Norway’s MiCAR Licensing Regime

A startup requires authorisation before it may:

1. Issue asset‑referenced tokens to the public or seek their admission to trading.

2. Issue e‑money tokens (stablecoins referencing one official currency) to the public or seek their admission to trading.

3. Provide any crypto‑asset service listed in MiCA Part V—including custody, operation of a trading platform, exchange of crypto‑assets for funds or other crypto‑assets, execution of client orders, placing, portfolio management or advice.

4. Continue activities previously registered only for anti‑money‑laundering purposes (e.g., virtual‑currency exchange or wallet services) after 30 December 2025 unless a MiCA licence has been granted or refused earlier.

• Classify Your Business Model

  • Identify whether you are an issuer (token creator) or a service provider (CASP). Multiple licences may be required if you perform several regulated functions.

• Prepare the Application Package for Finanstilsynet

  • Corporate documentation – articles of association, registered office in the EEA, organisational chart.

  • Programme of operations – detailed description of planned services, business model, target client groups, outsourcing arrangements and use of distributed‑ledger technology.

  • Governance & internal controls – evidence that all directors and senior managers are “fit and proper”, plus policies for risk management, conflicts of interest, complaints handling, cyber‑security and business continuity.

  • Capital & prudential resources – proof that you meet the initial capital or own‑funds requirements that MiCA sets for the relevant service category.

  • AML/CFT compliance framework – policies, customer‑due‑diligence procedures, transaction monitoring tools and appointment of a compliance officer.

  • Insurance or similar guarantee – where MiCA requires professional indemnity coverage (e.g., custody).

  • Crypto‑asset white paper (if issuing) – drafted in Norwegian or English, containing the prescribed disclosures; submit it to Finanstilsynet and publish it before the public offer or admission to trading.

• File the Application

  • Submit electronically to Finanstilsynet. The Authority will acknowledge receipt and may request further information during review.

• Regulatory Assessment

  • Finanstilsynet evaluates completeness, managerial suitability, operational soundness, capital adequacy and investor‑protection safeguards. Site visits or interviews can be ordered.

• Decision & Publication

  • A written authorisation decision is issued and published on Finanstilsynet’s website. Conditions or limitations can be attached. Once licensed, your firm is entered in the public register of crypto‑asset service providers/issuers.

• Post‑Authorisation Obligations

  • Ongoing reporting of significant changes, periodic financial information, incident notifications and market‑abuse monitoring.

  • Continuous compliance with white‑paper duties, marketing standards and MiCA conduct rules.

  • Immediate cooperation with any information requests or onsite inspections.

Firms already registered for AML purposes as exchange or custody providers may keep operating until 30 December 2025 at the latest, but must apply for and receive a full MiCA licence before that date to continue legally thereafter.