PIs and MiCAR: What You Need to Know

Alejandro Martínez · 2026-07-01

If your payment institution (PI) is already offering crypto-related services—like issuing e-money tokens (EMTs), handling crypto-asset transactions, or enabling crypto payments—you're probably familiar with the regulatory landscape. But there's a new layer coming: MiCAR (the Markets in Crypto-Assets Regulation). And it's not just a checkbox exercise. Here's the deal: you'll need a separate MiCAR authorization on top of your existing PI license. That's right—another application, another set of rules, and another pile of costs. Let's break down what this actually means for your business. ### What MiCAR Brings to the Table MiCAR isn't just a copy-paste of existing rules. It introduces conduct-of-business standards, conflict-of-interest policies, and client asset segregation requirements that look a lot like MiFID II. On top of that, if you're issuing EMTs, you'll need to prepare white paper disclosures—essentially detailed documents explaining the token's features, risks, and rights. The application process itself has four stages: - Pre-application engagement with your National Competent Authority (NCA) - Formal submission of your application - Assessment, including fit-and-proper checks on key personnel - Ongoing post-authorization supervision Here's the kicker: your existing documentation won't cut it. You'll need to adapt it meaningfully. That said, some regulators like Malta's MFSA are trying to reduce duplication by cross-referencing existing PI paperwork. But don't count on that being the norm everywhere. ### The Cost Reality Check Let's talk money. MiCAR authorization comes with fees that stack up quickly. Here's a rough breakdown (converted to USD for clarity): - **White paper notification fees**: $2,700 to $8,700 per token type, plus $1,100 for amendments - **Application fees**: $10,900 to $27,200 depending on your license class - **Annual supervisory fees**: $10,900 to $54,400 per class. For Class 3, expect the supervisory fee to double the application fee - **Minimum capital requirements**: $54,400 to $163,200 per class. This might exceed your existing PI thresholds, creating a standalone capital adequacy obligation And those are just the headline costs. You'll also need to budget for legal and advisory fees, hiring a dedicated compliance function, and investing in technology upgrades. It adds up fast. > "The MiCAR license is a strategic commercial decision, not a compliance formality." ### Is It Worth It? This is the big question. Before you jump in, ask yourself: what's the commercial upside? If your crypto services are a core part of your business, the investment might make sense. But if it's just a side offering, the costs could outweigh the benefits. Remember, once you add crypto services, you'll also get pulled into the full DORA-aligned regime for ICT risk management. That means more reporting, more testing, and more oversight. It's not a small commitment. ### Final Thoughts MiCAR isn't optional if you want to keep offering crypto services in the EU. But it's not something to rush into either. Take the time to weigh the costs against the potential revenue. Talk to your legal team. And don't forget to factor in the ongoing compliance burden. If you're serious about crypto, MiCAR is your new reality. Make sure you're ready for it.