Licenses for Cryptoassets and Payment Services

Establishing a new limited liability company involves several coordinated legal and administrative steps. This includes an initial consultation to assess the intended business model and propose an appropriate legal structure for the new company, taking into account regulatory aspects, particularly if a licensing process is anticipated in the future. Subsequently, the founding documents are drafted, business licenses are secured, and communication with the relevant public authorities is coordinated. The result is a company duly registered in the Commercial Register of the Slovak Republic, ready for further regulatory and licensing steps. The court fee for the initial registration of a limited liability company in the amount of EUR 220 is not included in the stated price.

In order to create a favorable business environment for the provision of crypto-asset services, the NBS offers the option of a pre-licensing dialogue—an informal discussion before the NBS commission that allows for an assessment of the applicant’s business situation in relation to their model for providing crypto-asset services even before the actual license application is submitted. Participation in the pre-licensing dialogue is not mandatory; however, our firm has had positive experiences with it—prospective applicants gain a realistic picture of their readiness for the licensing process, and the NBS can directly point out any shortcomings that can be addressed before the application is submitted. The NBS also notes that it will issue the license more promptly if the applicant participates in the pre-licensing dialogue. The price includes assistance in completing the questionnaire for license applicants, initiating and preparing for the dialogue, and participating in it.

The base fee for legal services related to a Crypto-Asset Service Provider (CASP) license under the MiCA Regulation starts at €19,500 excluding VAT, with any potential increase depending on the scope of the legal services required. The base price includes the preparation of the license application, including a checklist of attachments, a business plan, list of crypto-assets, outsourcing policy, description of prudential safeguards, description of management and internal control mechanisms, conflict of interest prevention plan, risk management policy, business continuity plan, complaint handling rules, and other mandatory documentation. The base fee is generally increased by the cost of preparing AML documentation (+€2,470) and by the applicable fees based on the class of crypto-asset services requested (Class 1: +€1,300 per service, Class 2: +€2,600 per service, Class 3: +€4,500).

The base fee for legal services related to a payment institution license under the PSD2 Directive is €22,000, excluding VAT. The base price includes the preparation of the license application, including the program of activities, business plan, proof of initial capital, draft articles of association of the payment institution, organizational structure and internal regulations, a description of security measures and risk management, AML/CFT internal control mechanisms, a description of measures to protect client funds, and other required documentation. In the case of concurrent processing of MiCA and PSD2 licenses for the same client, we offer a 30% discount on the PSD2 license fee, reducing the fee to €15,400 excluding VAT.

The base fee for legal services related to obtaining a license for an electronic money institution under EMD2 is €22,000, excluding VAT. The base price includes the preparation of the license application, including the program of activities, business plan, proof of initial capital, draft articles of association, organizational structure and internal regulations, a description of measures to protect client funds, a description of management and risk management, AML/CFT internal control mechanisms, and other required documentation. The administrative fee payable to the NBS for granting the license is EUR 3,400 and is not included in the price listed above.

The base fee for legal services related to the registration of a Small Payment Institution (SPI) starts at €17,000 excluding VAT. The base price includes the preparation of the registration application, including a checklist of attachments, a business plan, business plan, description of the organizational structure and management, description of measures to protect client funds, description of risk management, fit & proper documents for management personnel, information on qualified shareholders, founding documents, and a draft of the general terms and conditions. The administrative fee payable to the NBS for registration is EUR 3,400 and is not included in the stated price.

The additional fee of €1,950 (excluding VAT) covers communication in English and the preparation of bilingual documentation. We provide clients with checklists of the attachments required by the NBS, translated into English, as well as other supporting documents; we coordinate with certified translators and implement updates to documents in both language versions. The application, including attachments, must be submitted in Slovak; upon the applicant’s written request, the NBS may waive the requirement for an official translation of technical documentation if it is prepared in Czech or in a language commonly used in the field of international finance.