Crypto Licensing

Portugal Crypto Licence

The route only opened in December 2025, which is exactly why a clean early file still counts for something. We prepare and submit it.

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Why Portugal for Your Crypto Licence

Portugal gives you a full EU passport from a country with one of Europe’s deepest crypto-user bases, at MiCA’s own capital minimums and with a personal-tax position for long-term holders that no other EU jurisdiction matches. A Portuguese MiCA CASP authorisation lets you serve clients across all 30 EEA member states, and you secure it through a clean FATF-member jurisdiction with an English-friendly business environment. That combination is why we deliver serviced licensing here.

Expert Comment

The MiCA Article 70 safeguarding requirement—client funds must settle with a credit institution, not an EMI, within one business day—is the constraint that turns a Portuguese licence into a working business. We confirm banking is feasible before you commit capital; most operators underestimate the lead time for the safeguarding account, which is why we open those conversations during the application phase, in parallel with the file.

Daniel Tomberg CEO & Senior Partner, Tomberg & Partners
The short version: Portugal is the right call for operators who want EU-wide market access at MiCA’s capital minimums, in a jurisdiction whose founders also benefit from a 0% personal tax on long-held crypto. The route opened only in late December 2025, so it rewards a clean, early filing. That is precisely the kind of new-regime process we are built to run for you.

MiCA minimums, no national overlay. Portugal applies MiCA’s own-funds requirements directly: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3, with none of the national overlays Estonia stacks on top (€100,000–€250,000). A Portuguese CASP authorisation grants the right to provide crypto-asset services across all 30 EEA member states through a single notification under MiCA Article 65, with no additional host-country authorisation.

A personal-tax position founders relocate for. Gains on crypto held by individuals for 365 days or more are exempt, while shorter-term gains are taxed at a flat 28% under Category G. The IFICI regime offers a 20% flat personal income tax rate on qualifying employment income for up to 10 years. This is a draw for founders and key hires relocating to Lisbon; it does not reduce the corporate tax a licensed CASP pays on operating profit, and we are straight with you about that distinction when we structure the entity.

An early-mover advantage on a new route. Because Law No. 69/2025 only took effect on 23 December 2025, the Banco de Portugal is working through its first authorisation cohort while the legacy VASP grandfathering window runs to 1 July 2026. Around 10 entities held the legacy registration, so the larger flow is fresh applicants drawn by the passport and the tax position. A well-prepared application built directly to the MiCA standard moves faster and a weak one fails sooner. We make sure yours is the former.

Which Business Models Suit Portugal

Portugal fits operators who want broad EU reach at MiCA’s capital minimums, particularly where founders gain from the personal long-term holding exemption. Before we file, we confirm your model maps cleanly onto the MiCA service classes and that the jurisdiction genuinely serves your plan.

  • Exchanges and brokers seeking EU-wide reach. One Portuguese licence passports trading, exchange and execution services across the EEA, so you sell into 30 markets from a single Lisbon base.
  • Custody and wallet providers. Class 2 custody authorisation pairs with the safeguarding banking and segregated-account architecture custody businesses need under MiCA Article 70.
  • Founder-led teams relocating to Lisbon. The 0% personal tax on crypto held 365 days or more, and the IFICI regime for key hires, make Portugal attractive where principals are moving personal holdings and talent alongside the business.
  • Capital-conscious operators. MiCA minimums with no national overlay mean less idle capital than Estonia or most Western European options.
  • × Profit-reinvestment plays. If retaining earnings tax-free is the priority, the licensed entity still pays 19% IRC in Portugal; Lithuania or another route may suit the corporate position better. We will tell you straight.
  • × A fully settled pipeline today. Portugal’s authorisation route opened only in late December 2025. If you need a regulator with years of decided CASP cases behind it, Malta or Cyprus is worth weighing, and we deliver in both.
  • × Tokenised securities or RWA. A MiCA CASP licence does not cover financial instruments. Where your model needs it, we scope the MiFID securities route or EU fund licensing alongside crypto permissions.

What We Do for You

We obtain your Portuguese CASP authorisation, we do not hand you a shortlist and step back. From the first scoping call to the day your authorisation publishes, you deal with one accountable firm and our in-country specialists. We file the work and we stand behind it.

  • Form your Portuguese company. We incorporate your Lda or S.A., deposit the required own-funds, appoint the two effective directors and a compliance officer and MLRO, and establish a genuine head office in Portugal that satisfies the substance test.
  • Build the compliance suite. We draft every policy bespoke to your model and to Portuguese law: programme of operations, AML/CFT manual, enterprise-wide risk assessment, sanctions screening, transaction monitoring, Travel Rule implementation, KYC/CDD, the DORA ICT framework, complaints handling, conflicts of interest and wind-down plan. Adapted templates are the single most common cause of rejection, so we do not use them.
  • Prepare the people and the proof. We assemble fit-and-proper files for directors, officers and qualifying shareholders, including the source-of-funds and source-of-wealth evidence that decides most early MiCA applications.
  • File and manage the application. We file with the Banco de Portugal, coordinate the CMVM’s binding opinion, and deal with the regulator directly on every query and information request through to authorisation, in Portuguese.
  • Arrange banking. We open the two layers a CASP needs: an operational account with a licensed EU electronic money institution and a credit-institution relationship for client-fund safeguarding under MiCA Article 70. We start this during the application so banking is ready when your licence is.
  • Run ongoing compliance. After authorisation we set up reporting to the Banco de Portugal and the CMVM, the DAC8 obligations, and the annual cycle, so the licence stays in good standing.

We scope and quote each engagement to your specific model and service classes. Tell us what you are building and we will map your route to approval and price it.

Regulatory Framework

Portugal regulates crypto-asset service providers under the EU’s Markets in Crypto-Assets Regulation (MiCA), Regulation (EU) 2023/1114, which applies directly without national transposition. The national implementing legislation is Law No. 69/2025, in force from 23 December 2025. It establishes a twin-peaks model: the Banco de Portugal is the lead authority for CASP authorisation and prudential supervision, and the CMVM is the conduct and market-abuse supervisor. We file with the Banco de Portugal and manage both supervisory relationships for you.

The short version: MiCA governs; Law No. 69/2025 designates the Banco de Portugal and the CMVM as the two competent authorities and sets the transitional regime to 1 July 2026. Applications go to the Banco de Portugal, which obtains the CMVM’s binding opinion within 10 to 15 working days. We deal with the regulator directly and run both relationships through to authorisation.

Twin-peaks regulator structure

The Banco de Portugal is the competent authority for the authorisation of CASPs, the acquisition of qualifying holdings, significant CASPs, and the prudential, governance, outsourcing and orderly wind-down provisions. The CMVM supervises crypto-asset offers, market abuse, and CASPs’ conduct-of-business obligations, safekeeping of clients’ assets, complaints handling and conflicts of interest. For you this means a single submission point but two supervisory relationships to maintain after authorisation, and we manage both. Already-licensed financial institutions, including credit institutions, investment firms and EMIs, are not required to obtain a separate CASP licence: under MiCA Article 60 they notify the Banco de Portugal of their intention to provide crypto-asset services, a route faster than a fresh application, and we run that notification where it applies to you.

Regulatory overlap we classify before filing

Three adjacent regimes matter, and we map your tokens and services against them before we file. CASPs that issue or handle e-money tokens trigger EMD2/PSD2 requirements, and dual authorisation is required for EMT-related payment services. Crypto-assets that confer equity-like rights or are negotiable on capital markets are transferable securities under MiFID II, supervised by the CMVM, not MiCA. And Portuguese CASPs remain subject to the AML/CFT Law (Law No. 83/2017, as amended) and to the Travel Rule under the Transfer of Funds Regulation Recast, transposed by Law No. 70/2025. We classify your activity to the correct perimeter so you are neither under-licensed nor over-licensed.

From VASP Registration to MiCA CASP Authorisation

Portugal is mid-transition from its legacy Banco de Portugal VASP registration regime to full MiCA CASP authorisation. Because Law No. 69/2025 only entered into force on 23 December 2025, the authorisation process effectively opened in 2026. The national transitional period for legacy VASPs runs to 1 July 2026, aligned with the EU-wide MiCA Article 143(3) grandfathering cliff.

The short version: VASPs registered with the Banco de Portugal that had commenced and notified their activity by 30 December 2024 may keep operating until 1 July 2026, or until their MiCA authorisation is granted or refused. There is no automatic conversion: every grandfathered VASP must file a full MiCA CASP application to continue past the deadline. From 1 July 2026, providing crypto-asset services without MiCA authorisation has no legal basis. Whether you are a legacy VASP or a fresh applicant, we file the full application for you.
MilestoneDateImpact
MiCA fully applicable (EU-wide)30 December 2024MiCA in force; Portugal had not yet designated a competent authority
Law No. 69/2025 in force23 December 2025Banco de Portugal and CMVM designated; CASP authorisation route opens
VASP grandfathering windowTo 1 July 2026Registered VASPs (active by 30 Dec 2024) treated as CASPs in the interim
Transitional cliff1 July 2026Operating without MiCA authorisation loses its legal basis

The grandfathering relief is narrow: it covers only entities that, as at 30 December 2024, were already registered with the Banco de Portugal and had commenced and notified their virtual-asset activities. With roughly 10 registered VASPs, Portugal’s grandfathered cohort is small, and the larger flow is fresh applicants drawn by the EU passport and the tax position rather than legacy conversions. An applicant that has not filed in time to be decided by 1 July 2026 risks a gap in its legal basis to operate, and the compressed Portuguese timeline leaves limited margin. That is why we move on entity formation and the compliance build in parallel from day one, so your file reaches the Banco de Portugal early rather than against the cliff.

Licence Classes and Capital

MiCA defines 10 crypto-asset services grouped into three classes that set your capital tier. Portugal implements MiCA directly without additional national service categories, and applies the own-funds requirements of Article 67 and Annex IV: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3. You hold authorisation for the specific services you intend to provide, and the combination fixes the class and capital tier. Most exchange operators land in Class 2 (adding custody and exchange) or Class 3 (adding operation of a trading platform). We confirm the right class for your model before any capital is locked.

ClassServices AddedMinimum Own-Funds
1Reception and transmission of orders, advice, portfolio management, execution, placing, transfer services€50,000
2Custody and administration; exchange of crypto for funds or other crypto€125,000
3Operation of a trading platform€150,000

The ongoing own-funds obligation is the higher of the permanent minimum or 25% of the preceding year’s fixed overheads, and may be met through own funds, a qualifying insurance policy or a comparable guarantee. The scope limits matter, and we map your activity against them: services provided in a fully decentralised manner without any intermediary fall outside MiCA; unique, non-fungible tokens are excluded unless issued in large series, fractionalised or functioning as a payment or investment instrument; and crypto-assets that qualify as financial instruments under MiFID II follow the securities regime, supervised by the CMVM. A Portuguese MiCA CASP authorisation does not cover tokenised securities or real-world-asset tokens that are financial instruments. Where your model needs that route, we scope it and pair it with crypto permissions or EU fund licensing.

What the Banco de Portugal Requires

A Portuguese CASP needs a Portuguese corporate entity (typically a Lda or S.A.), own-funds of €50,000–€150,000 by service class, a real establishment in Portugal, at least two effective directors, a compliance officer and MLRO, and a bespoke compliance documentation suite. Every qualifying shareholder holding 10% or more of capital or voting rights undergoes fit-and-proper assessment with source-of-funds verification. The binding constraints are capital, real substance and documentation quality. We prepare each of these to the standard that clears.

The short version: the constraints are capital, genuine substance in Portugal, and documentation quality. Because the route is new, there is no settled body of decisions to lean on, so we build the application directly to the MiCA RTS standard and the published Banco de Portugal and CMVM expectations rather than to a recycled template.
RequirementDetail
Entity typePortuguese company: Sociedade por Quotas (Lda) or Sociedade Anónima (S.A.)
Minimum own-funds€50,000 (Class 1) / €125,000 (Class 2) / €150,000 (Class 3)
Management bodyAt least two effective directors (four-eyes principle); collective suitability and crypto/finance experience assessed
Compliance officer / MLRORequired; responsible for AML/CFT and the interface with both supervisors
EstablishmentReal establishment and head office in Portugal; effective management exercisable from Portugal
Foreign ownership100% foreign ownership permitted
Qualifying shareholdersAll holders of 10%+ undergo fit-and-proper assessment with source-of-funds verification

Portugal requires genuine substance: a letterbox entity with management outsourced elsewhere is not acceptable, and the supervisors assess whether the structure allows effective oversight of both prudential and conduct obligations from Portugal. We establish the office, place the people and structure the management body so the substance test is met, not finessed. Across early MiCA cohorts EU-wide, the most common failure point has been an inability to evidence the legitimate origin of owners’ capital, so we build the source-of-wealth file properly from the outset, with three to five years of tax returns, bank statements and employment records rather than a single certificate of deposit. On AML, there is no de minimis threshold for CASP-to-CASP transfers under the Travel Rule: full originator and beneficiary information must accompany every transfer, and the €1,000 threshold applies only to transfers involving self-hosted wallets. We build all of this into your compliance suite.

Application Process and Timeline

The realistic end-to-end timeline is 6–12 months given the new Portuguese route. The Banco de Portugal assesses within the statutory MiCA framework: 25 working days for completeness and 40 working days for substantive assessment (extendable if more information is requested), with the CMVM’s binding opinion in 10 to 15 working days. Most of the calendar time before that is preparation, which cannot be rushed with off-the-shelf templates. We run the whole sequence and keep the regulator’s clock moving.

The short version: the statutory assessment mirrors MiCA’s 40–60 working days, but the preparation phase (entity formation, documentation drafting, capital deposit) takes 8–12 weeks before filing, and dual-supervisor coordination adds time. The bespoke compliance documentation is where applications win or lose, and it is the work we do best.

The formal authorisation file is expected in Portuguese, with certified Portuguese translations of supporting documents (articles of association, internal policies, AML manual, ICT framework) and Portuguese-language correspondence throughout. Our in-country specialists handle the Portuguese-language filing and correspondence for you. As of June 2026 neither supervisor operated a CASP-specific formal pre-application programme, but we make early contact to confirm documentation expectations before the statutory clock begins, especially while the first authorisation cohort is being processed.

Stage 1 2–6 weeks

We form your company and deposit capital

We incorporate the Lda or S.A., obtain the corporate registration and deposit the required minimum own-funds (€50,000–€150,000). We appoint at least two effective directors and a compliance officer and MLRO, and establish a real head office in Portugal.

Stage 2 8–12 weeks

We build the compliance suite

We draft the full suite required under MiCA Article 62 and Commission Delegated Regulation (EU) 2025/305: programme of operations, AML/CFT manual, enterprise-wide risk assessment, sanctions screening, Travel Rule implementation, KYC/CDD procedures, business continuity, DORA/ICT framework, complaints handling, conflicts of interest and wind-down plan. Each document is bespoke; adapted templates are a common cause of rejection.

Stage 3 2–4 months (parallel)

We open banking

We open the operational account and arrange client-fund safeguarding. MiCA Article 70 requires client funds to be held with a credit institution in a segregated account by the end of the next business day; an EMI account does not satisfy this. We begin banking conversations early, as the safeguarding account is the harder one to obtain, and run it in parallel with the filing.

Stage 4 40–60 working days

We file and manage assessment to a decision

We submit the complete application to the Banco de Portugal, which coordinates with the CMVM, and handle every information request through the process. Completeness is checked within 25 working days; substantive assessment runs 40–60 working days. On authorisation your licence is published in the Portuguese register and notified to ESMA for the EU-wide register.

Taxation

Portugal is a moderate-tax EU jurisdiction with a well-known incentive for long-term individual crypto holders, but a standard corporate burden for the CASP itself. The standard corporate income tax (IRC) rate is 19% for financial years beginning on or after 1 January 2026, on a legislated path toward 17% by 2028, with a preferential 15% rate on the first €50,000 of taxable income for qualifying SMEs. Municipal and state surtaxes apply on top. We structure your entity to use the reliefs it qualifies for.

TaxRateCrypto Application
Corporate income tax (IRC)19% (standard, from January 2026)All CASP operating profits, before surtaxes
SME first bracket15% (first €50,000 of taxable income)Available if the CASP qualifies as an SME
Capital gains (individual, held < 365 days)28% flat (Category G)Short-term crypto disposals by individuals
Capital gains (individual, held ≥ 365 days)0% (exempt)Long-term holdings; excludes security-type tokens and blacklisted counterparties
VAT23% standard; crypto-to-fiat exchange VAT-exemptCrypto-to-fiat exchange exempt per CJEU Hedqvist ruling
Stamp duty on CASP commissions4%On fees and commissions; borne by the client
In short: Portugal’s headline tax appeal is for individuals, not for the licensed entity. Individual gains on crypto held for 365 days or more are exempt; gains held for under 365 days are taxed at a flat 28% under Category G, in force since 2023. The exemption does not extend to security-type tokens or counterparties in blacklisted jurisdictions, and a licensed CASP pays standard IRC on its operating profit regardless of the individual regime.

The IFICI (NHR 2.0) regime offers a 20% flat personal income tax rate on qualifying employment and self-employment income for up to 10 years, which can lower the personal tax burden on key hires, but it does not apply to passive investment income. As an EU member state, Portugal is also bound by DAC8 (transposing the OECD Crypto-Asset Reporting Framework): CASPs collect reportable data from 1 January 2026, with first reporting in 2027.

Ongoing Compliance and DORA

The authorisation does not lapse, but supervision is active. A Portuguese CASP files periodic prudential and activity reporting to the Banco de Portugal, meets the CMVM’s conduct, client-asset and complaints obligations, keeps its AML/CFT programme current under Law No. 83/2017 and the Travel Rule, and maintains the capital, governance and substance that won the licence. Both supervisors run inspections, and enforcement under MiCA reaches the EU-wide ceilings. We set up the reporting calendar and stay on as your standing compliance partner so the licence stays in good standing.

The short version: the work does not stop at authorisation. You have to keep the structure, capital and documentation quality that won the licence, across two supervisors. We run the ongoing cycle for you, including DAC8 data collection from 1 January 2026 with first reporting in 2027.

DORA and ICT resilience

The Digital Operational Resilience Act (DORA, Regulation (EU) 2022/2554) applies to every CASP authorised under MiCA and has done since 17 January 2025, with the Banco de Portugal as enforcer. It sets five pillars: ICT risk management, incident reporting (initial notification within 4 hours of classification as major), resilience testing, third-party ICT risk management and information sharing. Threat-led penetration testing applies only to entities the regulator designates as significant; most smaller and mid-size CASPs conduct general testing only. We build the DORA-compliant ICT framework into your application and operationalise it after authorisation.

Banking

Banking is the constraint that turns a Portuguese licence into a working business, and it is part of what we deliver. MiCA Article 70 requires client funds to be held with a licensed credit institution, not an EMI, in a segregated account by the end of the next business day. That means two layers: an operational account for day-to-day flows and a credit-institution relationship for safeguarding.

The short version: the challenge is not getting any account, it is getting the right ones. We arrange both layers and confirm banking is feasible before you commit, so your licence is not a certificate on the wall.

Domestic banks remain cautious with crypto businesses, and MiCA authorisation improves credibility without guaranteeing acceptance. The workable pattern pairs a licensed EU electronic money institution for operational payments with an EEA credit institution willing to hold the Article 70 safeguarding account. The safeguarding relationship is the harder one to obtain and typically takes two to four months, so we open and drive these conversations during the application phase rather than after authorisation, alongside the filing, so banking lands when your licence does. We hold the institutional relationships directly and put them to work for you. Learn about crypto business banking →

How Portugal Compares

Portugal sits alongside the other crypto jurisdictions we deliver in: Lithuania and the established centres of Cyprus and Malta, plus Gibraltar, Poland and Switzerland. Each MiCA route offers EU or EEA passporting; the differentiators are timeline, tax, regulatory maturity and how settled the authorisation route is. Gibraltar runs its own DLT regime outside MiCA, and Switzerland sits outside the EU passport entirely.

FactorPortugalLithuaniaCyprusMaltaPolandSwitzerland
RegimeMiCA CASPMiCA CASPMiCA CASPMiCA CASPMiCA CASPSwiss FINMA (non-EU)
RegulatorBanco de Portugal + CMVMBank of LithuaniaCySECMFSAKNFFINMA
Timeline6–12 months4–8 months4–6 months9–18 monthsNot operational6–12 months
Min. Capital€50,000–€150,000€50,000–€150,000€50,000–€150,000€50,000–€150,000€50,000–€150,000 (proposed)varies by category
Corporate Tax19% (15% SME first €50k)17% / 7% small15% (from Jan 2026)~5% effective (refund system)19% / 9% small~12–14% effective (cantonal)
Individual long-term crypto gains0% (held ≥ 365 days)15% (20% above ~€277k)8% flat (from 2026)0%–35% (case-by-case)19% flat0% (private wealth)
EU PassportingYesYesYesYesNo (legislation blocked)No (non-EEA)
Route maturityNew (law in force Dec 2025)Established (experienced supervisor)Established (CIF/AML track record)Established (former VFA regime)No CASP route yetEstablished (DLT Act)
Best ForEU access + long-term individual holders; Lisbon ecosystemCost-conscious EU access; fintech ecosystemFinancial-services groups; investment-firm overlapEstablished exchanges; English-language operationsAs of 2026, no MiCA implementationToken issuance and DLT-native models outside the EU

The key difference: the EU routes apply MiCA’s capital minimums directly, so the spread is on route maturity and tax. Portugal’s standout is the individual long-term holding exemption, which benefits founders rather than the entity. For the CASP itself, Malta’s low effective rate via the refund system and Cyprus’s 15% headline rate undercut Portugal’s 19% IRC, and both offer more settled, English-language authorisation routes. Lithuania is the lower-cost, faster Baltic option with an experienced supervisor; Poland still has no operational CASP route after repeated legislative blocks; and Switzerland is the non-EU alternative for DLT-native and token-issuance models that do not need an EU passport. Portugal’s route opened only in late December 2025, so its draw is the passport plus the founder tax position rather than a settled pipeline.

We deliver crypto licensing directly in Lithuania, Cyprus, Malta, Gibraltar, Poland and Switzerland as well as Portugal, handling company formation, the licence application, banking and post-licensing compliance ourselves. If another jurisdiction fits your model better, we will tell you and file there instead. See where we deliver →

Frequently Asked Questions

Working with us
What does Tomberg & Partners do for a Portuguese CASP licence?

We deliver the whole process and stand behind it. We form your Portuguese company, deposit the capital, appoint the management body and a compliance officer and MLRO, establish a real office in Portugal, build the full bespoke compliance suite, file with the Banco de Portugal and obtain the CMVM’s binding opinion, and deal with the regulator directly through to authorisation. We arrange both layers of banking and set up your ongoing reporting. You deal with one accountable firm and our in-country specialists, not a chain of intermediaries. Contact us and we will scope and quote your case.

How much does it cost?

It depends on your service classes, structure and complexity, so we scope each engagement and quote it rather than publish a number. Capital is set by MiCA and locked in your own company: €50,000 for Class 1, €125,000 for Class 2 and €150,000 for Class 3. Tell us what you are building for a quote.

Authority and structure
Which authority issues MiCA CASP authorisation in Portugal?

Portugal operates a twin-peaks model under Law No. 69/2025. The Banco de Portugal is the lead competent authority for CASP authorisation, prudential supervision and governance, and decides every application. The CMVM, the securities market regulator, supervises conduct of business, the safekeeping of client assets, complaints, conflicts of interest and market abuse, and issues a binding opinion during authorisation within 10 to 15 working days. We file with the Banco de Portugal and manage both supervisory relationships for you.

What type of company is required for a Portuguese CASP licence?

A Portuguese company, typically a Sociedade por Quotas (Lda) or a Sociedade Anónima (S.A.), is required, and we incorporate it before filing your CASP application. 100% foreign ownership is permitted. Every qualifying shareholder holding 10% or more undergoes fit-and-proper assessment, including source-of-funds verification, which we prepare with you. At least two effective directors are required under the four-eyes principle, along with a compliance officer and MLRO.

What happens to existing Portuguese VASP registrations under MiCA?

Entities registered with the Banco de Portugal as virtual asset service providers that had commenced and notified their activity by 30 December 2024 may continue operating under a grandfathering regime until 1 July 2026, or until their MiCA authorisation is granted or refused. There is no automatic conversion: every grandfathered VASP must file a full MiCA CASP authorisation application with the Banco de Portugal to continue after the deadline. We file the full application for you, whether you are a legacy VASP or a fresh applicant.

Process and capital
How long does it take to obtain authorisation?

6–12 months end-to-end: 2–6 weeks for formation and capital, 8–12 weeks while we build the compliance suite, then the statutory assessment of 25 working days for completeness and 40 working days for substantive review, with the CMVM’s binding opinion in 10 to 15 working days. Because Portugal’s route opened only in late December 2025, we build the file directly to the MiCA standard and keep the regulator’s clock moving.

What is the minimum capital requirement for a Portuguese MiCA CASP?

Portugal applies MiCA’s own-funds requirements directly under Article 67 and Annex IV: €50,000 for Class 1 services, €125,000 for Class 2 (adding custody and exchange) and €150,000 for Class 3 (adding operation of a trading platform). The prudential safeguard is the higher of the permanent minimum or one quarter of the preceding year’s fixed overheads, and may be met through own funds, a qualifying insurance policy or a comparable guarantee. Portugal imposes no national capital overlay above the MiCA minimums. We confirm the class your model needs before you lock up capital.

Passporting, banking and scope
Can a Portuguese CASP passport to all EU member states?

Yes. MiCA Article 65 grants a Portuguese CASP the right to provide crypto-asset services across all 30 EEA member states through a single notification to the Banco de Portugal. Both cross-border service provision and branch establishment are covered, and no additional authorisation, capital or waiting period is required from host regulators. Iceland, Liechtenstein and Norway are inside the MiCA passport via EEA Joint Committee Decision No 41/2025. We file the passporting notification for the markets you intend to serve.

Will you arrange banking for the licensed CASP?

Yes. MiCA Article 70 requires client funds to be held with a licensed credit institution, not an EMI, in a segregated account by the end of the next business day. We arrange both layers: an operational account with a licensed EU electronic money institution, and a credit-institution relationship for client-fund safeguarding. We start during the application so banking is ready when your licence is granted.

Does the licence cover tokenised securities or RWA?

No. MiCA Article 2(4) excludes crypto-assets that qualify as financial instruments. A tokenised security, share, bond or fund unit is regulated under MiFID II, the Prospectus Regulation and the EU DLT Pilot Regime, supervised in Portugal by the CMVM rather than under MiCA. Where your model needs it, we scope the securities route and pair it with crypto permissions or EU fund licensing.

Get a Portugal crypto licence quote

We form your Portuguese company, build the compliance suite, file with the Banco de Portugal, obtain the CASP authorisation and arrange banking. We deal with the regulator directly and stand behind the outcome. Tell us what you are building and we will map your route to approval and quote it. If another jurisdiction we serve suits you better, we will tell you straight.

Banking & Payments

A company and a licence still need a bank account

Banking is one of our three core services. We help high-risk and regulated businesses open the bank and payment accounts that others refuse: we work directly with EU EMIs, payment institutions and crypto-aware banks, confirm appetite before you apply, and make the introduction. Take it with your company and licence, or on its own.

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Tomberg & Partners

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