The Markets in Crypto-Assets (MiCA) Regulation is a turning point for the European crypto industry. Starting in 2025, all crypto service providers in the Czech Republic and across the EU will need to comply with a unified legal framework. The goal is to create clear regulatory standards for licensing, capital requirements, AML compliance, and technological security.
For crypto businesses already operating in the Czech market, adapting to MiCA is not optional. Existing companies must apply for a license by July 31, 2025, while new entrants must ensure full compliance from day one. Those who fail to meet the requirements face financial penalties and operational restrictions.
In this article, we will break down:
Why MiCA was introduced and what it means for the industry
New licensing requirements and deadlines for crypto businesses
Key compliance obligations, including capital reserves and AML policies
Potential risks for non-compliance and how to avoid them
Practical steps to prepare for the new regulatory landscape
With Czechia emerging as a leading hub for crypto businesses in the EU, understanding MiCA’s impact is crucial. Let’s explore how these changes will shape the industry in 2025.
What is MiCA Regulation and Why It Was Introduced
MiCA was introduced to address key challenges in the crypto sector, such as ensuring a well-regulated market, improving investor protection, and mitigating risks of financial crime. MiCA establishes clear regulatory standards and transparency measures, providing businesses and investors with greater certainty and legal clarity. By setting unified rules for crypto asset issuance, trading, and service providers, MiCA reduces regulatory fragmentation, enhances trust in the market, and mitigates risks associated with financial crime and misconduct.
Before MiCA, crypto businesses operated under fragmented national regulations, leading to inconsistencies and regulatory gaps across different EU jurisdictions. Some countries had strict oversight, while others provided minimal regulation, creating an uneven playing field and uncertainty for market participants.
Key Objectives of MiCA
Harmonization of Crypto Regulations – Establishing a single regulatory framework across the EU to replace inconsistent national rules.
Increased Consumer Protection – Ensuring that crypto businesses provide transparent information and comply with investor protection policies.
Market Stability – Reducing the risks associated with unregulated stablecoins, speculative trading, and fraudulent projects.
Anti-Money Laundering (AML) and Financial Security – Strengthening AML and CFT (Countering the Financing of Terrorism) measures to prevent illicit activities.
Encouragement of Innovation – Providing a clear and predictable legal environment that fosters responsible crypto adoption and blockchain innovation.
By 2025, any business dealing with crypto-assets, stablecoins, trading platforms, or wallet services will need to comply with MiCA’s legal standards. The Czech Republic, known for its crypto-friendly business environment, will fully integrate these new regulations, making it an attractive jurisdiction for companies that want legal certainty and access to the EU market.
Next, we will explore how MiCA is reshaping the crypto industry and what businesses must do to stay compliant.
Changes in Crypto Business Regulation and New MiCA Requirements
With MiCA Regulation coming into force in 2025, crypto businesses in the Czech Republic and across the EU are facing a new regulatory landscape. The most critical shift is the transition from fragmented national regulations to a unified licensing framework. This means that all companies involved in crypto-related activities, such as exchanges, custodial services, and advisory platforms, must undergo a formal authorization process to continue operating legally.
A key aspect of the new regulatory framework is the standardization of operational requirements. Under MiCA, crypto service providers must implement strict internal controls, ensuring that risk management, transparency, and governance structures align with EU financial sector standards. Companies will need to demonstrate compliance readiness, including secure handling of crypto transactions, structured reporting procedures, and documented business practices.
Another significant development is the introduction of supervisory oversight by national regulators. In the Czech Republic, the Czech National Bank (CNB) will be responsible for reviewing license applications and monitoring compliance. This shift brings crypto businesses closer to traditional financial institutions in terms of legal scrutiny and regulatory accountability. Companies will be required to submit regular reports, conduct internal audits, and ensure that their operations remain in line with MiCA’s evolving standards.
Additionally, customer protection rules have been reinforced, particularly regarding the handling of client assets. Crypto businesses must establish clear operational policies that prevent the commingling of company and client funds, ensuring that users have uninterrupted access to their holdings. These rules extend to custodial service providers, who will need to adopt enhanced security measures and guarantee the safety of stored digital assets.
MiCA also brings greater technological compliance requirements, focusing on the cybersecurity and ICT infrastructure of crypto platforms. Companies must implement secure data protection mechanisms, ensure operational resilience, and adopt preventive measures against cyber threats. In the Czech Republic, compliance with DORA (Digital Operational Resilience Act) will be a key requirement, aligning crypto firms with broader EU financial security regulations.
For businesses operating in or entering the Czech market, these changes signal a new era of regulatory certainty, but also a higher barrier to entry. Companies must take proactive steps to align with the MiCA framework, ensuring their operations meet both legal and technological requirements before the new rules take full effect.
In the next section, we will explore the different types of MiCA licenses and how they apply to crypto businesses in the Czech Republic.
Types of MiCA licenses.
The MiCA Regulation establishes a structured licensing framework for entities engaged in crypto-asset services. Under this new legal framework, licenses are divided into three main categories, depending on the nature and scope of the business activities. These include Crypto-Asset Service Providers (CASPs), issuers of asset-referenced tokens, and issuers of e-money tokens.
Crypto-Asset Service Providers (CASPs)
Crypto-Asset Service Providers are businesses that offer a range of services related to digital assets. These services are further categorized into three classes, each with specific operational permissions and compliance obligations.
Class 1 – General Crypto-Asset Services
Entities operating under Class 1 are authorized to provide foundational crypto services, such as:
Executing orders for crypto-assets, which involves facilitating the purchase, sale, or subscription of digital assets on behalf of clients.
Placing crypto-assets on the market, which entails marketing and distributing tokens for issuers or related parties.
Receiving and transmitting orders, ensuring that crypto transactions initiated by clients are routed to execution platforms.
Providing advisory services, offering clients personalized investment recommendations regarding digital asset transactions.
Managing crypto-asset portfolios, handling client funds in a discretionary manner based on predetermined investment strategies.
Facilitating crypto-asset transfers, allowing users to securely move their digital assets between addresses or accounts.
These activities represent the core functions of crypto service providers that do not engage in custodial services or operate an exchange.
Class 2 – Custodial and Exchange Services
Businesses under Class 2 are permitted to offer all Class 1 services, in addition to:
Providing custody and management of crypto-assets, meaning the safekeeping of digital assets or private cryptographic keys on behalf of clients.
Conducting crypto-to-fiat and crypto-to-crypto exchanges, enabling seamless conversion between digital assets and traditional currencies.
This class applies to custodial wallet providers, centralized exchanges, and platforms that facilitate crypto transactions involving fiat currency.
Class 3 – Trading Platforms and Market Operators
The highest tier, Class 3, allows companies to offer all services included in Class 1 and Class 2, with the additional ability to:
Operate crypto trading platforms, providing an infrastructure for third-party buyers and sellers to exchange digital assets in a structured environment.
This category applies to large-scale crypto exchanges and trading platforms that manage high-volume transactions and facilitate market liquidity.
Issuers of Asset-Referenced Tokens
This licensing category applies to companies that issue crypto-assets designed to maintain a stable value by referencing a specific value, right, or combination of assets, excluding e-money tokens. These tokens are often structured to mirror the price of commodities, baskets of currencies, or other assets, providing users with a more predictable value than standard cryptocurrencies.
Issuers of E-Money Tokens
Entities issuing e-money tokens must obtain a separate license under MiCA. These tokens are structured to retain a stable value by being pegged to a single official currency, such as the euro or US dollar. This category is particularly relevant for companies that provide digital alternatives to traditional fiat money and aim to integrate stablecoins into payment ecosystems.
Important Considerations Under MiCA
MiCA defines crypto-assets as digital representations of value or rights that are transferable and stored electronically using distributed ledger technology (DLT) or similar technologies. However, the regulation does not apply to NFTs (non-fungible tokens), as they are considered unique and non-interchangeable. Additionally, certain crypto-assets classified as financial instruments are exempt from MiCA, as they fall under existing financial regulations.
For businesses operating in the Czech Republic and across the EU, obtaining the appropriate MiCA license is a mandatory step to ensure compliance and continued operation within the regulated European crypto market. Choosing the right license category depends on the scope of services a company intends to offer, its operational structure, and its long-term business strategy.
Capital Requirements for MiCA Licensing
One of the key obligations under the MiCA Regulation is maintaining a minimum capital reserve, ensuring financial stability and risk management for crypto businesses. The required capital is directly linked to the type of MiCA license a company applies for, reflecting the level of risk and responsibility associated with its operations. Companies operating under MiCA must demonstrate sufficient liquidity to cover potential market risks, ensure client fund protection, and maintain operational continuity.
Minimum Capital Requirements Based on MiCA Licensing
The financial requirements for obtaining a Crypto-Asset Service Provider (CASP) license are divided into three tiers, each corresponding to the level of responsibility and risk associated with different business models.
€50,000 – Class 1 CASPs (General Crypto-Asset Services)
This capital threshold applies to businesses that provide non-custodial crypto services, meaning they facilitate transactions but do not hold or manage client funds. Companies operating under this category face lower financial risks, making them eligible for a reduced capital requirement.
These companies primarily act as intermediaries and do not engage in direct asset custody or large-scale trading, which is why they are subject to the lowest capital requirement under MiCA.
€125,000 – Class 2 CASPs (Custodial and Exchange Services)
Businesses that hold client assets or facilitate crypto-to-fiat and crypto-to-crypto exchanges must meet a higher capital reserve requirement. This ensures their ability to safeguard client funds, manage liquidity, and absorb potential operational risks.
€150,000 – Class 3 CASPs (Trading Platforms and Market Operators)
Companies that operate crypto-asset trading platforms or provide market-making and liquidity services face strict capital requirements under MiCA. These businesses are critical to the stability of digital asset markets and must demonstrate strong financial backing to manage high transaction volumes, prevent market manipulation, and ensure fair trading conditions.
Given their influence over trading activity, liquidity flows, and market confidence, these businesses must maintain significant financial reserves to meet regulatory standards and absorb operational risks.
€350,000 or 2% of Reserve Assets - Issuers of Asset-Referenced Tokens
Entities that issue digital tokens backed by a reserve of assets, such as fiat currencies, commodities, or other financial instruments. They are responsible for maintaining sufficient reserves, ensuring stability, and complying with regulatory requirements to mitigate financial and operational risks.
Issuers of Asset-Referenced Tokens are required to maintain capital of at least €350,000 or 2% of their reserve assets (whichever is higher). This is necessary to cover risks associated with asset management, price fluctuations, and operational risks.
2% - 20% of capital reserves - E-money Institutions
Entities that issue electronic money (e-money), including stablecoins—digital assets pegged to fiat currencies. These institutions facilitate the storage, transfer, and use of e-money for payments and financial transactions via digital wallets, prepaid cards, or online platforms.
E-money institutions must hold capital equal to at least 2% of the average outstanding e-money in circulation. If the outstanding e-money amount is uncertain, regulators may allow capital calculations based on a representative portion of projected issuance. New institutions must base their capital on forecasted issuance, with regulatory adjustments if needed. Regulators can increase or decrease the required capital by up to 20% based on risk assessments.
Ongoing Compliance and Financial Monitoring
Meeting the minimum capital requirements is not just a one-time obligation—companies must maintain compliance throughout their operations.
Companies can meet these capital requirements using one or a combination of the following prudential safeguards:
Own funds, including high-quality capital (Common Equity Tier 1) after all necessary deductions, without applying threshold exemptions.
An insurance policy or comparable guarantee, covering the territories of the Union where crypto-asset services are provided, ensuring regulatory compliance and financial stability.
Failure to meet capital adequacy requirements can lead to regulatory sanctions, operational restrictions, or even license revocation.
Further financial obligations, including budgeting, reporting, and forecasting requirements, will be covered separately in the section on business and financial planning for MiCA compliance.
Procedure of Obtaining MiCA license in the Czech Republic
The process of obtaining a MiCA license in the Czech Republic depends on the category of license a company applies for. Each category comes with its own set of requirements, ranging from financial obligations to compliance measures and ICT security. Businesses must carefully assess which license type fits their operations before starting the application process.
Requirements for Directors and Shareholders
Regulators closely evaluate the experience, credibility, and financial standing of company leadership. Directors and major shareholders must meet strict fit and proper criteria, ensuring they have no history of financial misconduct or regulatory violations.
Key requirements include:
Directors:
Must have a good reputation, appropriate knowledge, skills, and experience.
At least one of the directors should be resident in the Union.
Must not have criminal convictions for offenses related to money laundering, terrorist financing, or other crimes affecting their reputation.
Must be able to dedicate sufficient time to effectively perform their duties.
Shareholders (direct and indirect):
Must have a good reputation and no criminal convictions related to money laundering or terrorist financing.
Transparent and verifiable source of funds for shareholders with qualifying stakes, ensuring no ties to illicit activities, sanctions, or money laundering risks.
Submission of a detailed personal and financial background check, covering professional history, past directorships, and potential conflicts of interest.
Disclosure of political exposure, ensuring that Politically Exposed Persons (PEPs) are subject to enhanced scrutiny.
Their influence must not negatively impact the sound and prudent management of the company.
If risks are identified, regulatory authorities may restrict their voting rights, impose fines, or take other measures.
List of Required Documents
The documentation package must clearly demonstrate that the company has a well-defined operational structure, robust risk management policies, and financial stability. The specific list of required documents varies depending on the company's business model and the type of license sought.
Key documents include:
General Company Information – incorporation documents, ownership structure, personal data of executives, licenses (if applicable).
Business Plan – description of services, target audience, growth strategy.
Financial Plan – sources of funding, income and expense forecast, financial statements.
AML/CTF Documentation – AML policy, risk assessment, KYC procedures, internal controls, appointment of an AML officer.
Risk Management Policies – assessment of operational and market risks, incident response plan.
IT and Cybersecurity – IT infrastructure, data protection, GDPR compliance, cybersecurity measures.
Operational Procedures – internal audit, data processing, complaint handling.
Proof of MiCA Compliance – White Paper, public risk disclosures, reserve assets (if applicable).
Executive Documentation – resumes, criminal record certificates.
Additional Documents – agreements with banks, payment service providers, office lease, KYC and transaction monitoring systems.
Capital Confirmation – bank statement, financial commitments, auditor's report.
Liability Insurance (if required) – insurance contract, coverage limits, regulatory compliance confirmation.
Financial Plan, Business Plan, and Accounting Strategy (Three-Year Requirement)
In accordance with the Markets in Crypto-Assets Regulation (MiCA), companies applying for authorization as Crypto-Asset Service Providers (CASPs) must submit a detailed business plan, financial plan, and accounting strategy, covering a period of at least three years. These documents are essential for assessing the applicant’s financial stability and operational reliability.
Business Plan (Programme of Operations)
Companies applying for a CASP license must submit a detailed three-year business plan, including:
A description of the strategy and organizational structure, especially if the company is part of a group.
A description of the target audience (geographical coverage, customer categories).
Service delivery channels (websites, mobile applications, marketing strategies).
Marketing strategy (promotion methods, platforms used, advertising, social media, influencers).
Human, financial, and technical resources allocated for service provision.
Outsourcing strategy and a description of functions delegated to third parties.
Planned crypto services and their relation to types of crypto-assets.
Expected transaction volume and financial forecasts.
Financial Plan
The financial plan is also developed for three years and includes:
Projected financial statements (balance sheet, profit and loss statement, cash flow statement).
Estimated revenue and turnover in the crypto-services sector.
Forecasted trading volumes of crypto-assets.
Justification of capital requirements and financial stability assurance.
Funding sources, including potential loans and intra-group borrowings.
Compliance with prudential reserve requirements depending on the type of services (e.g., own capital, insurance guarantees).
Accounting Strategy
Compliance with EU standards – Accounting must comply with Directive 2013/34/EU, including reporting methodology and accounting policies.
Separation of client and company funds – Accounting must clearly distinguish between company and client assets, preventing their commingling.
Accounting and reporting systems – Accounting systems must record all transactions and ensure data availability for regulators and auditors.
Mandatory audit – The company is required to undergo regular external audits of its financial statements.
Differences in Requirements for New and Existing Companies
For new companies applying for a CASP license:
A projected financial plan and justification of model sustainability are required.
Proof of available capital in a settlement account before obtaining a license.
A business plan with a strong focus on business launch and development.
For existing companies:
Past financial statements for three years are mandatory (if the company is already operational).
Evidence of capital and reserve compliance is required.
Stricter requirements for internal controls and reporting apply.
AML and CFT Compliance
Strict AML (Anti-Money Laundering) and CFT (Countering the Financing of Terrorism) measures must be in place before obtaining a MiCA license. These include:
Risk Assessment and Implementation of Measures to Prevent Money Laundering and Terrorist Financing
Conducting an internal risk assessment related to money laundering and terrorist financing, including an analysis of the customer base, provided services, distribution channels, and geographical areas of operation.
Developing and implementing procedures to mitigate identified risks.
Internal Control System
Establishing and maintaining effective mechanisms, systems, and procedures to manage AML/CFT risks.
Implementing and adhering to policies and procedures for customer due diligence (CDD).
Defining procedures for identifying, analyzing, and reporting suspicious transactions.
Transaction Monitoring
Companies are required to implement automated transaction monitoring systems to detect anomalous and suspicious activities.
Monitoring should consider money laundering schemes, transaction structuring, and terrorist financing.
Both on-chain (blockchain) and off-chain (off-blockchain) data analysis must be ensured, with mechanisms for their correlation.
Companies must store transaction records and provide them to regulators upon request.
Implementation of mechanisms for detecting and reporting suspicious transactions.
AML Compliance Officer and MLRO
Appointment of a responsible AML officer to ensure the company’s compliance with AML/CFT requirements.
The company must hire and appoint a Money Laundering Reporting Officer (MLRO) responsible for submitting Suspicious Activity Reports (SARs) to the regulatory authority.
Verification of this person's qualifications and experience.
Staff Training
Development and implementation of AML and CFT training programs for employees.
Regular training sessions to enhance awareness and professional expertise.
Frequency of AML Mechanism Effectiveness Assessment
Regular testing and evaluation of the effectiveness of AML and CFT mechanisms.
Designation of a responsible person or function for conducting such assessments.
Policies and Procedures for Preventing Conflicts of Interest
Implementation of mechanisms for preventing, identifying, and managing conflicts of interest that could lead to non-compliance with AML/CFT requirements.
Failure to comply with these standards can result in license denial or regulatory sanctions.
AML Officer and MLRO Services – Compliance Support from AMS Europe s.r.o.
Each MiCA-licensed company is required to have both an AML Officer and a Money Laundering Reporting Officer (MLRO) to ensure full compliance with AML and CFT laws.
AML Officer Responsibilities
The AML Officer is responsible for implementing and overseeing the company’s AML/CFT policies and procedures. This includes:
Developing and enforcing AML frameworks, including transaction monitoring systems and risk assessments.
Implementing KYC (Know Your Customer) and due diligence frameworks, ensuring proper client verification and risk categorization.
Training employees on AML policies and ensuring that compliance protocols are followed across the organization.
Ensuring internal AML audits and reviews are conducted periodically to assess compliance effectiveness.
MLRO (Money Laundering Reporting Officer) Responsibilities
The MLRO is specifically responsible for handling regulatory reporting and liaising with financial authorities. Key duties include:
Monitoring financial transactions and investigating suspicious activities.
Submitting Suspicious Activity Reports (SARs) and Suspicious Transaction Reports (STRs) to financial regulators.
Acting as the primary contact for regulatory bodies, including the Czech National Bank (CNB) and the Financial Analytical Unit (FAU).
Maintaining records of AML investigations and ensuring that all compliance reporting obligations are met.
For companies without in-house expertise, outsourcing the AML Officer and MLRO roles can be an efficient way to ensure compliance.
AMS Europe s.r.o., a consulting firm based in Prague, provides AML and MLRO services tailored for crypto businesses applying for a MiCA license. Our team assists with:
AML officer outsourcing for businesses of all sizes.
Preparation of AML/CFT documentation required for licensing.
Regulatory audits and compliance assessments.
Appointment and support of MLRO
Consultations on AML compliance, responses to regulatory inquiries, and risk assessments
Transaction review, enhanced due diligence (EDD) for high-risk clients, and identification of red flags
Updating AML policies, conducting internal and external audits, and ensuring regulatory compliance
Staff training on AML/CFT and legislative updates
Assistance with SAR (Suspicious Activity Reports) filing and interaction with regulators
If your company is preparing for MiCA compliance, our experts can handle your AML obligations, allowing you to focus on business operations. Contact us to learn more.
Separation of Crypto Assets and Client Funds
Crypto companies must maintain a clear separation between company assets and client funds to prevent misuse and ensure regulatory transparency. This ensures:
Protection of Client Assets
Clients’ funds (fiat) cannot be used by the company (only by the client).
Clients’ crypto-assets cannot be used by the company without the client’s explicit consent.
Clients’ wallets must be separate from the company’s wallets (different blockchain addresses).
Cryptographic Key Protection System:
Description of the key storage mechanism (e.g., multi-signature wallets).
Access control and approval procedures for key operations.
Segregation of Client Assets:
How the CASP ensures the segregation of clients’ crypto-assets from its own assets.
Procedure for Depositing Clients' Funds (Fiat, excluding e-money tokens):
Clients' funds must be deposited with a central bank or a credit institution.
The transfer of funds to the bank must be completed by the end of the next business day after their receipt.
Selection of a Bank for Storing Clients' Funds:
If the CASP does not use a central bank, it must:
Explain the criteria for selecting a bank.
Describe its diversification policy if funds are held in multiple banks.
Indicate how frequently the choice of banking partner is reviewed.
Client Information:
Clients must be provided with clear, concise, and accessible information on how the CASP complies with Article 70 of MiCA (segregation of client funds).
ICT Systems and Security Measures Under MiCA and DORA Compliance Requirements
The Markets in Crypto-Assets Regulation (MiCA) establishes a regulatory framework for Crypto-Asset Service Providers (CASPs) in the European Union, ensuring the secure and resilient operation of crypto-related services. A key aspect of MiCA compliance is adherence to ICT Systems and Security Measures, covering cybersecurity, risk management, and operational resilience.
Additionally, the Digital Operational Resilience Act (DORA), mandates strict ICT risk management and resilience measures for financial entities, including CASPs. Compliance with MiCA and DORA is essential for protecting client assets, mitigating cyber threats, and ensuring business continuity.
ICT Security and Resilience (MiCA & DORA Requirements)
Effective ICT systems and security arrangements are required to ensure the secure functioning of crypto-asset services. CASPs must comply with Regulation DORA and implement robust security policies, tools, and procedures.
Key Requirements:
Technical documentation on ICT systems, including Distributed Ledger Technology (DLT) infrastructure, if applicable.
Audits and penetration testing of ICT systems conducted by independent third parties within the last three years.
Comprehensive cybersecurity policies, procedures, and tools for ICT risk management.
Business Continuity and Disaster Recovery Plans
CASPs must ensure continuity and regularity in service provision. A business continuity plan must include:
Steps to maintain operational capacity and compliance with MiCA.
Periodic testing of resilience strategies to validate effectiveness.
Mitigation measures for:
Third-party service failures.
Insolvency risks.
Key personnel risks.
Political risks in relevant jurisdictions.
Operational Resilience and Risk Management
CASPs must assess and manage risks related to operational resilience, aligning with both MiCA and DORA.
CASPs must provide:
A risk management framework that aligns with MiCA and DORA.
A strategy for handling cyber incidents and operational disruptions.
Stress testing and continuous risk monitoring for ICT systems.
Governance and Internal Controls for ICT Risk Management
CASPs must establish internal governance policies in line with DORA’s ICT risk management framework.
Key compliance aspects:
Clearly defined roles and responsibilities for managing ICT risks.
Regular security audits and compliance reporting to regulators.
Designation of a cybersecurity officer or team responsible for ICT risk management.
Compliance with Cybersecurity and Anti-Fraud Measures
CASPs must implement strong fraud detection and cybersecurity measures to protect client assets.
This includes:
Real-time monitoring of transactions to detect market abuse and fraud.
Advanced systems to detect and prevent hacking attempts on client crypto-assets.
Data encryption, identity verification, and secure storage solutions.
Outsourcing and Third-Party Risk Management
CASPs that outsource ICT services must comply with DORA’s outsourcing requirements to ensure third-party risks are effectively managed.
CASPs must:
Provide a list of outsourced services and third-party providers.
Implement measures to mitigate third-party risks.
Ensure outsourced functions align with EU regulatory standards.
Regulatory Reporting and Incident Notification
Under MiCA and DORA, CASPs must report cybersecurity incidents to regulatory authorities.
They must:
Submit detailed incident reports for major security breaches.
Maintain records of ICT-related incidents and their impact.
Implement real-time monitoring and anomaly detection systems.
By meeting these requirements, CASPs can enhance trust, minimize operational risks, and ensure compliance with the evolving regulatory framework in the European crypto-asset market.
Deadlines for applying for a Mica license for existing companies incorporated before 2025
The transition to MiCA licensing comes with strict deadlines that existing crypto businesses in the Czech Republic must follow. Any company operating before December 30, 2024, must obtain a MiCA license to continue its activities legally. The key date to keep in mind is July 31, 2025—this is the final deadline for submitting an application.
Businesses that fail to meet this deadline will no longer be able to operate in the EU market. However, companies that submit their applications on time will be allowed to continue operations until the end of July 2026 or until they receive a final decision on their license application. While applications are under review, companies may continue their activities, but only if they have submitted all required documents on time.
Regulators will assess compliance readiness, operational transparency, and financial stability before granting approval. Failure to demonstrate adherence to MiCA requirements may result in license denial and forced cessation of activities within the EU.
It is important to note that the licensing process involves multiple regulatory checks, and delays in preparation can significantly affect approval timelines. Companies should start gathering required documentation, reviewing compliance measures, and preparing their application well in advance.
Penalties for Non-Compliance with MiCA Requirements
Failure to comply with MiCA Regulation can have severe consequences for crypto businesses in the Czech Republic and across the EU. Regulators have the authority to impose heavy fines, restrict operations, and revoke licenses. Companies that do not meet the requirements risk not only financial losses but also reputational damage and exclusion from the European market.
Financial penalties are one of the most immediate risks. Depending on the severity of the violation, fines can reach €2.5–15 million or 2–15% of a company’s total annual turnover. In some cases, authorities may impose daily fines that continue accumulating until compliance is restored. For businesses that delay regulatory adjustments, these financial burdens can quickly escalate, turning a compliance issue into a serious operational threat.
Beyond monetary fines, MiCA gives regulators the power to suspend or permanently revoke a company’s license if serious breaches are detected. Exchanges and custodial platforms are particularly vulnerable. If found non-compliant, they may face frozen accounts, temporary suspensions, or even a complete ban on handling client assets. Companies operating without a MiCA license after the transition deadline will be forced to cease operations within the EU market.
AML and cybersecurity compliance pose additional risks. Regulators are especially strict about anti-money laundering measures, and businesses that fail to meet KYC and transaction monitoring requirements can be classified as high-risk entities. Once blacklisted, it becomes nearly impossible to access banking services or work with financial institutions. At the same time, firms that do not meet ICT security standards could face regulatory scrutiny under DORA (Digital Operational Resilience Act), further limiting their ability to operate.
With these risks in mind, regular compliance audits are essential. Identifying weaknesses in AML policies, financial documentation, or IT security before a regulatory inspection can prevent major disruptions. A company that waits until the last minute to address compliance gaps will likely face legal and financial consequences.
To support crypto businesses preparing for MiCA, AMS Europe s.r.o. offers compliance audit services. Our team conducts detailed evaluations of company policies, identifies risk areas, and provides actionable recommendations to ensure regulatory alignment. Businesses that take a proactive approach will not only avoid penalties but also gain a competitive edge in a market where compliance is becoming a key success factor.
In the next section, we will outline practical steps companies should take now to prepare for MiCA compliance.
Practical Recommendations for Businesses Preparing for MiCA
With MiCA coming into full force in 2025, crypto businesses must take a proactive approach to compliance. Waiting until the last minute to adapt to new regulations can lead to operational disruptions, financial penalties, or even the inability to obtain a license. Companies that start preparing now will be in a much stronger position to secure regulatory approval and continue their operations smoothly in the Czech Republic and across the EU.
The first step is to assess the company’s current regulatory standing. Businesses should conduct an internal audit to determine whether their existing operations align with MiCA’s licensing, AML, financial, and technological requirements. Identifying gaps early allows companies to develop a clear action plan for meeting compliance standards without unnecessary delays.
Equally important is a risk assessment of financial and operational structures. Companies need to ensure they meet minimum capital requirements based on their license category, as well as implement robust AML procedures to satisfy regulatory expectations. Ensuring proper fund segregation and secure ICT systems should also be a priority, as these are areas regulators will closely examine during the licensing process.
Another critical aspect is document preparation. The licensing process requires companies to submit a comprehensive set of documents, including business plans, financial models, security policies, and compliance frameworks. Preparing these materials in advance will significantly speed up the application process and reduce the risk of rejection.
Navigating MiCA requirements can be complex, and many businesses lack the internal expertise to handle the entire process independently. AMS Europe s.r.o., a consulting firm based in Prague, provides full support for crypto companies at every stage of MiCA compliance. We offer comprehensive advisory services, guiding businesses through regulatory requirements, risk management, and operational alignment. Additionally, for companies that want a seamless licensing experience, we can fully manage the licensing process, from document preparation to regulatory submission and approval.
With enforcement deadlines fast approaching, companies that act now will avoid last-minute complications and position themselves for long-term success in the European crypto market. Ensuring full compliance with MiCA is no longer an option—it is a necessity for any business that wants to continue operating in the EU’s regulated crypto environment. If your company needs expert assistance in obtaining a MiCA license, AMS Europe s.r.o. is ready to take care of the entire process for you. Contact us today for a consultation on MiCA compliance.