Estonia's crypto regulation divides into two eras, and this page's first discipline is the label: the competent authority for CASP authorisation today is the financial supervision authority — Finantsinspektsioon (fi.ee). The old VASP regime belonged to the Financial Intelligence Unit (FIU) and ran only to the end of 2024 — the FIU is now historical context, and its era's figures no longer apply to a new application.
The second discipline is the fee: the processing fee for an authorisation application is officially €3 000 — exactly that figure, from Finantsinspektsioon's own page. The old FIU-era amount and the numbers circulating among intermediaries do not appear on this page: they are outdated, and they were never verified for the new regime.
The EU Frame: MiCA and the Route for a Georgian-Owned Group
MiCA ((EU) 2023/1114) Article 59(2) demands the same everywhere: a registered office in a Member State where part of the services are carried out, effective management in the Union, and at least one EU-resident director. For a Georgian group the Estonian route means an Estonian company (OÜ) with local substance — and Estonia's practical attraction is that the corporate environment and the crypto authorisation assemble into one package. A third-country firm serves Union clients only at the client's own exclusive initiative (Article 61(1)).
The statutory clocks in Estonia follow MiCA's text: a completeness check within 25 working days, assessment within 40 working days, a possible suspension of up to 20 working days for missing documents, and the decision notified within 5 working days (Article 63). The own-funds requirement comes from Article 67 — the higher of the Annex IV class minimum or one quarter of the preceding year's fixed overheads; confirm your class amount in Annex IV. The grandfathering window (Article 143(3)) closed on 1 July 2026.
History and Contrast: from the FIU Era to the Full Window
Until the end of 2024, VASP licences in Estonia were issued by the Financial Intelligence Unit (FIU). The MiCA transition rule was this: FIU licences issued before 30 December 2024 remained valid until 1 July 2026 — Estonia used the full transition window. For comparison: Lithuania closed the same window on 31 December 2025 — two different national strategies on one regulation in the same region.
Whoever held no FIU licence had to apply to Finantsinspektsioon from 30 December 2024; entities left without any authorisation operate illegally. For a new entrant those dates are history — the operative fact is one: entry now happens only through a full new application.
Fee and Process: €3 000 and the Statutory Clocks
In Finantsinspektsioon's own wording, the processing fee payable when applying for authorisation of a crypto-asset service provider is 3 000 euros. That is the single printable figure — and it is current: a cross-border notification under Article 65 (an authorised CASP starting to serve other Member States) carries no fee at all.
The procedure: the application fits the Annex VI form of ESMA's RTS (Regulation (EU) 2025/305) and carries the Article 62(2) stack — the programme of operations, proof of Article 67 prudential safeguards, governance arrangements, fit-and-proper documentation for the management body and qualifying shareholders, AML/CFT internal mechanisms, ICT documentation, custody policy, trading-platform rules, exchange price methodology, execution policy, proof of adviser competence and more. Since 18 March 2026 applications are received through the Finantsinspektsioon application portal. The language rule matters: the application is submitted in Estonian, with English attachments flagged separately; the authority may also demand additional documents.
Scope: What the New Law Covers
The Estonian Crypto Markets Act supplements MiCA nationally and covers issuers, offer and admission, and all ten MiCA service categories. The old RahaPTS counted only four virtual-currency services — order execution, reception and transmission of orders, advice and portfolio management became newly regulated. For ART issuers the clocks differ: a 25-working-day completeness check and 60 working days of assessment under the EBA's RTS.
The Georgian Layer: What Applies at Home Despite an Estonian Authorisation
An Estonian CASP status is a key to the European market; it rewrites nothing in Georgian law. The organic law on the National Bank of Georgia (No 101044): Article 52-5(2) — a VASP registers with the National Bank; Article 52-5(3) — unregistered provision is impermissible; Article 52-5(4) — the provider carries on only the virtual asset service and auxiliary activity; Article 39-1 — a virtual asset is not legal tender; Article 48 — supervision belongs to the National Bank.
The AML law (No 4690334): Article 3(1) makes VASPs accountable persons; Article 4 assigns AML supervision to the National Bank; Article 11(1) sets the crypto KYC trigger at USD 1 000 / EUR 1 000 / GEL 3 000; Article 17¹ is the Travel Rule, with the accompanying-information content defined by a National Bank act (Article 52-5(1) of the organic law). Two markets, two rings — the Estonian authorisation does not cancel the Georgian one.
Frequently Asked Questions
What is the Estonian application fee?
€3 000 — in Finantsinspektsioon's official wording, the processing fee payable when applying for authorisation of a crypto-asset service provider. The Article 65 cross-border notification is free. Do not use the old FIU-era or intermediary figures.
Can the application be in English?
No — it is submitted in Estonian, with English attachments flagged separately. Since 18 March 2026 filings are received through the Finantsinspektsioon application portal.
How long is the decision?
The statutory clocks: a 25-working-day completeness check, 40 working days of assessment, a pause of up to 20 working days if documents are demanded, and notification of the decision within 5 working days.
Does an Estonian authorisation change Georgian requirements?
No — Georgia-facing services still require National Bank registration under Article 52-5(2); the USD 1 000 / EUR 1 000 / GEL 3 000 KYC trigger and the Travel Rule remain part of the Georgian layer.
How We Help on Legal.ge
Legal.ge assembles the Estonian route as one package: we set up the OÜ with Article 59(2) substance, fill in ESMA's Annex VI form with the Article 62(2) stack — including the Article 67 prudential-safeguards proof — file through the portal in Estonian, and track the 25/40/20/5 working-day clocks. In parallel we build the Georgian ring: National Bank registration and AML compliance. And since the fee has one official figure — €3 000 — the first line of your budget is exact from day one. Contact us to start the Estonian route from your service list.