#
The Czech Republic implements MiCA (Regulation (EU) 2023/1114) via national Act No. 31/2025 Sb. (zákon o digitalizaci finančního trhu). The Czech National Bank (CNB) is the sole national competent authority (NCA) covering all MiCA Titles, and has been actively authorising domestic crypto-asset service providers (CASPs) since early 2026, following the end of the Article 143 grandfathering/transitional period on 1 July 2026.
The transitional mechanics governing the shift from pre-MiCA to MiCA-based authorisation have now fully played out. Entities holding a pre-MiCA Czech crypto trade licence that applied for CASP authorisation by 31 July 2025 were permitted to continue operating under their old authorisation only until the earlier of their CASP decision or 1 July 2026. That window closed on 1 July 2026, and as of that date, providers without Czech National Bank authorisation, or authorisation from another EU competent authority under MiCA's passporting mechanism, may no longer provide crypto-asset services in the Czech Republic and must cease onboarding new clients.
The Czech National Bank received the highest volume of MiCA authorisation applications of any EU competent authority, more than 248 applications, and has to date granted authorisation to 11 crypto-asset service providers. The scale mismatch between application volume and authorisation grants indicates a rigorous authorisation bar rather than a formality-driven licensing process.
Outlook
The immediate question following the transitional period's close is what happens to the large population of applicants that did not secure Czech authorisation: exit from the Czech and EU market, redirection of the application to a different EU competent authority, or unlawful continued operation are the plausible pathways, though this cycle's evidence base does not establish which pathway predominates. The 11-provider authorised cohort now represents the steady-state population against which future supervisory activity and market development in the Czech crypto-asset sector should be measured.
Crypto Licensing
The Czech National Bank operates the national authorisation regime for crypto-asset service providers under Regulation (EU) 2023/1114 (MiCA), as implemented via Act No. 31/2025 Coll. By 1 July 2026, the CNB had assessed 251 applications and notifications relating to the provision of crypto-asset services and had granted authorisation to 11 entities. This milestone coincides with the close of a transitional regime under Section 26 of Act No. 31/2025 Coll.: incumbent providers that filed a complete CASP application with the CNB by 31 July 2025 were permitted to continue operating under their legacy trade licence during the grandfathering window, which ended on 1 July 2026. From that date, provision of MiCA-scoped crypto-asset services under a legacy trade licence is no longer available; providers must hold CNB authorisation under the Regulation.
The prudential dimension of the licensing regime is set directly by MiCA itself rather than by Czech-specific rulemaking: Article 67 and Annex IV of the Regulation establish minimum own-funds requirements of EUR 50,000, 125,000 or 150,000 depending on the class of service an entity provides, and these thresholds apply to CNB-authorised entities without need for domestic transposition. The CNB's own public communications confirm the authorisation of 11 entities as of the deadline, and the same communications confirm that CNB-authorised CASPs may provide services across the EU single market via notification, meaning the Czech authorisation functions as an entry point to a passported, EU-wide service offering rather than a Czech-only permission.
The ratio of 11 authorisations against 251 applications and notifications assessed indicates a regime that has processed a substantial volume of incumbent-market activity but has, to this point, authorised only a small proportion of it, with the remainder presumably still in train, withdrawn, or redirected to a different regulatory treatment. The precise disposition of the unauthorised balance of the 251 was not evidenced this cycle.
Outlook
With the transitional grandfathering window closed as of 1 July 2026, the central question for the licensing regime going forward is the pace at which the CNB authorises or otherwise resolves the remaining applications beyond the 11 already granted. Any further authorisation grants, refusals, or withdrawal of legacy trade-licence operation by providers that did not secure timely authorisation would be the next material development in this module.
1 earlier distinct update(s)
Crypto Licensing
The Czech National Bank has held competent-authority status under the Markets in Crypto-Assets Regulation, MiCA, Regulation (EU) 2023/1114, since 15 February 2025, and crypto-asset service providers, CASPs, must hold ČNB authorisation to lawfully provide crypto-asset services in Czechia. This cycle's material development is the closure of the transitional bridge between the pre-MiCA and MiCA regimes: CNB issued its first six MiCA CASP authorisations on 11 February 2026, and by mid-2026 had licensed eleven entities out of 248 applications received, the highest application volume reported for any EU competent authority. The transitional regime that had permitted operators holding a pre-existing Czech trade licence to continue operating pending a MiCA decision formally ended on 1 July 2026, meaning entities not authorised by that date may no longer lawfully offer crypto-asset services.
The scale of the application backlog relative to the authorisation count is the module's central analytical fact. CNB publicly stated that a significant share of the 248 applications were wholly insufficient or lacked a verifiable track record, a disclosure that directly informs this module's amber traffic-light rationale: the underlying licensing framework is settled and fully in force, but the transitional period has just closed while a substantial portion of the applicant pool remains either unauthorised or was found deficient. This creates a population of entities whose lawful operating status as of 1 July 2026 is genuinely unclear from public reporting, since an application still pending review does not confer authorisation, and the trade-licence fallback that previously covered such gaps no longer applies.
CNB accompanied its authorisation announcements with a consumer-facing caution that granting a MiCA authorisation does not mean the central bank considers a specific crypto-asset investment safe, nor does it constitute a product recommendation. That disclosure is a recurring feature of CNB's public communications around this licensing wave rather than a one-off statement, and it signals CNB is deliberately separating regulatory authorisation from any implied endorsement of investment merit as the authorised population grows.
All of the claims underpinning this module trace to CNB's own Tier-1 press releases, giving this module a strong primary-source anchor despite the underlying uncertainty about the unauthorised-applicant population's eventual treatment. No CZ-specific ČNB interpretive guidance narrowing MiCA's own asset-referenced-token, e-money-token, or utility-token taxonomy was located this cycle, and no CZ-specific staking or DeFi guidance under MiCA's on-chain-activity scope was found either; both are noted as open gaps rather than settled absences.
Outlook
The near-term marker to watch is CNB's handling of the unresolved portion of the 248-application pool: whether further authorisations are granted, applications are formally refused, or enforcement action is taken against entities continuing to offer services without MiCA authorisation after 1 July 2026. Any of those three outcomes would materially sharpen the currently amber assessment. A secondary marker is whether CNB or another Czech authority issues interpretive guidance on the token-classification taxonomy or on-chain-activity treatment, neither of which has surfaced at the national level to date, leaving Czech CASPs and their counterparties to rely on the general MiCA text alone.
1 further periodic run re-emitted the standing brief unchanged and is not shown.
Sources and findings (4)
- T1 · ESMAESMA — Providing crypto-asset services in the Czech Republic requires authorisation as a crypto-asset service provider (CASP) from the Czech National Bank (CNB), which is designated as the national competent authority for ALL Titles of Regulation (EU) 2023/1114 (MiCA).retrieved M5bindingin force
- T1 · ESMAESMA — Entities lawfully providing crypto-asset services under pre-MiCA Czech national law before 30 December 2024 could continue operating under a grandfathering regime until 1 July 2026 or until granted/refused MiCA authorisation, whichever came first.retrieved M4bindingin force
- T1 · ESMAESMA — CNB has granted MiCA CASP authorisation to multiple Czech-domiciled entities during the first half of 2026, including MP Developers s.r.o. (Anycoin), ILAVO GROUP a.s., Pluso a.s., and COINMATE a.s.retrieved M3non-binding
- T1 · Sbírka zákonů ČR / EUR-LexSbírka zákonů ČR / EUR-Lex — Act No. 31/2025 Sb., on the implementation of European Union regulations in the area of digitalisation of the financial market, published in the Czech Collection of Laws on 14 February 2025, is the national instrument transposing MiCA-related implementing/supervisory provisions for the Czech Republic.retrieved M4bindingin forceour coverage gap, expected to resolve on a re-run