CASP crypto licence in Luxembourg

CASP authorisation in Luxembourg, now MiCA is fully in force

The grey zone is gone. Since the Markets in Crypto-Assets (MiCA) regulation became fully applicable on 30 December 2024, offering crypto-asset services in the EU means holding a CASP authorisation. Luxembourg's eighteen-month transitional regime — which let firms already operating carry on without a licence — ended on 1 July 2026. That window has closed: a provider without authorisation can no longer lawfully operate, so the question is no longer whether you need a licence but whether your file is ready.

Luxembourg approaches this shift with an unusual advantage: the CSSF, a supervisor long practised in overseeing financial-sector actors, backed by a full ecosystem of banks, auditors and specialist service providers. An authorisation granted here opens all 27 EU markets through a single passport.

MiCA Framework Overview

The Markets in Crypto-Assets (MiCA) regulation creates a harmonized EU framework for:

• Crypto-Asset Service Providers (CASPs)
• Issuers of crypto-assets
• Stablecoin issuers (ARTs and EMTs)

Services Requiring CASP Authorization

Service	Minimum Capital
Custody and administration	€125,000
Trading platform operation	€150,000
Exchange services	€125,000
Order execution	€125,000
Placement services	€50,000
Reception/transmission of orders	€50,000
Advisory services	€50,000
Portfolio management	€125,000
Transfer services	€125,000

Planning an application? Read the full CASP application guide — classes and capital, CSSF steps, statutory timeline and common rejection pitfalls.

CASP Licensing Process

Step 1: Pre-Application

• Initial meeting with CSSF
• Business model assessment
• Gap analysis for compliance
• Capital planning

Step 2: Documentation

• Program of operations
• Organizational structure and governance
• IT and cybersecurity policies
• AML/CFT procedures
• Business continuity plan
• Complaints handling procedures
• Proof of capital

Step 3: Application Review

• CSSF review (up to 40 working days for complete applications)
• Fit and proper assessment of directors
• On-site inspection if required
• Authorization decision

Key Requirements

Governance

• At least 2 directors (4-eyes principle)
• Directors with relevant experience
• Compliance officer and MLRO
• Clear organizational structure

AML/CFT Compliance

• Customer due diligence procedures
• Transaction monitoring
• Suspicious activity reporting
• Travel Rule compliance

Prudential Requirements

• Minimum capital requirements
• Professional indemnity insurance
• Asset segregation requirements
• Regular reporting to CSSF

Why Luxembourg for Crypto?

• First-mover advantage: Early adoption of crypto regulation
• EU passport: Access to all EU markets with single license
• CSSF expertise: Experienced regulator in financial services
• Talent pool: Strong financial services ecosystem
• Tax clarity: Clear taxation of crypto-assets
• Infrastructure: World-class financial infrastructure

Our Services

• Pre-application strategy and planning
• CASP license application preparation
• Policy and procedure development
• Regulatory liaison with CSSF
• Ongoing compliance support
• VASP to CASP transition assistance