Crypto & Digital Assets · Luxembourg
Crypto license in Luxembourg: MiCA CASP requirements (2026)
Luxembourg shaded by its crypto & digital assets status
Crypto is regulated in Luxembourg.
FrameworkEU Markets in Crypto-Assets Regulation (MiCA/MiCAR, Regulation (EU) 2023/1114), in force across the EU since 30 June 2024 (Titles III & IV on ARTs/EMTs) and 30 December 2024 (full application). Luxembourg designated the CSSF (Commission de Surveillance du Secteur Financier) as the competent authority via the national MiCA implementing law published in the Mémorial on 10 February 2025. National blockchain framework completed by Blockchain Laws I-IV (most recently the Law of 20 December 2024 amending the 6 April 2013 law on dematerialised securities). AML/CFT registration of VASPs continues under the Law of 25 March 2020 (as amended).
Crypto is legal in Luxembourg and is now subject to a comprehensive EU-wide regulatory regime under MiCA, with the CSSF acting as the national competent authority for authorisation and supervision of crypto-asset service providers (CASPs) and issuers of asset-referenced and e-money tokens. Luxembourg has long been a pro-DLT jurisdiction, its successive 'Blockchain Laws' (most recently Blockchain Law IV of 20 December 2024) explicitly recognise DLT for issuing and holding dematerialised securities, and the country has already granted MiCA authorisations (e.g., Zodia Custody, Banking Circle/EURI, Alipay Europe). Legacy AML-registered VASPs benefit from a transitional period that ends on 1 July 2026, after which a full MiCA licence is required.
How to get a crypto license in Luxembourg
To provide crypto-asset services in Luxembourg you need a MiCA CASP authorisation (Crypto-Asset Service Provider), supervised by the Commission de Surveillance du Secteur Financier (CSSF), under the EU Markets in Crypto-Assets Regulation (MiCA), Title V.
- Authority
- the Commission de Surveillance du Secteur Financier (CSSF)
- License required
- a MiCA CASP authorisation (Crypto-Asset Service Provider)
- Framework / law
- the EU Markets in Crypto-Assets Regulation (MiCA), Title V
- Minimum capital
- €50,000–€150,000 minimum, by service class (Class 1/2/3)
- Timeline
- about 40 working days of substantive review; 1–3 months for a well-prepared application
- Cost
- an application fee of roughly €5,000–€25,000, plus ongoing supervisory fees
- Passporting
- Yes — a single MiCA CASP licence passports across all 27 EU member states.
What a crypto license in Luxembourg covers
- Custody and administration of crypto-assets for clients
- Operating a trading platform for crypto-assets
- Exchanging crypto-assets for funds, or for other crypto-assets
- Executing orders for crypto-assets on behalf of clients
- Reception and transmission of orders, and placing of crypto-assets
- Advice and portfolio management on crypto-assets
- Transfer services for crypto-assets on behalf of clients
How to get a crypto license in Luxembourg: step by step
- 1Incorporate a legal entity with a registered office in the member state, with at least one director resident in the EU.
- 2Build the application file: programme of operations, business plan, governance, AML/CFT, ICT resilience and client-asset segregation.
- 3Submit the application to the national competent authority.
- 4Completeness check: the authority has 25 working days to confirm the file is complete and request anything missing.
- 5Substantive assessment: the authority has 40 working days to grant or refuse the authorisation.
- 6Once authorised, notify the passport to the host member states you intend to serve, then begin operating across the EU.
Documents required in Luxembourg
- Programme of operations describing each crypto-asset service you will provide
- Business plan with three-year financial projections
- Evidence of prudential safeguards (own funds or qualifying insurance)
- Governance arrangements, organisational chart and internal-control description
- AML/CFT policies and the appointment of a compliance officer
- ICT security, business-continuity and DORA-aligned resilience policies
- Custody and client-asset segregation arrangements
- Complaints-handling procedure and conflict-of-interest policy
- Fit-and-proper evidence for directors and qualifying shareholders (CVs, criminal-record certificates)
After authorisation: ongoing obligations in Luxembourg
- Maintain prudential safeguards and own funds at or above the class minimum
- Keep client crypto-assets segregated from the firm's own assets
- Run continuous AML/CFT monitoring, screening and suspicious-activity reporting
- Keep marketing communications fair, clear and not misleading
- Operate complaints handling and manage conflicts of interest
- Meet ICT resilience and incident-reporting duties under DORA
- File periodic reports to the national competent authority
Crypto license in Luxembourg: FAQ
Yes. To provide crypto-asset services in Luxembourg you need a MiCA CASP authorisation (Crypto-Asset Service Provider), supervised by the Commission de Surveillance du Secteur Financier (CSSF), under the EU Markets in Crypto-Assets Regulation (MiCA), Title V.
The Commission de Surveillance du Secteur Financier (CSSF).
An application fee of roughly €5,000–€25,000, plus ongoing supervisory fees.
Typically about 40 working days of substantive review; 1–3 months for a well-prepared application.
The application file centres on programme of operations describing each crypto-asset service you will provide; business plan with three-year financial projections; evidence of prudential safeguards (own funds or qualifying insurance); governance arrangements, organisational chart and internal-control description; plus fit-and-proper evidence for directors and qualifying shareholders.
Incorporate a legal entity with a registered office in the member state, with at least one director resident in the EU. Build the application file: programme of operations, business plan, governance, AML/CFT, ICT resilience and client-asset segregation. The authority then assesses the file and, once authorised, you can begin operating.
Yes — a single MiCA CASP licence passports across all 27 EU member states.
Key points
MiCA applies in full since 30 December 2024. The Luxembourg implementing law (published in the Official Journal on 10 February 2025) designates the CSSF as the competent authority with supervisory, investigative and sanctioning powers over CASPs and ART/EMT issuers.
VASPs registered with the CSSF before 30 December 2024 may continue to operate under a national transitional regime until 1 July 2026; after that date a CASP authorisation under MiCA is required to provide crypto-asset services in or from Luxembourg.
The Law of 20 December 2024 (Blockchain Law IV, in force 31 December 2024) amended the 6 April 2013 law on dematerialised securities to extend the DLT framework to unlisted equity securities and introduced the 'control agent' role (bank, investment firm or settlement organisation, on prior notification to the CSSF).
The CSSF has already granted MiCA authorisations to several major operators, including Zodia Custody (CASP) and Alipay Europe (EMT licence for a euro stablecoin); Banking Circle issues the EURI EMT from Luxembourg under CSSF supervision, evidence that the regime is operational, not just on paper.
Luxembourg transposed the EU DAC8 directive (Council Directive (EU) 2023/2226) and the OECD Crypto-Asset Reporting Framework through the law of 27 March 2026, imposing structured due-diligence, data-collection and reporting obligations on CASPs and equivalent operators from 1 January 2026.
The CSSF published Version 7 of its FAQ on virtual/crypto-assets on 4 February 2026, aligning terminology with MiCA, requiring prior CSSF notification before a fund invests in crypto-assets, case-by-case risk assessment, internal control functions and investor disclosure, retail UCITS still cannot gain direct exposure.
Timeline - major decisions & events
The CSSF published Version 7 of its FAQ on crypto-assets, replacing all 'virtual asset' references with 'crypto-assets' to align with MiCA and allowing UCITS to obtain indirect crypto exposure of up to 10% of NAV. It marks the regulator's most permissive stance to date for Luxembourg funds.
CSSF ↗The CSSF granted Bitstamp a Crypto-Asset Service Provider (CASP) authorisation under MiCA, covering trading, order execution and custody with an EEA passport. It was the first full CASP licence issued by the CSSF, signalling Luxembourg's role as an EU crypto hub.
Luxembourg for Finance ↗The Law of 6 February 2025 formally named the CSSF as the sole national competent authority for MiCA, vesting all CASP licensing, supervision and enforcement powers in the regulator. It completed Luxembourg's domestic anchoring of the EU regime.
CSSF ↗The Law of 20 December 2024 entered into force, introducing an optional 'control agent' model and broadening DLT issuance to equities, fund units and tokenised physical assets. It deepened Luxembourg's tokenisation framework beyond debt instruments.
Luxembourg for Finance ↗The Law of 15 March 2023 implemented EU Regulation 2022/858, letting market infrastructures trade and settle tokenised securities on DLT and recognising DLT for financial collateral arrangements. It extended Luxembourg's blockchain framework to market-infrastructure level.
Luxembourg for Finance ↗Amendments to the 2004 AML/CFT law transposed the EU 5th AML Directive, defining virtual assets and requiring VASPs to register with and be AML-supervised by the CSSF. This was Luxembourg's first dedicated legal regime for crypto businesses.
CSSF ↗Luxembourg - other topics
Crypto & Digital Assets in other countries
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