Estonia Crypto License

Estonia moved crypto from an Anti Money Laundering (AML) registration matter to a financial services authorization matter. The Crypto Markets Act brought issuance, offers, admission to trading, and crypto asset services under FSA supervision. The act distinguishes three tracks: asset referenced token (ART) issuance, e-money token (EMT) issuance, and other crypto asset services, which is the CASP track most founders need.

The FSA licensing page states the CASP test directly. An applicant must meet the conditions of MiCA Article 62 and section 6(1) of the national act, and submit proper and complete information on the ESMA form.

The file covers the program of operations, prudential safeguards under Article 67, governance, management reputation and experience, qualifying shareholders, internal controls including money laundering and terrorist financing risk, ICT systems and security, client asset segregation, complaints handling, and service-specific policies for custody, trading platforms, exchange, order execution, advice, portfolio management, and transfers. The application goes in Estonian; English documents are possible only when the applicant states so in the filing.

The transitional story ended on schedule. The FIU and the FSA confirmed jointly on 30 June 2026 that from 1 July only authorized firms may operate. The FIU cancelled the old register data on that date. Firms without an authorization may not take new clients, open new accounts, or market actively to EEA clients.

Firms still in the application queue must limit activity until the decision lands. All firms that provided virtual currency services in the second quarter of 2026, including cancelled ones, had to file their regular reports through the Eesti Pank portal by 20 July 2026.

Scale of the cleanup puts the regime change in context. The FIU counted 641 valid VASP licenses when it started cleaning the sector in mid-2021. Thirty-six remained at the start of 2026. By the end of June 2026, one firm held a fresh FSA CASP authorization, Lightspark Payments Europe AS, alongside institutions operating under existing rights such as LHV Pank and Lightyear Europe AS, plus several EEA-authorized firms serving Estonia cross-border.

External sources: FSA operating license page for crypto asset markets, FIU and FSA end-of-transition notice of 30 June 2026, Crypto Markets Act in the State Gazette, ESMA MiCA page.

MiCA sets one Union standard for crypto market entry. Title II covers offerors of crypto assets other than ARTs and EMTs through notified white papers. Title III covers ART issuers. Title IV covers EMT issuers. Title V covers CASPs: custody, trading platform operation, exchange of crypto assets for funds or for other crypto assets, order execution, order reception and transmission, portfolio management, placement, transfer services, advice, and transfer execution on behalf of clients.

Estonia adds one local nuance worth knowing. Licensed banks, e-money institutions, investment firms, and similar institutions can serve as CASPs under MiCA Article 60 by notifying the FSA, without a full Article 62 authorization.

Everyone else files the full CASP application. Either way, the authorization passports across all 27 member states after home notification under Article 65. The MiCA license overview explains the Union framework, the CASP license guide details the service classes, and the MiCA regulation tracker follows national implementation across member states.

From 2017, Estonia registered virtual currency exchangers and wallet providers through the FIU under the Money Laundering and Terrorist Financing Prevention Act. The market called that entry the Estonian crypto license of its era.

Founders still searching for the old cryptocurrency license in Estonia should know that track is closed history, not a live option. At its peak the regime was famously light: fast entry, low capital, remote setup. That lightness became the problem. After risk events that hurt the country’s reputation, the FIU tightened supervision from 2021, revoked hundreds of licenses, and raised the state fee and substance bar.

The Crypto Markets Act replaced that regime in July 2024. VASP holders received the maximum 18-month grandfathering window, to 1 July 2026, to align with MiCA and obtain an FSA authorization. The FSA warned in March 2026 that late filers were unlikely to beat the deadline and had to attach a wind-down plan to any new application. On 1 July 2026 the window shut and the FIU register with it.

Founders still ask about the old track because it was fast and cheap. It no longer opens. The VASP license guide covers the EU-wide shift from national registers to MiCA authorization.