Crypto Assets, Blockchain & Fintech

Being one of the first countries to have its regulatory framework for Virtual Financial Assets, Cryptocurrency and Blockchain technology in 2018, Malta is considered to be at the forefront of embracing this revolutionary innovation. CSB Group can provide you with regulatory advisory services, assistance with licence applications and setting up a Fintech operation in Malta.

Fintech – Malta’s Beating Heart

Malta has long positioned itself as a dynamic hub for financial innovation, and today, it stands at the forefront of the fintech revolution. With its robust regulatory framework, forward-thinking approach, and EU-compliant structures, Malta offers a fertile ground for crypto, blockchain, and digital finance ventures. As the EU rolls out the Markets in Crypto-Assets Regulation (MiCA), Malta is uniquely equipped to bridge innovation with compliance — providing clarity, legal certainty, and a launchpad for cross-border operations.

Our firm is proud to operate in the heart of this vibrant ecosystem, offering tailored legal and regulatory support to fintech pioneers. Whether you are launching a crypto project, structuring a token offering, or seeking licensing under MiCA, we guide you through each step with deep expertise, strategic insight, and a commitment to unlocking your growth potential in Europe’s evolving digital finance landscape.

MiCA (Markets in Crypto-Assets (‘MiCA’) Regulation) 

Following its publication in the Official Journal of the European Union on 31 May 2023, the MiCA Regulation entered into force in two stages in 2024 – the requirements applicable to issuers of e-money tokens (EMTs) and asset-referenced tokens (ARTs) applied from 30 June 2024, while the requirements regulating crypto-asset services and other crypto-assets applied from 30 December 2024.

MiCA now constitutes the primary regulatory framework governing crypto-assets and crypto-asset service providers across the EU, including Malta.

Crypto-asset service providers (CASPs) choosing Malta as their jurisdiction will benefit from Malta’s regulatory experience, as the VFA framework was broadly aligned with MiCA principles, facilitating a structured transition rather than direct equivalence.

The Malta Financial Services Authority (MFSA) is the national competent authority in Malta for MiCA authorisations and supervision. Under MiCA, CASPs must obtain authorisation directly under the Regulation, and once authorised, benefit from EU passporting rights across the EEA.

National Implementation and Transition

In preparation for MiCA, Malta enacted the Markets in Crypto-Assets Act, 2024 (Chapter 647, Laws of Malta), which supplements MiCA by establishing national procedures, supervisory powers, fees, penalties, and transitional arrangements.

Recent amendments to Malta’s Virtual Financial Assets (VFA) Act, ratified through the Virtual Financial Assets (Amendment) Act, 2024, came into force on 30 June 2024 to facilitate the transition to MiCA. The VFA Act is now operating on a transitional basis and will be phased out once all VFA Service Providers have migrated to MiCA authorisation, expected by mid-2026.

Asset-Referenced Tokens (ARTs) under MiCA

Asset-Referenced Tokens (ARTs) are a category of crypto-assets defined under the MiCA Regulation as tokens that aim to maintain stable value by referencing multiple assets, such as fiat currencies, commodities, or other crypto-assets. Unlike e-money tokens, ARTs are not limited to referencing a single fiat currency. Issuers of ARTs are subject to strict regulatory requirements, including authorisation from a competent authority, publication of a whitepaper, and robust governance and reserve management obligations. These measures aim to ensure financial stability, consumer protection, and market integrity across the EU.

Electronic Money Tokens (EMTs) under MiCA

E-Money Tokens (EMTs) are crypto-assets that aim to maintain a stable value by being pegged to a single official currency (e.g. EUR, USD). Under the MiCA Regulation, EMTs are treated similarly to traditional e-money and can only be issued by credit institutions or electronic money institutions. EMT issuers are required to ensure full redeemability at par value and maintain adequate reserve assets. The regulation enforces strong consumer protection, anti-money laundering compliance, and supervision mechanisms to ensure stability and trust in digital financial services.

Other Crypto Assets (OCAs) under MiCA

Other Crypto-Assets (OCAs) refer to all crypto-assets that do not qualify as Asset-Referenced Tokens (ARTs) or E-Money Tokens (EMTs). This broad category includes utility tokens and most digital assets used for access to services, digital platforms, or specific blockchain-based applications. Under MiCA, issuers of OCAs must publish a whitepaper that is notified (but not approved) by the relevant competent authority, ensuring transparency and informed decision-making for potential users. While OCAs are subject to lighter requirements than ARTs and EMTs, they are still bound by rules on market abuse, consumer protection, and fair disclosure.

Crypto Asset Service Providers (CASPs)

Under the MiCA Regulation, Crypto-Asset Service Providers (CASPs) are legal persons or undertakings that provide professional services related to crypto-assets on behalf of clients. These services include, but are not limited to: custody and administration of crypto-assets, operation of trading platforms, exchange of crypto-assets for funds or other crypto-assets, execution of orders, placing of crypto-assets, and providing advice on crypto-assets.

CASPs must obtain prior authorisation from the competent authority in their Member State and comply with stringent organisational, prudential, and conduct requirements. Once authorised, CASPs benefit from an EU passport, allowing them to operate across all EU Member States under a single licence.

Preparation for current VFA Service Providers authorised by the MFSA

With MiCA set to fully apply across the EU, VFA Service Providers currently licensed by the MFSA must begin preparing for transition. Entities authorised before 30 December 2024 will benefit from an 18-month transitional period, expected to last until mid-2026. To take advantage of this, providers will need to formally notify the MFSA of their intention to continue operating under MiCA — a process likely to begin in Q3 2024.

During this period, VFA Service Providers must carry out a detailed gap analysis to align their existing operations with MiCA requirements. This includes updating internal governance structures, enhancing AML/CFT procedures, and ensuring all fit-and-proper requirements for key personnel are met. Additional focus should be placed on meeting MiCA’s prudential safeguards, which may include capital requirements ranging from €50,000 to €150,000 depending on the services offered.

Updated documentation will also be essential. Service providers will need to prepare a full CASP application in line with MiCA Annex I, along with revised internal policies, risk frameworks, and client disclosures. Customer-facing materials, such as terms of service and risk warnings, must also be reviewed to comply with MiCA’s enhanced transparency obligations.

The MFSA may request further information or conduct supervisory reviews during the transition. Engaging proactively with the regulator and preparing thoroughly will be key to maintaining continuity of service across the EU’s regulated crypto market.

Annual Fees and Ongoing Regulatory Obligations

Entities operating under the MiCA framework — whether issuing Asset-Referenced Tokens (ARTs), E-Money Tokens (EMTs), Other Crypto-Assets (OCAs), or providing services as Crypto-Asset Service Providers (CASPs) — are subject to ongoing supervisory fees, reporting duties, and transparency requirements. While specific figures vary based on the nature and scale of activity, the regulatory burden reflects the EU’s commitment to safeguarding financial stability and consumer protection.

Annual supervisory fees typically range from €5,000 to €50,000, with ART and EMT issuers facing the higher end of the spectrum due to heightened systemic risks and reserve requirements. CASPs can expect fees generally within the €10,000–€25,000 range, depending on the services offered and volume of operations. Issuers of OCAs — such as utility tokens — will likely be subject to lower fees, starting around €3,000–€7,000.

In addition to fees, all entities must maintain ongoing compliance obligations, including submission of regular financial and operational reports, maintaining internal control frameworks, and ensuring real-time or near real-time disclosures for certain market activities. Governance, risk management, and AML/CFT structures must remain continuously effective and aligned with MiCA’s evolving guidance.

MiCA also imposes robust transparency standards. This includes the publication and ongoing updating of whitepapers, disclosure of material events or changes, and periodic attestations of reserve backing for stablecoins (in the case of ARTs and EMTs).

White Paper Requirements under MiCA

Under the MiCA Regulation, the white paper is a foundational disclosure document that ensures transparency and protects users engaging with crypto-assets. Its primary purpose is to provide potential acquirers with clear, accurate, and non-misleading information about the nature, functionality, risks, and rights associated with a crypto-asset offering.

The content of a MiCA-compliant white paper must include detailed information on the issuer, the crypto-asset’s technical features, its intended use, associated risks, governance mechanisms, and any rights attached to the asset. It must also describe the offering’s timeline, distribution model, and the technologies involved. For ARTs and EMTs, additional details regarding reserve assets, stabilisation mechanisms, and redemption rights are required.

As for the scope, white papers are mandatory for the issuance and offering to the public of most crypto-assets within the EU, unless a specific exemption applies (e.g. offerings to fewer than 150 persons per Member State or a total consideration under €1 million over 12 months).

In terms of procedure, white papers for OCAs and utility tokens are subject to a notification regime — meaning they must be submitted to the national competent authority (NCA) before publication, without requiring formal approval. Conversely, white papers for ARTs and EMTs must be approved by the relevant NCA prior to their release. Once published, the white paper must be made freely accessible to the public and kept up to date, especially in the event of significant changes.

White paper obligations under MiCA reflect a regulatory shift toward increased market discipline, ensuring that crypto projects are held to the same standards of clarity and accountability as traditional financial instruments.

How Can CSB Group Support Your Crypto Asset Licensing under MiCA

With over 35 years of experience in Malta’s corporate and financial services sector, CSB Group is well-positioned to guide clients through the complexities of crypto-asset licensing under the MiCA Regulation. Whether you are an existing VFA Service Provider preparing for transition or a new market entrant seeking authorisation, our multidisciplinary team provides end-to-end support tailored to your business model.

We assist with the full MiCA application process — from strategic advisory and regulatory gap analysis to the drafting of whitepapers, internal policies, risk frameworks, and governance structures. For issuers of ARTs, EMTs, and OCAs, we ensure that all MiCA documentation is prepared in accordance with EU standards and, where applicable, reviewed and approved by the MFSA. For CASPs, we guide you through licensing requirements, prudential obligations, and operational readiness, ensuring your compliance framework is audit-ready and future-proof.

Beyond licensing, CSB Group also offers ongoing compliance support, including AML/CFT integration, internal audits, and regulatory reporting, ensuring that your operations remain aligned with MiCA’s evolving obligations.

Whether you're looking to launch a new crypto venture or scale your licensed operations across the EU, CSB Group delivers the regulatory expertise and local insight to help you succeed under MiCA.