MiCA CASP Class 1 vs Class 2 vs Class 3
The short answer: the classes differ by which crypto-asset services they cover, and the capital floor rises with them. They are cumulative, and you do not choose between them. Your services decide.
| Class | Services it adds | Annex IV minimum | Typically suits |
|---|---|---|---|
| Class 1 |
| €50,000 | Advisory, brokerage and transfer models that never take control of client assets. |
| Class 2 |
…plus everything in class 1. | €125,000 | Exchanges trading on their own account, custodial wallets and brokers holding client assets. |
| Class 3 |
…plus everything in class 2. | €150,000 | Operators of a venue that matches third-party buying and selling interests. |
What is identical across all three
Every class sits under one authorisation regime. The application contents in Article 62(2), the procedure and timetable in Article 63, the establishment conditions in Article 59, the governance requirements in Article 68 and the passporting mechanism in Article 65 do not vary by class. Neither does the Article 67 structure: whatever the floor, the requirement is the higher of it and a quarter of fixed overheads.
Annex IV sets permanent minimum capital of EUR 50 000 for class 1, EUR 125 000 for class 2 and EUR 150 000 for class 3, by reference to the crypto-asset services the provider is authorised for.
EUR-Lex, Regulation (EU) 2023/1114 (MiCA), consolidated text · Verified on 2026-09-14 · Next review 2027-03-14
What actually differs
Three things, and only three: the capital floor, the set of services you may provide, and the service-specific evidence each additional service brings into the file.
| Service that raises the class | Additional evidence under Article 62(2) |
|---|---|
| Providing custody and administration of crypto-assets on behalf of clients | Custody and administration policy (Article 62(2)(m)). |
| Exchange of crypto-assets for funds | Non-discriminatory commercial policy and the methodology for determining price (Article 62(2)(o)). |
| Exchange of crypto-assets for other crypto-assets | Non-discriminatory commercial policy and the methodology for determining price (Article 62(2)(o)). |
| Operation of a trading platform for crypto-assets | Operating rules of the platform, plus the procedure and system to detect market abuse (Article 62(2)(n)). |
The distinction that decides most applications
A firm that quotes a price and trades against its client on its own account is providing class 2 exchange services. A firm running a system that matches the buying and selling interests of third parties is operating a trading platform, which is class 3. Many applicants describe both as "an exchange". The second carries a higher floor and obliges you to produce operating rules and a working market-abuse detection system, a build rather than a document.
Why the class is not a commercial choice
Annex IV to Regulation (EU) 2023/1114 groups crypto-asset service providers into prudential classes by reference to the services they are authorised for. It does not offer three products. An applicant who decides to "apply for class 1 to keep capital down" while intending to hold client assets has not chosen a cheaper licence; they have described their business inaccurately in a document the Bank of Lithuania will assess.
The practical order of work is therefore fixed: establish the activity, derive the service, derive the class, then derive the capital. The picker does the middle two steps.
Questions
Are MiCA CASP classes three different licences?
No. Annex IV to Regulation (EU) 2023/1114 groups crypto-asset service providers into prudential classes according to the services they are authorised for. There is one authorisation, and the class is a consequence of the services named in it rather than a package an applicant selects.
What is the difference between class 2 exchange services and a class 3 trading platform?
Class 2 exchange services mean the provider quotes a price and trades against the client on its own account. A class 3 trading platform means operating a system that matches buying and selling interests of third parties. The second is a venue, carries a higher capital floor, and additionally requires operating rules and a system to detect market abuse.
Can a class be changed after authorisation?
Adding services to an existing authorisation is an extension request under MiCA Article 59(8), complemented and updated under Article 62 and processed in accordance with Article 63. If the added service sits in a higher class, the prudential floor moves with it.
Regulatory references on this page were read against the primary text on 14 September 2026. Every figure is held in the source register with the document it came from.