The Markets in Crypto-Assets Regulation (MiCA) introduces a unified regulatory framework for crypto-assets across the European Union (EU), promoting legal certainty, investor protection, and market stability. One of the core requirements under MiCA is obtaining a Crypto-Asset Service Provider (CASP) license, mandatory for businesses offering crypto asset services.
This licensing ensures compliance with strict standards on governance, security, and anti-money laundering (AML), enabling licensed CASPs to operate seamlessly across all EU member states. Whether you are an emerging startup or an established operator, obtaining a CASP license is essential to access the EU’s vast and dynamic market for digital assets.
In Hungary, the National Bank of Hungary (Magyar Nemzeti Bank / MNB) is the competent authority overseeing CASP licensing under MiCA. Businesses operating or planning to provide crypto-asset services in Hungary must adhere to local implementation requirements alongside MiCA’s EU-wide provisions.
Our firm has a thorough knowledge of Hungarian law, ensuring that your compliance efforts are efficient and effective.
We can help your business meet compliance requirements and unlock the potential of the EU crypto market!
In Hungary, the National Bank of Hungary (MNB) is the competent authority overseeing CASP licensing under MiCA
Key Numbers about a CASP License in Hungary
3 mountsaverage term of obtaining CASP license after application submission |
at least severaldirectors in a CASP |
up to €150kamount of the share capital depending from CASP activity |
15%personal income tax (PIT) rate |
9%corporate income tax (CIT) rate |
15%capital gains tax (CGT) rate |
Legal Opinion about a CASP License in Hungary
Ganna Voievodina
Manimama
|
CEO
“Obtaining a CASP license in Hungary is essential for businesses offering crypto-asset services. Applicants must meet requirements, including robust AML/CFT compliance, a formal governance structure, and sufficient operational capital. Once licensed, CASPs must adhere to ongoing reporting obligations and maintain compliance with Hungarian and EU regulations. A CASP license enhances credibility and provides access to the EU market under a clear regulatory framework”.
Types of Activities with a CASP License in Hungary
Providing custody and administration of crypto-assets on behalf of clients
This service means safekeeping or controlling, on behalf of third parties, crypto-assets or the means of access to such crypto-assets, where applicable in the form of private cryptographic keys. Holdings of crypto-assets on behalf of the clients shall be segregated from CASP’s holdings.
Operation of a trading platform for crypto-assets
This service contains of the management of one or more multilateral systems, which brings together or facilitates the bringing together of multiple third-party buying and selling interests for crypto-assets – in the system and in accordance with its rules – in a way that results in a contract, either by exchanging one crypto-asset for another, or a crypto-asset for funds.
Exchange of crypto-assets for funds
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for funds by using proprietary capital.
Exchange of crypto-assets for other crypto-assets
This service means the conclusion of purchase or sale contracts concerning crypto-assets with clients for other crypto-assets by using proprietary capital.
Execution of orders for crypto-assets on behalf of clients
This service means concluding agreements to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets on behalf of third parties and includes the conclusion of agreements to sell crypto-assets at the moment of their issuance.
Placing of crypto-assets
This service includes the marketing, on behalf of or for the account of the offeror or of a party related to the offeror, of crypto-assets to purchasers. Before placing the crypto-assets a CASP shall obtain the agreement of the issuers or any third party acting on their behalf.
Reception and transmission of orders for crypto-assets on behalf of clients
This service means the reception from a person of an order to buy or to sell one or more crypto-assets or to subscribe for one or more crypto-assets and the transmission of that order to a third party for execution.
Providing advice on crypto-assets
This service means offering, giving or agreeing to give personalized recommendations to a third party, either at the third party’s request or on the initiative of the a CASP providing the advice, in respect of one or more transactions relating to crypto-assets, or the use of crypto-asset services.
Providing portfolio management on crypto-assets
This service includes managing portfolios in accordance with mandates given by clients on a discretionary client-by-client basis where such portfolios include one or more crypto-assets.
Providing transfer services for crypto-assets on behalf of clients
This service means transfer, on behalf of a natural or legal person, crypto-assets from one distributed ledger address or account to another. Such service may be provided without virtual currency wallet opened for a CASP’s client.
Benefits of Obtaining a CASP License in Hungary
Government support for digital transformation:
- Hungary is actively promoting digital transformation, particularly in sectors like finance and technology, with incentives for businesses to adopt innovative digital solutions.
- A CASP license in Hungary positions companies to benefit from these initiatives and participate in the country’s digitalization efforts.
Access to the Hungarian crypto market:
- With a CASP license, businesses can offer their services in Hungary, tapping into a growing market of crypto users and investors.
- Hungary has seen an increase in crypto adoption, providing a developing base of local consumers who are familiar with blockchain and digital assets.
Tax benefits for crypto companies:
- Hungary offers favorable tax rates for crypto businesses, including a competitive corporate tax rate of 9%, one of the lowest in the EU.
- Additionally, there are tax incentives and credits for businesses investing in innovation and blockchain technology, making Hungary an attractive location for crypto ventures.
Attracting high-quality talent:
- Hungary has a highly educated workforce, particularly in fields such as technology, finance, and law. A CASP license helps attract top talent in blockchain, cryptocurrency, and regulatory compliance.
- Companies can leverage this local expertise to build a strong, knowledgeable team that can drive growth and innovation in the crypto sector.
EU-wide passporting under MiCA:
- CASPs are able to offer services across the EU without additional licensing.
- This enables companies to expand into 27 EU countries seamlessly.
Opportunities for blockchain innovation:
- Hungary has a growing ecosystem for blockchain innovation, with government support for projects related to DLT.
- A CASP license opens opportunities for collaboration with other tech and blockchain companies within Hungary, fostering a dynamic environment for innovation.
Our Services
STEP 1
- Company formation in Hungary
- Provision of a registered address for 1 year
- Opening corporate bank account and transferring the share capital
- Appointment and employment of a local director
- Detailed company structure documentation
STEP 2
Pre-licensing stage
- Preparation and submission legal and financial documents (non-exhaustive list) according to MiCA
- Review of existing policies and procedures, if the company already has them
STEP 3
Licensing stage
- CASP license application assistance
- Conducting communication with the MNB during the license process
Our Experts in this Area
Step by Step Description
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Initial setup
- Initiating a preliminary project assessment
- Creating an action plan
- Preparation and filing of the package of documents
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Company registration
- Verification and reservation of the company name at the Hungarian Trade Registry
- Facilitating the notarial process for the company's official registration
- Opening a bank account and depositing the share capital
- Incorporating the company's data into the Hungarian Court of Registration (Cégbíróság)
- Obtaining the Certificate of incorporation, Memorandum and Articles of Association
- Registration for tax purposes
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Obtaining a CASP license
- Preparation of documents according to MICA
- Submission an application to the licensing authority - MNB
- Reviewing the application to ensure it is complete (if any documents or information are missing, the applicant will be notified and given a specific deadline to provide the necessary additional documentation)
- Assessment of the documents` content submitted (a detailed review to verify that all regulatory requirements are met)
- Requesting of additional details (if applicable)
- Notification of grant or refusal of the CASP license
- Granting or refusal notification to European Securities and Markets Authority (ESMA)
- Publication in ESMA register
National Legislation of Hungary
In Hungary, the transition period means that applicants may continue to provide services related to the provision of crypto-asset services until July 1, 2025
Regulation:
The implementation of MiCA is primarily governed by 2024. évi VII. törvény a kriptoeszközök piacáról (also known as the Act VII of 2024 About the Crypto-asset Market / Act). This law aims to align Hungary’s legal framework with the European Union's MiCA regulation, which is designed to regulate the crypto asset market and ensure consumer protection, financial stability, and market integrity across the EU.
Licensing authority:
As of 30 June 2024, the Act has placed the supervision of entities, persons and activities covered by the relevant legislation, including CASPs, under the supervision of the MNB. Article 40(41) of the MNB Act specifically states that "..in the course of its tasks as defined in Article 39(1)(t), the MNB shall ensure the implementation of MiCA Regulation..".
The MNB has the authority to issue fines and sanctions against non-compliant entities. There are also provisions for cooperation with other EU regulators and the ESMA for cross-border enforcement.
Procedure, timelines, fees:
Following the full application of MiCA, i.e. after 30 December 2024, the MNB must assess within 25 working days of receiving an application for authorisation whether all of the required information has been included in the application. At this stage, however, the MNB will not assess the quality of the information provided. The MNB may ask the applicant to supplement the application if some or all of the required information is missing. The MNB will set a deadline for the submission of any missing information. After the submission of missing information, the MNB will have 40 working days to make a qualitative assessment of the application. During this period, the MNB has the opportunity to submit additional requests for clarification, but only the first of these requests will suspend the 40 working day assessment period, for a maximum of 20 working days.
Pursuant to Paragraph 1 of Article 19/A of Decree No. 32/2023 (VII.19.) of the Governor of the MNB on the administrative service fee for certain licensing and registration procedures conducted by the MNB within the framework of the supervision of the financial intermediary system and in respect of fiduciary asset management undertakings, the licensing procedure is subject to the payment of an administrative service fee of HUF 1,900,000 (approximately €4,700).
Transition period:
A CASP already operating before December 30, 2024 shall comply with the requirements set out in MiCA from July 1, 2025 at the latest.
Requirements for Obtaining a CASP License in Hungary
Capital requirements for a CASP vary depending on what services the company will provide - from €50,000 to €150,000
Physical office requirements
A CASP shall have a registered office in Hungary where it carries out at least part of their crypto-asset services.
Requirements for key persons
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Senior managers (directors):
- Number: MICA does not specify a minimum and maximum number of directors. However, MICA states (part 2, article 59) that there shall be at least several directors.
- Residency requirements: At least one director must be an EU resident.
- General requirements: Directories must have a solid reputation, necessary skills, and relevant experience.
- Required documents:
- a clean criminal record;
- a detailed CV;
- statements on time commitment and past professional conduct.
-
Shareholders:
- Number: MICA does not specify a minimum and maximum number of shareholders.
- Residency requirements: There is no restriction.
- General requirements: Shareholders must have a solid reputation, necessary skills, and relevant experience.
- Required documents:
- a clean criminal record;
- an ownership structure chart.
Capital requirements
Capital requirements vary depending on what services the company will provide:
Class 1: A CASP authorized for the following crypto-asset services:
- execution of orders on behalf of clients;
- placing of crypto-assets;
- providing transfer services for crypto-assets on behalf of clients;
- reception and transmission of orders for crypto-assets on behalf of clients;
- providing advice on crypto-assets; and/or
- providing portfolio management on crypto-assets.
Minimum capital requirements - €50,000.
Class 2: A CASP authorized for any crypto-asset services under Class 1 and:
- providing custody and administration of crypto-assets on behalf of clients;
- exchange of crypto-assets for funds; and/or
- exchange of crypto-assets for other crypto-assets.
Minimum capital requirements - €125,000.
Class 3: A CASP authorized for any crypto-asset services under Class 2 and:
- operation of a trading platform for crypto-assets.
Minimum capital requirements - €150,000.
Documentation requirements
There are list of documents that must be submitted with the application:
-
Documents required for all CASPs:
- The articles of association of the applicant CASP
- Identity and proof of good repute, knowledge, skills, experience and of sufficient time commitment of the members of the management body
- Information relating to shareholders or members with qualifying holdings
- A program of operations setting out the types of crypto-asset services that the applicant CASP wishes to provide, including where and how these services are to be marketed
- A description of the applicant CASP’s prudential safeguards (insurance policy)
- A description of the applicant CASP’s governance arrangements and internal control mechanisms
- A description of the applicant CASP’s business continuity plan
- Detection and prevention of money laundering and terrorist financing (full packet of policies)
- Descriptions both in technical and non-technical language of applicant CASP’s IT systems and security arrangements
- A description of the applicant CASP’s procedures to handle complaints from clients
- Documents required in case CASP wishes to offer services in other countries:
- List of EU countries where the company wishes to offer its services
- Documents required for certain services (each of the 10 services requires its own documents):
- Custody and administration policy
- A description of the procedure for the segregation of client’s crypto-assets and fund
- The operating rules of the trading platform and market abuse detection
- Information on the exchange of crypto-assets for funds or other crypto-assets (commercial policy)
- The execution policy
- Information on the provision of advice or portfolio management on crypto-assets
- Information on transfer services
Taxes in Hungary
The CIT rate of 9 % applies to most companies
Corporate Income Tax (CIT)
Hungary offers one of the lowest corporate tax rates in the EU at 9%.
Corporate tax is levied on the net income (profits after deducting expenses such as wages, operational costs, depreciation, and interest expenses).
If a company is trading or mining cryptocurrency, the profits generated from these activities are subject to the standard corporate tax. This includes any profits made from buying, selling, and trading crypto-assets.
Capital Gains Tax (CGT)
Capital gains are subject to a 15% tax rate, which is the same as the PIT rate.
Capital gains tax applies to profits made from the sale of securities, real estate (in certain cases), and other assets.
Personal Income Tax (PIT)
The PIT rate in Hungary is a flat 15% on gross income.
This tax applies to all forms of income, including salaries, business income, and rental income.
In the case of the consolidated tax base, the tax allowances are deductible: allowance for mothers under the age of 30, family tax allowance after dependent children, allowance for young couples in first marriage, allowance for young people under the age of 25 years, etc.
Frequently Asked Questions
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What is a CASP license in Hungary?A CASP license is a regulatory authorization required for companies providing cryptocurrency-related services such as exchanges, custodial services, advisory services, etc. in Hungary.
-
Who issues the CASP license in Hungary?The MNB issues CASP licenses.
-
What services can be provided under a CASP license?
It allows services such as:
- 1) Providing custody and administration of crypto-assets on behalf of clients
- 2) Operation of a trading platform for crypto-assets
- 3) Exchange of crypto-assets for funds
- 4) Exchange of crypto-assets for other crypto-assets
- 5) Execution of orders for crypto-assets on behalf of clients
- 6) Placing of crypto-assets
- 7) Reception and transmission of orders for crypto-assets on behalf of clients
- 8) Providing advice on crypto-assets
- 9) Providing portfolio management on crypto-assets
- 10) Providing transfer services for crypto-assets on behalf of clients
-
What are the key requirements to obtain a CASP license in Hungary?Companies must meet physical office requirements, requirements for managers and shareholders, minimum capital requirements, documentation requirements.
-
Is it mandatory to have a physical office in Hungary to obtain a CASP license?Yes, a local office in Hungary is required for regulatory oversight.
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Is there a minimum capital requirement for obtaining a CASP license?Yes, applicants must meet specific financial and operational adequacy standards, but the exact minimum capital depends on the services offered (€50,000, €125,000, €150,000).
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What is the process for applying for a CASP license?The process involves submitting an application to the MNB with detailed documentation on the company structure, management, AML policies, and financial plans, etc.
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How long does it take to obtain a CASP license?The preparation of documents and the review process typically takes several months, depending on the completeness of the application and the authority's workload.
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Can CASPs provide cross-border services in the EU?Yes, once licensed under MiCA, CASPs can offer services across the EU without needing separate licenses in other Member States.
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Why is a CASP license necessary in Hungary?A CASP license ensures compliance with Hungarian and EU financial regulations under the MiCA Regulation, providing legal security and consumer protection.
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