Detailed overview
Czech Republic: CNB MiCA Authorisation under the Financial Market Digitalisation Act
The Czech Republic is a full MiCA jurisdiction. The Czech framework is based on Regulation 2023/1114 and the Czech Financial Market Digitalisation Act.
The Czech National Bank is the competent authority for MiCA activity in the Czech Republic. It receives MiCA applications and notifications and supervises crypto-asset service providers, relevant crypto-asset offerors, issuers and persons seeking admission of crypto-assets to trading.
The former Czech route under which crypto-asset services could be carried out as an unqualified trade has ended. New Czech-facing crypto-asset service activity must be structured through MiCA authorisation, a valid Article 60 notification route, a valid MiCA passport, or another applicable regulated route.
Regulator
The main regulator is the Czech National Bank.
The CNB is responsible for receiving CASP authorisation applications, receiving Article 60 notifications from eligible financial entities, supervising authorised CASPs, maintaining MiCA-related lists, and exercising supervisory powers under MiCA and Czech implementing law.
AML and non-MiCA activity may require separate analysis. A token or service that falls outside MiCA may still be regulated under another Czech or EU regime.
Licensing route
A person may not provide crypto-asset services in the Czech Republic unless it is authorised as a crypto-asset service provider under MiCA, is an eligible financial entity using the Article 60 notification route, or is passporting validly from another EU Member State.
The relevant crypto-asset services are custody and administration of crypto-assets for clients, operation of a crypto-asset trading platform, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of client orders, placing of crypto-assets, reception and transmission of orders, advice on crypto-assets, portfolio management on crypto-assets, and transfer services for clients.
Transfer services are a separate MiCA service and should be included in the service-mapping analysis.
The licence perimeter applies only where the asset is within MiCA. Tokens that qualify as financial instruments, deposits, structured deposits, fund interests, payment instruments, insurance products, e-money outside the relevant MiCA treatment, or other regulated products require separate analysis.
Article 63 authorisation
A standard unregulated Czech CASP applicant applies to the CNB for MiCA authorisation.
The applicant must be a legal person or other eligible undertaking. From August 2025, natural persons may no longer provide services falling within MiCA scope in the Czech Republic.
An Article 63 CASP must have its registered office in a Member State where it carries out at least part of its crypto-asset services, its place of effective management in the EU, and at least one EU-resident director.
A credible Czech application should include a full service map, legal perimeter analysis, programme of operations, business plan, legal-entity documents, governance materials, management fit-and-proper evidence, qualifying-holder information, proof of prudential safeguards, AML and counter-terrorist-financing policies, internal controls, risk management, business continuity, ICT and security documentation, DORA materials, complaints procedures, conflicts management, outsourcing arrangements, client-asset segregation procedures, client disclosures, fee and cost disclosures, and service-specific policies.
Service-specific materials are required for custody, trading-platform operation, exchange, order execution, advice, portfolio management and transfer services.
Article 60 notification
Article 60 is not a general shortcut. It is available only to eligible financial entities and only for permitted crypto-asset services.
The Article 60 route may be relevant for credit institutions, central securities depositories, investment firms, market operators, electronic-money institutions, UCITS management companies and alternative investment fund managers.
The financial entity must notify the CNB before providing the crypto-asset services and must provide the information required under MiCA and the applicable EU technical standards.
A regulated entity that wants to provide non-equivalent or additional crypto-asset services may still need full CASP authorisation.
Transitional position
The Czech transitional route is narrow and late-stage.
The old national unqualified-trade route ended on 15 February 2025. Providers that wanted to use the MiCA transitional period had to submit their CASP authorisation application by the end of July 2025.
Providers that submitted on time may continue under transition until the CNB reaches its decision, but no later than 1 July 2026.
A legacy trade licence or transitional status is not a MiCA authorisation. It should not be marketed as a MiCA licence.
New providers cannot rely on the old Czech trade-licence regime. They must use MiCA authorisation, Article 60 notification where available, a valid passport, or another applicable regulated route.
Current market status
The Czech MiCA authorisation route is operational.
On 11 February 2026, the CNB issued its first six MiCA CASP authorisations. CNB stated that it had received 248 applications and that further applications were being assessed within the MiCA timetable.
The current CNB and ESMA registers should be checked before relying on a provider’s authorisation status, onboarding a counterparty, or publishing a list of authorised Czech providers.
Costs
The Czech administrative fee for authorisation to act as a provider of crypto-asset services is CZK 20,000.
This is only the administrative fee. The total cost of authorisation will usually be materially higher once legal, governance, AML, ICT, DORA, custody, prudential, insurance, audit, accounting, translation, documentation and implementation work is included.
Prudential requirements
A Czech CASP must maintain MiCA prudential safeguards at all times.
The required amount is at least the higher of the applicable permanent minimum capital amount or one quarter of fixed overheads for the preceding year.
The MiCA class amounts are EUR 50,000 for class 1, EUR 125,000 for class 2 and EUR 150,000 for class 3.
Class 1 covers execution of orders, placing, transfer services, reception and transmission of orders, advice and portfolio management.
Class 2 includes class 1 services plus custody and administration, exchange of crypto-assets for funds, and exchange of crypto-assets for other crypto-assets.
Class 3 includes class 2 services plus operation of a crypto-asset trading platform.
Where a provider offers services in more than one class, the highest applicable class applies.
Prudential safeguards may be met through own funds, an insurance policy, a comparable guarantee, or a permitted combination. The applicant should be ready to evidence the prudential package in the application.
Ongoing obligations
Czech CASPs must comply with MiCA, Czech implementing law, applicable EU technical standards, CNB supervisory expectations, AML and counter-terrorist-financing obligations, DORA-related ICT requirements, and applicable transfer-of-funds and sanctions controls.
Core obligations include governance, management suitability, qualifying-holder controls, prudential safeguards, internal controls, risk management, complaints handling, conflicts management, outsourcing oversight, ICT and security controls, business continuity, client-asset segregation, recordkeeping, fair and non-misleading client information, cost and fee transparency, marketing controls and service-specific conduct rules.
Staff who provide information or advice on crypto-assets or crypto-asset services must have appropriate knowledge and competence. Staff providing advice should meet a higher standard than staff who provide information only.
White papers and marketing
White-paper and CASP licensing obligations are separate but may overlap in launch projects.
For most crypto-assets, CNB does not substantively approve the white paper. For e-money tokens and crypto-assets other than asset-referenced tokens and e-money tokens, publication or notification of a white paper does not mean that CNB has verified the correctness of the information or the credibility of the offeror.
Asset-referenced token white papers are the main case where CNB carries out substantive review before publication.
Marketing and client information must be fair, clear and not misleading. CASPs should not imply that CNB approves the economic value of a project or guarantees investment returns.
Enforcement risk
The Czech Republic is not a light-touch jurisdiction.
The main enforcement risks are providing crypto-asset services without MiCA authorisation, continuing activity after the transitional period without authorisation, filing late and still operating, providing MiCA-scope services as a natural person after August 2025, presenting trade-licence or transitional status as a MiCA licence, relying on Article 60 without a proper equivalence analysis, and providing services outside the authorised scope.
MiCA requires Member States to provide administrative penalties and supervisory measures for CASP breaches. These can include public statements, cease-and-desist orders, benefit-based fines, management bans, authorisation suspension or withdrawal, and substantial fines for natural and legal persons.
Exact Czech-koruna penalty exposure depends on the breach, the offender category, turnover, benefit obtained, repeated-breach status and the current Czech statutory provision.
Practical assessment
The Czech Republic is suitable for firms that want MiCA authorisation through a single, sophisticated financial regulator and are prepared for a substantive CNB review.
It is not suitable for firms looking for a paper registration, continued reliance on the former trade-licence regime, natural-person provision of MiCA services, or indefinite grandfathering.
The main execution risks are misclassifying the service, failing to form an eligible legal applicant, missing transition conditions, treating Article 60 as a general shortcut, underestimating CNB documentation expectations, failing to evidence prudential safeguards, and filing before AML, ICT, DORA, governance, custody, complaints, conflicts, staff-competence and service-specific materials are ready.