CASP licence in Luxembourg: MiCA application guide
How to get a CASP licence in Luxembourg under MiCA: who needs one, capital by class (€50,000-€150,000), CSSF application steps, timeline and costs.
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To provide crypto-asset services in or from Luxembourg, you need a CASP authorisation from the CSSF under MiCA. Minimum capital ranges from €50,000 to €150,000 depending on your service class, the statutory review clock is 25 + 40 working days once your file is complete, and a single licence passports you into all 27 EU member states. The transitional regime ended on 1 July 2026.
CASP licence at a glance
Sources: CSSF, MiCA Regulation (EU) 2023/1114, ESMA — MiCA
Who needs a CASP licence in Luxembourg?
Any business providing one or more of the crypto-asset services defined by MiCA to clients in the EU needs a CASP (Crypto-Asset Service Provider) authorisation. MiCA has applied in full to CASPs since 30 December 2024. The regulated services are:
- Custody and administration of crypto-assets on behalf of clients
- Operating a trading platform for crypto-assets
- Exchange of crypto-assets for funds or for other crypto-assets
- Execution of orders on behalf of clients
- Placing of crypto-assets
- Reception and transmission of orders
- Advice on crypto-assets
- Portfolio management of crypto-assets
- Transfer services for crypto-assets
For the wider regulatory picture — stablecoins, DORA, AML — see our broader MiCA licence guide for Luxembourg.
What are the three CASP classes and how much capital do you need?
MiCA groups crypto-asset services into three classes, each with its own permanent minimum capital requirement:
| Class | Services covered | Minimum capital |
|---|---|---|
| Class 1 | Advice; reception and transmission of orders | €50,000 |
| Class 2 | Class 1 services plus custody and administration, exchange, execution of orders, placing | €125,000 |
| Class 3 | Class 2 services plus operating a trading platform | €150,000 |
Two points are often missed. First, the class minimum is a floor, not the whole test: own funds must be at least the higher of the class minimum and one quarter of the previous year's fixed overheads, so an established business may need substantially more than the headline figure. Second, MiCA also allows the prudential safeguard to take the form of a professional indemnity insurance policy, or a combination of own funds and insurance.
How do you apply for a CASP licence with the CSSF?
Step 1: Set up the Luxembourg entity
Applicants typically incorporate a Luxembourg company — usually an SARL (minimum capital €12,000) or an SA (minimum capital €30,000) — sized so that the entity can evidence the required own funds.
Step 2: Prepare the application file
This is where most of the elapsed time goes. The CSSF expects, among other things:
- A programme of operations describing each crypto-asset service you will provide
- A detailed business plan and evidence of capital / own funds
- Governance documentation: at least two effective directors, fitness and propriety files (CVs, criminal records)
- AML/KYC policies and procedures, including Travel Rule compliance
- ICT security and business continuity documentation (DORA also applies to CASPs)
- Client asset segregation and complaints-handling procedures
Step 3: Submit and respond
The file is submitted to the CSSF, which checks completeness and typically comes back with questions. Directors' honourability and the firm's substance in Luxembourg are scrutinised — the CSSF expects directors to be effectively present, not letterbox appointments.
Step 4: Decision and passporting
Once authorised, the CASP can notify its intention to provide services in other member states and passport across the EU.
How long does CASP authorisation take?
Article 63 MiCA sets the statutory clock: the CSSF has 25 working days to confirm whether the application is complete, then 40 working days from a complete file to grant or refuse authorisation. That 40-day period can be suspended for up to 20 working days while the regulator waits for additional information.
The statutory clock only measures the review of a complete file. Counting preparation, incorporation and rounds of CSSF questions, practitioners typically report an indicative 4 to 12 months from project start to authorisation — treat that as an estimate, not a commitment; the CSSF controls its own timetable.
How much does a CASP licence cost?
Costs vary widely with the service classes applied for and the complexity of the business. The ranges below are indicative third-party market estimates (excluding VAT and disbursements), not fixed prices and not fees of this platform:
| Item | Indicative range |
|---|---|
| Company incorporation | €5,000 – €8,000 |
| Minimum capital (by class) | €50,000 – €150,000 |
| CSSF file preparation (legal and regulatory) | €30,000 – €80,000 |
| AML compliance setup | €15,000 – €40,000 |
| IT / cybersecurity infrastructure | €20,000 – €100,000 |
Recurring annual costs — compliance staff, external audit, professional indemnity insurance, monitoring tools — commonly run into six figures for an operating CASP. A partner lawyer can scope a realistic budget for your specific service mix.
Why do CASP applications fail or stall?
The CSSF rarely publishes refusal statistics, but recurring problem areas practitioners cite include:
- Incomplete files — the most common cause of delay: gaps trigger the completeness check and can suspend the 40-working-day decision clock
- Insufficient Luxembourg substance — directors not effectively present or too little time dedicated to the role
- Generic AML/KYC frameworks — copy-paste policies not tailored to the actual crypto-asset services and client base
- Unclear programme of operations — services described too vaguely for the CSSF to map them to MiCA classes
- Capital not properly evidenced — or sized only to the class minimum where the fixed-overheads test requires more
- Weak ICT and outsourcing arrangements — critical functions outsourced without demonstrated oversight, or DORA requirements underestimated
Frequently asked questions
Can I still operate under the transitional (grandfathering) regime?
No. Luxembourg’s 18-month transitional period under MiCA ended on 1 July 2026. Entities that had not obtained CASP authorisation by that date had to cease providing crypto-asset services. Any new entrant must be authorised by the CSSF before offering services.
How long does it take to get a CASP licence in Luxembourg?
The statutory clock under Article 63 MiCA is 25 working days for the CSSF to confirm the file is complete, then 40 working days to grant or refuse authorisation (suspendable by up to 20 working days if more information is requested). In practice, practitioners typically report an indicative 4 to 12 months elapsed time from project start to authorisation, largely driven by file preparation.
What is the minimum capital for a CASP?
It depends on the class of services: €50,000 for Class 1 (advice, reception and transmission of orders), €125,000 for Class 2 (including custody and administration, exchange, execution and placing), and €150,000 for Class 3 (operating a trading platform). Own funds must also be at least one quarter of the previous year’s fixed overheads, if that amount is higher.
Does a Luxembourg CASP licence cover the whole EU?
Yes. Once authorised by the CSSF, a CASP can passport its services into all 27 EU member states via a notification procedure, without needing a separate licence in each country.
Do I need a Luxembourg company before applying?
Applicants typically incorporate a Luxembourg entity, usually an SARL (minimum capital €12,000) or an SA (minimum capital €30,000), before or alongside preparing the CSSF file. A lawyer can advise on the appropriate form for your shareholding and governance structure.
Who supervises CASPs in Luxembourg?
The CSSF (Commission de Surveillance du Secteur Financier), Luxembourg’s financial regulator, receives applications, grants CASP authorisations under MiCA and supervises licensed providers on an ongoing basis.
Official references: CSSF · Regulation (EU) 2023/1114 (MiCA) on EUR-Lex · ESMA — Markets in Crypto-Assets Regulation
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