MiCAR in Czech Republic
The EU Markets‑in‑Crypto‑Assets Regulation (MiCA) already applies in the Czech Republic, but Prague has gone further by hard‑coding the regime in national law. Act No. 32/2025 Coll. – the “Digital Finance Act” – took effect on 15 February 2025 and amends more than twenty financial statutes so that Czech supervisors can exercise all MiCA powers, set fees and impose sanctions directly in Czech crowns.
The Czech National Bank (CNB) is the designated “competent authority” for every MiCA title. It will authorise crypto‑asset service providers (CASPs), vet white papers for asset‑referenced tokens (ARTs) and e‑money tokens (EMTs), and police the new market‑abuse rules. The CNB has announced that it is “ready to receive applications and notifications” now that the Digital Finance Act is in force. The Ministry of Finance’s Financial Analytical Office (FAU) remains the AML supervisor; its guidance confirms that anyone wishing to offer MiCA‑covered services must obtain a CNB licence, while NFT‑style activities that fall outside MiCA continue to be registered with the FAU.
Unlike many EU states, the Czech Republic has chosen a short grandfathering period. CASPs that were already operating lawfully before 30 December 2024 may keep doing so only until 31 July 2025 – or until the CNB grants or refuses their MiCA licence, whichever comes first. To benefit from this grace period, firms must file a complete application with the CNB by that same 31 July 2025 deadline.
Draft CNB forms require:
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incorporation of an EU‑established legal entity (usually a Czech s.r.o. or a local branch of another EU company);
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a MiCA‑compliant governance framework, including two fit‑and‑proper directors resident in the EU;
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evidence of own‑funds in line with MiCA Article 67 (EUR 50 000 – 150 000, depending on the services);
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robust ICT and cyber‑risk documentation that will later be assessed under the EU Digital Operational Resilience Act; and
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a detailed white paper for any planned public offering or trading admission of crypto‑assets. These requirements are summarised in Czech practitioner commentaries aimed at issuers and CASPs.
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• Final ESMA/EBA technical standards are expected in late 2025; the CNB will update its application pack immediately afterwards.
• Firms that miss the 31 July 2025 filing deadline must cease Czech operations until they secure a full MiCA licence.
• Supervisory priorities for 2025‑26 include client‑asset safeguarding, market‑abuse surveillance and early alignment with DORA cyber‑resilience testing.
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