---
title: "Crypto Licence: Where and How We Obtain It — Comparison of Verified Regimes"
url: "https://legal.ge/en/service/crypto-blockchain-services-en/crypto-licence-where-and-how-we-obtain-it-comparison-of-verified-regimes-en"
field: "Crypto & Blockchain Services"
description: "Crypto licence compared: MiCA CASP in Cyprus, Czechia, Lithuania, Estonia; Dubai VARA, Armenia CBA, Montenegro — plus the Georgian NBG layer. Legal.ge."
updated: "2026-10-15"
publisher: "legal.ge"
---

# Crypto Licence: Where and How We Obtain It — Comparison of Verified Regimes

> Source: legal.ge, https://legal.ge/en/service/crypto-blockchain-services-en/crypto-licence-where-and-how-we-obtain-it-comparison-of-verified-regimes-en

"Crypto licence" is one phrase covering several entirely different regulatory regimes: the European Union's MiCA authorisation in Cyprus, Czechia, Lithuania or Estonia; non-EU options such as Dubai (VARA) and Armenia (CBA); and regimes that are restricted or suspended outright, like Saint Vincent and the Grenadines. This hub compares them honestly: we only include regimes verified against the regulators' own pages, laws and official fee instruments, and we set out separately the Georgian statutory layer that applies no matter which jurisdiction you choose for the group.

Our discipline matters on this market, because most comparison content does not follow it: where no amount is published in an official source, we print no number and write "confirm with the regulator". Where fees or capital requirements are officially fixed — the Cyprus fee directive rows, the Estonian fee, the Dubai AED schedule, Armenia's AMD capital ladder — the exact figures appear below. Numbers circulating in intermediary marketing that cannot be traced to an official source are deliberately absent.

## The EU Frame: MiCA and the Route for a Georgian-Owned Group

In the European Union, authorisation of a crypto-asset service provider (CASP) is governed by Regulation MiCA ((EU) 2023/1114), and one of its rules is decisive for foreign owners: under Article 59(2) a CASP must have its registered office in a Member State where it carries out at least part of its services, its place of effective management in the Union, and at least one director resident in the Union. In practice this means a Georgian-owned group enters the European market through an EU-incorporated, EU-managed company — a Georgian company cannot obtain a MiCA authorisation directly.

Third-country firms may serve EU clients only at the client's own exclusive initiative (Article 61(1), reverse solicitation); soliciting or promoting in the Union already requires authorisation. The statutory clock is uniform across the Union: a completeness check within 25 working days, a decision within 40 working days of a complete application, and a possible suspension of up to 20 further working days for missing documents (Article 63). Own funds follow Article 67: the higher of the permanent minimum capital of the provider's class in Annex IV or one quarter of the preceding year's fixed overheads — confirm the exact class amount for your service stack in Annex IV or with the regulator. The grandfathering window of Article 143(3) closed on 1 July 2026 — Lithuania closed it even earlier, on 31 December 2025 — so every new entrant now files a full Article 62 application.

## Comparison of the Verified Regimes

Below is each regime's regulator, current status and verified fee data. Each country has its own detailed page on Legal.ge covering the procedure, the document stack and the Georgian layer; this table gives you the comparative picture. Every cell traces to the regulator named in it.

-   **Cyprus (CySEC).** The only EU jurisdiction in our set whose entire fee schedule is verifiable to the euro through an official directive (DI 73-2009-04): application charges per service from €5 000 (exchange services) to €30 000 (trading platform), an Article 60 notification at €10 000, and an annual fee plus a turnover surcharge capped at €500 000. The old register dates from 2021; new register applications stopped on 17 October 2024, and legacy CASPs had to file their Article 62 pack by 27 February 2026. Official source: cysec.gov.cy. Detailed page: [MiCA CASP licence in Cyprus (CySEC)](https://legal.ge/en/service/international-crypto-licensing-en/mica-casp-licence-in-cyprus-cysec-en).
-   **Czech Republic (CNB).** The Czech National Bank has been competent since 15 February 2025 (Act 31/2025 Sb.); the transition ended on 1 July 2026. The regulator's own numbers tell the story: of 251 applications assessed by 1 July 2026 — the EU's largest queue — 11 authorisations had been granted. No fee amount is published on CNB pages (the legal basis is Act 634/2004 Sb. on administrative fees) — confirm the amount with the CNB. Official source: cnb.cz. Detailed page: [MiCA CASP licence in the Czech Republic (CNB)](https://legal.ge/en/service/international-crypto-licensing-en/mica-casp-licence-in-the-czech-republic-cnb-en).
-   **Lithuania (Bank of Lithuania).** Authorisation is granted and supervised by the Bank of Lithuania (Law XIV-2879), with AML supervision retained by the FCIS/FNTT. Lithuania closed its transition early, on 31 December 2025: unlicensed activity is now treated as "illegal financial activities", punishable under the Criminal Code by up to 4 years' imprisonment, and the Bank may block offenders' websites. No euro amount is stated on the fetchable lb.lt pages (the levy is set by Government Resolution 1458) — confirm with the regulator. Detailed page: [MiCA CASP licence in Lithuania (Bank of Lithuania)](https://legal.ge/en/service/international-crypto-licensing-en/mica-casp-licence-in-lithuania-bank-of-lithuania-en).
-   **Estonia (Finantsinspektsioon).** The CASP authority is the Estonian Financial Supervision Authority (fi.ee); the application processing fee is officially €3 000; the statutory clock runs 25 working days for completeness and 40 for assessment; since 18 March 2026 applications go through the FSA's application portal. The old FIU VASP regime ran only to the end of 2024. Detailed page: [CASP licence in Estonia (Finantsinspektsioon)](https://legal.ge/en/service/international-crypto-licensing-en/casp-licence-in-estonia-finantsinspektsioon-en).
-   **Dubai (VARA).** The Virtual Assets Regulatory Authority regulates activity "in or from Dubai" — mainland and free zones alike, with the DIFC carved out (the DFSA runs a separate regime). Fees come from the official Schedule 2 table: advisory and transfer/settlement activities at AED 40 000 application plus AED 80 000 annual supervision; the other licensed activities at AED 100 000 plus AED 200 000. A VARA licence gives no EU passport. Official source: vara.ae. Detailed page: [Crypto licence in Dubai (VARA)](https://legal.ge/en/service/international-crypto-licensing-en/crypto-licence-in-dubai-vara-en).
-   **Armenia (CBA).** The Central Bank of Armenia regulates offerings and services under the Law on Crypto-assets (HO-159-N, in force since 4 July 2025); the capital ladder runs from AMD 10 000 000 (advice) to AMD 200 000 000 (ART issuance), set by CBA Decision 228-N. For existing operators the hard date is 31 January 2027: registered and licensed by then, or cease. Official source: cba.am. Detailed page: [Crypto-asset licence in Armenia (CBA)](https://legal.ge/en/service/international-crypto-licensing-en/crypto-asset-licence-in-armenia-cba-en).
-   **Montenegro.** No dedicated crypto law exists; the operative regime is the crypto chapter of the AML law (articles 40a–40r), under which a provider enrols in the register of the Capital Market Commission before starting. No fee is published (confirm with the Commission) and there is no capital requirement — the cheapest EU-adjacent official route in the set, with exactly one company registered so far. Official source: scmn.me. Detailed page: [Crypto-asset service provider registration in Montenegro](https://legal.ge/en/service/international-crypto-licensing-en/crypto-asset-service-provider-registration-in-montenegro-capital-market-commission-en).
-   **Saint Vincent and the Grenadines.** Status: the FSA suspended acceptance of new virtual-asset business applications from 1 September 2026 "until further notice", with no reopening date announced; applications filed before 1 September continue to be processed. This is no longer an entry route — our status page covers it in detail ([SVG status and alternatives](https://legal.ge/en/service/international-crypto-licensing-en/saint-vincent-and-the-grenadines-virtual-asset-business-registration-status-and-alternatives-en)).
-   **Serbia.** The region's incumbent true-licence regime — the Law on Digital Assets (Gazette 153/2020) with NBS licences issued since 2021; details are verifiable in the NBS register at nbs.rs.
-   **Norway / EEA.** A live non-EU MiCA route: the Crypto-Assets Act has been in force since 1 July 2025, applications go to Finanstilsynet, the transition expired on 1 July 2026, and no fee is stated on the fetched pages — confirm with the regulator.

The full text is available on legal.ge after signing in: https://legal.ge/en/service/crypto-blockchain-services-en/crypto-licence-where-and-how-we-obtain-it-comparison-of-verified-regimes-en

### Which jurisdiction's crypto licence is the most accessible?

On verified data: Estonia's application fee is €3 000, Cyprus starts at €5 000, Dubai at AED 40 000, and Armenia's capital minimum is AMD 10 000 000. Czech and Lithuanian fees are not officially published — confirm with the regulators before budgeting.

### Can a Georgian company be authorised under MiCA directly?

No. MiCA Article 59(2) requires a registered office in a Member State, effective management in the Union and at least one EU-resident director. The route is an EU-incorporated subsidiary with local substance.

### Which regimes are restricted right now?

Saint Vincent and the Grenadines: new applications suspended from 1 September 2026 until further notice. The EU transition period ended on 1 July 2026 (Lithuania closed it on 31 December 2025), so every new entrant files a full application.

### Does a foreign licence exempt me from National Bank registration?

No. Article 52-5(2)–(3) of the NBG organic law makes registration mandatory for Georgia-facing virtual asset services; the AML law adds the USD 1 000 / EUR 1 000 / GEL 3 000 KYC trigger and the Travel Rule (Article 17¹).