--- title: "Crypto payments licence under MiCA · LT MiCA Desk" description: "Providing transfer services for crypto-assets is a class 1 CASP service, but it rarely stands alone and it overlaps with e-money and payment licensing. Where the perimeters meet and which permission you actually need." url: https://unbui.lt/business-models/crypto-payments/ lang: en-GB updated: 2026-10-24 --- [Home](/) / [Business models](/business-models/) / Payments and transfers # Payments and transfers The only model on this site where the right answer is sometimes that you do not need a CASP authorisation at all, and the only one where getting that question wrong costs you twice. ## The service itself is narrow **Providing transfer services for crypto-assets on behalf of clients is a class 1 service with a floor of €50,000. You move crypto-assets from one address to another on a client instruction. That is all it covers: moving the asset on instruction, from one address to another.** Almost nobody provides only that. Of the 217 register rows naming transfer services, 203 also name custody, which is the tightest pairing on the register in either direction. The reason is mechanical. To move an asset on a client's instruction you generally have to be holding it, or holding the key to it, and the moment that is true you are a custodian and you are in class 2 at €125,000. [The custody test](/business-models/crypto-custody/). So the honest version of the capital answer for a payments firm is €125,000 unless you can demonstrate a genuinely non-custodial flow, and those exist but they are narrower than most product descriptions suggest. ### What the European register shows for this permission Register rows naming it **217** across 27 home states Recorded as Article 63 authorisations 61 Recorded as Article 60 notifications 24 No legal basis recorded 132 Held in Lithuania 5 **Largest home states:** France 28, Malta 21, Netherlands 21, Cyprus 18, Germany 17. **Most often held alongside:** providing custody and administration of crypto-assets on behalf of clients (203 of 217) , exchange of crypto-assets for funds (152 of 217) , exchange of crypto-assets for other crypto-assets (118 of 217) , execution of orders on behalf of clients (118 of 217) . Counted from ESMA's interim register of crypto-asset service providers, file last updated 20 October 2026, counted 23 October 2026. The three basis figures do not sum to the total because the register's legal-basis column is optional and most national authorities leave it empty, Lithuania among them. [Why that gap matters](/insights/vasp-to-casp-under-mica/#register). Rows naming providing transfer services for crypto-assets on behalf of clients are counted, whether or not the firm also holds other permissions. ## Where MiCA stops and payment law starts This is the question that actually matters here, and it turns on what is moving. MiCA regulates services in relation to crypto-assets. Moving euros is payment services law and moving electronic money is the e-money regime, and neither becomes a crypto-asset service because the front end has a wallet in it. A firm that takes fiat from a payer, converts it and delivers crypto to a payee is doing more than one regulated thing, and the usual error is to apply for one permission and discover the other at the worst moment. The conversion step is exchange, which is class 2. The fiat leg may be a payment service. The crypto leg is transfers and probably custody. [What the conversion step adds](/business-models/crypto-exchange/). Stablecoins make the line finer rather than clearer. An e-money token is a crypto-asset for MiCA purposes, so moving one for a client is a transfer service, but issuing one is a different Title of the regulation and a different authorisation entirely. Issuing and moving your own token is a combination worth scoping carefully rather than assuming. ## The case for not applying If you already hold an electronic money institution licence, Article 60(4) lets you notify your competent authority instead of applying for a CASP authorisation. The permission it gives is narrow and worth reading before you rely on it: custody and administration, and transfer services, and only in relation to the e-money tokens you issue yourself. It does not reach anyone else's tokens and it does not reach exchange. Article 60(4) permits an electronic money institution to provide only custody and administration of crypto-assets on behalf of clients and transfer services for crypto-assets on behalf of clients, and only with regard to the e-money tokens it issues itself. [EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1114) · Verified on 2026-10-24 · Next review 2027-04-24 That is the shape the Lithuanian register actually shows. Lithuania shows six entries on the ESMA crypto-asset service provider register, not four. Two of them, Newrails UAB and UAB BLUE EMI LT, are recorded there as providing crypto-asset services under Article 60(4) of MiCA in relation to an e-money token they issue themselves. That is a notification by an institution already authorised for something else, not an authorisation under Article 63, and it cannot be applied for by a firm that has no other licence. [ESMA, Interim MiCA register, crypto-asset service providers (CASPS.csv)](https://www.esma.europa.eu/sites/default/files/2024-12/CASPS.csv) (2026-10-20) · [EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32023R1114) · Verified on 2026-10-23 · Next review 2026-11-23 Both of those firms hold custody, one of them holds transfers as well, and both are recorded against an e-money token they issue themselves. If that describes you, settle the Article 60 question before you budget for an application, because the two routes are not comparable in cost. [Which route you are on](/insights/casp-authorisation-or-article-60-notification/). **A payment institution has no equivalent route. Article 60 lists the authorised entities that may notify, and a payment institution authorised under Directive (EU) 2015/2366 is not one of them, although MiCA defines the term elsewhere in the regulation.** The e-money licence and the payment licence are different permissions here, and the distinction is easy to lose because the two regimes sit so close together in every other respect. If you hold a payment institution licence and intend to provide crypto-asset services, the route is an authorisation under Article 63. The same applies to a company being formed. Article 60 is a notification made against an existing permission, so a new firm has nothing to notify against. ## Where the real weight falls Transfers add no extra item to the Article 62(2) list, which makes this look like the lightest file on the site. It is not, and the weight is in a different place. A transfer business is read for its anti-money-laundering architecture more closely than any other model here, because moving value for clients between addresses is the activity the whole framework exists to watch. Expect the questions to be about transaction monitoring, about how you handle transfers to and from addresses you cannot attribute, about the information that travels with a transfer, and about what your system does when it cannot complete that picture. None of that is a MiCA document requirement. All of it is what the assessment will turn on. [What ends an application](/licensing/refusal-grounds/). ## What this page could not verify - **No AML standard is quoted.** The description of where the assessment weight falls is our reading of how a transfer business is supervised, not a published position of the Bank of Lithuania or any other authority. - **Article 60 eligibility is not advice.** Whether a particular e-money or payment licence reaches a particular crypto-asset service is a question about your permission and your intended activity, and it is settled with your competent authority rather than from a page. - **The register moves.** Counted 23 October 2026 from a file ESMA last updated four days earlier. Readiness assessment ## Settle the perimeter before the application A payments model usually touches two regimes and sometimes three. Working out which permissions the flow actually engages is the first piece of work, and it occasionally ends with a notification rather than an application. [Request an assessment](/assessment/) [Check your licensing scope first](/requirements/service-classes/) Enquiries go by email for now. Nothing on this site collects your details, and [the assessment page](/assessment/) sets out what to include. Regulatory references on this page were read against the primary text on 23 October 2026. Every figure is held in the [source register](/sources/) with the document it came from.