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Crypto Market Oversight in Estonia Passes to the Financial Supervision Authority

A new market act moves oversight of virtual currency businesses to another regulator: pending applications, key deadlines and what license holders should do now.

The Financial Supervision Authority of Estonia (Finantsinspektsioon, FSA) is taking over supervision of the crypto industry, and in particular of crypto-asset service providers (CASP), from the Financial Intelligence Unit (FIU). The transfer is based on the Market in Crypto-Assets Act (Krüptovaraturu seadus), the national law in force since 1 July 2024 that puts the EU Markets in Crypto-Assets Regulation (MiCA) into effect in Estonia and is aimed at strengthening financial supervision of the sector. From now on, obtaining a crypto license in Estonia means applying directly to the Financial Supervision Authority.

Eesti Firma provides consulting and accounting services for crypto companies, including assistance with preparing a CASP license application and adapting to the new requirements.

What Is Changing: From the FIU to the Financial Supervision Authority

The Financial Intelligence Unit ceases issuing licenses for the provision of virtual currency services. Instead, the Financial Supervision Authority begins authorising crypto-asset service providers under MiCA. The transfer of powers is carried out in accordance with the Market in Crypto-Assets Act, which sets out the new requirements and the CASP authorisation procedure. Under its transitional provisions, anyone wishing to provide crypto-asset services is governed by the Act from 30 December 2024, while existing virtual currency service providers are given until the end of the transition period to bring their activities into line with it.

In practice the move from VASP to CASP means a different regulator, a different legal basis and a different type of permit. The FIU license is a national, AML-based permit valid only in Estonia; the FSA authorisation is a MiCA license recognised throughout the EU. An existing license is not converted into a CASP authorisation automatically: every provider that wishes to continue must apply to the FSA.

Transition Period for Crypto Licenses in Estonia: Key Dates

Service providers will be fully subject to the supervision of the Financial Supervision Authority from 1 July 2026, when licenses issued by the Financial Intelligence Unit expire. Until that date, supervision of existing license holders continues to be exercised by the FIU.

Date What happens
1 July 2024 The Market in Crypto-Assets Act enters into force and designates the Financial Supervision Authority as the competent authority for crypto-asset service providers in Estonia.
30 December 2024 MiCA rules for crypto-asset service providers start to apply. The FIU stops issuing new licenses; applications for a crypto license are filed with the Financial Supervision Authority.
30 December 2024 – 1 July 2026 Transition period. Existing licenses remain valid, their holders stay under FIU supervision, and amendments to current licenses are still accepted.
1 July 2026 FIU licenses expire. Only companies authorised by the Financial Supervision Authority may continue providing crypto-asset services in Estonia.

Virtual asset service providers (VASP) holding valid licenses can therefore continue their activities until 1 July 2026 or until they receive a CASP authorisation from Finantsinspektsioon, whichever comes first. New applications for a crypto license in Estonia are now submitted to the FSA.

Pending License Applications at the Financial Intelligence Unit

Applications submitted to the Financial Intelligence Unit before 30 December 2024 that are not processed by that date will be left unconsidered, and the documents will be returned to the applicants. The FIU will, however, continue to accept applications for amendments to existing licenses until 1 July 2026.

As of 5 December 2024, 43 FIU-issued licenses for providing virtual asset services in Estonia remain valid, down from 54 at the start of the year and from more than 600 when the clean-up of the sector began in 2021. Each of these companies will have to decide whether to seek a CASP authorisation from the FSA before the transition period ends.

AML and Sanctions Obligations Remain in Place

These changes follow Regulation (EU) 2023/1114 of the European Parliament and of the Council (MiCA), which brings the sector under financial supervision. Crypto-asset service providers remain obliged entities under the Money Laundering and Terrorist Financing Prevention Act and are also subject to special obligations under the International Sanctions Act. The duty to report suspicious transactions to the Financial Intelligence Unit therefore continues, and the unit keeps its control function in these areas regardless of which authority issued the license.

Supervision by the FSA adds a prudential layer on top of AML compliance: governance, own funds, safeguarding of client crypto-assets and operational resilience are assessed at the authorisation stage and monitored on an ongoing basis. The bar for crypto regulation in Estonia is therefore rising, and the earlier a company starts preparing its MiCA authorisation, the smoother the transition will be.

What a licensed provider should do now

Do not treat 1 July 2026 as a distant deadline: authorisation by the FSA is not granted overnight, and a company without it on that date will have to stop providing services. A sensible first step is to map your activity to the MiCA service categories and bring your AML/CFT policies in line with the expectations of the new supervisor.

Need Assistance?

Contact us to discuss how we can help your business successfully adapt to the new requirements. We offer professional support, tailored solutions and guidance at every stage of the VASP-to-CASP transition, from the first assessment to the MiCA authorisation itself.

Leave a request on our website, and our specialists will contact you to prepare your company for the new supervisory regime and keep providing crypto-asset services in Estonia without interruption once the transition period ends.

FAQ

This guide was prepared by the Eesti Firma team, including Lawyer & Partnerships Lead Dmitry Malyshev, and is intended solely for informational purposes. None of the provided content constitutes legal, tax, or investment advice. While every effort has been made to ensure accuracy at the time of publication, laws and regulations may change. For personalized legal assistance, please contact Eesti Firma directly.