Estonia crypto company after MiCA: what happened to VASP licences
Estonia once issued more crypto VASP licences than any other EU member state, but MiCA replaced that regime and the old licences no longer exist. For founders, the question is no longer how to keep a VASP licence but how to run an Estonia crypto company after the transition, either as a MiCA-authorised CASP or under a different structure.
What Estonia's VASP regime actually was
Estonia amended its Money Laundering and Terrorist Financing Act in 2017 and began licensing virtual currency service providers from 2018. Two categories existed: a virtual currency wallet service and a virtual currency exchange service. A provider could hold one or both, and the licence was issued by the Estonian Financial Intelligence Unit (FIU). At its peak, Estonia had issued several thousand VASP licences, far more than any other EU jurisdiction, largely because the application process was comparatively quick and the capital requirement was low.
The regime was an anti-money laundering licence, not a full financial services licence. It did not grant passporting rights across the EU, and it did not cover investment services, custody in the MiFID sense, or the issuance of tokens. That distinction matters because many founders assumed a VASP licence was a general crypto licence for Europe. It was not. It allowed a company registered in Estonia to provide exchange and wallet services while complying with Estonian AML rules, and it was widely used as a base for serving clients outside Estonia.
The Estonian FIU tightened the regime over time. Fees rose, fit-and-proper requirements became stricter, and the regulator withdrew licences from companies that failed to demonstrate real activity in Estonia. By the time MiCA was agreed at EU level, the direction of travel was clear: the national VASP regime would be replaced by a single EU framework for crypto-asset service providers.
How MiCA replaced the national VASP licence
MiCA, the Markets in Crypto-Assets Regulation, entered into force in 2023 and its main provisions for crypto-asset service providers applied from 30 December 2024. It is directly applicable across the EU, which means it replaced national licensing regimes for the activities it covers. Estonia could no longer maintain a separate VASP licence for services that fall within MiCA's scope. The old FIU licences were wound down through a transitional arrangement, and by 2026 the position is settled: a firm providing MiCA-regulated crypto services in or from Estonia needs CASP authorisation.
The transition was not instant for everyone. Estonia, like other member states, used the grandfathering window to allow existing VASP holders to continue temporarily while they applied for CASP authorisation. That window has now closed. A company that held an Estonian VASP licence and did not obtain CASP authorisation cannot lawfully continue providing regulated crypto-asset services. Continuing to do so exposes the company to enforcement, and the FIU and the Estonian Financial Supervision Authority (Finantsinspektsioon) have shown willingness to act against unlicensed activity.
It is important to separate the licence from the company. The Estonian private limited company (OÜ) that held a VASP licence still exists as a legal entity. What changed is the permission to provide regulated services. The company can keep trading as a software business, a consultancy, or a holding company, but it cannot hold itself out as a licensed crypto-asset service provider unless it has CASP authorisation or is providing services that fall outside MiCA.
What a MiCA CASP authorisation requires in Estonia
A CASP authorisation is granted by the national competent authority, which in Estonia is Finantsinspektsioon. The applicant must be an Estonian legal entity, typically an OÜ or an AS, with a registered office in Estonia and substantive management there. The application covers the specific crypto-asset services the firm intends to provide, such as custody and administration, operation of a trading platform, exchange of crypto-assets for funds, exchange for other crypto-assets, execution of orders, placement, transfer services, reception and transmission of orders, advice, and portfolio management. Each service must be applied for individually.
Capital requirements depend on the class of service. MiCA sets three tiers: EUR 50,000 for certain advisory, order transmission, and execution services; EUR 125,000 for custody, exchange, transfer, and reception and transmission of orders; and EUR 150,000 for operating a trading platform or dealing on own account. These are minimum own funds requirements and must be met on an ongoing basis, not just at application. The capital can be held in cash or in a combination of instruments that the regulator accepts, and it must be free from encumbrances.
Beyond capital, the applicant needs a credible governance structure, fit-and-proper directors and shareholders, an AML/CFT framework, safeguarding arrangements for client crypto-assets and funds, a complaints procedure, and a business plan that explains the services, the target market, and the systems in place. Finantsinspektsioon reviews the application and can ask for further information. Timelines vary depending on the completeness of the file and the complexity of the services, and applicants should expect several months rather than weeks. Preparation quality is usually the main driver of how quickly an application moves.
What happened to companies that did not convert
Companies that held an Estonian VASP licence and did not obtain CASP authorisation had a few practical options. Some wound down their regulated activity and continued as software or consulting businesses. Some moved their regulated activity to another structure or jurisdiction. Some simply stopped operating. The common thread is that the licence itself has no residual value for MiCA-regulated services. It cannot be sold, transferred, or used as a passport. Anyone marketing an 'Estonian VASP licence for sale' in 2026 is either selling something outside MiCA's scope or misrepresenting the position.
There is a narrow category of activity that may fall outside MiCA. A company that only develops software, provides purely technical infrastructure, or offers services to other licensed firms may not need CASP authorisation. Similarly, a company that issues its own token may be outside CASP requirements, though the issuance itself may be subject to MiCA's rules on asset-referenced tokens, e-money tokens, or other crypto-assets. These distinctions are fact-specific and depend on the exact service being provided, who the client is, and how the service is described.
For founders who want to keep an Estonian company but do not want to go through CASP authorisation, the honest answer is that the company can exist but cannot provide regulated crypto services to EU clients. It can be a development house, a holding company, or a service provider to licensed entities. If the goal is to serve EU retail or institutional clients with exchange, custody, or trading services, CASP authorisation is the route.
Panama as an alternative for non-EU focused founders
Some founders who served clients outside the EU, or who wanted a simpler corporate base, have looked at Panama. Panama does not have a dedicated crypto licence. Instead, a crypto business typically incorporates a Sociedad Anonima, the Panamanian corporation, and operates under general commercial law. Incorporation is usually completed in two to three weeks, and the corporate tax position is generally 0% on foreign-source income. Panama does not impose exchange controls and does not require local shareholders or directors in the way some jurisdictions do.
The trade-off is that a Panamanian company is not a MiCA-authorised CASP. It cannot passport into the EU or provide regulated crypto services to EU clients on the basis of its Panamanian status. If a founder's clients are in Latin America, Asia, or elsewhere outside the EU, and if the services do not trigger licensing in the clients' jurisdictions, Panama can be a workable base. If the clients are in the EU, Panama does not solve the MiCA question. It may still be useful as a holding or treasury entity, but the regulated activity needs a licensed entity in the relevant jurisdiction.
Panama also has its own AML obligations and substance expectations, and banks and payment providers will apply their own due diligence. The absence of a crypto-specific licence does not mean the absence of compliance. Founders should treat Panama as a corporate and tax structuring option, not as a regulatory shortcut. The decision between Estonia and Panama usually comes down to where the clients are and which licences the business actually needs.
How to decide what to do with your Estonian company
Start with the services. List every activity the company performs and map each one to the MiCA service categories. If any activity is a MiCA service and the clients are in the EU, CASP authorisation is likely required. If the activity is purely technical, or the clients are outside the EU, the analysis may be different. The mapping exercise is the single most useful step because it prevents founders from either over-licensing or operating without a required permission.
Then look at capital and substance. The EUR 50,000, 125,000, and 150,000 tiers are minimums, and the regulator will expect the firm to hold enough capital for its risk profile. Substance means real management in Estonia, not just a registered address. Directors should be able to explain the business, the risks, and the controls. If the company cannot meet these expectations, the application will struggle, and the founder should consider whether a different structure or a different market focus is more realistic.
Finally, consider timing and cost. CASP authorisation is a project, not a formality. It involves legal drafting, policies, capital, and ongoing supervision. For some founders, the right answer is to pursue authorisation because the EU market is the target. For others, the right answer is to keep the Estonian company for non-regulated activity and use a different structure for regulated services elsewhere. Consulting24 advises founders on both paths, including Estonian CASP applications and alternative structures such as Panama, so the decision is based on the actual business rather than on outdated assumptions about VASP licences.
How to Choose the Right Jurisdiction
Work the decision in this order: customers first, everything else second:
- Who are your customers? EU retail means you need a MiCA passport (Lithuania, Malta or another EU CASP). US customers mean state-by-state money-transmitter licensing or a FinCEN MSB, so consider a Canada MSB or a US setup. Latin America, Asia or HNW clients mean an offshore or territorial base such as Panama is usually the better fit.
- Do you need a regulator badge? A public-facing exchange chasing institutional partners and fundraising often needs the reputational lift of an EU, Swiss or VARA licence. An OTC desk or token treasury usually does not.
- What is your budget and timeline? Offshore and territorial routes set up in weeks for tens of thousands; premium onshore licences take many months and six figures.
- What about tax? Territorial-tax jurisdictions like Panama charge 0% on foreign-source income; EU jurisdictions apply standard corporate tax. Factor total cost of ownership, not just setup fees.
For many offshore-first founders, Panama lands at the intersection of fast incorporation, low cost and 0% tax on foreign-source income, which is why it features so heavily in our work. But the honest answer is that the “best” jurisdiction is the one that matches the four answers above, and that is a conversation worth having before you spend a cent. See our cost breakdown and application process to ground the decision in real numbers.
Banking and Compliance: Where Most Setups Actually Stall
Incorporation is the easy part of any crypto project. Banking is where timelines slip and where under-prepared founders lose months. Since 2023, banks and payment processors worldwide have tightened their onboarding of crypto-adjacent businesses, and they now expect a genuinely professional application , not a one-page business summary. A thin file is simply rejected, and re-applying with the same bank is far harder than getting it right the first time.
Three documents do the heavy lifting. The first is a written AML/KYC compliance program: your customer-onboarding flow, transaction-monitoring rules, sanctions and PEP screening, a named compliance officer, and record-keeping policies. The second is a clear, evidenced source-of-funds file for both the company and its beneficial owners. The third is a coherent business description that explains who your customers are, how money moves, and what volumes you project. Banks approve businesses they understand; ambiguity reads as risk.
Sequencing matters as much as substance. The correct order is: incorporate the operating entity, build the compliance program, assemble the source-of-funds package, and only then approach banking, ideally through a warm introduction rather than a cold application. Founders who approach banks mid-setup, before their file is complete, create the very delays they are trying to avoid. We make direct introductions to banks and crypto-friendly payment rails as part of every engagement, but the introduction only works if the file behind it is ready.
None of this is optional, and none of it changes much from one jurisdiction to the next, the compliance bar is now broadly global. What changes is the appetite of local banks and the speed of onboarding. Our requirements checklist sets out exactly what you need to assemble before you approach a bank.
Crypto Licensing in 2026: The Bigger Picture
Choosing where to license a crypto business in 2026 is no longer a simple cost calculation. The regulatory map has hardened considerably over the last three years. In the European Union, the Markets in Crypto-Assets Regulation (MiCA) has replaced the patchwork of national VASP registers with a single Crypto-Asset Service Provider (CASP) authorisation that passports across all 27 member states. That passport is powerful, but it comes with capital requirements, governance obligations and a multi-month authorisation process that smaller projects often underestimate.
Outside the EU, the picture is more varied. Offshore and territorial-tax jurisdictions compete on speed, cost and privacy, while major financial centres such as Switzerland, the UAE and Singapore compete on credibility and institutional access. The Financial Action Task Force (FATF) sits over all of them: its “travel rule” and AML standards now apply, in some form, almost everywhere a serious crypto business would consider basing itself. Jurisdictions that ignore FATF expectations end up grey-listed, which quietly closes correspondent-banking doors for every company registered there.
This is why the question behind Estonia crypto company after is rarely “which licence is cheapest?” It is “which regime matches my customers, my risk appetite and my banking needs?” An EU-retail exchange and an offshore OTC desk serving high-net-worth clients in Latin America have almost nothing in common in terms of the right base. Getting this decision right at the start saves you from the single most expensive mistake in the industry: licensing in the wrong place and having to re-domicile a live business.
Consulting24 has guided more than 200 crypto company setups across 15+ jurisdictions since 2017, which means we have seen how each of these regimes behaves in practice rather than just on paper. The summary below is the same framework we use with clients, and we are always happy to map it to your specific model. Start with our Panama vs Lithuania comparison to see how the trade-offs play out between an offshore base and an EU-passported one.
Common Mistakes to Avoid
The failures we see when founders research Estonia crypto company after on their own are remarkably consistent, and almost all of them are avoidable. The first is licensing to the headline tax rate. A 0% jurisdiction is worthless if your customers legally require a regulated provider you cannot become there, and you will simply have to start again. Decide who you are allowed to serve first, then optimise for tax.
The second is treating the compliance program as paperwork. The AML/KYC program is not a formality to satisfy a regulator; it is the document your bank reads most closely. A generic template downloaded from the internet is transparent to any compliance officer and will sink your banking application. It needs to reflect your actual product, customer base and risk profile.
The third is underestimating banking lead time. Founders routinely budget for incorporation and forget that the bank account, the thing that actually lets the business operate, can take longer than the licence itself. Build banking into your launch timeline from day one, not as an afterthought.
The fourth is ignoring personal tax residency. A company in a low-tax jurisdiction does not erase your obligations where you personally live. Many founders create unexpected liabilities by structuring the company perfectly and ignoring themselves. We introduce qualified tax advisors precisely to close this gap.
The fifth and most expensive is choosing a provider on price alone. The cheapest setup that results in a rejected bank application or a re-domiciliation is far more expensive than doing it properly once. Ask any provider to itemise their fee and explain their banking track record before you commit.
What Happens After You Are Licensed
Getting licensed and banked is the start, not the finish. Every regulated or registered crypto business carries ongoing obligations, and letting them lapse is how companies lose their standing, and their banking. At minimum you will maintain a registered agent or local presence, file annual renewals or supervision fees, keep accounting records, and keep your compliance program live with periodic reviews and updated sanctions and PEP screening lists.
Most jurisdictions also expect you to keep your beneficial-ownership information current and to report material changes, new directors, new shareholders, a pivot in business activity, promptly. Transaction monitoring is not a one-time setup either; screening rules need tuning as your volumes and customer mix evolve. Banks may request periodic refreshes of your KYC and source-of-funds documentation, particularly after a year of trading or a significant change in activity.
This is why we offer ongoing maintenance on an annual retainer rather than treating setup as a one-off transaction. The cost of staying compliant is a fraction of the cost of losing a banking relationship and having to rebuild one from scratch. Plan for it in your year-two budget from the outset, and treat your compliance function as a living part of the business rather than a box you ticked at launch.
It is also worth planning ahead for growth. A structure that suits a pre-revenue startup may not suit the same company once it is processing meaningful volume, adding new product lines, or expanding into new markets. Many of the businesses we work with begin in a fast, low-cost offshore base to validate the model, then add a second regulated entity, an EU CASP, for example, once revenue justifies the cost and the market access genuinely matters. Designing the first structure with that possible second step in mind keeps your options open and avoids a disruptive re-domiciliation later. We map this growth path out with clients during the initial planning stage so the early decisions support, rather than constrain, where the business is heading.
Consulting24 has completed 200+ crypto company setups across 15+ jurisdictions. Talk to our team for a fixed-fee proposal and realistic timeline.
Learn more WhatsApp usEmail mardo@consulting24.co · Phone +372 58155779
About Consulting24 & Mardo Soo
Founder & CEO, Consulting24 · LinkedIn
Consulting24 is an eight-year-old advisory firm that has completed 200+ crypto company setups across 15+ jurisdictions since 2017. Founder and CEO Mardo Soo and the team specialise in crypto, VASP and exchange licensing, from Panama and the EU (MiCA) to Dubai, Canada and the offshore world. We don't push a single “best” jurisdiction; we map your business to the regime that actually fits, then handle incorporation, the AML/KYC compliance program, and banking and payment-processor introductions end to end.
Every engagement begins with an honest conversation about your customers, budget and timeline and ends with a fixed-fee proposal, so you know the all-in number before you commit. We also introduce vetted local lawyers and tax advisors wherever your structure requires them.
Operated by X24Consulting OÜ (Estonian Business Register code 16971898), Põrdi tn 3-63, 10156 Tallinn, Estonia · mardo@consulting24.co · +372 58155779
Frequently Asked Questions
Do Estonian VASP licences still exist in 2026?
No. The national VASP regime was replaced by MiCA, and the transitional window for existing holders has closed. A firm providing MiCA-regulated crypto services in or from Estonia now needs CASP authorisation from Finantsinspektsioon. Old VASP licences are not valid for those services.
Can I still buy an Estonian VASP licence?
There is no meaningful market for Estonian VASP licences for MiCA-regulated activity. The licence does not carry passporting rights and cannot be used to provide regulated crypto services after the transition. Anyone offering one for sale is likely selling a shell company or a licence for activity outside MiCA's scope.
What is the capital requirement for a MiCA CASP in Estonia?
MiCA sets three tiers: EUR 50,000 for certain advisory, order transmission, and execution services; EUR 125,000 for custody, exchange, transfer, and reception and transmission of orders; and EUR 150,000 for operating a trading platform or dealing on own account. These are minimum own funds requirements that must be maintained on an ongoing basis.
Who grants CASP authorisation in Estonia?
Finantsinspektsioon, the Estonian Financial Supervision Authority, is the national competent authority for MiCA. Applications are made to Finantsinspektsioon, which reviews the business plan, governance, capital, AML framework, and safeguarding arrangements.
How long does CASP authorisation take in Estonia?
Timelines vary with the completeness of the application and the complexity of the services. Founders should expect several months rather than weeks. A well-prepared file with clear policies and a realistic business plan usually moves faster than an incomplete one.
Can I keep my Estonian company if I do not get a CASP licence?
Yes, the company can continue to exist. What it cannot do is provide MiCA-regulated crypto services to EU clients without authorisation. It can operate as a software developer, consultancy, holding company, or service provider to licensed firms, depending on its actual activity.
Does Panama have a crypto licence?
Panama does not have a dedicated crypto licence. Crypto businesses typically incorporate a Sociedad Anonima and operate under general commercial law. Setup usually takes two to three weeks, and the corporate tax position is generally 0% on foreign-source income, but a Panamanian company is not a MiCA-authorised CASP and cannot passport into the EU.
Should I choose Estonia or Panama for my crypto company?
It depends on where your clients are and which services you provide. If you serve EU clients with regulated crypto services, Estonia with CASP authorisation is the route. If your clients are outside the EU and your services do not trigger licensing in their jurisdictions, Panama can be a simpler corporate and tax base. Many founders use both, with a licensed EU entity and a non-EU holding or treasury company.
Related reading
More crypto-license guides on this blog
- Crypto License in Panama: Cost, Requirements & Setup (2026)
- Crypto Exchange License: How and Where to Get One in 2026
- Crypto License Cost by Jurisdiction: 2026 Comparison
Related crypto licensing routes
A few relevant guides on consulting24.co, each with real cost, timeline and requirements:
This article reflects 2026 market conditions and is general guidance, not legal or tax advice. Regulations change, so confirm specifics with qualified counsel before acting. Consulting24 (X24Consulting OÜ, Estonian reg. 16971898) introduces vetted local lawyers and tax advisors during every engagement.
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