Navigating the Full MiCA Transition: Beyond the Old National Registry
The era of simple national registration is over. From 30 December 2024, new crypto-asset service providers seeking to operate in the EU must prepare for authorization under MiCA (Regulation (EU) 2023/1114), with Cyprus applying transitional arrangements until 1 July 2026.
At CX Financia, we specialize in the MiCA 2026 transition. We don’t just “register” your firm; we architect a regulatory-grade crypto institution that benefits from full EU Passporting rights across all 27 member states from Day 1.
Pro Tip: If you missed the legacy “grandfathering” window (July 1, 2026), your only entry point is a full MiCA license. We help you accelerate this 3–6 month authorization process.
Once national transitional regimes expire (no later than 1 July 2026), the only entry point for new firms is a full MiCA license
The Three Classes of MiCA Licenses: Which One Fits Your Model?
“The Three MiCA Capital Tiers: Which One Fits Your Model?”
To optimize your capital efficiency, we match your crypto business model with the correct MiCA Class under Title V of the regulation.
The “Substance-First” Governance: 2026 CySEC Requirements
CySEC acts as the competent authority for MiCA authorization in Cyprus and applies a substance-focused review. Firms seeking CASP authorization must demonstrate effective management, real operational presence, and decision-making in Cyprus, rather than operating as a letterbox entity.
- The “4-Eyes” Rule: You must have at least two local executive directors and two non-executive directors. The majority of your Board must be Cyprus tax residents.
- You must demonstrate effective management and real decision-making presence in Cyprus, including at least two individuals directing the business on a day-to-day basis, with sufficient local availability
- Technical Resilience (DORA): Since January 2025, DORA is no longer optional. Your application must include a “Digital Operational Resilience” manual and a plan for annual penetration testing.
- From 17 January 2025, firms must demonstrate ICT risk management and operational resilience aligned with DORA principles, including documented controls and proportionate testing arrangements.
- Prudential Safeguards: Beyond initial capital, you must maintain own funds equal to one-quarter of your previous year’s fixed overheads.
The CX Financia Roadmap to MiCA Authorization
We target a 4-to-6 month activation timeline, utilizing our pre-submission success filters to reduce CySEC queries.
We target an indicative 6–9 month authorization timeline, leveraging pre-submission reviews and completeness checks to reduce CySEC follow-up queries
Phase 1: Corporate & Capital Structuring
(Month 1)
- Incorporation of the Cyprus Entity and opening the capital deposit account.
- Capital Efficiency Audit: We ensure you don’t over-provision capital for your service scope.
Phase 2: The MiCA Dossier Submission
(Months 2-5)
- Drafting the Program of Operations and IT Resilience Manual.
- Whitepaper Preparation: For asset-referenced or e-money tokens, we draft and file the mandatory MiCA Whitepapers.
- Whitepaper Preparation: Where the applicant also acts as an issuer of asset-referenced or e-money tokens, we lead the preparation and structuring of the mandatory MiCA Whitepapers and support their regulatory submission, with final approval and responsibility remaining with the issuer.
Phase 3: Authorization & EU Passporting
(Month 6+)
- Final “Fit & Proper” interviews with CySEC.
- Activation of your EU Passport, allowing you to offer services to 450 million consumers across the EEA.
Why CX Financia? Bridging the Gap Between Crypto and Compliance
Most firms treat crypto like “Traditional Finance” (TradFin). We understand the unique technical
challenges of On-chain Transaction Monitoring and Cold Storage Custody governance.
- Banking Rails: We solve the hardest part—securing fiat banking for your crypto institution.
- Market Abuse Surveillance: We help you implement 2026-standard tools to detect “Wash Trading” and “Pump & Dumps” as required by MiCA.
Ready to Lead the EU Crypto Market? The 2026 regulatory deadline is approaching. Don’t wait for the
licensing bottleneck. Secure your place in the EU financial ecosystem today.
FAQ – Cyprus CASP & MiCA Licensing
Can I still apply for a "legacy" CASP registration in Cyprus?
No. The national registration regime is closed. All new entrants must apply under the full MiCA (Regulation (EU) 2023/1114) framework.
How does the MiCA Passporting work?
Once CySEC authorizes you, you simply notify them of your intent to provide services in other EU states. There is no need for additional licenses in France, Germany, or Italy.
What is the minimum capital for a Crypto Wallet (Custody) license?
Under Class 3, the requirement is €150,000. However, the regulator may require higher safeguards depending on the volume of assets under custody.