Licensing and intellectual property
CASP License in Belgium: MiCA Authorisation
Hero
We prepare, file and follow your crypto-asset service provider authorisation through the statutory stages with the Belgian regulator.
- Decision period: 40 working days from a complete file (Art. 63(9) MiCA)
- Authority: Financial Services and Markets Authority (FSMA)
- Belgian company and an EU-resident director required (Art. 59(2))
- EU passport after authorisation (Art. 65)
CASP authorisation in Belgium in brief
This page is for a founder or foreign group that wants to provide crypto-asset services from Belgium. We prepare and file the authorisation under MiCA (Regulation (EU) 2023/1114, also written MiCAR) with the Financial Services and Markets Authority (FSMA). If the company does not exist yet, start with setting up a company in Belgium.
The rules here are the Belgian implementation, the Law of 11 December 2025, and the Belgian fee decree, not another Member State's. No new-entrant authorisation appears on the FSMA list at 25 September 2026: it reads "Nihil". Belgium is a first-file jurisdiction.
What's included
Scoping the services
We match your plan to the ten services of Art. 3(1)(16) MiCA. That fixes the Annex IV capital class, the FSMA fee lines and the service-specific parts of the file.
Confirming the route
We confirm whether you file an Art. 63 authorisation or an Art. 60 notification, and whether the FSMA or the National Bank of Belgium (NBB) is the authority.
The Belgian company underneath
The company needs a registered office, effective management in the Union and an EU-resident director. We form it through NV company Belgium or the BV/SRL route, or you start from a ready made company Belgium.
The application file
We assemble the Art. 62(2) documents together with the fit-and-proper evidence of Art. 62(3), from the papers you supply.
Filing and follow-up
We file with the FSMA, pay the statutory contribution on your behalf and follow the file through the statutory stages.
The passport notification
After authorisation we prepare the optional notification to other Member States under Art. 65.
Where the service stops: we are not the regulator, the notary, the bank or the insurer. We promise no outcome, supply no nominee and give no tax advice. Our own fee is on request.
Which route and which authority
Self-check by criteria. The statute decides which route applies, not us.
New entrant, Art. 63 authorisation
The FSMA handles it (Art. 19 of the Law of 11 December 2025).
Existing financial institution, Art. 60 notification
The NBB is competent for Art. 60(1), (2) and (4) entities and for stockbroking firms under Art. 60(3). The FSMA takes the others.
Belgian-law stockbroking firm, e-money or payment institution
These apply to the NBB (Art. 18 §1, 3°). The wording is narrower than payment institutions in general. For the e-money and payment side, see EMI license Belgium.
Conduct stays with the FSMA
Arts. 66, 71, 75(1) and 76 to 82 MiCA remain with the FSMA, even for entities the NBB supervises (Art. 19 §2).
- Route
- Authorisation, Art. 63
- Authority
- FSMA (Art. 19 of the Law of 11 December 2025)
- Route
- Notification, Art. 60
- Authority
- NBB for Art. 60(1), (2), (4) and stockbroking firms under Art. 60(3); FSMA for the rest
- Route
- Application to the NBB
- Authority
- NBB (Art. 18 par. 1, 3°)
- Route
- All providers
- Authority
- FSMA, even for entities the NBB supervises (Art. 19 par. 2)
- Articles
- Arts. 66, 71, 75(1) and 76 to 82 MiCA
How the process works
Statutory periods carry their article. Where the law sets no period, the step says so and we invent none.
Scope the services and confirm the route
Client with us. No statutory period.
Form the Belgian company
Notarial deed, publication and KBO/BCE registration. Add a local director for a Belgian company and a virtual office in Belgium where the substance rule needs them.
Open the bank account and fund the safeguard
Arrange the insurance form of Art. 67(4) if you use it. See opening a company account in Belgium. No statutory period; bank timing is not published.
Assemble the Art. 62(2) file
and collect the fit-and-proper evidence of Art. 62(3). Foreign extracts, apostille and translation are the usual delay.
File with the FSMA
and pay the Art. 7 §1 contribution. No statutory period.
Acknowledgement and completeness check
The FSMA acknowledges within 5 working days and checks completeness within 25 (Art. 63(1) to (3)).
Assessment and decision
40 working days from a complete application, plus a suspension of up to 20. Questions come no later than working day 20; the decision is notified within 5 (Art. 63(9), (12)).
After authorisation
The optional passport notification (Art. 65), then the annual contribution (Art. 7 §2), MiCA duties and AML obligations as an obliged entity. Company-side VAT is covered under registering for Belgian VAT.
- PreparationYou, with usNo statutory period
- Clock starts at a complete fileThe FSMAComplete application
- AcknowledgementThe FSMA5 working days (Art. 63(1))
- Completeness checkThe FSMA25 working days (Art. 63(2))
- DecisionThe FSMA40 working days from a complete application (Art. 63(9))
- Possible suspensionThe FSMAUp to 20 working days (Art. 63(12))
- Decision notifiedThe FSMAWithin 5 working days
- ESMA informedThe FSMAWithin 2 working days
- Passport notification forwardedThe home authorityWithin 10 working days
Not sure which of the ten services your plan involves?
Tell us what you want to offer and from where, and we map it to the statute.
Documents you will need
- Identity documents for every director and every holder of 10 percent or more.
- Criminal record extracts and no-penalty declarations for every management member and qualifying shareholder.
- CVs and evidence of time commitment for the management body.
- The ownership chain up to the ultimate beneficial owners.
- A business plan with projected overheads for the first 12 months (Art. 67(2)).
- ICT documentation for the services you will provide.
- The policy set: AML/CFT, complaints, client-asset segregation, continuity, outsourcing.
- Proof of the prudential safeguard: own funds or the insurance form.
- The formation documents of the new Belgian company.
Apostille and translation follow no single rule: it depends on the procedure.
Belgian requirements and state costs
Every figure is a state or regulator amount, with its source and year.
| Item | Rule | Source |
|---|---|---|
| Capital, class 1 | Minimum EUR 50,000 | MiCA, Annex IV |
| Capital, class 2 | Minimum EUR 125,000 | MiCA, Annex IV |
| Capital, class 3 | Minimum EUR 150,000 | MiCA, Annex IV |
| Prudential safeguard | The higher of the Annex IV amount or one quarter of the preceding year's fixed overheads (projected for a first-year applicant), held as own funds, insurance or both | MiCA, Art. 67 |
| Qualifying holding | 10 percent of capital or voting rights | MiCA, Art. 3(1)(36) |
| Company underneath, BV/SRL | No minimum capital; sufficient initial own funds and a financial plan | Companies and Associations Code, Arts. 5:3, 5:4 |
| Company underneath, NV/SA | EUR 61,500 | Companies and Associations Code, Art. 7:2 |
Requirements an applicant meets. The service-to-class mapping is in Annex IV and is not reproduced here.
| Item | Amount | Source and year |
|---|---|---|
| FSMA application contribution, base | EUR 20,000 | Royal Decree of 23 January 2026, Art. 7 §1, 2026 |
| Add-on: custody and administration | EUR 15,000 | Art. 7 §1, 2026 |
| Add-on: operating a trading platform | EUR 25,000 | Art. 7 §1, 2026 |
| Add-on: each of the other eight services | EUR 2,500 each | Art. 7 §1, 2026 |
| FSMA annual contribution | EUR 20,000 a year per CASP authorised at 1 January, plus the same per-service scale for services provided in Belgium | Art. 7 §2, 2026 |
| KBO/BCE registration of the company | EUR 111.50 per establishment unit | FPS Economy, tariff in force 2026 |
| Moniteur belge, incorporation, electronic | EUR 236.50 excl. VAT (EUR 286.17 incl.) | Tariff for filings from 1 March 2026 |
| Moniteur belge, incorporation, paper | EUR 292.90 excl. VAT (EUR 354.41 incl.) | Same tariff |
| Notary, incorporation deed | Quoted by the notary | None |
State and regulator amounts for 2026. Our own fee is on request.
| Example scope | Calculation | Total |
|---|---|---|
| Advice only | 20,000 + 2,500 | EUR 22,500 |
| Custody, exchange for funds, exchange for other crypto-assets | 20,000 + 15,000 + 2,500 + 2,500 | EUR 40,000 |
| All ten services | 20,000 + 25,000 + 15,000 + 8 x 2,500 | EUR 80,000 |
Our arithmetic on Art. 7 §1, not a recommendation of a scope.
The lines exclude the notarial fee, the droit d'écriture, search costs, the safeguard, the bank, apostille and translation, and VAT where stated.
Problems we solve
"Has anyone actually been authorised?"
No new-entrant authorisation appears on the FSMA lists at 25 September 2026: both read "Nihil". ESMA's interim register shows two Belgian home-state entries, both credit institutions, on the Art. 60 route.
"Is the transitional period over?"
Yes. Art. 143(3) MiCA ran to 1 July 2026 or until a decision, whichever came first, and the simplified route of Art. 143(6) has closed.
"Which regulator do I deal with?"
New entrants go to the FSMA. Existing Belgian stockbroking firms, e-money institutions and payment institutions go to the NBB, by article (Arts. 18 and 19 of the Law of 11 December 2025).
"I am not based in the EU"
The statute asks for a Belgian seat, effective management in the Union and an EU-resident director. A nominee does not remove the fit-and-proper test (Arts. 62(3), 68). We cover the seat, the director and the bank account on their own pages.
"I keep reading about VASP registration"
That term belonged to the Royal Decree of 8 February 2022, now repealed. No registration was granted under it. MiCA authorisation replaced it.
Want your route and services checked against the statute?
Send us the services you plan and the company structure, and we check both against the articles.
Why work with us
From our practice: we check the planned services against the ten of MiCA, ask for the foreign extracts early, coordinate the notary and the registries, and work in English, French and Dutch. We hold no licence ourselves, and the regulator decides.
Related services
- E-money and payment licencesThe separate NBB regime for e-money and payment institutions.
- Trade marksour trade mark registration service: protecting the name of the platform. A related question is how an invention is protected by a patent in Belgium.
- BankingThe account that holds the safeguard.
- Ready-made companiesAn existing Belgian company to apply from.
- Tax pointerA guide for the company's own tax position.
Frequently Asked Questions
Has anyone actually been authorised as a crypto-asset service provider in Belgium yet?
No new-entrant authorisation appears on the Financial Services and Markets Authority (FSMA) list at 25 September 2026: it reads "Nihil", as does the Art. 60 notification list. ESMA's interim register shows two Belgian home-state entries, both credit institutions, which is the Art. 60 route. Belgium is a first-file jurisdiction.
Is the FSMA or the National Bank of Belgium the authority I apply to?
A new entrant applies to the FSMA (Art. 19 of the Law of 11 December 2025). The National Bank of Belgium takes Belgian-law stockbroking firms, e-money institutions and payment institutions applying under Art. 59(1)(a) MiCA (Art. 18 §1, 3°). Conduct articles stay with the FSMA (Art. 19 §2).
Is the MiCA transitional period over, and can I still use a simplified route?
Yes, it is over. Art. 143(3) MiCA let providers continue until 1 July 2026 or until authorisation was granted or refused, whichever came first. The simplified procedure of Art. 143(6) for applications filed between 30 December 2024 and 1 July 2026 has closed.
How much does the FSMA charge, for the application and each year afterwards?
The application contribution is EUR 20,000 plus EUR 15,000 for custody, EUR 25,000 for a trading platform and EUR 2,500 for each of the other eight services (Art. 7 §1 of the Royal Decree of 23 January 2026). The annual contribution is EUR 20,000 plus the same per-service scale for services provided in Belgium (Art. 7 §2).
How much capital is required, and what is the prudential safeguard?
Minimum capital is EUR 50,000, EUR 125,000 or EUR 150,000 for class 1, 2 or 3 (Annex IV MiCA). The safeguard is the higher of that amount or one quarter of the preceding year's fixed overheads, projected for a first-year applicant, held as own funds, insurance or both (Art. 67).
How long does the authority have to decide, and when does the clock start?
The clock starts at a complete file. The authority acknowledges receipt within 5 working days, checks completeness within 25 and decides within 40 working days of a complete application, with a suspension of up to 20 (Art. 63). Company, bank, safeguard and foreign documents come first and have no statutory period.
Do I need a Belgian company and a director resident in the EU?
Yes. Art. 59(2) MiCA requires a registered office in a Member State where part of the services is carried out, effective management in the Union and at least one director resident in the Union. The Belgian company is formed through the linked formation services.
Who has to be fit and proper: the directors only, or the shareholders too?
Both. Art. 62(3) MiCA covers every member of the management body and every direct and indirect qualifying shareholder, meaning 10 percent or more of capital or voting rights (Art. 3(1)(36)). Art. 68 applies the test, so a nominee arrangement does not remove it.
Can I serve customers in other EU countries with a Belgian authorisation?
Yes, by passporting (Art. 59(7) and Art. 65 MiCA), without a physical presence in the host state. The provider sends a four-item notification to the home authority, which forwards it within 10 working days. Services may start on receipt of the communication or by the 15th calendar day.
What happened to the Belgian VASP registration regime?
It belonged to the Royal Decree of 8 February 2022, now repealed. No registration was ever granted under it and no complete file was submitted. Search results still using the term VASP registration are stale; MiCA authorisation has replaced it.
What is the difference between an Art. 63 authorisation and an Art. 60 notification?
Art. 63 is the authorisation route for a new entrant, filed with the FSMA. Art. 60 is the notification route for existing financial institutions; the National Bank of Belgium is competent for Art. 60(1), (2) and (4) entities and for stockbroking firms under Art. 60(3).
Which of the ten crypto-asset services need authorisation?
All ten of Art. 3(1)(16) MiCA: custody and administration, operating a trading platform, exchange for funds, exchange for other crypto-assets, execution of orders, placing, reception and transmission of orders, advice, portfolio management and transfer services. The authorisation names the services; adding one later needs an extension.
How do I register as a CASP?
In Belgium it is an authorisation, not a registration. Scope the services, form the Belgian company, assemble the Art. 62(2) file with the fit-and-proper evidence, file it with the FSMA and pay the Art. 7 §1 contribution. The process section sets out each step and its period.
What does a MiCA licence mean?
It means an authorisation under Art. 63 of Regulation (EU) 2023/1114, also written MiCAR, to provide named crypto-asset services as a crypto-asset service provider. Once granted, it can be passported to other Member States under Art. 65. No outcome is promised: the FSMA decides.
Who needs a VASP or CASP licence?
Under Art. 59(1) MiCA nobody may provide crypto-asset services in the Union unless authorised as a CASP under Art. 63 or entitled under Art. 60. VASP is the older term of the repealed Belgian registration regime; the current requirement is MiCA authorisation.
Ready to scope your authorisation file?
Send us the services, the owners and the planned seat, and we prepare the scoping plan.