Opinion by: Slava Demchuk, co-founder and CEO of AMLBot
All virtual asset service providers (VASPs) registered in the EU before 2025 must comply with Markets in Crypto-Assets Regulation (MiCA) requirements this year. Not all will be able to do so.
The MiCA regulation is, in essence, a good legal framework for the crypto industry, but it also has some disadvantages, especially for crypto startups and small businesses.
Looking at the case of Estonia and its implementation of crypto licenses in 2017, it is possible to predict that around 75% of VASPs will need to cease their operations in the EU.
What happened in Estonia with crypto licenses?
In 2017, Estonia was one of the first EU member states to introduce a crypto licensing process. Getting a crypto license (a VASP registration) was easy and fast. No physical presence, share capital requirement, or proof of having sound Anti-Money Laundering (AML) and Know Your Customer (KYC) systems in place were required. The result? By 2019, Estonia had issued around 2,000 crypto licenses.
Starting in 2019, however, Estonia adopted several amendments to the law, incorporating requirements similar to MiCA. As a consequence, the majority of licensed crypto companies were not able to comply with new requirements and lost their licenses. Today, Estonia has only around 45 licensed crypto businesses.
Current situation in the EU with VASP registration
Similar situations will occur in countries with light VASP registration requirements, such as Poland and the Czech Republic. There are around 1,600 VASPs registered in Poland, owing to the easy and fast process of registering in the country before the MiCA implementation. With minimal requirements, one can open a company and receive a VASP registration in these countries within a few weeks.
These licensing processes completely changed in 2025 when MiCA entered fully into force. All the registered VASPs must comply with new requirements, which will be the same regardless of their country of incorporation; otherwise, they will be required to cease their business.
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Most of them will not be able to comply, based on previous experience, such as when 1,900 companies lost their VASP registrations in Estonia. Those license losses occurred as a result of several key factors:
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Their size: Many registered VASPs were one-to-three-person companies that provided essential exchange in p2p platforms or over-the-counter. They will not have enough resources to comply with strict MiCA requirements.
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The cost: Acquiring a MiCA license is expensive. It was previously possible to receive VASP registration in Poland or the Czech Republic for 2,000-4,000 euros. The price for a MiCA license is much more than that, typically around 30,000-80,000 euros, depending on the business model and country of incorporation.
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The requirements: Companies that apply for a MiCA license must prove they have many complex processes in place, including but not limited to AML/KYC, data protection and cyber resilience. Therefore, the company must hire many specialists and build many processes. Based on the number of VASPs registered in Poland, those 1,600 VASPs will need to find 1,600 AML/compliance officers (one per VASP) by July 2025 — when all VASPs in Poland shall comply with MiCA — that have relevant knowledge, expertise and pass the fit-and-proper test. This will be nearly impossible.
In addition, MiCA has high share capital requirements ranging from 50,000 to 150,000 euros, depending on the services a company provides. Many currently registered VASPs are startups or small companies whose revenue will not be able to cover all the costs needed to build the processes mentioned above and satisfy the share capital requirements.
Where does that leave the small businesses and the startups? They will not be equipped to comply with MiCA.
Opinion by: Slava Demchuk, co-founder and CEO of AMLBot.
This article is for general information purposes and is not intended to be and should not be taken as legal or investment advice. The views, thoughts, and opinions expressed here are the author’s alone and do not necessarily reflect or represent the views and opinions of Cointelegraph.
