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MiCA · own funds · Annex IV

Three capital tiers, and almost everyone lands on the middle one.

MiCA sets minimum own funds of 50,000, 125,000 or 150,000 euro depending on the heaviest service you are authorised for. Reading the CNMV register shows how little that choice is really exercised: of ''' + str(len(R)) + ''' entries, ''' + str(cc[2]) + ''' sit in the 125,000 class, because custody or an exchange service is in almost every permission set anyone asks for. And for a firm with staff and premises the floor is rarely the number that binds.

Price your permission set ↗ Scope an application ↗
Entries in class 2
153 of 178
Triggered by custody or an exchange service. The 125,000 euro floor.
Stayed in class 1
10
Firms that touch no client assets and keep the 50,000 euro floor.
Distinct permission sets
67
Across all entries. The average firm holds 4.1 of the ten services.

Article 67 of MiCA requires a crypto-asset service provider to hold own funds of at least the higher of two amounts: the permanent minimum for its class, set in Annex IV, and one quarter of the fixed overheads of the preceding year. Both parts matter, and the second is the one that decides real cases.

The ten services
Select what you intend to do

The class is set by the heaviest service in the set, not by how many you hold. The counters show how many entities in the CNMV register hold the same combination, which is a reasonable check on whether your intended scope is a normal one.

Own-funds class
—
Select at least one service.
Annex IV floor
—
The permanent minimum. Not necessarily your requirement.
Firms with this exact set
—
Out of 178 entries in the register.
What actually binds
Own funds must be the higher of the floor and a quarter of last year of fixed overheads.

The three classes, and why the middle one swallowed the market

ClassServicesFloorRegister
Class 1Execution of orders, placement, transfer services, reception and transmission of orders, advice, portfolio management50,000 EUR10 entries
Class 2Any class 1 service, plus custody and administration, exchange for funds or exchange for other crypto-assets125,000 EUR153 entries
Class 3Any class 2 service, plus operating a trading platform150,000 EUR15 entries

Custody appears in 80 per cent of the register and one of the two exchange services in most of the rest. That is why the tiering barely functions as a tiering: the spread between the cheapest and dearest class is 100,000 euro, and 86 per cent of firms are on the same rung.

The permission sets firms actually asked for

CombinationFirmsClass
Transfer services · Custody · Exchange for funds · Crypto for crypto182
Execution · Transfer services · Custody · Exchange for funds · Crypto for crypto162
Transfer services · Custody102
Reception and transmission · Execution · Transfer services · Custody · Exchange for funds · Crypto for crypto92
Transfer services · Exchange for funds · Crypto for crypto72
Execution · Transfer services · Custody62

The two most common sets are the same business with and without execution: custody, both exchange legs and transfer services. Between them they account for 34 of the 178 entries. If your intended scope looks nothing like anything on this list, that is worth a conversation before the file is written, because an unusual combination invites questions the CNMV will ask and the business plan has to answer.

The mistake we see most often

People budget the Annex IV floor and nothing else. Own funds are the higher of the floor and one quarter of the previous year of fixed overheads. A class 2 firm stays on the 125,000 euro floor only while its fixed overheads are under 500,000 euro a year. Add a compliance officer, a risk function, an office, audited systems and an external auditor, and a modest CASP passes that quickly. The requirement then rises every year with the cost base, and it is tested against the audited accounts rather than the business plan.

What own funds are, and are not

  • They are not a deposit. Own funds are regulatory capital on your balance sheet, not money handed to the regulator or blocked in an account. They have to be there, evidenced, and maintained.
  • They are not client money. Client crypto-assets and funds are segregated and are not yours; they never count towards own funds, and conflating the two is a fast route to a returned file.
  • They can be met by an insurance policy in part. MiCA allows the prudential safeguard to be satisfied by own funds, by a qualifying insurance policy, or by a combination, subject to conditions on the policy. Whether a policy is available on acceptable terms is a market question, and it has been a thin market.
  • They are not the cost of the licence. Capital sits on your balance sheet; the application, the systems and the people are the spend. Firms that confuse the two under-budget the project by an order of magnitude.
Frequently asked
Does holding more services cost more capital?
Not in itself. The class is set by the heaviest service you are authorised for, so a firm with six class 1 services still sits on the 50,000 euro floor, and a firm with custody alone sits on 125,000. What adding services does is add obligations, systems and staff, which raises your fixed overheads and therefore the overheads limb of the requirement.
What counts as fixed overheads?
Broadly the recurring costs of running the firm rather than variable or discretionary items, taken from the previous year of audited figures. The detail matters because the quarter-of-overheads figure is compared against your floor, and firms tend to read the definition generously in their own favour. It is worth getting the classification reviewed before it is filed rather than after.
Is 150,000 euro really enough to run a trading platform?
As a regulatory floor, that is what Annex IV says. As a business proposition, no: the overheads test will take any real platform well past it, and the market-integrity, systems resilience and transparency obligations for operating a platform are the substance of the work. The capital step from class 2 is the smallest part of the difference.
Do Spanish banks have to meet these figures?
No. A credit institution providing crypto-asset services does so under its banking authorisation on notification, and its capital is governed by the banking framework, not Annex IV. That is part of why six Spanish banks appear in the CNMV register alongside nine CASPs.
Where do the register figures on this page come from?
From our own transcription of the CNMV list of crypto-asset service providers, classified service by service. The distribution across classes is computed from that, not taken from any published statistic, and the underlying page-by-page data is on the register analysis linked below.
Who is actually licensed in Spain ↗ What the 1 July 2026 deadline did ↗ Why firms licence elsewhere ↗ CASP authorisation, scoped ↗
Position as at September 2026. Own-funds classes and floors are those in Annex IV of Regulation (EU) 2023/1114 as reproduced in the ESMA interactive single rulebook; the ongoing requirement in article 67(1) is the higher of that permanent minimum and one quarter of the fixed overheads of the preceding year, and the Regulation also permits the prudential safeguard to be met by a qualifying insurance policy or a combination. Class distribution, permission sets and service frequencies are computed from our transcription of the CNMV list of crypto-asset service providers and may differ from the CNMV list if it has been updated since. The selector is a reading aid, not a determination of any firm’s capital requirement. General information, not legal advice.

Everyone lands on 125,000. Then the overheads test moves the number.

Scope the application ↗
Fixed scope and fee before work starts
About the author
AB

Alexander Baranov

Founder, Voixa Consultors · International corporate structuring since 2008

Seventeen years designing and delivering cross-border corporate structures — incorporation, tax, holding, banking and market entry — for founders and companies expanding into Spain and the EU. Author of professional books on entering the Spanish market.

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