Estonia Financial Licensing — CASP (MiCA/FSA), EMI/PI & Crypto

Since 30 December 2024, crypto-asset service providers (CASPs) are licensed and supervised by the FSA (Finantsinspektsioon) under MiCA — not the FIU. The bar: minimum paid-in capital of €50,000–€150,000 by service class, a physical office in Estonia, an experienced AML officer, a detailed AML/KYC programme, and board members who pass fit-and-proper. Review runs 6–12 months. The old FIU VASP regime is now legacy — before 2022 Estonia issued VASP licences with almost no requirements, over 1,400 entities piled up, and the FIU revoked most — and the remaining FIU VASP registrations lapsed on 1 July 2026, so crypto-asset services now need an FSA authorisation.

Under MiCA the minimum capital for a CASP authorisation from the FSA is €50,000, €125,000 or €150,000, set by the service class you provide. It must be genuinely paid in, not nominal. The FSA also weighs ongoing own funds against the volume and risk of the crypto-asset services — larger operators hold a buffer above the floor. The legacy FIU VASP figure of €250,000 applied only to registrations that ran out the transition, which ended on 1 July 2026.

The Financial Supervisory Authority (Finantsinspektsioon, FSA) supervises and licenses crypto-asset service providers (CASPs) under MiCA, payment institutions (PI), electronic money institutions (EMI), investment firms, credit institutions, and insurers. EMI and PI licences under PSD2 and EMD2 give passporting into all 30 EEA states — and a MiCA CASP authorisation passports too. The full FSA package — regulatory business plan, capital-requirement modelling, fit-and-proper — we run end to end.

The FSA's target review period for an EMI application is 3 months from a complete submission. In practice — with pre-application consultations, document preparation, and FSA queries — the whole path takes 6–12 months. Minimum starting capital for a full EMI licence is €350,000; for a small EMI (limited activities), €50,000. The regulatory business plan, AML programme, and IT-security documentation, we prepare ourselves.

Only a MiCA one. A legacy VASP licence from the Estonian FIU was purely domestic and granted no EU passporting rights. Under MiCA (the Markets in Crypto-Assets Regulation), in force across the EU since December 2024, crypto-asset service providers (CASPs) hold FSA authorisation — and that's what carries the passport.