Detailed overview
Latvia: Latvijas Banka MiCA Authorisation under the Crypto-Asset Services Law
Latvia is a full MiCA jurisdiction. The Latvian framework is based on Regulation 2023/1114 and the Latvian Crypto-Asset Services Law.
Latvijas Banka is the Latvian competent authority for MiCA. It is the main regulator for crypto-asset service provider authorisation, Article 60 notifications, crypto-asset issuer supervision and MiCA enforcement in Latvia.
Latvia’s general transition from the former AML-supervised virtual-asset regime has expired. New or continuing Latvia-facing crypto-asset service activity should be structured through MiCA authorisation, a valid Article 60 route or a valid MiCA passport.
Regulator
The main regulator is Latvijas Banka.
Latvijas Banka receives CASP authorisation applications, receives Article 60 notifications from eligible financial market participants, supervises authorised providers, maintains the Latvian financial market participant register and exercises MiCA supervisory powers.
Latvijas Banka is also the Latvian AML supervisory authority for CASPs.
Other Latvian and EU regimes may still apply where the activity involves financial instruments, deposits, funds, insurance products, payment services, e-money, asset-referenced tokens, e-money tokens, AML, sanctions, TFR, DORA or tax reporting.
Licensing route
A business that provides crypto-asset services in or from Latvia generally needs MiCA authorisation as a crypto-asset service provider unless it is an eligible financial entity using Article 60 or a duly authorised EU CASP passporting into Latvia.
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, insurance products, payment instruments, non-MiCA e-money arrangements, securitisation positions, NFTs or other excluded products require separate legal analysis.
Article 63 authorisation
A standard unregulated Latvian CASP applicant applies to Latvijas Banka for MiCA authorisation.
A MiCA-authorised CASP must have a registered office in an EU Member State where it carries out at least part of its crypto-asset services, its effective management in the EU and at least one EU-resident director.
A credible Latvian application should include a full service map, legal perimeter analysis, Latvian home-state analysis, programme of operations, business plan, constitutional documents, proof of prudential safeguards, governance materials, management fit-and-proper evidence, qualifying-holder information, internal controls, AML and counter-terrorist-financing procedures, proliferation-financing controls, sanctions controls, TFR procedures, self-hosted-address risk controls, risk assessment, business-continuity plan, ICT and DORA materials, client-asset and client-fund segregation procedures, complaints procedures, conflicts management, outsourcing framework, custody policy where relevant, trading-platform rules and market-abuse systems where relevant, exchange commercial policy and pricing methodology where relevant, execution policy where relevant, advice and portfolio-management competence evidence where relevant and transfer-service procedures where relevant.
Latvijas Banka assesses whether the application is complete within 25 working days. After completeness is confirmed, Latvijas Banka generally reviews the application and decides whether to grant or refuse authorisation within 40 working days. The review period may be extended where the information is insufficient to take a decision.
Pre-licensing process
Latvijas Banka offers a pre-licensing and familiarisation process.
The applicant may discuss its proposed activities with Latvijas Banka before formal filing. At this stage, the company does not necessarily have to be legally established.
This process can be used to test the service map, business model, governance structure, AML controls, ICT arrangements and application documentation.
Pre-licensing support is not authorisation and should not be marketed as regulatory approval.
Article 60 notification
Article 60 is not a general shortcut for unregulated applicants. It is a notification route for specified existing financial market participants and permitted equivalent crypto-asset services.
The Article 60 route may be relevant for credit institutions, central securities depositories, investment firms, regulated market operators, electronic-money institutions, investment management companies and alternative investment fund managers.
Latvijas Banka’s service mapping is entity-specific. Credit institutions may provide crypto-asset services and ART or EMT-related services. CSDs may provide custody and administration. Investment firms may provide specified services other than transfer services. Regulated market operators may operate crypto-asset trading platforms. Electronic-money institutions may provide custody and transfer services for their own issued EMTs. Investment management companies may provide advice and portfolio management. AIFMs may provide reception and transmission, advice and portfolio management.
A financial market participant must submit the Article 60 application at least 40 business days before first providing the relevant crypto-asset services. Latvijas Banka assesses completeness within 20 business days.
A regulated entity must map each proposed crypto-asset service to its existing authorisation and the MiCA Article 60 equivalence rules.
A regulated entity that wants to provide non-equivalent crypto-asset services may still need full CASP authorisation.
Transitional position
Latvia’s MiCA transition has expired.
A legacy provider that started providing crypto-asset services before 30 December 2024 and was supervised by the State Revenue Service under the former AML framework could continue without Latvijas Banka authorisation only until 30 June 2025.
If such a provider submitted a MiCA authorisation application to Latvijas Banka by 30 June 2025, it could continue until Latvijas Banka reviewed the application and granted or refused authorisation.
The State Revenue Service stopped registering new crypto-asset service providers from 30 December 2024.
Legacy State Revenue Service supervision or old AML status is not MiCA authorisation and should not be marketed as such.
New or continuing Latvia-facing crypto-asset service activity should be structured through MiCA authorisation, a valid Article 60 route or a valid MiCA passport.
Passporting and register checks
A MiCA-authorised CASP may provide its authorised services across the EU through the MiCA passport, subject to the required notification process and authorised service scope.
A Latvian legacy status or expired transitional position does not itself create a MiCA passport.
Latvijas Banka maintains a financial market participant register. The register includes entities licensed by Latvijas Banka and entities licensed in another EU country that provide cross-border services in Latvia.
Latvijas Banka issued its first MiCA CASP licence in December 2025. The Latvian register currently lists BlockBen SIA and Nexdesk SIA under the crypto-asset market segment.
Latvijas Banka and ESMA register information should be checked before relying on a provider’s authorisation status, onboarding a counterparty, launching services or publishing any authorisation claim.
Costs
A standard CASP applicant that is not already a financial market participant supervised by Latvijas Banka pays EUR 2,500 for review of the authorisation application.
An authorised CASP pays Latvijas Banka up to 0.6 percent per year of gross income from crypto-asset services, with a minimum of EUR 3,000 per year.
For Article 60 financial market participants, annual payments may also apply depending on the entity type and gross income from crypto-asset services.
These amounts are not the full cost of authorisation. Applicants should also budget for legal, governance, AML, sanctions, TFR, self-hosted-address controls, DORA, ICT, custody, outsourcing, complaints, conflicts, audit, accounting, prudential, insurance and operational implementation costs.
The current annual supervisory-fee decision and Latvijas Banka payment procedure should be checked before filing or publication.
Prudential safeguards
A CASP must maintain MiCA prudential safeguards at all times.
The required amount is at least the higher of the applicable permanent minimum capital requirement and 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 take the form of own funds, an insurance policy, a comparable guarantee or a permitted combination.
Management suitability and transfer services
Latvian applicants should prepare management-suitability materials before filing.
Latvijas Banka rules require CASPs and ART issuers to ensure that management-body members meet the relevant EBA and ESMA suitability criteria, except where the CASP is a credit institution or investment firm.
Transfer-service models require dedicated attention. A CASP providing crypto-asset transfer services on behalf of clients must inform clients about their rights and obligations and develop transfer-service policies and procedures.
Wallet, transfer, settlement and payment-like models should therefore include a specific transfer-service analysis.
AML, TFR and self-hosted addresses
Latvian CASPs are subject to the Latvian AML framework.
CASPs must maintain an internal control system covering risk assessment, customer due diligence, transaction monitoring, suspicious-transaction procedures, reporting to the Financial Intelligence Unit, record retention, staff standards, whistleblowing where applicable, audit functions and regular review of policies and procedures.
CASPs must appoint responsible AML staff both at senior-management level and in the internal-control function.
CASPs must also address transfers to or from self-hosted addresses. For those transfers, the CASP must assess money-laundering, terrorist-financing and proliferation-financing risks and take risk-mitigation measures. These may include risk-based identification and verification of the originator, beneficiary or beneficial owner, additional information on the origin and destination of the crypto-assets, enhanced monitoring and other controls.
A Latvian CASP filing should include AML/CFT risk assessment, customer due diligence, beneficial ownership controls, sanctions screening, transaction monitoring, suspicious-activity escalation, TFR travel-rule procedures, treatment of self-hosted addresses, outsourcing oversight, recordkeeping, staff training and audit arrangements.
ARTs, EMTs and token issuance
CASP authorisation and token-offer compliance are separate.
Latvijas Banka distinguishes asset-referenced tokens, e-money tokens and crypto-assets other than ARTs and EMTs.
An EMT may be issued and offered to the public or admitted to trading only by a credit institution or e-money institution that has notified Latvijas Banka of the white paper and published it under MiCA. The issuer must notify Latvijas Banka at least 40 working days in advance.
An ART generally requires issuer authorisation or a credit-institution route under MiCA.
A CASP licence should not be treated as covering public offers, admission to trading, ART issuance, EMT issuance or white-paper obligations.
Stablecoin, wallet, exchange, settlement and payment-like structures should be reviewed for EMT, e-money and payment implications.
Ongoing obligations
A Latvian CASP must comply with MiCA, the Latvian Crypto-Asset Services Law, Latvijas Banka rules, the Latvian AML law, sanctions controls, TFR, DORA and applicable supervisory reporting requirements.
Core obligations include governance, management suitability, qualifying-holder controls, prudential safeguards, internal controls, risk management, AML and counter-terrorist-financing procedures, proliferation-financing controls, sanctions controls, transaction monitoring, TFR implementation, self-hosted-address controls, business continuity, ICT and DORA controls, outsourcing oversight, complaints handling, conflicts management, custody safeguards, client-asset and client-fund segregation, recordkeeping, fair and non-misleading client information, cost and fee transparency, market-abuse systems where relevant and service-specific conduct rules.
A CASP must promptly inform Latvijas Banka of material changes, including circumstances that may negatively affect its ongoing activity or changes to information submitted for authorisation.
Enforcement risk
Latvia is not a light-touch jurisdiction.
Latvijas Banka may impose warnings, fines, management bans, temporary restrictions, administrative measures and authorisation withdrawal.
For CASP-related MiCA breaches, natural-person fines may reach EUR 700,000 or twice the benefit gained or loss avoided.
For legal persons, fines for CASP-related breaches may reach EUR 5,000,000, 5 percent of annual turnover or twice the benefit gained or loss avoided.
Market-abuse breaches can carry higher exposure.
Latvijas Banka may require a person to cease infringing conduct and may apply administrative measures separately or together with sanctions.
A Latvijas Banka administrative act in the crypto-asset area may be appealed to the Administrative Regional Court. However, appeal generally does not suspend the act’s effect, except for decisions imposing a monetary fine.
The main enforcement risks are operating without MiCA authorisation, relying on expired transition, presenting State Revenue Service legacy status as MiCA authorisation, using Article 60 without eligibility, providing services outside authorised scope, weak AML or TFR controls, weak self-hosted-address controls, weak DORA readiness, inadequate transfer-service policies and misleading marketing or authorisation claims.
Practical assessment
Latvia is suitable for firms that want MiCA authorisation through a single EU competent authority and are prepared for a structured pre-licensing and licensing process.
It is not suitable for firms looking for a continuing legacy registration, informal AML-only entry route or expired transition.
The main execution risks are incorrect service classification, missing transfer services, treating Article 60 as a general shortcut, relying on expired transition, underestimating Latvijas Banka documentation expectations, failing to evidence prudential safeguards, weak AML or self-hosted-address controls, and filing before TFR, DORA, ICT, custody, outsourcing, complaints, conflicts and service-specific controls are ready.