Key Requirements, Documents & Approval Timelines

The European Union’s Markets in Crypto-Assets Regulation has made regulatory compliance a priority for businesses operating in the digital asset space. For exchanges, custodians, wallet providers, and Web3 platforms, securing a MiCA crypto license is now essential to legally offer services across EU member states. The MiCA License Application process requires careful preparation, covering governance, compliance frameworks, technical infrastructure, and financial stability.

Understanding MiCA license requirements, documentation standards, regulatory processes, and approval timelines is critical for avoiding delays and compliance risks. This guide is designed for the decision-makers seeking clarity on how to prepare effectively. With support from an experienced blockchain legal consultant, crypto businesses can align with EU regulations and build a strong foundation for long-term, compliant growth through professional crypto license services.

What is a MiCA Crypto License?

A MiCA crypto license authorises businesses to operate as Crypto-Asset Service Providers within the EU. It replaces fragmented national regimes by setting minimum standards for investor protection, governance, capital, risk management, and disclosure.

Activities requiring authorisation typically include:

• Custody and administration of crypto-assets
• Crypto trading and exchange services
• Execution and transmission of orders
• Portfolio management and advisory services
• Placing of crypto-assets
• Reception and transmission of crypto orders on behalf of clients

Once granted, a MiCA crypto license can be passported across all EU member states, eliminating the need to apply separately in each jurisdiction

Who Needs a MiCA License?

Any entity that offers crypto-asset services to EU clients must hold a MiCA license unless an exemption applies. This includes, but is not limited to:

• Crypto exchanges and trading platforms
• Custodial services and wallet providers
• Brokers and liquidity providers
• Crypto investment advisory and portfolio management firms
• Issuers of asset-referenced tokens (ARTs) and e-money tokens (EMTs) 

Even if your entity is incorporated outside the EU, offering services to EU clients triggers MiCA compliance. Non-compliance can result in significant penalties and legal action. 

Understanding MiCA License Requirements

A successful MiCA license application hinges on satisfying a structured set of regulatory requirements that speak to an applicant’s financial, operational, governance, and compliance capabilities.

1. Legal and Corporate Requirements

• Applicant must be a legal entity established in an EU member state.
• Demonstrably effective place of management and registered office in that state.
• Transparency about owners and stakeholders.
• Appropriate legal form and registration documents must be provided. 

2. Governance and Management

Regulators expect a robust governance structure with clarity around roles, responsibilities, and reporting lines. Senior management must be of good standing and possess suitable expertise. 

3. Financial and Capital Requirements

Applicants must demonstrate adequate funds and capital to ensure regulatory and operational resilience. Requirements vary by member state and service type, and NCAs set specific minimum thresholds.

4. Compliance and Risk Framework

A MiCA candidate must show strong policies for:

• Anti-Money Laundering (AML) and Counter-Financing of Terrorism (CFT) compliance
• Risk management and internal audit
• Customer data protection and operational risk controls
• Consumer safeguards and dispute resolution mechanisms 

Integration with regulations like the Digital Operational Resilience Act (DORA) may be expected in certain jurisdictions to strengthen digital risk management.

Documents Required for a MiCA License Application

NCAs generally expect an extensive documentation package, though exact requirements differ by jurisdiction. Common document types expected include:

1. Core Corporate Documents

• Legal entity registration and articles of association
• Beneficial ownership and shareholder structure
• Contact information for the responsible regulatory relations personnel 

2. Business Plan and Operational Strategy

• Description of crypto services
• Target markets and revenue model
• Financial projections and capital utilization plan 

3. Compliance Documentation

• AML/KYC policies and procedures
• Risk management plan
• Consumer protection and complaint handling approaches

4. Technical and Security Documents

• ICT architecture and cybersecurity arrangements
• Incident response and monitoring mechanisms
• Client asset segregation policies
• Network and systems resilience documentation 

5. Governance and Expertise Evidence

• Profiles and qualifications of board members and key executives
• Evidence of risk oversight and governance controls 

Step-by-Step MiCA License Application Process

Navigating the MiCA License Application consists of several phases:

1. Preparation & Pre-Application Assessment

Conduct a compliance gap analysis and readiness assessment. This may take several months, depending on existing maturity. 

2. Document Compilation and Policy Drafting

Draft and refine all internal policies, technical descriptions, governance documents, and financial plans. This phase can be the most time-intensive. 

3. Application Submission

Submit the complete application to your chosen NCA through the official portal along with the applicable fees. 

4. Completeness Check and Clarifications

Regulators verify whether the submission is complete. Timelines vary by member state, and additional information may be requested.

5. Regulatory Review, Dialogue, and Approval

During this period, the regulator conducts a substantive assessment, which can include interviews, additional documentation requests, and extended evaluation. 

Once approved, your entity becomes a licensed CASP under MiCA, thus enabling legal operations across the EU. 

Timelines & Transitional Periods

MiCA’s transitional regime under Article 143 allows incumbent providers who were legally operating before 30 December 2024 to continue offering services while their CASP application is pending. This transitional period can last until 1 July 2026 or until authorisation is granted or refused, but member states may shorten or opt out of this period. 

As transitional timelines vary, many regulators encourage early engagement to avoid operational disruptions.

MiCA Passporting & Supervision

Once authorised, a CASP can operate in all EU member states under a single licence – a benefit known as passporting. The European Securities and Markets Authority (ESMA) maintains an interim register of authorised CASPs and non‑compliant entities to enhance transparency and supervisory convergence across the EU. 

Common Application Challenges and How to Overcome Them

1. Incomplete or Inadequate Documentation

Incomplete documentation is one of the most common reasons regulators delay or reject applications. Starting early and aligning all teams on document standards is key.

2. Governance and People Risk

Regulators scrutinize governance depth, independence, and executive experience. Lack of evidence of proper oversight can raise red flags.

3. Technical and Operational Gaps

Failing to demonstrate robust ICT systems, AML/CFT processes, or risk controls often slows approvals.

Engaging a blockchain legal consultant early helps companies understand expectations and pre-empt common issues, thus reducing rework and maximising approval probability.

The Role of a Blockchain Legal Consultant

Given the complexity of MiCA, many companies choose to work with specialist advisors who can:

• Conduct compliance gap assessments
• Draft regulator-ready documentation
• Advocate with National Competent Authorities
• Integrate MiCA requirements with broader legal obligations
• Provide ongoing compliance support post-licensing

Working with a Web3 legal consulting firm significantly increases your chances of meeting MiCA licence requirements on time and within budget.

Building a Compliant Path Forward Under MiCA

Preparing for a MiCA License Application is not just a regulatory task—it is a strategic step toward sustainable operations in the European crypto market. From meeting MiCA license requirements to submitting regulator-ready documentation and managing approval timelines, each phase demands accuracy, planning, and compliance expertise. Businesses that underestimate this process often face delays or regulatory challenges.

By adopting a structured approach and working with a specialized Web3 legal consulting firm, organizations can navigate MiCA compliance with confidence. Antier provides end-to-end crypto license services, supporting businesses with regulatory strategy, documentation, and ongoing compliance. Backed by experienced blockchain legal consultants, Antier helps crypto enterprises build a secure, compliant foundation for scalable growth across the EU.