Detailed overview
Slovakia: NBS MiCA Authorisation under Act No. 248/2024
Slovakia is a full MiCA jurisdiction. The Slovak framework is based on Regulation 2023/1114 and Act No. 248/2024 on certain obligations and powers in the field of crypto-assets.
The National Bank of Slovakia is the Slovak competent authority for MiCA. NBS is the main regulator for crypto-asset service provider authorisation, Article 60 notifications, supervision, reporting and enforcement.
The former Slovak tied-business route for virtual-currency exchange and wallet services has ended. New or continuing Slovakia-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 NBS.
NBS receives CASP authorisation applications, receives Article 60 notifications from eligible financial entities, supervises authorised providers, maintains register information and exercises MiCA supervisory powers.
Other Slovak and EU regimes may still apply where the activity involves banking, payment services, e-money, e-money tokens, asset-referenced tokens, financial instruments, funds, deposits, insurance products, AML, sanctions, TFR, cybersecurity or DORA.
Licensing route
A business that provides crypto-asset services in or from Slovakia 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 Slovakia.
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, non-MiCA e-money arrangements, insurance products or other regulated products require separate legal analysis.
Article 63 authorisation
A standard unregulated Slovak CASP applicant applies to NBS 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.
NBS has published a CASP application form, checklist, application guide and DORA questionnaire.
A credible Slovak application should include a full service map, legal perimeter analysis, Slovakia home-state analysis, legal-form analysis, programme of operations, business plan, constitutional documents, proof of prudential safeguards, governance materials, management fit-and-proper evidence, qualifying-holder information, source-of-funds evidence, internal controls, AML and counter-terrorist-financing procedures, sanctions controls, TFR procedures, self-hosted-address controls, risk assessment, business-continuity plan, ICT and DORA materials, cybersecurity-audit information where relevant, 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.
NBS confirms receipt within five working days, checks completeness within 25 working days and assesses a complete application within 40 working days. NBS may request additional information and may suspend the assessment period for up to 20 working days.
Legal form and Slovak substance
Slovakia is a high-substance licensing jurisdiction.
NBS identifies suitable legal forms for CASP applicants as a joint stock company, limited liability company, simple joint stock company or European company.
NBS warns that a general partnership, sole entrepreneur, cooperative and limited partnership are not suitable legal forms for CASP applicants.
The applicant must show real connection with Slovakia. NBS expects a registered office and physical premises that allow on-site supervision, key personnel in Slovakia, risk management and compliance functions carried out in Slovakia, strategic decision-making in Slovakia, and documentation and data available at the registered office.
NBS applies a material review, not only a formal review. It focuses on application completeness, previous proceedings in other jurisdictions, local substance, key persons, qualifying holders, reputation risk, source of funds and whether the documentation genuinely reflects the applicant's business model.
Generic or template documentation that does not match the actual business model is a licensing risk.
Article 60 notification
Article 60 is not a general shortcut for unregulated applicants. It is a notification route for specified regulated financial entities and permitted equivalent 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.
A financial entity must notify the competent authority at least 40 working days before first providing the relevant crypto-asset services.
A regulated entity must map each proposed crypto-asset service to its existing authorisation and to 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
Slovakia's MiCA transition has expired.
The transitional period ended on 30 December 2025. From that date, crypto-asset services in Slovakia may be provided only by providers authorised by NBS under MiCA or by providers authorised by another EU competent authority and passporting into Slovakia.
Legacy Slovak tied-business authorisation for virtual-currency exchange or wallet services is not MiCA authorisation and should not be marketed as such.
NBS expects former tied-business providers to have stopped providing crypto-asset services. Where they held client crypto-assets, NBS expects client crypto-assets to have been returned to clients.
A new Slovakia-facing provider should use 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 Slovak legacy tied-business authorisation does not itself create a MiCA passport.
A CASP authorised in another EU Member State may provide services in Slovakia through the MiCA passport.
NBS 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
NBS application fees apply.
For lower-risk service packages covering execution, placing, transfer services, reception and transmission, advice and portfolio management, the current authorisation fee is EUR 1,700.
For service packages including custody and administration, exchange of crypto-assets for funds or exchange of crypto-assets for other crypto-assets, the current authorisation fee is EUR 2,500.
For service packages including operation of a crypto-asset trading platform, the current authorisation fee is EUR 3,400.
The fee for changing a CASP authorisation is EUR 350. The qualifying-holding approval fee is EUR 600. Withdrawal of CASP authorisation at the CASP's request attracts a EUR 350 fee.
The filing fee obligation arises when the application is submitted. It must be paid within five working days, and proof of payment must be provided.
CASPs also pay annual supervisory contributions. NBS materials state that the 2025 annual contribution was 0.1 percent of CASP assets, with a minimum of EUR 1,000.
The current annual contribution decision should be checked before filing or budgeting.
These fees are not the full cost of authorisation. Applicants should also budget for legal, governance, AML, sanctions, TFR, self-hosted-address controls, DORA, ICT, cybersecurity audit, custody, outsourcing, complaints, conflicts, audit, accounting, prudential, insurance and operational implementation costs.
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.
The applicant must evidence prudential safeguards when filing and provide projected prudential-safeguard calculations for the first three financial years after authorisation.
Client-asset protection
Slovakia has a national client-asset protection rule for entrusted crypto-assets.
Crypto-assets entrusted to a CASP that do not form part of the CASP's own assets are protected from enforcement against the CASP. Bankruptcy or similar proceedings concerning the CASP do not affect the client's right to receive entrusted crypto-assets back.
Custody, wallet, exchange, transfer and settlement models should therefore address legal ownership, segregation, reconciliation, bankruptcy scenario, private-key control, sub-custody, records, client disclosures and liability before filing.
The national client-asset protection rule does not replace MiCA custody, safeguarding, operational-resilience and service-specific requirements.
AML, TFR and self-hosted addresses
Slovak CASPs are subject to the Slovak AML framework, except where the provider only provides crypto-asset advice for AML-law purposes.
CASPs must maintain internal policies, procedures and controls to identify and assess AML and terrorist-financing risks associated with transfers to or from self-hosted addresses.
Those controls should include risk-based identification and verification of the originator or recipient and, for legal persons, beneficial owners; additional information on the origin and destination of transferred crypto-assets; enhanced ongoing monitoring; and measures to mitigate AML, terrorist-financing and sanctions-evasion risks.
CASPs must also address cross-border correspondent relationships involving crypto-asset services. This includes checking whether the partner institution is licensed or registered, gathering information on its business and reputation, assessing its AML controls, obtaining senior approval before a new relationship, documenting responsibilities and assessing whether relevant customer identification has been performed.
A Slovak 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, self-hosted-address controls, correspondent-CASP controls, outsourcing oversight, recordkeeping and staff training.
DORA, ICT and cybersecurity
DORA and ICT readiness are central to Slovak CASP authorisation.
NBS application materials include a DORA questionnaire.
Where the applicant uses a network and information system in its business, the application must include cybersecurity-audit information and ICT/security documentation.
A Slovak CASP application should include ICT governance, cybersecurity controls, DORA mapping, incident-management procedures, business-continuity planning, outsourcing controls, wallet and custody technology controls, operational-resilience evidence and ICT third-party risk management.
Reporting
Slovak CASPs have supervisory reporting obligations.
NBS has issued a reporting measure for CASPs, effective from 1 July 2025.
The reporting framework includes balance sheet and profit-and-loss reporting, own-funds and prudential-requirement reporting, crypto-asset services and fee reporting, wallet-address reporting, complaints reporting, provider information reporting, AML/CFT reporting and management-change notifications.
A Slovak applicant should build reporting capability before launch.
Advice and staff competence
Slovakia removed its former national crypto-advice examination and education requirements with effect from 1 March 2026.
Persons providing information or advice on crypto-assets or crypto-asset services must still have appropriate knowledge and skills under the applicable ESMA guidelines published by NBS.
Advice and client-information models should therefore prepare staff-competence evidence, training, periodic review and recordkeeping.
ARTs, EMTs and token issuance
CASP authorisation and token-offer compliance are separate.
A CASP licence does not itself cover public offers, admission to trading, ART issuance, EMT issuance or white-paper obligations.
Stablecoin, wallet, exchange, settlement and payment-like structures should be reviewed separately for EMT, ART, e-money and payment-services implications.
White-paper-related fees may apply for ART matters.
Ongoing obligations
A Slovak CASP must comply with MiCA, Act No. 248/2024, NBS supervisory requirements, Slovak AML law, sanctions controls, TFR, DORA, cybersecurity requirements and applicable NBS reporting measures.
Core obligations include governance, management suitability, qualifying-holder controls, prudential safeguards, internal controls, risk management, AML and counter-terrorist-financing procedures, sanctions controls, transaction monitoring, TFR implementation, self-hosted-address controls, business continuity, ICT and DORA controls, cybersecurity 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 should also maintain clear processes for reporting to NBS, communicating material changes and handling supervisory information requests.
Enforcement risk
Slovakia is not a light-touch jurisdiction.
NBS may impose remedial measures and fines. Remedial measures and fines may be imposed together and repeatedly.
NBS may prohibit or restrict activity through measures or urgent temporary measures.
NBS may require removal of content from an online interface, restriction of access to an online interface, deletion of a domain name or measures preventing registration of a domain name.
NBS decisions in this area may be reviewable before the administrative court, but ordinary appeal may not be available for some measures.
MiCA requires Member States to provide administrative penalties and measures for CASP infringements, including public statements, cease-and-desist orders, benefit-based fines, natural-person fines and legal-person fines.
The main enforcement risks are operating without MiCA authorisation, relying on expired tied-business status, presenting old trade authorisation 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, weak cybersecurity evidence, custody segregation failures, insufficient Slovak substance and misleading authorisation or marketing claims.
Practical assessment
Slovakia is suitable for firms that want MiCA authorisation through a single national competent authority and are prepared to build real Slovak substance.
It is not suitable for firms looking for a paper registration, continued reliance on former tied-business authorisation, indefinite grandfathering or a low-substance market-entry route.
The main execution risks are incorrect service classification, missing transfer services, using an unsuitable legal form, treating Article 60 as a general shortcut, relying on expired transition, underestimating NBS documentation expectations, failing to show Slovak substance, weak source-of-funds evidence, inadequate prudential safeguards, weak AML or TFR controls, insufficient self-hosted-address controls, weak DORA or cybersecurity evidence and filing before custody, outsourcing, complaints, conflicts and service-specific controls are ready.