MiCA licence in Latvia
How to become a crypto-asset service provider. One EU authorisation, own funds from €50,000, a €2,500 fee.
MiCA, Regulation (EU) 2023/1114, has applied to crypto-asset service providers since 30 December 2024. In Latvia, Latvijas Banka grants the authorisation, and a Latvian licence can be passported across the EU.
Where Latvia stands on MiCA
Latvia's Law on Crypto-Asset Services makes Latvijas Banka the competent authority and sets the fees, and otherwise leaves the substance to the Regulation. Latvia chose a short transitional period of six months for providers already operating under the previous regime.
Latvijas Banka issued its first two CASP licences in December 2025. In June 2026 it authorised an existing investment firm, AS TWINO Investments, to add crypto-asset services under the route MiCA reserves for already-licensed institutions.
One pattern from 2026 matters more than the count. Paybis Europe, Trek Technologies (Backpack EU), Nodu Digital and Noah LV each received a CASP licence and a payment institution licence on the same day. A CASP licence lets you exchange, custody and transfer crypto-assets; it does not let you execute your clients' euro payments. The regulator licenses both, side by side.
What a MiCA licence covers: ten services, three classes
MiCA defines ten crypto-asset services and authorisation is granted service by service: custody and administration; operating a trading platform; exchange of crypto-assets for funds; exchange of crypto-assets for other crypto-assets; execution of orders; placing; reception and transmission of orders; advice; portfolio management; and transfer services. Adding a service later is a change to the authorisation, not a formality.
- Class 1, €50,000. Execution of orders, placing, reception and transmission, advice, portfolio management and transfer services.
- Class 2, €125,000. Class 1 plus custody and administration and both kinds of exchange.
- Class 3, €150,000. Class 2 plus operating a trading platform.
The actual requirement is the higher of the class minimum and one quarter of the preceding year's fixed overheads, and it may be met with own funds, an insurance policy, or a combination (Article 67).
Three things a CASP licence does not cover. It does not let you issue an e-money token, a euro stablecoin: under Article 48 the issuer must be a credit institution or an e-money institution. It does not let you provide payment services in fiat. And it does not reach tokens that are financial instruments under MiFID, which sit outside MiCA. The first question in pre-licensing is therefore: what is the token?
CASP classes vs the Article 60 route: the comparison
| Class 1 | Class 2 | Class 3 | Existing institution (Article 60) | |
|---|---|---|---|---|
| Services | Orders, placing, advice, portfolio management, transfers | Class 1 plus custody and exchange | Class 2 plus trading platform | Services MiCA maps to the existing licence |
| Minimum own funds | €50,000 | €125,000 | €150,000 | Existing prudential regime |
| Or, if higher | ¼ of fixed overheads | Same | Same | Not applicable |
| Application fee | €2,500 | €2,500 | €2,500 | Not applicable |
| Annual fee | Up to 0.6% of gross income from crypto-asset services, at least €3,000 | Same | Same | Set by Latvijas Banka |
| Statutory clock | Completeness within 25 working days; decision within 40 working days of a complete file | Same | Same | Notify at least 40 working days before starting |
| EU passport | Yes | Yes | Yes | Yes |
Who should apply? Six models
The class follows the custody question: do you hold the client's keys, and do you hold the client's euros?
- Exchange and brokerage. Buying and selling crypto-assets against euros or other crypto-assets: Class 2, €125,000. Client funds go to a credit institution or a central bank by the end of the next business day (Article 70).
- Custody and wallets. Holding keys on behalf of clients: Class 2. The custody policy (Article 75) is the centre of the file: a register of positions per client and segregation from your own assets.
- On-ramps, off-ramps and crypto payments. Transfer services alone are Class 1; most models add exchange and land in Class 2. This is the model behind the 2026 dual licences: a CASP licence for the crypto leg, a payment institution licence for the euro leg.
- Trading platforms. Class 3, €150,000, and the heaviest file: operating rules, admission criteria, non-discriminatory access and market-abuse detection (Article 76).
- Advice, portfolio management, placing. Class 1 at €50,000, with a competence requirement for staff who advise.
- Already licensed. A bank, investment firm or e-money institution does not apply for a CASP licence; it notifies Latvijas Banka at least 40 working days before starting, under Article 60.
And one thing that is not a licence. Offering a utility or other crypto-asset to the public needs a white paper, not a CASP authorisation. An asset-referenced token needs its own authorisation, and an e-money token needs an e-money institution or a bank behind it.
Requirements: capital, client assets, people, substance
- Own funds. The application shows the Article 67 calculation, the class and the source of the money. If part of the capital was raised in crypto-assets, the trail from the raise to the euro account has to be documented.
- Client funds and client crypto. Client funds are placed with a credit institution or a central bank by the end of the next business day (Article 70). Client crypto-assets are held under a custody policy, segregated from the firm's own (Article 75). Open the safeguarding bank conversation early.
- People. The management body must be of good repute and have the knowledge, skills and experience to run the business, and shareholders with qualifying holdings must be of good repute (Article 68). At least one director must be resident in the EU and the registered office must be in Latvia, with at least part of the services carried out here (Article 59).
- Substance. Outsourcing is allowed under Article 73, with a policy and with critical functions kept under your control. A company with every function contracted abroad will be asked where the provider actually is. The vehicle is usually a Latvian SIA.
- ICT and DORA. The Digital Operational Resilience Act has applied since 17 January 2025: an ICT risk management framework, incident reporting, a register of ICT third-party providers and key-management arrangements, described for your actual systems.
- AML/CFT and the Travel Rule. Regulation (EU) 2023/1113 has applied since 30 December 2024: originator and beneficiary information travels with every crypto-asset transfer. The file includes AML/CFT and sanctions rules and a risk assessment built on your actual products and corridors.
- Policies. Programme of operations, governance, internal control, business continuity, ICT, segregation of client assets, complaints and, where relevant, custody, trading-platform rules and outsourcing, plus an orderly wind-down plan (Article 74). Written to be operated, and consistent with the programme of operations.
The process, step by step
- 01
Consultation
A free meeting with Latvijas Banka to settle what the token is and which services you need.
- 02
Pre-licensing
Free, and worth it. Latvijas Banka's experts guide you on the legal framework and the documents required. They do not draft the documents for you. This is where the file is built.
- 03
Formal application
The application and supporting documents, with the €2,500 fee paid on submission. Completeness is confirmed within 25 working days (Article 63).
- 04
Assessment
A decision within 40 working days of a complete file. Expect written questions and a close reading of the custody policy, the AML risk assessment and the ICT risk assessment.
- 05
Decision and passporting
The authorisation is published and notified to ESMA. To serve other Member States, notify Latvijas Banka (Article 65); it forwards the information within 10 working days, and you may start 15 calendar days after your submission.
Timeline and costs
The statutory clock is 25 working days to completeness and 40 working days to a decision. The variable is the file: how long it takes to assemble one that is complete on day one.
The regulator's fees are small: €2,500 to examine the application, then an annual fee of up to 0.6% of gross income from crypto-asset services, and never less than €3,000. Consultations and pre-licensing are free. Budget instead for the own funds, custody technology, blockchain analytics and Travel Rule tooling, the safeguarding bank and the people.
After the licence
- Use it. An authorisation not used within twelve months, or with no services provided for nine consecutive months, can be withdrawn (Article 64).
- Conduct. Honest, fair and professional dealing with clients (Article 66), a complaints procedure (Article 71) and conflicts of interest managed and disclosed (Article 72).
- Market abuse. Arrangements to detect and report suspected market abuse under MiCA.
- Add the euro leg. A payment institution licence lets you execute client euro payments beside the crypto services. An e-money institution licence is the route, short of a bank, to issuing a euro-pegged e-money token.
- Grow up. Taking deposits or lending from the balance sheet describes a bank; Latvia now licenses one from €1 million, the specialised credit institution.
Where applications go wrong
| What goes wrong | What it looks like |
|---|---|
| Token misclassified | A financial instrument filed as an "other crypto-asset" |
| Wrong class | Custody in the programme of operations, Class 1 capital in the prudential annex |
| Fiat without a licence | Client euro payments on a CASP licence that does not cover them |
| Travel Rule bolted on | No originator or beneficiary data in the transfer flow |
| DORA by name only | An ICT policy that quotes the Regulation and names none of the systems |
| Keys without an owner | A custody policy that does not say who holds the keys or where |
| Latvia as a letterbox | A board abroad, operations abroad, a Riga address |
| Capital with no trail | Own funds raised in crypto with no documented path to the euro account |
| No way out | No orderly wind-down plan |
A licensing file describes a company that already exists on paper. The reviewer notices when the custody policy, the ICT risk assessment and the AML risk assessment were written by three vendors who never met.
How Nordant helps
We are based in Riga and work on crypto-asset, payment and e-money files before Latvijas Banka. For a crypto business the project is often two licences with one regulator, and we scope it that way from the first call.
- Licensing & Authorisation. Settle the token classification and service list, build the file through pre-licensing, answer the regulator to the decision.→
- Regulatory Advisory. Which class, which services now and later, whether you need a payment licence beside it, and whether the Article 60 route applies.→
- Legal & Corporate Advisory. The SIA, shareholder agreement, group structure, custody and outsourcing contracts.→
- Outsourced Legal Counsel. Senior capacity for the months the build takes.→
- Outsourced Compliance & MLRO. An AML risk assessment that matches your products and corridors, and Travel Rule procedures that match your transfer flow.→
Our default answer is "yes, safely." On a MiCA file that sometimes means telling you in the first call that your token is a security, or that your model is a payment institution with a crypto feature.
Common questions
- What is a MiCA licence in Latvia?
- An authorisation from Latvijas Banka under Regulation (EU) 2023/1114 (MiCA) to provide one or more of the ten crypto-asset services. It can be passported across the EU by notification.
- How much capital does a crypto-asset service provider need?
- €50,000, €125,000 or €150,000 depending on the services, or one quarter of the previous year's fixed overheads if higher. It may be held as own funds, an insurance policy, or both.
- How long does it take?
- Completeness is confirmed within 25 working days and a decision is due within 40 working days of a complete application. Preparation and pre-licensing come on top.
- What does it cost?
- The application fee is €2,500. The annual fee is up to 0.6% of gross income from crypto-asset services, with a minimum of €3,000 a year. Consultations and pre-licensing are free.
- Does a bank or investment firm need a CASP licence?
- No. Under Article 60 of MiCA an already-licensed institution notifies Latvijas Banka at least 40 working days before starting the crypto-asset services MiCA maps to its existing licence.
- Can a CASP run euro payments?
- Not on the CASP licence alone. Executing payments or holding stored value needs a payment institution or e-money institution licence, which Latvijas Banka can grant alongside the CASP licence.
Figures reflect the position at publication. We confirm the current rules for your case in the scoping call.