Estonia used to be Europe’s ‘go-to’ crypto jurisdiction — but it is no longer so. On 1 July 2026, the transition period ended: the old VASP licences issued by the Money Laundering Data Bureau have been revoked, and only companies holding a CASP (authorisation) from the Financial Supervision Authority or another EEA regulator under the MiCA regulation. This is bad news for those looking for a ‘licence in a couple of weeks’, and very good news for everyone else.
This is because the majority of Web3 projects are not required to obtain a licence at all. The development of protocols and smart contracts, infrastructure and nodes, on-chain analytics, non-custodial interfaces, NFT utilities, GameFi mechanics, DAO tools, consultancy and marketing in Web3 — all of these are standard business activities for which an Estonian OÜ is sufficient, with its 0% tax on reinvested profits, fully remote management and EU jurisdiction when signing contracts. The problem is that the line between ‘outside MiCA’ and ‘CASP’ is not drawn by the product’s name, but by what a user can actually do via your interface.
We don’t start by selling a package, but by examining this boundary: we analyse your business model, tell you honestly whether you fall within the scope of MiCA or not, and then — either we quickly set up a standard company with proper crypto accounting, or we explain the true scope of the licensing process so that you can make an informed decision.
| Topic | Practical explanation |
|---|---|
| Legal form | OÜ – a private company, 100% foreign-owned, with a minimum share capital of €0.01 (for unlicensed activities) |
| Income tax | 0% on reinvested profits; 22/78 when dividends are distributed |
| ‘Defence’ tax: 2 per cent | Suspended until it comes into force — there is no additional tax rate on company profits |
| Crypto services regulator | Finantsinspektsioon (Financial Supervision Authority) — from 1 July 2024 under the Crypto-Asset Market Act (KrüTS) |
| Status of existing licences | RAB VASP licences were revoked on 1 July 2026; there was no automatic conversion to CASP |
| Who needs a CASP | 10 services under MiCA: custody, exchange, trading venue, execution and reception/transmission of orders, placement, transfer, advisory services, portfolio management |
| Who does not need one | Development, infrastructure, analytics, non-custodial software, NFT utilities, consultancy — provided no services from the MiCA list are offered |
| CASP capital | €50,000 / €125,000 / €150,000 depending on the class of services (Annex IV MiCA) + own funds requirement |
| CASP review period | 40 working days for substantive assessment (+20 for requests); in practice, 6–9 months including preparation |
| VAT | 24% standard rate; crypto/fiat exchange — exempt financial service; development and NFTs — subject to VAT |
| VAT threshold | €40,000 of Estonian taxable supplies per year |
| CARF/DAC8 reporting | Data collection and reporting obligations for crypto services came into effect on 1 January 2026 |
If you have any questions, our managers are always on hand and ready to help! If you’re not sure whether your product falls under MiCA, please submit an enquiry: our specialists will carry out a basic scope assessment free of charge.
MiCA does not regulate ‘cryptocurrencies in general’, but rather a specific list of 10 services: the custody and administration of crypto-assets for clients; the operation of a trading platform; the exchange of crypto-assets for fiat currency; the exchange of one crypto-asset for another; the execution of client orders; placement of crypto-assets; receipt and transmission of orders; advice on crypto-assets; portfolio management; crypto-asset transfer services. If you provide even one of these, you need a CASP.
What the regulator looks at in practice:
News about MiCA has given rise to the myth that ‘you can now only operate a blockchain in the EU if you have a licence’. This is incorrect — and it costs founders either hundreds of thousands of euros on a track they don’t need, or, conversely, a wasted year trying to achieve the unachievable.
Outside the scope of MiCA, the following operate without issue: protocol and smart contract development studios; code auditors and security teams; infrastructure, node and RPC providers; on-chain analytics and data services; non-custodial wallets and interfaces where the user always holds the keys; NFT projects with utility or collectible mechanics; GameFi without a built-in exchange; DAO tools; Web3 marketing, community management and consultancy; SaaS for crypto companies. For all of this, a standard Estonian OÜ is sufficient — with a minimum authorised capital of €0.01, and no requirements for capital, a local office or an AML officer.
Practical takeaway: the right first step is not to ask ‘how much does a licence cost?’, but to carry out a proper assessment of the product. It often turns out that simply moving a single functional element (for example, replacing a built-in swap with a redirect to a licensed provider) is enough to keep the project outside the regulatory scope and get it up and running in a week rather than a year. Sometimes the opposite is true: the product is already, de facto, providing a service from the list, and it is not permitted to operate without authorisation. We discuss both scenarios openly, before payment for the package is made.
Launching a Web3 project through an Estonian company — a range of services that we bring together under one umbrella:
By ordering a package from a single provider, you get a structure where the descriptions of activities, tax regime and accounting correspond to the actual product architecture — rather than being pieced together from fragments, which could result in the company either overpaying or unwittingly falling within the scope of regulation.
Registering an OÜ — online via e-Residency (usually 1–5 days), at a notary’s office or by power of attorney. For non-residents, a registered office in Estonia and a contact person are mandatory: the address must be a genuine physical address, and the contact person must be a licensed service provider who accepts official correspondence and is responsible for it. Authorised capital: from €0.01; no resident director is required; 100% foreign ownership. Pay particular attention to the wording of the company’s activities in the articles of association and the EMTAK code: overly broad wording (‘virtual currency services’) raises questions with banks and the registrar when you are actually entering the code.
Important: e-Residency is a tool for remote management and digital signatures. It does not confer any rights to provide crypto services and does not replace authorisation from the Financial Inspectorate.
The Financial Supervision Authority has confirmed that, from this date, only companies holding a MiCA authorisation issued by the Authority itself or by a regulator in another EEA country are authorised to provide crypto services in Estonia, and the registration details of previous VASP licences are deemed invalid. Companies without authorisation are obliged to cease or restrict their activities in order to protect the interests of their customers: they must not accept new customers, open accounts or engage in active marketing towards EEA customers. You can check whether a counterparty holds a licence in the Financial Supervision Authority’s register of supervised entities — this, incidentally, is a useful due diligence step before integrating with any provider.
The scale of the changes is telling: whilst there were 641 virtual currency service provider licences in force in Estonia in mid-2021, by early 2026 only 36 remained, and by the end of the transition period, only one company – Lightspark Payments Europe AS – had received its own CASP authorisation from the Financial Supervision Authority; apart from this, AS LHV Pank and the investment firm Lightyear Europe AS are authorised to offer crypto services. In addition, there are numerous providers with licences from other EEA countries operating across borders.
Practical implications for founders: an Estonian licence in 2026 will be a fully-fledged financial licensing scheme on a par with that of an investment firm, rather than a mere formality. However, its status is different: the licence is valid across all 27 EU countries.
| Parameter | Guideline |
|---|---|
| Capital (Annex IV MiCA) | Class 1 – €50,000; Class 2 – €125,000; Class 3 (trading venue) – €150,000 |
| Own funds rule | Not less than a quarter of the previous year’s fixed overheads |
| Legal entity | Estonian OÜ with a registered office in Estonia |
| Board of Directors | At least two members; a ‘fit and proper’ assessment of each director and qualifying shareholder |
| Local presence | A genuine, operational office and an AML officer; a registered address alone is not sufficient |
| Processing time | 40 working days for a substantive assessment, with a possible extension of 20 days |
| State fee | To be confirmed according to the regulator’s current price list |
We would like to highlight something that is rarely mentioned in promotional articles: the ongoing costs after obtaining authorisation (AML tools, screening, audits, internal controls, DORA ICT requirements, reporting) usually exceed the cost of the application itself. You need to budget for a year’s operation, not just for the set of documents.
| Tax | How it applies |
|---|---|
| Corporate income tax | 0% on reinvested profits; 22/78 when dividends are distributed |
| Capital gains on tokens on the balance sheet | Does not, in itself, give rise to tax until profits are distributed |
| VAT, rate | 24% (standard rate in Estonia) |
| VAT registration threshold | €40,000 of Estonian taxable supplies per year |
| B2B development services in the EU | Reverse charge — 0% VAT, tax is accounted for by the customer (subject to VIES number verification) |
| B2B services outside the EU | Export of services — VAT-exempt |
| Income tax for individuals on crypto gains | 22%; losses from the sale of crypto-assets are not tax-deductible |
| CARF / DAC8 | Obligations to collect and report user data came into effect on 1 January 2026 |
The main advantage of the Estonian model for Web3 is deferred taxation. A company can hold tokens on its balance sheet for years, reinvest revenue in development and liquidity, and not pay corporation tax until the money actually reaches the owners. For projects with volatile revenue, this is fundamentally more convenient than traditional systems, where tax is due at the end of the year regardless of whether you have distributed any funds or not.
The mistake that most frequently comes to light during the very first audit is the assumption that ‘crypto is not subject to VAT’. In reality, transactions fall into three categories, each with different implications for input VAT deduction:
Most real-world projects involve two or three different categories simultaneously, which gives rise to a pro-rata input VAT deduction — the very part of the accounts where errors are most costly. A particular pitfall: even a company not required to register as a VAT payer may be obliged to register as a limited-liability VAT payer if it receives services from foreign suppliers (a typical scenario: infrastructure subscriptions, smart contract audits carried out by an overseas team).
We set up this accounting system from the very first month so that we do not have to reconstruct a year’s worth of transactions when preparing the annual report.
An Estonian company does not come with an automatic bank account, and the client’s crypto profile complicates onboarding: banks and EMIs carry out in-depth checks. What works in practice: a clear description of the business model without crypto jargon, a transparent source of funds, a genuine website and contracts, and the separation of operational cash flows (fiat revenue from development kept separate from the project’s treasury). We prepare a package of documents for onboarding and advise on which providers are realistic for your profile. However, the decision to open an account with a bank or EMI always rests with the bank itself.
If your model is a centralised exchange, a custodial wallet or a full-fledged payment gateway with currency conversion, your path lies through full licensing, and Estonia is neither faster nor cheaper than other EU countries in this regard — in fact, given the jurisdiction’s history and the Financial Supervision Authority’s experience in supervising banks and investment firms, the regulatory oversight is actually stricter. If anyone promises you an ‘Estonian crypto licence in two weeks, turnkey ready’ — this describes a scheme that ceased to exist on 1 July 2026.
However, for Web3 product and infrastructure teams, NFT and GameFi projects, analytics, auditing and Web3 services, Estonia remains one of the most convenient entry points into the EU: a low-cost start-up, no tax on reinvestment and fully remote management.
Describe your product (user interface, keys, financial flows, user geolocation) — within 24 hours, we will provide a legal assessment under MiCA and draw up a practical plan: company registration, tax regime and accounting.
Order