Malta vs. Ireland CASP License: Comparing 2 of the Best EU Jurisdiction for Your Crypto Business

The implementation of the Markets in Crypto-Assets (MiCA) regulation marks a watershed moment for the European digital asset industry. For the first time, a harmonised legal framework allows crypto-asset service providers (CASPs) to operate across the entire European Economic Area (EEA) with a single authorisation. 

This mechanism, known as “passporting,” allows a company licensed in one Member State to offer its services in all 27 other countries without the need for additional physical presence or local licenses in those jurisdictions.

Choosing the right home Member State for this passport is the most critical strategic decision a business seeking a crypto license in Europe will make in 2025. While many jurisdictions are racing to attract crypto businesses, two islands stand out for very different reasons: Malta and Ireland. While both jurisdictions offer EU-wide access, Malta offers speed and a mature crypto-specific framework, while Ireland offers a Tier-1 reputation with a rigorous, measured authorisation process.

Malta: The “Blockchain Island” approach

Malta has a long-standing reputation in the digital asset space. It was the first EU jurisdiction to introduce a comprehensive regulatory framework for crypto-assets via the Virtual Financial Assets Framework in 2018. This early adoption created a deep pool of expertise among local regulators, lawyers, and service providers, giving Malta a significant head start over other EU nations that are only now operationalising their crypto frameworks.

Regulatory maturity 

The transition from the national VFA regime to the EU-wide MiCA regulation in Malta has been smoother than perhaps anywhere else. Because the VFA Act was largely modelled on MiFID II principles—similar to MiCA—the Malta Financial Services Authority (MFSA) and local businesses were already accustomed to high standards of compliance, governance, and capital adequacy. The MFSA has updated its rulebooks to align perfectly with MiCA, ensuring legal certainty for operators.

Transition for existing firms 

A unique advantage for Malta is the treatment of incumbent firms. Entities that were already licensed under the VFA Act by 30 December 2024 benefit from a grandfathering period. These firms can continue to operate under the VFA framework until 1 July 2026, or until they are granted or refused a CASP authorisation under MiCA, whichever comes first. This provides a stable runway for businesses to adapt to the new EU standards without disrupting their operations.

Licensing process 

The Maltese licensing process is known for being dynamic. The MFSA encourages open dialogue with applicants, and the ecosystem is designed to facilitate business. This efficiency is driven by the regulator’s familiarity with crypto business models, from crypto exchanges to custodians, which they have supervised for over five years.

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Ireland: The tech hub approach

Ireland approaches the crypto sector not as a niche pioneer, but as an established global technology hub. Home to the European headquarters of giants like Google, Meta, and Stripe, Ireland offers an ecosystem deeply integrated with traditional finance and big tech.

Regulatory maturity 

Unlike Malta, Ireland did not have a bespoke crypto licensing regime prior to MiCA. It operated a Virtual Asset Service Provider (VASP) registration regime strictly for Anti-Money Laundering (AML) and Countering the Financing of Terrorism (CFT) purposes.

Consequently, Ireland is moving from a basic registration regime to active MiCA licensing in 2025. For companies interested in token issuance in Ireland or full CASP services, this means the regulatory pathway is less “battle-tested” than Malta’s, but it benefits from the prestige of the Central Bank of Ireland (CBI).

Licensing process 

The CBI is known for its “gatekeeper” mentality. The licensing process is rigorous and front-loaded. It involves a pre-application phase where applicants must submit a “Key Facts Document” before a full application is even considered. The regulator focuses heavily on governance, detailed capital projections, and the segregation of client assets. 

Applicants often refer to the Central Bank of Ireland’s “Guidance Note for Crypto-Asset Service Providers” for deep dives on governance requirements to prepare for this scrutiny. While Ireland had no full CASP authorisations by December 2024, active licensing began in earnest in 2025, attracting major players like Coinbase and Kraken, who value the reputational alignment with the US and UK markets.

Related: 5 Reasons Why Ireland Is the Top ICO Country in the ESMA Register

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Malta vs Ireland CASP: Head-to-head comparison

When deciding between these two jurisdictions, businesses must weigh several factors, including speed, cost, tax efficiency, and risk appetite.

Speed of authorisation 

Time-to-market is often the deciding factor for startups and agile fintechs.

• Malta: The process is fast. Recent cases have seen authorisations move from submission to decision in weeks to months, rather than years. However, this speed has attracted attention. A July 2025 report by the European Securities and Markets Authority (ESMA) criticised the MFSA for approving licenses too quickly, specifically citing the granting of licenses to major exchanges like OKX and Crypto.com shortly after regulations came into force. While this scrutiny implies a need for caution, it highlights Malta’s commitment to business efficiency;
• Ireland: The process is measured and rigorous. The CBI requires deep engagement and will not be rushed. Applicants must provide detailed financial projections for the first three years and demonstrate robust substance before a license is granted.

Costs, capital, and fees 

The cost of doing business varies significantly between the two jurisdictions, both in terms of regulatory fees and operational overhead.

• Malta: Malta offers a transparent fee structure that has remained competitive. Under the VFA framework, which set the baseline for the current regime, the annual supervisory fees were categorised clearly:
  • Class 1 (Advisory): EUR 6,000;
  • Class 2 (Custody/Wallet): EUR 10,000;
  • Class 3 (Exchange): EUR 14,000;
  • Class 4 (Complex/VFA Exchange): EUR 24,000. While MiCA brings its own fee schedule, Malta remains cost-effective regarding professional services and labour;
• Ireland: Ireland is a high-cost jurisdiction. The requirement for substantive presence (senior management and key function holders residing in Ireland) drives up operational costs significantly. Application fees vary by scale, but the real expense lies in salaries, office space in Dublin, and legal counsel. Annual pan-European compliance costs are estimated between EUR 200,000 and EUR 700,000 depending on the jurisdiction and scale, with Ireland sitting at the top end of that spectrum.

Tax environment 

Fiscal efficiency is a major differentiator.

• Malta: Malta’s tax system is highly attractive for international business. While the headline corporate tax rate is 35%, the full imputation system allows shareholders to claim refunds that can reduce the effective tax rate to as low as 5% on trading income. Furthermore, for individuals, there is generally 0% tax on long-term holdings of crypto-assets (capital gains), provided the trading is not executed as a business activity;
• Ireland: Ireland’s tax regime is less favourable for crypto specifically. The country applies a flat 33% Capital Gains Tax on crypto disposals. Unlike its intellectual property (IP) boxes or general corporate tax rate of 12.5% for trading companies, no preferential regimes currently exist specifically for crypto-asset gains.

Reputation and risk

• Malta: Malta has the highest volume of licenses in the EU after Poland and Lithuania. It is the “crypto-native” choice. However, it faces ongoing scrutiny regarding the quality of due diligence, as highlighted by the ESMA report. It is a jurisdiction for companies that want to move fast and be understood by their regulator;
• Ireland: Ireland positions itself as a “safe and sound” jurisdiction. A license from the CBI is viewed as a badge of quality, offering higher trust with traditional banks and institutional partners. It is the choice for companies preparing for an IPO or those heavily integrated with the traditional banking sector.

Conclusion

The choice between Malta and Ireland depends on the specific DNA of your crypto projects. Malta offers a plug-and-play environment with a regulator that speaks the language of crypto, while Ireland offers an institutional stamp of approval at a higher price point.

Summary of pros and cons

Final verdict 

If your priority is speed, fiscal efficiency, and specific crypto experience, Malta is the superior choice. The MFSA’s rulebook is mature, the fees are transparent, and the transition for existing VFA holders is seamless.

If your priority is institutional reputation, proximity to big tech, and traditional banking integration, and you have the capital to support high operational costs, Ireland is the correct path.

At LegalBison, we can assist you in navigating the application process for both jurisdictions, ensuring your business model aligns with the local requirements for substance and governance.

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