🇪🇪 Estonia vs 🇫🇷 France: crypto licensing compared
On paper, Estonia's MiCA CASP authorisation; implemented via the Crypto-Assets Market Act (Kruptovarade turu seadus, KrüTS), in force 1 July 2024. and France's MiCA CASP authorisation (French 'agrement PSCA'); replaces the legacy PSAN regime (mandatory AML registration + optional licence). A single authorisation covers the 10 MiCA services. answer the same question; in practice the detail decides it. The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. This page compares the two side by side: the identity columns are free, the decision figures are one pass away, and every cell shows when it was last checked.
Estonia: verified 2026-07-02 · France: verified 2026-07-03
| Dimension |
🇪🇪 Estonia
partly open
Verified 2026-07-02
|
🇫🇷 France
partly open
Verified 2026-07-03
|
|---|---|---|
| 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 locked. Unlock with the £349 pass. | France capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Estonia timeline to authorisation is locked. Unlock with the £349 pass. | France timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Estonia local substance is locked. Unlock with the £349 pass. | France local substance is locked. Unlock with the £349 pass. |
| Application cost | Estonia application cost is locked. Unlock with the £349 pass. | France application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Estonia ongoing cost is locked. Unlock with the £349 pass. | France ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Estonia passporting is locked. Unlock with the £349 pass. | France passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Estonia mica casps approved is locked. Unlock with the £349 pass. | France mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Estonia key restrictions is locked. Unlock with the £349 pass. | France key restrictions is locked. Unlock with 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 locked. Unlock with the £349 pass. | France difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 6 of 9 tracked decision dimensions, including timeline to authorisation and local substance. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇪🇪 Estonia (verified 2026-07-02): 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 2026-07-01): 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.