🇪🇪 Estonia vs 🇫🇷 France: crypto licensing compared
Decision context and regulator route
Estonia's public MiCA CASP authorisation; implemented via the Crypto-Assets Market Act (Kruptovarade turu seadus, KrüTS), in force 1 July 2024. and France's public MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Estonia: verified 2026-08-15 · France: verified 2026-08-15
| Dimension |
🇪🇪 Estonia
partly open
Verified 2026-08-15
|
🇫🇷 France
partly open
Verified 2026-08-15
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|---|---|---|
| Licence type | MiCA CASP authorisation; implemented via the Crypto-Assets Market Act (Kruptovarade turu seadus, KrüTS), in force 1 July 2024. | MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. |
| Regulator | Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority) | AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team. |
| Capital requirement | Estonia capital requirement is included in the £349 pass. | France capital requirement is included in the £349 pass. |
| Timeline to authorisation | Estonia timeline to authorisation is included in the £349 pass. | France timeline to authorisation is included in the £349 pass. |
| Local substance | Estonia local substance is included in the £349 pass. | France local substance is included in the £349 pass. |
| Application cost | Estonia application cost is included in the £349 pass. | France application cost is included in the £349 pass. |
| Ongoing cost | Estonia ongoing cost is included in the £349 pass. | France ongoing cost is included in the £349 pass. |
| Passporting | Estonia passporting is included in the £349 pass. | France passporting is included in the £349 pass. |
| MiCA CASPs approved | Estonia mica casps approved is included in the £349 pass. | France mica casps approved is included in the £349 pass. |
| Key restrictions | Estonia key restrictions is included in the £349 pass. | France key restrictions is included in the £349 pass. |
| Recent changes | Estonia's VASP population collapsed from 641 valid licences (mid-2021 peak) to 36 remaining by early 2026; as of recent reporting only one entity (Lightspark Payments Europe AS) had received full MiCA CASP authorisation. From 18 March 2026, CASP applications must go through FI's new application portal. | France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026). |
| Difficulty rating | Estonia difficulty rating is included in the £349 pass. | France difficulty rating is included in the £349 pass. |
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What changed recently
🇪🇪 Estonia (verified 2026-07-15): Estonia's VASP population collapsed from 641 valid licences (mid-2021 peak) to 36 remaining by early 2026; as of recent reporting only one entity (Lightspark Payments Europe AS) had received full MiCA CASP authorisation. From 18 March 2026, CASP applications must go through FI's new application portal.
🇫🇷 France (verified 2026-08-15): France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026).
Quick answers
Who regulates crypto licensing in Estonia and France?
Estonia: Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority). France: AMF (Autorite des marches financiers) grants and supervises the CASP authorisation; ACPR (Banque de France) gives binding assent on AML/CFT and prudential aspects via a joint examination team..
What licence do you need in Estonia compared with France?
In Estonia the authorisation route is MiCA CASP authorisation; implemented via the Crypto-Assets Market Act (Kruptovarade turu seadus, KrüTS), in force 1 July 2024.; in France it is MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Estonia vs France comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/estonia-vs-france.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.