CASP licensing: What it is, requirements, and how to obtain it

by bvnlaw22 | Jul 8, 2025 | News & Analysis

What is CASP license under MiCA is a question that many crypto entrepreneurs are asking. Under the Markets in Crypto-Assets Regulation (MiCA), a Crypto-Asset Service Provider (CASP) is a legal person or other type of undertaking that offers one or more crypto-asset services to clients on a professional basis and is authorized to do so under Article 59 of the Regulation (EU 2023/1114). The definition is set out in Article 3(1)(15) of MiCA, which makes it clear that only legal entities (not natural persons) can qualify as CASPs, and they must meet the conditions for authorisation.

To become an authorised CASP, an applicant must obtain prior approval from the competent authority in the EU Member State where it is established. This authorisation process ensures that the provider has in place appropriate internal structures, systems, and safeguards. The requirements include the establishment of effective governance arrangements, internal controls, risk management systems, ICT security frameworks, and mechanisms for safeguarding clients’ assets. In addition, CASPs must demonstrate that their management is composed of individuals who are fit and proper to carry out the business, and that they have sufficient capital or equivalent insurance coverage to meet prudential standards.

CASPs are only permitted to offer crypto-asset services that are clearly defined under MiCA. These services include offering to the public of crypto-assets other than asset-referenced tokens or e-money tokens, custody and administration of crypto-assets on behalf of clients, operation of a trading platform for crypto-assets, exchange of crypto-assets for funds or for other crypto-assets, execution of client orders, placing of crypto-assets, receiving and transmitting orders, providing advice on crypto-assets, and portfolio management of crypto-assets. Once authorised, a CASP may also benefit from passporting rights, allowing it to provide services across the EU without needing separate national authorisations in each Member State.

The provisions relating to CASPs will apply from 30 December 2024, at which point entities currently operating in the crypto sector will need to comply with the new regulatory framework or cease their activities. The objective of MiCA is to bring greater legal clarity, investor protection, and market integrity to the rapidly evolving crypto-asset market across the European Union.

CASP Authorisation – Required Documents (per MiCA Article 60 & Annex I)

To obtain authorisation as a CASP under MiCA, an applicant must submit a comprehensive application to the competent authority of the EU Member State where it is established. The application must demonstrate that the applicant meets all the organisational, operational, prudential, and governance requirements set out in Articles 59 to 63 and Annex I of the Regulation.

One of the core elements of the application is the programme of operations, which provides a clear description of the crypto-asset services the applicant intends to offer, the types of crypto-assets involved, the target client groups, and the intended geographic scope. This should also detail any planned outsourcing arrangements. Alongside this, the business plan must set out a thorough overview of the business model, financial forecasts for the next three years – including projected profit and loss statements, balance sheets, and capital adequacy figures – and information on funding sources and expected income.

The applicant must also provide details of its organisational structure, including the legal form and ownership structure of the entity, supported by an organisational chart that outlines departments, reporting lines, and staffing levels. Full information on shareholders or owners holding significant stakes, whether directly or indirectly, must be disclosed.

Another critical requirement is evidence of sound governance. This includes the submission of a list of managers and board members, along with their CVs and certificates confirming clean criminal records, to demonstrate that they are fit and proper persons. Applicants must also present policies and procedures covering internal controls, risk management, audit, complaint handling, and business continuity.

The application must describe the applicant’s ICT systems and cybersecurity infrastructure, outlining how it protects client data and ensures operational resilience. Furthermore, the applicant must detail how it will safeguard client assets, showing how client funds or crypto-assets will be held separately from the firm’s own assets and disclosing any custodial arrangements.

Proof of prudential safeguards is also necessary. CASPs must meet capital requirements by either holding a minimum level of own funds or securing appropriate insurance or guarantees. The minimum own funds requirement varies depending on the services offered but generally ranges from €50,000 to €150,000, or 25% of the provider’s fixed overheads.

In addition to the above, applicants must submit policies addressing anti-money laundering (AML) and counter-terrorism financing (CTF), conflicts of interest, outsourcing, and consumer protection. They must also provide documentation on how they handle client complaints, including access to redress mechanisms.

If applicable, CASPs must include further details on trading or order execution procedures, especially if they intend to operate platforms or manage client portfolios. Lastly, the application should confirm that the provider is registered with the appropriate national financial intelligence unit under AML regulations and may include any other relevant legal or technical documentation required by the competent authority.

Once the application is complete, the competent authority is expected to assess and respond within 40 working days. This authorisation process is essential to ensure that CASPs operate safely, transparently, and in compliance with EU regulatory standards.

✅ CASP Application Checklist (MiCA – Article 60 & Annex I)

Below is a checklist with the most frequently required documents for CASP licensing:

Why choose Bulgaria?

There are several compelling reasons why potential entrepreneurs should consider Bulgaria as a base for launching crypto-related startups and obtaining CASP (licensing under the EU’s MiCA framework:

🇧🇬 1. EU Single market access through a cost-efficient jurisdiction

Bulgaria is a full member of the European Union, which means that once a CASP license is granted by the Financial Supervision Commission (FSC), the provider gains passporting rights under MiCA—allowing the company to offer crypto-asset services across all EU Member States.

At the same time, Bulgaria has one of the lowest operational costs in the EU. This includes low corporate taxes (10%), competitive labor costs, and affordable legal and accounting services, relatively good access to e-government services. This makes it an ideal jurisdiction for cost-sensitive startups.

📜 2. Forward-Looking Regulatory Framework (MiCA Alignment)

Bulgaria has just adopted the Crypto-Asset Markets Act (CAMA), which aligns national rules with MiCA. The proposed framework reflects a clear intention to encourage innovation while ensuring regulatory certainty. Establishing early in a MiCA-aligned jurisdiction positions your startup to benefit from first-mover advantage, as regulation across the EU becomes fully harmonized.

🏦 Robust but Accessible Licensing Process

Compared to some larger EU economies, Bulgaria is shaping its regulatory framework to be structured but not overly burdensome. The FSC is expected to provide clear guidance and reasonable timelines for CASP authorisation.  This makes Bulgaria attractive for small and medium-sized fintech and crypto startups seeking regulated status without the overhead of jurisdictions like Germany or France.

📈 Growing Fintech and Blockchain Ecosystem

Bulgaria is home to a vibrant and growing tech and fintech community, particularly in cities like Sofia and Plovdiv. The country has produced successful IT and blockchain ventures and offers a deep pool of skilled software engineers and compliance professionals.

In addition, several business incubators, venture capital funds, and accelerators are active in the country and increasingly supportive of blockchain innovation.

📑 Favorable Tax Environment and Business Setup

• Flat 10% corporate and personal income tax—among the lowest in the EU.
• Simple and fast company registration procedures.
• Access to EU funding and innovation grants for tech startups.
• Option to structure your startup flexibly, including remote teams and hybrid operations.

🛡️ AML-Compliant Reputation with Experience in Crypto Regulation

Bulgaria has already been regulating Virtual Asset Service Providers (VASPs) under its AML law, requiring registration with the national Financial Intelligence Directorate. This means that both the FSC and local professionals (legal, tax, compliance) have experience handling crypto-related businesses and are preparing for MiCA’s full implementation.

✅ Summary: Why Bulgaria?

• Full EU license recognition (passporting)
• Low taxes and affordable operations
• EU-compliant, modern crypto legislation
• Growing blockchain/fintech ecosystem
• Reasonable licensing costs and bureaucracy
• Access to EU tech talent, funding, and grants

Why choose Benov & Vasilev Attorneys at law?

If you plan to launch a CASP-licensed crypto business in Bulgaria, Benov & Vasilev offers seamless, practical support throughout your licensing and operation under MiCA.

✅ Full CASP Licensing Support
We handle the entire process: company setup, program of operations, business plan, AML/CTF policies, and regulator liaison.

✅ Crypto-Savvy Team
We have years of experience advising blockchain and fintech projects, ensuring your compliance while aligning with your business model.

✅ Cost-Efficient, Business-Focused
Based in Sofia, we offer high-quality legal services at competitive rates, helping you preserve budget while securing EU market entry.

✅ Long-Term Partnership
We support your EU expansion with cross-border strategies, GDPR compliance, IP protection, and VC investment documentation.

Benov & Vasilev Attorneys at law combines deep regulatory knowledge and crypto expertise to guide your venture confidently into the EU market.

Contact us to begin your CASP licensing process effectively!

https://bvnlaw.com/en/contacts/