Malta
Overview
Malta was among the first EU states with a bespoke regime — the Virtual Financial Assets (VFA) Act of 2018 — supervised by the Malta Financial Services Authority (MFSA). MiCA now supplies the CASP authorisation regime, and existing VFA licence holders transition into it.
Malta publishes an unusually explicit fee schedule for CASPs: application and annual charges are set by class, with a per-service add-on and a turnover-linked supervisory component. That makes it one of the few EU home states where a licence budget can be built from an official instrument rather than a consultant range.
Regulatory framework
MiCA (Regulation (EU) 2023/1114) is directly applicable, supported by the Maltese Markets in Crypto-Assets Act and the Fees Regulations (SL 647.01). The MFSA authorises and supervises CASPs; the VFA Act is legacy. Financial instruments remain in the MiFID II perimeter.
Third-country firms can use the MiCA Article 60 route only for services at the client's own initiative; reverse solicitation is narrow. A Maltese authorisation passports across the EEA after the Article 62 notification.
Licensing & authorisation
Route and clock. Apply to the MFSA (MiCA Arts 62–63). The authority acknowledges within 5 working days, assesses completeness within 25 working days and decides within 40 working days of a complete file; the clock stops for information requests. Plan for completeness rounds; the statutory clock is not an end-to-end promise.
Charges. The application fee is €10,000 (Class 1), €20,000 (Class 2) or €25,000 (Class 3); only the highest class is charged. The annual supervisory fee is €10,000 / €25,000 / €50,000 by class, plus €2,000 per authorised service and 0.05% of transaction volume, capped at €250,000. Source: SL 647.01.
Own funds. MiCA Art 67 and Annex IV set the minimum at €50,000 (Class 1), €125,000 (Class 2) or €150,000 (Class 3), plus one quarter of the previous year's fixed overheads, held continuously. The class follows the services authorised.
Substance and passport. MiCA Art 59 requires the registered office and head office in Malta. Plan for a Maltese entity, local-resident management, a local AML officer and outsourcing/ICT arrangements that meet MFSA and DORA expectations. Once authorised, notify under Art 62 to passport into the EEA.
AML & Travel Rule
The EU Transfer of Funds Regulation (TFR, (EU) 2023/1113) has applied since 30 December 2024. CASP-to-CASP transfers must carry originator and beneficiary information from the first euro; transfers to or from self-hosted wallets above €1,000 require verification of the counterparty.
The MFSA supervises AML/CFT; the Financial Intelligence Analysis Unit (FIAU) receives suspicious transaction reports. DORA has applied since 17 January 2025, and the EU AML Regulation (AMLR) applies from 10 July 2027.
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