Czech Republic Crypto License

1. Establish a Czech Company (s.r.o.)

The first step is to incorporate a limited liability company (společnost s ručením omezeným, s.r.o.) in the Czech Republic, which will serve as the legal vehicle for your MiCA CASP license. While the statutory minimum capital is only 1 CZK, companies seeking a license must meet MiCA-specific capital thresholds (see next step). At incorporation, the articles of association should explicitly mention crypto-asset related services in the scope of business. Appoint at least one director and one shareholder (these can be foreign individuals). The company must have a registered office in the Czech Republic. After successful registration with the Czech Commercial Register, you will obtain a company ID number (IČO) and may apply for a VAT number if relevant. The process typically takes 5–10 business days if documentation is complete and notarised.
 

2. Meet Capital Requirements

MiCA requires crypto service providers to meet strict minimum capital thresholds, depending on the nature of the services provided:

• Class 1 (e.g., advisory or order execution): €50,000

• Class 2 (custody, exchange): €125,000

• Class 3 (operation of a trading platform): €150,000

This capital must be fully paid into the company's bank account and be verifiably available before the license application is submitted. There is no phased deposit option at the licensing stage—100% of the required capital must be deposited in full. An account with a Czech or EU-based bank or payment institution must be opened for this purpose.
 

3. Appoint Key Personnel

You must appoint qualified and vetted individuals to all required positions. The following roles are essential:

• Chief Executive Officer (CEO) – Oversees general company operations

• Chief Compliance Officer (CCO) – Manages regulatory compliance and internal control frameworks

• Money Laundering Reporting Officer (MLRO) – Handles AML obligations and reports to the Financial Analytical Office

• Data Protection Officer (DPO) – Ensures GDPR compliance and supervises handling of personal data

• Chief Information Security Officer (CISO) – Manages cybersecurity and IT risk

All key individuals must have a clean criminal record, relevant qualifications, and appropriate experience. While most roles can be held by foreign residents, the MLRO is typically expected to maintain strong ties to the Czech Republic, and local presence is recommended for efficient communication with Czech regulators. Each person must pass the Czech National Bank’s (CNB) “fit and proper” assessment.
 

4. Establish Office Presence

Although a full-scale commercial office is not explicitly mandated, the company must maintain a real and operational presence in the Czech Republic. This includes a physical address suitable for regulatory correspondence, storing of records, and ensuring the AML Officer’s accessibility. Some firms secure a modest office and designate it as their operational hub. Virtual offices alone are not considered sufficient under substance requirements.
 

5. Set Up Financial and Technical Infrastructure

The company must open a corporate bank account (with an EEA credit institution or payment service provider) for capital deposit and ongoing operations. Additionally, the company must have a documented and secure IT infrastructure to support its intended crypto-asset services. This includes business continuity protocols, secure wallet storage if custody is offered, and monitoring systems to detect suspicious transactions. While audited financials are not required at inception, the CNB may review your financial projections and technical documentation to assess operational soundness.
 

6. Draft and Implement Internal Policies

The licensing application must include a comprehensive set of internal documents demonstrating governance and operational readiness. These include:

• A detailed business plan outlining your services, market focus, and financial model

• AML/CTF policies fully compliant with Czech and EU law

• A risk management framework, including tools to assess and mitigate crypto-specific risks

• Internal control policies for corporate governance, segregation of duties, and conflict of interest handling

• IT security policies to protect customer assets and data

• A complaint resolution process to handle client disputes transparently

• Data protection procedures for GDPR alignment

Each policy must be aligned with MiCA’s regulatory expectations and demonstrate that your company is operationally ready to serve clients in a secure and compliant manner.
 

7. Submit the License Application

When the company is incorporated, funded, and all documentation is in order, you may submit your CASP license application to the Czech National Bank (CNB). The application must be in Czech and include all supporting materials: company formation documents, capital verification, CVs and background checks for key personnel, operational policies, and a service description. The CNB will first check for completeness. Once the submission is deemed complete, the formal assessment process begins.

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8. Respond to Regulatory Inquiries

During the review process, the CNB may request additional documentation, clarifications, or even interviews with key personnel. These inquiries aim to ensure that your company meets all MiCA requirements—not just formally, but substantively. You must respond promptly, clearly, and thoroughly. Regulatory engagement at this stage is critical and may influence the speed and outcome of your licensing application.

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9. Receive the Licensing Decision

After completing its assessment, the CNB will issue a licensing decision. If successful, your company will receive a formal authorization to operate as a CASP. If the application is denied, you will be provided with reasons and may reapply after addressing the identified shortcomings. A licensed CASP in the Czech Republic benefits from passporting rights, meaning it can offer its services across the entire European Economic Area without obtaining separate licenses in each country.

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10. Maintain Post-Licensing Compliance

Once licensed, a CASP must comply with all ongoing obligations under MiCA and national law. These include:

• Submitting periodic reports to the CNB

• Keeping all AML and governance policies up to date

• Maintaining proper recordkeeping and internal audits

• Ensuring the continued "fit and proper" status of key personnel

• Updating the regulator about any changes in operations, structure, or capital

• Responding to inspections, information requests, and regulatory audits

Failure to maintain full compliance may result in sanctions, license suspension, or revocation.