CASP Capital Requirements & the 3 MiCA Licence Classes (2026)

MiCA sets minimum CASP capital by service class: €50,000 (Class 1), €125,000 (Class 2) and €150,000 (Class 3) — the capital, not the state fee, is what shapes the business. Most operators budgeting a MiCA licence fixate on the state fee and miss the number that actually shapes the business: the capital. Under MiCA a Crypto-Asset Service Provider must hold minimum own funds of €50,000, €125,000 or €150,000 depending on the services it offers — and, crucially, that figure is the same in every EU country. In our practice preparing CASP files, the capital line is where founders either under-plan and stall, or over-engineer a jurisdiction choice that changes nothing, because the one variable they are shopping for is fixed by the regulation itself.

This is the capital and prudential deep-dive. If you want the broad picture of what MiCA is, start with our MiCA regulation explainer; if you want the cheapest route to a licence, our cheapest crypto licence guide ranks the field on fees. Here we go one layer down — into the three classes, what “own funds” really means, the fixed-overheads test that catches scaling firms, and the wider prudential stack around the capital.

The three CASP classes and their minimum capital

MiCA sizes the capital requirement to the risk of the service you provide. Article 67 groups the crypto-asset services into three prudential classes, each with a minimum initial capital floor. The more custody and market risk a service carries, the higher the floor. Here is the full mapping:

The classes are cumulative, not exclusive. A firm that runs a trading platform and also holds client assets is a Class 3 CASP — the €150,000 applies to the whole authorisation, not per service. In practice, most operators building a real product land in Class 2 or Class 3, because the moment you touch custody or run an exchange you are past the €50,000 tier. The €50,000 Class 1 floor is for the lighter, advisory and order-routing models that never hold client crypto.

One point that trips up first-time applicants: these are minimum initial capital figures, the entry ticket. They are not the whole prudential requirement, and they are not the number a growing firm will actually be held to for very long. That is where the fixed-overheads test comes in.

What “qualifying own funds” actually means

MiCA does not let you satisfy the requirement with just any money on the balance sheet. Own funds must be qualifying — and MiCA borrows the definition from banking law. Qualifying own funds are the higher-quality items listed in the EU Capital Requirements Regulation: Common Equity Tier 1, which in plain terms means paid-up share capital, share premium, and retained earnings and reserves, less specified deductions.

What that rules out matters more than what it includes:

• Client money is never own funds. Assets you hold for customers are safeguarded and segregated; they can never double as your capital. This is the single most common misconception we correct.
• Loans and shareholder debt do not count. Own funds are equity that absorbs losses, not liabilities you owe back. A director’s loan on the books is not capital.
• Intangibles are deducted. Goodwill and other intangible assets are stripped out, so a balance sheet that looks well-capitalised on paper can fall short once the deductions bite.

The regulator assesses composition, not just the headline figure. A CASP showing €150,000 of “capital” that is really a convertible loan plus capitalised software costs is not meeting the requirement, even though the number matches. Get the structure right at incorporation — genuine paid-up equity, cleanly documented — and the capital section of the file becomes a formality rather than a rework. The VASP, CASP & MiCA explainer sets out how this fits the broader authorisation.

The fixed-overheads test: the number that scales with you

Here is the part most cost comparisons omit entirely. MiCA does not cap the requirement at the class minimum. A CASP must hold, at all times, own funds equal to the higher of two amounts:

1. the permanent minimum for its class (€50,000, €125,000 or €150,000); or
2. one quarter of the preceding year’s fixed overheads.

For a small, pre-revenue firm, the class minimum is the binding number — a Class 2 startup holds €125,000 and the overheads test produces something lower. But the moment your annual fixed overheads exceed four times your class floor, the overheads calculation takes over. A Class 2 CASP with €1,000,000 of fixed overheads must hold €250,000 in own funds, not €125,000 — the quarter-of-overheads figure wins.

“Fixed overheads” broadly means the previous year’s total expenses less variable, discretionary items — staff bonuses tied to profit, and similar amounts that fall away if the business slows. ESMA’s technical standards set out the precise deductions, and regulators expect the calculation to be shown, not asserted. For a firm scaling toward serious volume, this is the requirement that actually determines how much equity has to sit in the business — and it is easy to under-provision if you only ever read the class table.

Capital is identical EU-wide — so compete on everything else

Because MiCA is a directly-applicable EU regulation rather than a directive each country transposes its own way, the capital figures are the same in every member state. Lithuania, Estonia, Bulgaria, Malta, Ireland — the Class 2 floor is €125,000 in all of them. There is no member state where custody-tier capital is cheaper, and any provider implying otherwise is misreading the regulation.

This is why the jurisdiction question is real but the capital question is not. In our experience Lithuania and Estonia offer the shortest review queues and the most established crypto-banking relationships, Bulgaria the lowest official fees and a flat 10% tax, and Malta the strongest reputational signal. Our Estonia vs Lithuania comparison works through that specific choice. What none of them change is the €50k–€150k you must fund — so decide on the levers that actually move, and treat capital as a fixed cost of doing business anywhere in the union.

The wider prudential picture: DORA, insurance and ongoing monitoring

Capital is one pillar of the prudential regime, not the whole of it. A MiCA authorisation carries a stack of ongoing obligations that sit alongside own funds, and a serious application has to address all of them:

• DORA operational resilience. The Digital Operational Resilience Act (EU 2022/2554) applies to CASPs. You need ICT risk management, incident reporting, resilience testing and oversight of critical third-party providers. This is a technology-governance programme, and regulators increasingly want to see it evidenced, not promised.
• Professional indemnity insurance or additional own funds. For certain services — advice and portfolio management in particular — MiCA expects either PII cover or extra own funds to backstop operational and liability risk. It is an either/or in the regulation, and the choice has a real capital cost either way.
• Safeguarding of client assets. Custodial CASPs must segregate client crypto and funds from their own, hold them so they are insulated from the firm’s insolvency, and are liable for losses of client assets within their control. Segregation is a hard line: client assets are never a funding source.
• Continuous own-funds monitoring. The requirement is not a one-time gate at application. A CASP must ensure own funds never fall below the floor, monitor the position on an ongoing basis, and notify its regulator if capital is or is likely to be breached. Capital is a permanent balance to maintain, not a deposit to show once.

Read together, these obligations are why we treat a CASP file as a financial-services application, not a company registration. Undercapitalising or thinning out one pillar to save money does not remove the risk — it just moves it somewhere the regulator will find it. If your users sit outside the EU, an offshore VASP may carry a lighter prudential load at lower cost; our EU CASP vs offshore VASP guide weighs that trade-off honestly.

The capital requirement, then, is the easy part to state and the easy part to get wrong: three classes, three numbers, identical across the EU, but layered with a fixed-overheads test, an own-funds quality standard, and a prudential stack that grows with the business. We build the file so every one of those holds up under review. Compare the full field on the crypto licences hub, then book a free consultation and we’ll model your class, your overheads-test trajectory and your all-in capital against the market you actually serve.

This article is for general informational purposes only and is not legal, tax or financial advice. Consult a qualified professional before acting.