 2Class 1 plus custody and administration, exchange for funds or other cryptoEUR 125,000
Class 3Class 2 plus operating a trading platformEUR 150,000

Capital must be held in cash or eligible instruments, and a quarter of last year's fixed overheads applies if higher. Custody also needs segregation of client assets and a liability regime for losses.

03 · Where

Luxembourg or the Netherlands?

LuxembourgNetherlands
RegulatorCSSFAFM, with DNB for stablecoins and integrity checks
Transitional periodEnded 1 July 2026Ended 30 June 2025
Track recordInstitutional, custody, funds and tokenisationFirst EU CASP licences on 30 December 2024; broad retail and payment players
Typical client baseBanks, funds, professional investorsRetail and professional
Corporate taxAbout 23.87%19% up to EUR 200,000, 25.8% above
Talent and languageInternational, multilingualLarge English-speaking tech market
Choose the regulator that understands your clients. The passport does the rest.
04 · Application

What the regulator wants to see

  • A precise business plan. Services, clients, countries, revenue model and three years of financials; generic plans are the first reason for refusal.
  • Fit and proper management. Directors with crypto and financial services experience, at least one resident in the EU, and real time in the business.
  • Financial crime controls. AML and sanctions framework, travel rule for transfers, transaction monitoring.
  • ICT and DORA. Operational resilience, outsourcing and third-party risk under DORA.
  • Custody and conflicts. Segregation, reconciliation and complaint handling, with policies that match what you really do.
  • Local substance. Office, people and decisions in the licensing country.
Building the EU entity behind a MiCA licence?We set up the Luxembourg or Dutch company, provide resident directors, office and accounts, and work alongside your regulatory counsel on the application.
Book a free call
05 · Your case

Check your MiCA readiness

The result updates with each answer.

MiCA readiness check

Tick your services and answer four questions. You get your capital class, the regulator and the gaps to close.

Which crypto services will you offer?
Clients
Management and team
Do you already hold a licence?
Preferred country
01Transition is over

Every CASP needs authorisation since 1 July 2026.

02Capital by class

EUR 50,000, 125,000 or 150,000.

03Real EU substance

Office, management and a resident director.

04DAC8 is live

Client transactions reported from 2027.

06 · FAQ

MiCA licences in Luxembourg and the Netherlands: frequent questions

Do I need a MiCA licence in 2026?

Yes, if you provide crypto-asset services in the EU. All national transitional periods ended by 1 July 2026; the Dutch one ended on 30 June 2025. Since then every crypto-asset service provider needs a CASP authorisation.

How much capital does a CASP need?

EUR 50,000 for advice, order handling, placing, transfers and portfolio management; EUR 125,000 if you also hold client assets or exchange crypto; EUR 150,000 for a trading platform; or a quarter of last year's fixed overheads if higher.

How long does a MiCA licence take?

The regulation gives 25 working days to check completeness and 40 to decide, but with questions and preparation most firms should plan six to twelve months.

Luxembourg or the Netherlands for a MiCA licence?

The AFM issued the first MiCA licences in the EU and has a track record with crypto firms. Luxembourg's CSSF is slower but strong for institutional, custody and fund-related business. Both give an EU passport.

Can a non-EU company get a MiCA licence?

Only through an EU company with its registered office and place of effective management in the EU and at least one director resident in the EU.

What is DAC8?

The EU directive that makes crypto-asset service providers report their clients' transactions to tax authorities. It applies from 1 January 2026, with first reports in 2027.

Your structure

Building the EU company behind your MiCA licence?

We set up the Luxembourg or Dutch entity, provide resident directors, office, payroll and accounts, and work alongside your regulatory counsel on the CASP file.