MiCAR for Payment Institutions: Key Costs & Steps

Alejandro Martínez · 2026-07-01

If you run a Payment Institution (PI) and you're thinking about offering crypto services — like issuing e-money tokens (EMTs), handling crypto-assets, or letting customers pay with crypto — you're going to need a separate MiCAR authorization. That's right: your existing PI license won't cut it. MiCAR, the EU's Markets in Crypto-Assets Regulation, adds a whole new layer of rules on top of what you already have. ### What MiCAR Actually Requires MiCAR is no joke. It brings in conduct-of-business rules, conflict-of-interest policies, and client asset segregation requirements that feel a lot like MiFID II. If you're issuing EMTs, you'll also need to publish a detailed white paper — think of it as a prospectus for your token. The application process has four stages: first, you engage with your National Competent Authority (NCA) before you even apply; then you make a formal submission; next comes the assessment phase (including fit-and-proper checks on your team); and finally, ongoing supervision after you're authorized. Your existing PI documentation won't just slide into MiCAR. You'll need to adapt it meaningfully. That said, Malta's MFSA makes things a bit easier by letting you cross-reference your existing PI docs — so you're not starting from scratch. But here's a catch: if you're on a simplified ICT framework now, adding crypto services pushes you into the full DORA-aligned regime. That means more compliance work. ### The Real Price Tag: What It Costs Let's talk money. Costs stack up across four main categories, and I've converted everything to USD for you: - **White paper notification fees:** $2,700 to $8,700 (depends on your entity and token type), plus $1,100 for any amendments - **Application fees:** $10,900 to $27,200, based on your license class - **Annual supervisory fees:** $10,900 to $54,500 per year (for Class 3, the supervisory fee doubles the application fee) - **Minimum capital requirements:** $54,500 to $163,500, depending on your class — this might be higher than your existing PI threshold, creating a standalone capital adequacy obligation Beyond those headline costs, you need to budget for legal and advisory fees, hiring a compliance function, and technology investments. It adds up fast. ### Is It Worth It? A Strategic Decision So, is getting a MiCAR license worth the hassle? It's not just a compliance checkbox. It's a strategic commercial decision. You need to weigh the commercial upside — like offering crypto services to your customers — against the genuine scope of new obligations. For many PIs, the answer will be yes, but only if you have a clear business case. > "The MiCAR licence is a strategic commercial decision, not a compliance formality. The commercial upside should be weighed against the genuine scope of new obligations." ### Next Steps for Your PI If you're serious about this, start by engaging with your NCA early. The pre-application phase is your chance to ask questions and understand what they expect. Then, get your documentation in order — you'll likely need outside legal help. And don't forget the tech side: your systems need to handle crypto assets and meet DORA requirements. This isn't a quick or cheap process, but for PIs that want to stay competitive in the crypto space, it's the only way forward. Plan ahead, budget generously, and treat it like the major business move it is.