Malta Crypto Licence (VFA/MiCA)

Malta was one of the first EU countries to regulate crypto businesses through its Malta VFA licence back in 2018. That framework put Malta on the map as “Blockchain Island”.

But as of 30 December 2024, the EU’s Markets in Crypto-Assets Regulation (MiCA) became law for all member states — meaning new applicants must now apply for a MiCA CASP licence if they want to obtain a crypto licence in Malta.

Existing licence-holders under the old VFA licence in Malta can continue operating during a grandfathering period until 1 July 2026, after which they must either convert to MiCA or stop servicing EU clients.

This guide explains the Malta crypto licence landscape in 2025: what MiCA requires, how the old VFA regime still matters, the costs, challenges, and the steps to successfully get a crypto licence in Malta.

Why Pick Malta for Your Crypto Business in 2025

Malta has long been called “Blockchain Island”, and for good reason. Even as the EU moves under MiCA, Malta remains one of the smartest jurisdictions to obtain a crypto licence in Malta or launch a Malta crypto exchange licence. Here’s why:

• Pro-Crypto Legacy & Legal Certainty – Malta was the first EU member to regulate crypto with the Malta VFA licence, so the MFSA already knows how to supervise exchanges, custodians, and token platforms. That experience makes the shift to MiCA far smoother than in newer jurisdictions.
• EU Passporting Advantage – A Malta crypto licence granted under MiCA lets you serve all 27 EU/EEA states without having to reapply in each country — a single licence for the entire European market.
• Established Compliance Ecosystem – Malta has built a strong base of crypto-savvy lawyers, compliance officers, MLROs, auditors, and IT-security specialists who understand how to prepare MiCA-ready applications and maintain ongoing supervision.
• Banking & Payments Access – Thanks to its regulatory track record, Maltese-licensed firms often find it easier to open local and EU business bank accounts, secure payment gateways, and integrate fiat on-/off-ramps compared to less regulated jurisdictions.
• Investor & Partner Credibility – Operating under the MFSA’s oversight with a proper Malta crypto exchange licence reassures investors, PSPs, and institutional partners that your business meets EU-grade AML/CFT, governance, and cybersecurity standards.
• Smooth Transition for Existing VFA Holders – Companies that already hold a VFA licence in Malta can continue during the grandfathering period until July 2026 and convert to MiCA with a streamlined process.

In short, Malta combines a proven regulatory track record with EU market access — making it one of the most reliable places to get a crypto licence in Malta and build a compliant, scalable crypto business.

MiCA Licence Categories in Malta – Transition from the Old VFA Classes

With the EU’s Markets in Crypto-Assets Regulation (MiCA) now fully in force, Malta regulates crypto firms under the CASP licence (Crypto-Asset Service Provider licence). This is the new standard for anyone looking to obtain a crypto licence in Malta or launch a Malta crypto exchange licence.

MiCA focuses on the services a business provides — such as exchange operations, custody, brokerage, portfolio management, or investment advice — rather than the four rigid licence classes used in the past.

The Malta VFA licence, introduced in 2018, divided firms into four classes (Class 1-4). Those categories still matter only for companies that already hold a VFA licence in Malta and need to convert to MiCA during the grandfathering period until July 2026.

Here’s how the old VFA structure maps to MiCA’s new CASP model — helpful for both new applicants and firms transitioning their VFA licence in Malta to a MiCA authorisation:

New entrants applying today do not choose among the old VFA classes; instead, they apply directly for the relevant MiCA CASP licence in Malta that matches their business model — for example, a Malta crypto exchange licence for trading platforms or a MiCA custody CASP licence for wallet and safekeeping services.

This service-based approach makes the Malta crypto licence under MiCA more flexible and consistent across the EU, while ensuring that existing businesses holding a VFA licence in Malta have a clear conversion pathway without disrupting operations.

Costs of a Malta Crypto Licence under MiCA

The permanent minimum capital for MiCA applicants in Malta remains broadly in line with the updated 2024 VFA Rulebook:

Key Takeaways

• Total Malta crypto exchange licence cost: A lean advisory or brokerage CASP can often budget €200k – €300k in total (including capital), while a full-scale Malta crypto exchange licence with custody, high-end IT security, and extra compliance layers typically requires €400k – €600k+ to launch compliantly.
  
  
• Capital vs. Fees: The permanent minimum capital (e.g., €150,000 for an exchange) is not a fee — it remains locked on the company’s balance sheet as regulatory funds.

Proper financial planning ensures you won’t face last-minute funding gaps that could delay your approval for a Malta crypto licence under MiCA.

Step-by-Step: How to Obtain a Malta Crypto Licence under MiCA

Here’s a practical roadmap for startups and established firms aiming to obtain a crypto licence in Malta or launch a fully regulated Malta crypto exchange licence. This process applies to new MiCA applicants as well as existing holders of a VFA licence in Malta who need to convert to the MiCA framework.

1. Define Your Crypto-Asset Services
   Decide what you’ll actually provide: exchange operations, custody, brokerage/dealing, liquidity-provision, advisory, or portfolio management.
   
   Your business model determines the MiCA CASP licence category you’ll apply for — for example, an exchange & custody licence for a trading platform or an advisory/brokerage licence for order-routing services.
2. Incorporate in Malta with Paid-Up Share Capital Set up a Maltese limited company that satisfies MiCA’s permanent minimum capital thresholds:
   – €50,000 for advisory/order-handling,
   – €125,000 for brokerage/dealing,
   – €150,000 for an exchange or custody licence.
   The capital must be paid in full before final approval.
3. Appoint Governance & Control Functions
   MiCA requires genuine “mind-and-management” in Malta:
   – at least two resident executive directors,
   – a Compliance Officer, MLRO (Money-Laundering Reporting Officer),
   – plus Risk and, if needed, Internal Audit.
   These roles are mandatory whether you’re converting a VFA licence in Malta or seeking a new MiCA authorisation.
4. Prepare the Full Compliance Stack
   Draft and approve all MiCA-compliant policies before filing:
   – AML/KYC manual & risk-assessment,
   – outsourcing policy & vendor-oversight plan,
   – IT-security framework (wallet segregation, incident-response, penetration testing),
   – complaints-handling, best-execution, and client-asset-segregation rules for exchanges and custodians.
5. Plan for Capital & Liquidity Buffers
   Demonstrate not just the minimum capital but also an adequate liquidity buffer to cover operational costs, volatility in trading activity, and orderly wind-down obligations — a key factor for MFSA approval of a Malta crypto licence.
6. Engage Early with the MFSA
   Schedule a pre-application meeting to confirm your chosen MiCA category, capital level, and documentation expectations. Submit all forms and application fees once your pack is ready.
7. Respond Quickly to MFSA RFIs
   The MFSA typically issues Requests for Information (RFIs) for clarifications on governance, IT readiness, outsourcing, or risk policies. Timely and complete responses help avoid delays in obtaining your Malta crypto exchange licence.
8. Meet All Pre-Commencement Conditions
   Before going live, you must:
   – pay the capital in full,
   – activate all control function appointments,
   – complete system tests and security checks,
   – satisfy any final MFSA recommendations.
   After MFSA sign-off, you can officially launch operations under your MiCA crypto licence in Malta.

High-Risk Banking for Crypto Businesses in Malta

Even after you’ve secured your Malta crypto licence or converted your VFA licence in Malta to MiCA, opening a business bank account can be one of the toughest hurdles. Most traditional banks still categorise crypto-asset service providers as high-risk clients, which means extra checks, longer onboarding, and sometimes outright rejection.

Why Banking Is a Challenge for Licensed Crypto Firms

• High-Risk: Banks see exchanges, brokerages, and custody CASPs as exposed to AML/CFT, sanctions, and fraud risk, so they treat them as high-risk clients even if the firm holds a legitimate Malta crypto exchange licence.
• Enhanced Due Diligence (EDD): Expect to undergo deeper KYC/KYB reviews, including beneficial-owner screening, transaction-flow mapping, and reviews of your on-/off-ramp controls.
• Proof of Substance: Banks want clear evidence that your company has real operations in Malta — a local office lease, resident directors, active staff, and audited accounts. Paper entities or thin governance structures often trigger rejections.
• Relationship-Based Approvals: In Malta, opening a high-risk banking relationship often depends on trusted introductions and relationship managers who understand the crypto sector. Without these, even MiCA-licensed firms can face long delays.
• Tighter Transaction Monitoring: Once approved, banks will typically impose enhanced ongoing monitoring on crypto companies — e.g., reporting large transactions, explaining counterparties, and proving Travel-Rule compliance for incoming/outgoing transfers.

On-Ramps, Off-Ramps, High-Risk Merchant Accounts & Payment Gateways in Malta

Even after you’ve cleared the hurdle of securing a Malta crypto licence under MiCA, your exchange or brokerage can’t operate smoothly without reliable fiat on-ramp and off-ramp solutions and high-risk merchant accounts. These services connect your platform’s crypto world to traditional banking and card networks — but in Malta, they come with their own regulatory and operational challenges.

Why They’re Crucial

• On-Ramps: Let customers buy crypto with EUR, USD, GBP or AED via bank transfers, SEPA, cards, or alternative payments.
• Off-Ramps: Allow clients to liquidate crypto back to fiat and withdraw to their bank accounts or cards.
• High-Risk Merchant Accounts: Essential for processing card payments (Visa/Mastercard) and handling recurring billing for brokerage or exchange fees.
• Payment Gateways: Integrate the merchant account into your exchange front-end or brokerage dashboard so transactions settle automatically and securely.

Bottom Line

Launching a crypto venture in Europe has never been more competitive — and MiCA has raised the bar for compliance. Choosing Malta gives you a real edge: it’s one of the few EU jurisdictions with years of hands-on experience regulating exchanges and custody providers through the earlier Malta VFA licence, and it now offers a smooth transition to the new MiCA crypto-asset service provider framework.

A well-structured Maltese company with the correct paid-up share capital, solid governance (two-mind management, MLRO, Compliance Officer), and robust AML/KYC and IT-security policies can unlock EU-wide passporting under a single Malta crypto licence. This foundation earns credibility with banks, PSPs, investors, and even card networks — which is crucial for securing high-risk merchant accounts, fiat on-/off-ramps, and payment gateways.

Cutting corners at the setup stage almost always leads to costly re-drafts, regulator push-backs, or delays in opening accounts. Get the incorporation, compliance stack, and banking relationships right from day one, and your Malta crypto exchange licence becomes more than just a regulatory badge — it becomes your ticket to fast, sustainable growth across all 27 EU states.

Binderr: Your Malta Crypto Business Launch Partner

• End-to-End MiCA Licensing Support – From pre-screening to submission, we guide you through every MFSA requirement to obtain a crypto licence in Malta without delays.
• Company Incorporation & Governance Setup – We handle formation, M&As, paid-up capital, resident directors, and substance proof tailored to MiCA standards.
• Bank Match & Fast Account Activation – We connect you to Maltese/EU banks and EMIs ready to work with licensed CASPs, avoiding rejections and speeding up IBAN activation.
• On-Ramp / Off-Ramp & High-Risk Merchant Accounts – Access PSPs, acquirers, and multi-currency gateways that integrate seamlessly with your Malta crypto exchange licence.
• Compliance Suite & Reporting Tools – AML/KYC manuals, Travel-Rule integrations, risk monitoring dashboards, and IT-security documentation all regulator-ready.
• Ongoing Regulator Liaison – We stay involved post-approval to handle MFSA queries, banking KYC reviews, and policy updates so you remain compliant as you scale.

With Binderr, you don’t just get a licence — you get a launchpad that brings together licensing, banking, payments, and compliance, so your Maltese-based crypto business can go live and expand across the EU with confidence

FAQs — Malta Crypto Licence