Fintech Licensing Hub

Slovenia

Slovenia regulates crypto under MiCA through its implementing act (ZIUTK, Official Gazette 95/2024), with the Securities Market Agency (ATVP) as the main CASP authority and Banka Slovenije for e-money tokens; it took a short 6-month transition that ended 1 July 2025 and did not apply the simplified conversion for legacy providers. From 1 January 2026 Slovenia introduced a flat 25% tax on individual crypto disposal profits, ending the prior tax-free position, with crypto-to-crypto swaps exempt. Payments and e-money run under the ZPlaSSIED (PSD2/EMD2), supervised by Banka Slovenije, with the Instant Payments Regulation and DORA in force; gambling is one of the EU's most restrictive markets, supervised by FURS under the Gaming Act โ€” and Slovenia is in the euro area and banking union.

Available licences

Crypto-Asset Service Provider authorisation (ATVP under MiCAR and ZIUTK)

Custody, operation of a trading platform, exchange of crypto-assets for funds or other crypto-assets, execution, placing, reception and transmission of orders, advice, portfolio management and transfer services require ATVP authorisation under Article 63 MiCAR; an authorisation passports across the EEA.

Asset-Referenced Token (ART) issuer authorisation (ATVP)

Public offering or admission to trading of a token referencing a basket of values, rights or currencies requires authorisation as an ART issuer under Title III MiCAR, handled by the ATVP.

E-Money Token (EMT) issuer (credit institution or EMI; Banka Slovenije)

EMTs (including fiat-backed stablecoins) may be issued only by an authorised credit institution or e-money institution, with redemption at par; Banka Slovenije is the competent authority for EMT issuers.

Article 60 MiCAR notification route (existing financial entities)

Most Article 60 notifications go to the ATVP; e-money institutions intending to provide custody or transfer services in relation to EMTs they issue notify Banka Slovenije, at least 40 working days before starting.

Payment Institution authorisation (Banka Slovenije under the ZPlaSSIED)

A licence to provide payment services under the Payment Services, Electronic Money Services and Payment Systems Act, supervised by Banka Slovenije and passportable across the EEA.

E-Money Institution authorisation (Banka Slovenije)

A licence to issue electronic money and provide related payment services, with EUR 350,000 minimum initial capital, supervised by Banka Slovenije.

Account Information and Payment Initiation Services (Banka Slovenije)

Open-banking providers โ€” account information and payment initiation service providers โ€” fall within the ZPlaSSIED, with strong customer authentication.

Banking authorisation (Banka Slovenije and the ECB/SSM)

Deposit-taking and lending require a banking licence; in the banking union the European Central Bank grants the licence and directly supervises significant institutions, with Banka Slovenije supervising less-significant ones.

Investment firm authorisation (ATVP โ€” MiFID II)

Investment services in financial instruments require ATVP authorisation under the Slovenian MiFID II framework.

Special-games concession (Government โ€” casinos and gaming halls)

A government concession to operate casino or gaming-hall games of chance, capped nationally at 15 casino and 45 gaming-hall concessions, held by a Slovenian stock company.

Classic-games concession (lotteries and sports betting)

A concession to operate lotteries, sports betting and similar classic games on an ongoing basis โ€” reserved, in practice, to the two state-linked operators (Loterija Slovenije and ล portna loterija).

Detailed overview

Slovenia at a glance

Slovenia combines a split crypto-supervisory model, a new 25% crypto tax and a tightly controlled gambling market. Crypto is supervised by the ATVP (CASPs) and Banka Slovenije (EMTs); the short 6-month transition ended 1 July 2025. Payments run under the ZPlaSSIED with Banka Slovenije as supervisor and the Instant Payments Regulation and DORA in force. Gambling runs under the Gaming Act, supervised by FURS. The euro is the currency, and Slovenia sits inside the euro area and banking union.

Crypto regime under MiCA โ€” ATVP-led, split with Banka Slovenije:

  • MiCA + national implementing law โ€” Regulation (EU) 2023/1114 (MiCAR); the ZIUTK (Official Gazette 95/2024, in force 23 November 2024), designating the ATVP and Banka Slovenije
  • Competent authorities โ€” the ATVP for ordinary CASP authorisation, supervision, ART matters and most Article 60 notifications; Banka Slovenije for EMTs and for EMIs providing custody or transfer of their own EMTs
  • Grandfathering โ€” closed. Slovenia chose a short 6-month transition: providers lawful before 30 December 2024 (including virtual-currency providers under the AML framework) could continue only until 1 July 2025, and Slovenia did not apply the simplified Article 143(6) conversion procedure
  • Pre-MiCA heritage โ€” an AML-based virtual-currency registration under the AML Act (ZPPDFT-2), conferring no passport
  • Fees โ€” the ATVP charges tariff-point-based authorisation fees scaled to the range of services provided
  • AML/CFT โ€” the AML Act applies; the EU AML package (Regulation (EU) 2024/1624 / AMLR, with AMLA in Frankfurt) applies from 10 July 2027
  • TFR / DORA โ€” the Travel Rule (Regulation (EU) 2023/1113) applies from 30 December 2024 and DORA from 17 January 2025; DAC8 reporting runs from 2026
  • Tax โ€” a major change: from 1 January 2026, the Law on the Tax on Profit from the Disposal of Crypto Assets imposes a flat 25% tax on individual crypto disposal profits (converting crypto to fiat, or paying for goods and services), ending the prior tax-free position for individuals. Crypto-to-crypto swaps and transfers between a person's own wallets are exempt; a step-up base value is set at 1 January 2026 (pre-2026 gains are not taxed); losses offset and carry forward; an optional simplified method taxes 25% of 40% of holdings. A one-time wallet snapshot was due to FURS by 30 June 2026, with the first annual return due 31 March 2027. Companies are subject to corporate income tax

Payments and e-money regime (Banka Slovenije-led):

  • PSD2 โ€” Directive (EU) 2015/2366; transposed by the ZPlaSSIED, supervised by Banka Slovenije
  • Payment Institution licensing โ€” initial capital EUR 20,000 (money remittance), EUR 50,000 (payment initiation) and EUR 125,000 (other payment services)
  • EMD2 / E-Money Institution โ€” Directive 2009/110/EC; EUR 350,000 initial capital; stablecoin (EMT) issuers must be EMIs or credit institutions
  • Instant Payments Regulation (Regulation (EU) 2024/886) โ€” euro instant payments: receiving applicable from 9 January 2025 and sending from 9 October 2025
  • DORA (Regulation (EU) 2022/2554) โ€” applicable from 17 January 2025
  • PSD3 / PSR โ€” Commission proposals of 28 June 2023; provisional political agreement reached 27 November 2025, with final compromise texts published 23 April 2026 and formal adoption expected during 2026; the package will repeal PSD2 and EMD2 and fold e-money institutions into payment institutions
  • Banking โ€” in the banking union the ECB grants banking licences and directly supervises significant institutions, with Banka Slovenije supervising less-significant ones
  • Currency: euro (since 2007); no exchange controls

Gambling regime โ€” FURS-supervised, highly restrictive:

  • Gaming Act (Zakon o igrah na sreฤo, 1995, as amended) โ€” the framework for all games of chance
  • Regulator โ€” FURS (through its Special Financial Office) supervises gambling; the Ministry of Finance and Government grant concessions
  • Classic games (lotteries and sports betting) โ€” only two operators may hold ongoing concessions, in practice Loterija Slovenije (lotteries) and ล portna loterija (sports betting), making these de facto exclusive
  • Special games (casinos and gaming halls) โ€” capped at 15 casino and 45 gaming-hall concessions, held by Slovenian stock companies (no single shareholder above 20%), with concessions up to ten years
  • Online gambling โ€” restricted to existing domestic concessionaires and the two lottery operators; foreign and private operators are barred, which has drawn European Commission pressure to liberalise
  • Tax and player rules โ€” operators pay concession fees and gambling tax; player winnings above EUR 42 are subject to 25% advance income tax withholding; minimum age 18, with a self-exclusion system
  • Enforcement and reform โ€” ISP and payment blocking of unlicensed sites; the Ministry of Finance is reviewing the gambling framework
  • No EU passport โ€” gambling is licensed nationally

Last verified: July 2026. Reference rate: USD 1 โ‰ˆ EUR 0.87 (EUR 1 โ‰ˆ USD 1.15).

Slovenia is a euro-area jurisdiction with a split MiCA model (ATVP for CASPs, Banka Slovenije for EMTs), a new 25% crypto tax from 2026, and one of the EU's most closed gambling markets, where online play is reserved to domestic concessionaires.

Is there a crypto licence in Slovenia?

Yes. Slovenia applies MiCAR through the ZIUTK, with the ATVP authorising and supervising CASPs and Banka Slovenije handling EMTs. The short 6-month transition ended 1 July 2025, so operating now requires an ATVP authorisation, a valid MiCA passport, or an Article 60 notification.

The legal foundation:

  • Regulation (EU) 2023/1114 (MiCAR) โ€” the directly applicable EU framework for offerings, admission and crypto-asset services
  • ZIUTK (Official Gazette 95/2024) โ€” the implementing act, designating the ATVP and Banka Slovenije
  • AML Act (ZPPDFT-2) โ€” AML/CFT obligations and the legacy virtual-currency registration
  • Regulation (EU) 2023/1113 โ€” Travel Rule for crypto-asset transfers

Structure:

  • A Slovenian entity with genuine substance and fit-and-proper management
  • MiCAR own-funds floors by class โ€” EUR 50,000 (Class 1), EUR 125,000 (Class 2), EUR 150,000 (Class 3) โ€” with the higher of the floor or a fixed-overheads measure
  • AML systems, a white paper for in-scope offerings, custody and client-asset segregation, ICT and governance documentation, and a business plan โ€” filed with the ATVP after a pre-application consultation

Operational reality:

  • Slovenia ran one of the shortest transitions and did not offer a simplified conversion, so legacy virtual-currency status is not a route to ongoing activity
  • The new 25% crypto tax from 2026 ends the prior tax-free position for individuals, though the step-up base value protects historical gains
  • New activity should be structured through an ATVP authorisation, a valid passport or an Article 60 notification โ€” not the closed transitional regime

Official CASP roadmap: The ATVP is the main CASP authority โ€” applications are filed with it (with Banka Slovenije handling EMTs) โ€” under the ZIUTK; Slovenia did not apply the simplified conversion procedure, and the 6-month transition ended 1 July 2025. See the ATVP crypto-asset pages.

Payments & E-money (Banka Slovenije โ€” PSD2 / EMD2)

Best for payment, remittance, acquiring, wallet and e-money operators wanting a euro-area base.

What it is: Authorisation as a payment institution or e-money institution under the ZPlaSSIED, supervised by Banka Slovenije and passportable across the EEA.

Who it suits: Money-remittance and transfer providers, acquirers, card and wallet issuers, payment-initiation and account-information providers, and e-money issuers (including stablecoin issuers, who must be EMIs or credit institutions).

Covers: The payment services under the ZPlaSSIED โ€” incoming and outgoing transactions, transfers, card and instrument-based payments, money remittance, payment initiation and account information โ€” plus issuance of electronic money.

Operational requirement: A Slovenian entity; minimum initial capital by service type; ongoing own-funds and safeguarding of client funds; strong customer authentication; AML/CFT; DORA operational-resilience obligations; and fit-and-proper management.

Headline figures

  • Primary instruments: ZPlaSSIED (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA (Regulation (EU) 2022/2554)
  • Regulator: Banka Slovenije (authorisation and supervision)
  • Entry capital: payment institutions EUR 20,000 / 50,000 / 125,000 by service type; e-money institutions EUR 350,000
  • Instant payments: euro instant payments receiving from 9 January 2025 and sending from 9 October 2025
  • Reform pipeline: PSD3 / PSR โ€” political agreement November 2025, compromise texts April 2026, adoption expected during 2026; EMD2 to be repealed and EMIs folded into payment institutions
  • Currency: euro (euro-area member); no exchange controls

Is there a gambling licence in Slovenia?

Mostly no, for new entrants. Slovenia runs one of the EU's most restrictive regimes: lotteries and betting are reserved to two state-linked operators, casino concessions are capped, and online gambling is limited to domestic concessionaires.

The legal foundation:

  • Gaming Act (1995, as amended) โ€” the framework for classic and special games of chance
  • FURS โ€” gambling supervision, with the Ministry of Finance and Government granting concessions
  • Concession model โ€” classic games (lotteries, betting) and special games (casinos, gaming halls)

Structure:

  • Classic-games concessions are de facto reserved to Loterija Slovenije and ล portna loterija
  • Special-games concessions are capped at 15 casinos and 45 gaming halls, held by Slovenian stock companies
  • Online gambling is open only to existing domestic concessionaires; foreign operators are barred

Gambling โ€” Special-games concession (Government)

Best for established domestic casino operators; the market is largely closed to new and foreign entrants.

What it is: A government concession to operate casino or gaming-hall games of chance, including online for existing concessionaires.

Who it suits: Slovenian stock companies able to meet capital and ownership-concentration rules; foreign or new private operators are effectively excluded.

Covers: Casino table games and machines (special games); online operation is limited to existing land-based concessionaires and the two lottery operators.

Operational requirement: A Slovenian stock company, at least EUR 100,000 share capital per concession, no single shareholder above 20%, technical certification, AML/KYC and responsible-gambling measures.

Headline figures

  • Primary instruments: Gaming Act (1995, as amended)
  • Regulator: FURS (supervision); Ministry of Finance and Government (concessions)
  • Market structure: lotteries and betting reserved to Loterija Slovenije and ล portna loterija; casinos capped at 15 concessions; online limited to domestic concessionaires
  • Tax: operator concession fees and gambling tax; player winnings above EUR 42 subject to 25% withholding
  • Other: minimum age 18; self-exclusion system; European Commission pressure to liberalise

Costs and timelines at a glance

  • Crypto: MiCAR via the ZIUTK, ATVP (CASPs) and Banka Slovenije (EMTs); own-funds floors EUR 50,000 / 125,000 / 150,000 by class; tariff-point ATVP fees; transition closed 1 July 2025
  • Payments primary instruments: ZPlaSSIED (PSD2 / EMD2); Instant Payments Regulation (EU) 2024/886; DORA
  • Payments regulator: Banka Slovenije; banking licences via the ECB/SSM (banking-union member)
  • Reform pipeline: PSD3 / PSR โ€” agreement November 2025, compromise texts April 2026, adoption expected during 2026
  • Gambling: highly restrictive โ€” lotteries/betting reserved to two operators; casinos capped at 15 concessions; online limited to domestic concessionaires
  • Tax: new flat 25% on individual crypto disposals from 1 January 2026 (crypto-to-crypto exempt; step-up base value); corporate income tax applies
  • Currency: euro (euro-area and banking-union member); no exchange controls
  • FX: USD 1 โ‰ˆ EUR 0.87 (EUR 1 โ‰ˆ USD 1.15)

Who Slovenia suits and who it does not

Suitable for

  • Crypto exchanges, custodians and token issuers wanting a defined MiCAR framework with ATVP authorisation and EEA passporting
  • Long-term holders who acquired crypto before 2026, protected by the step-up base value at 1 January 2026
  • Stablecoin (EMT) issuers working with Banka Slovenije and an authorised credit or e-money institution
  • Payment, e-money, acquiring and wallet operators wanting a euro-area base
  • Established domestic casino concessionaires operating within the closed gambling framework

Not suitable for

  • Providers relying on a former virtual-currency registration โ€” the transition closed on 1 July 2025 with no simplified conversion
  • Active traders sensitive to tax โ€” from 2026 crypto disposals are taxed at a flat 25% (though swaps remain exempt)
  • Letterbox structures โ€” the ATVP and Banka Slovenije expect genuine substance
  • Foreign or new private gambling operators โ€” lotteries and betting are reserved to two operators and online is limited to domestic concessionaires
  • Gambling operators wanting crypto payments or an open online market โ€” the regime is euro-based and closed