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| Dimension |
Pinned 🇮🇹 Italy partly open Verified 2026-08-15
|
🇵🇹 Portugal
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | MiCA CASP authorisation under EU Regulation 2023/1114, transposed via Legislative Decree 129/2025 and implemented through Consob Resolution 23700/2025. Pre-MiCA VASPs (registered under the OAM register per AML Decree 90/2017) had to convert to full CASP authorisation; transitional regime for existing VASPs was extended to 1 July 2026. | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. |
| Regulator | Split regulator model: Consob (Commissione Nazionale per le Società e la Borsa) is the lead competent authority issuing CASP authorisation and supervising conduct-of-business/market integrity; Banca d'Italia is consulted on and supervises prudential aspects (capital, governance, AML) and directly handles credit institutions/e-money institutions offering crypto services (e.g. Banca Sella's notification route). | 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 | Italy capital requirement is included in the £349 pass. | Portugal capital requirement is included in the £349 pass. |
| Timeline to authorisation | Italy timeline to authorisation is included in the £349 pass. | Portugal timeline to authorisation is included in the £349 pass. |
| Local substance | Italy local substance is included in the £349 pass. | Portugal local substance is included in the £349 pass. |
| Application cost | Italy application cost is included in the £349 pass. | Portugal application cost is included in the £349 pass. |
| Ongoing cost | Italy ongoing cost is included in the £349 pass. | Portugal ongoing cost is included in the £349 pass. |
| Passporting | Italy passporting is included in the £349 pass. | Portugal passporting is included in the £349 pass. |
| MiCA CASPs approved | Italy mica casps approved is included in the £349 pass. | Portugal mica casps approved is included in the £349 pass. |
| Key restrictions | Italy key restrictions is included in the £349 pass. | Portugal key restrictions is included in the £349 pass. |
| Recent changes | Consob Resolution 23700/2025 (introducing the EUR 20,000 fee) took effect 1 December 2025; the transitional regime for pre-MiCA VASPs was extended to 1 July 2026 (later than the original MiCA default cut-off), giving Italian firms extra runway. As of 1 July 2026, 8 firms hold full CASP authorisation, a sharp jump from near-zero conversions reported earlier in 2026, though still a small fraction of the pre-MiCA registered population. | 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 | Italy difficulty rating is included in the £349 pass. | Portugal difficulty rating is included in the £349 pass. |
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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