Licensing and Regulations | 5 min read

MiCA CASP Authorization: What Payment Companies Need to Do Before July 2026

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Saloni Sucklecha
Growth Marketing & FinTech Content Lead
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MiCA CASP Authorization: What Payment Companies Need to Do Before July 2026

TL;DR

If your business provides any crypto-asset service to EU customers and you are not MiCA-authorized by July 1, 2026, you are operating illegally. Authorization requires a legal entity in the EU, minimum capital of EUR 150,000, a documented governance and risk framework, and fit-and-proper management. The reward: one CASP license passports to all 27 member states. USDT is non-compliant under MiCA. USDC (Circle) is compliant.

MiCA is the world's first unified regulatory framework for digital assets, and the compliance clock is ticking. The final transitional deadline is July 1, 2026. After that date, every entity providing crypto-asset services to EU customers must hold MiCA authorization or stop operating.

For cross-border payment companies that use stablecoins in settlement flows, this determines which stablecoins you can use, which providers you can work with, and whether your EU payment flows are legal.

What CASP Authorization Requires

A CASP license under MiCA covers ten enumerated services including custody, trading, exchange, transfer, advisory, and order execution for crypto-assets [1].

The authorization process requires establishing a legal entity in an EU member state with genuine management presence (not a brass-plate subsidiary). Minimum capital is EUR 150,000 for most CASP categories. The applicant must submit a business plan, AML/KYC policies, a risk management framework, cybersecurity measures compliant with DORA, governance structure, and financial statements. Management must pass fit-and-proper assessments [2].

Regulator review typically takes 60 to 90 business days from complete application. Total cost from scratch runs EUR 50,000 to EUR 120,000 in legal and compliance preparation fees, plus the capital requirement [3].

1
Choose jurisdiction and establish EU legal entity
Germany, Netherlands, Malta, Luxembourg, Lithuania are the main hubs.
2
Build compliance documentation
Business plan, AML/KYC, risk framework, DORA cybersecurity, governance, financials. 3-6 months prep.
3
Submit to National Competent Authority
Pay application fee. Regulator reviews within 60-90 business days.
4
Authorization granted. Passport to all 27 EU member states.
Notify ESMA via home NCA. No additional applications needed.
Total timeline: 6-12 months from scratch
Total cost: EUR 50K-120K prep + EUR 150K minimum capital

The Passporting Advantage

The single most valuable feature of MiCA CASP authorization is passporting. One license from any EU member state covers all 27 member states. A CASP authorized in Lithuania can serve customers in Germany, France, Spain, and every other EU country without additional applications [1].

This replaces the pre-MiCA world where each country had its own VASP registration framework, and operating in five EU markets meant five separate registrations with five different compliance regimes.

Where Companies Are Getting Licensed

Five jurisdictions have emerged as primary licensing hubs [4]. Germany attracts larger institutions seeking bank-grade regulatory optics. The Netherlands processed applications quickly and attracted on/off-ramp specialists. Luxembourg hosts global exchanges like Coinbase and Bitstamp. Malta has become home to OKX, Gemini, and Bitpanda. Lithuania is the cost-effective entry point for smaller fintechs transitioning from its existing VASP regime.

The EMT/PSD2 Overlap

From March 2026, custody and transfer services involving E-Money Tokens may require both MiCA authorization and a separate payment services license under PSD2, because EMTs are functionally electronic money [5].

This dual licensing requirement could increase compliance costs substantially for providers handling euro-denominated stablecoins. The overlap has drawn criticism from the industry, with concerns that it undermines Euro stablecoin competitiveness. This is one of several parallel regulatory shifts across global payment markets that are reshaping compliance requirements in 2026.

Separately, Tether's USDT does not meet MiCA's EMT requirements. USDT has been delisted from major EU exchanges. For payment companies processing stablecoin settlements with EU counterparties, USDC (issued by MiCA-compliant Circle) is currently the primary compliant option [5].

What This Means for Payment Companies

If you process stablecoin payments involving EU customers, verify two things. First, that any stablecoin you use is issued by a MiCA-authorized entity. Second, that any intermediary handling settlement is authorized as a CASP or has a valid transitional arrangement that has not yet expired.

The July 1, 2026 deadline is the hard stop. After that, all remaining transitional provisions expire across the EU.

Sources:

[1] Hacken. "MiCA Regulation: What Crypto Projects Must Know For 2026 Compliance." April 2026. https://hacken.io/discover/mica-regulation/

[2] LegalBison. "Secure Your MiCA License: Gateway to the EU Market." March 2026. https://legalbison.com/mica-license/

[3] Codono. "MiCA Compliance for Crypto Exchanges 2026." March 2026. https://codono.com/blog/mica-compliance-crypto-exchange-guide

[4] Sumsub. "MiCA Regulation and EU Crypto Rules: What Changes in 2026." https://sumsub.com/blog/crypto-regulations-in-the-european-union-markets-in-crypto-assets-mica/

[5] Cyfrin. "MiCA Regulation Explained." November 2025. https://www.cyfrin.io/blog/mica-regulation-explained-a-guide-to-eu-crypto-compliance

Disclaimer: Stablecoin-related services are provided exclusively by Tazapay Canada Corp, a FINTRAC-registered Money Services Business. Tazapay Pte. Ltd. (Singapore) does not provide Digital Payment Token services under the Payment Services Act 2019.

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Saloni Sucklecha
Growth Marketing & FinTech Content Lead
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