Introduction
On February 15, 2025, Act No. 31/2025 Sb. (hereinafter – “Act”) came into force in the Czech Republic. This regulatory act implements EU Regulation 2023/1114 on crypto-asset markets (hereinafter – “MiCA”) into Czech law and introduces significant changes to the regulation of crypto-assets. In particular, the Act designates the Czech National Bank (hereinafter – “ČNB”) as the competent authority for supervising the crypto-asset market, granting it the power to review license applications and supervise crypto-asset service providers (hereinafter – “CASPs”) in the Czech Republic.
Transitional period
A key feature of the Act is Article 26, a transitional provision (grandfathering), which provides for a grace period for existing crypto asset service providers to continue their activities while they obtain new authorization under MiCA.
The Czech National Bank announced that the Act will enter into force on February 15, 2025, as an adaptation of the MiCA regulation.
Under this law, the Czech National Bank is the supervisory authority for crypto-assets, responsible for receiving notifications and applications for licenses in accordance with MiCA and supervising CASPs.
In addition, the ČNB has also issued guidance and an official call for interested parties to apply for MiCA licensing, reflecting the practical implementation of the transitional provisions in accordance with Act.
At the same time, in February 2025, the Prague Financial Department published an information notice entitled “Změny u virtuálních aktiv” (“Changes to Virtual Assets”) to inform local entrepreneurs about the new legislation.
According to this notice, it is stated that:
“Anyone who, by December 30, 2024, had a license to provide services related to crypto assets, on the basis of a trading license and submitted an application for a provider license in accordance with Article 63 of Regulation (EU) 2023/1114 by July 31, 2025, may continue to carry out this activity on the basis of this license until a final decision on the application is made, but no later than July 1, 2026.”
In addition, the Prague Financial Department emphasized the consequences – the provision of services related to virtual assets as an unregulated trading activity is no longer permitted, as the provision of services related to virtual assets is now classified as a “non-trading” regulated activity requiring a special license.
A detailed guide by AMS Europe s.r.o. (a financial technology consulting company) states that existing crypto companies in the Czech Republic “must apply for a license by July 31, 2025,” and warns that companies that do not meet this deadline will no longer be able to operate in the market after that date.
According to the guide, it is confirmed that those who apply on time will be able to continue their activities “until the end of July 2026 or until a final decision on their license application is made,” provided that they have submitted all the necessary documents.
Conclusions
In summary, Article 26 of the Act establishes a clear but time-limited transition period for Czech CASPs to transition to the new pan-European regulatory regime.
The attention given to this in materials published by Czech law firms, consulting companies, and the ČNB underscores the importance of this transition period.
Thus, the transition period, according to the Act means that any Company offering crypto services on the basis of a trading license must urgently apply for a MiCA license by July 31, 2025, and that this will grant it a grace period for operations until a decision on the license is made, with a final deadline of July 1, 2026.
After that date, operating without a license will be prohibited, marking the definitive end of the old laissez-faire approach (the principle of non-interference in the economy). This transition aims to ensure the continuity of business operations and customer service in the short term, while achieving
After this date, operating without a license will be prohibited, marking the definitive end of the old laissez-faire approach (the principle of non-interference in the economy). This transition aims to ensure business continuity of business operations and client service in the short term, while achieving full compliance with the regulatory requirements of the Czech Republic in the long term.
All sources agree that interested parties should take active steps to comply with MiCA requirements well in advance of the deadlines — preparing reliable documentation and meeting all regulatory requirements — to secure their future in the Czech and European cryptocurrency markets, as the Act paves the way for a new era of regulated digital finance in the Czech Republic.
Contact Information
If you want to become our client or partner, you can contact us via email: support@manimama.eu.
Or send a message to Telegram: @manimama_sales.
Welcome to our website: https://manimama.eu/.
Also, please join our Telegram channel: Manimama Legal Channel.
Manimama Law Firm provides a gateway for the companies operating as the virtual asset wallet and exchange providers allowing to enter to the markets legally. We are ready to offer an appropriate support in obtaining a license with lower founding and operating costs. We offer KYC/AML launch, support in risk assessment, legal services, legal opinions, advice on general data protection provisions, contracts and all necessary legal and business tools to start business of virtual asset service provider.
The content of this article is intended to provide a general guide to the subject matter, not to be considered as a legal consultation.
