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🇪🇪 Estonia partly open
Verified 2026-08-15
🇵🇹 Portugal partly open
Verified 2026-08-15
Licence type MiCA CASP authorisation; implemented via the Crypto-Assets Market Act (Kruptovarade turu seadus, KrüTS), in force 1 July 2024. MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration.
Verified 2026-08-15 Source: Lei n.o 69/2025 - Diario da Republica: https://diariodarepublica.pt/dr/detalhe/lei/69-2025-992098939
Regulator Finantsinspektsioon (Estonian Financial Supervision and Resolution Authority)
Verified 2026-08-15 Source: Finantsinspektsioon: https://www.fi.ee
Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.)
Capital requirement Estonia capital requirement is included in the £349 pass. Portugal capital requirement is included in the £349 pass.
Timeline to authorisation Estonia timeline to authorisation is included in the £349 pass. Portugal timeline to authorisation is included in the £349 pass.
Local substance Estonia local substance is included in the £349 pass. Portugal local substance is included in the £349 pass.
Application cost Estonia application cost is included in the £349 pass. Portugal application cost is included in the £349 pass.
Ongoing cost Estonia ongoing cost is included in the £349 pass. Portugal ongoing cost is included in the £349 pass.
Passporting Estonia passporting is included in the £349 pass. Portugal passporting is included in the £349 pass.
MiCA CASPs approved Estonia mica casps approved is included in the £349 pass. Portugal mica casps approved is included in the £349 pass.
Key restrictions Estonia key restrictions is included in the £349 pass. Portugal 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. Lei 69/2025 (MiCA) and Lei 70/2025 (Travel Rule) published 22 Dec 2025, about a year late. The legacy-VASP transitional window closed 1 Jul 2026. Bison Bank became Portugal's first MiCA-authorised CASP in late Jun 2026, following approval from Banco de Portugal and the CMVM.
Difficulty rating Estonia difficulty rating is included in the £349 pass. Portugal difficulty rating is included in the £349 pass.

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Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.

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