EU/EEA PassportingMiCA CASP authorisation

CASP Authorisation in Belgium

Belgium is an FSMA-supervised EU/MiCA CASP route for teams that want Benelux and EU positioning, Brussels regulated-market credibility and a serious operating model with local substance, governance, AML, audit and banking readiness.

Processing time
From 6 months
Service price
22 300 EUR
Required share capital
From 50 000 EUR
State fee
Approx. 5,000 EUR
Annual supervision fee
Approx. 3,000 EUR
Banking difficulty
Medium to high
RegulatorFinancial Services and Markets Authority (FSMA)

Confirm current FSMA authorisation process, fee schedule, application forms and transitional MiCA guidance before using this page for client advice.

Regulatory status should be confirmed by local counsel before relying on this route.

What is Belgium CASP authorisation?

Belgium CASP authorisation is the FSMA-supervised route for crypto-asset service providers under MiCA. It is relevant when the business wants an EU regulator profile, Benelux/EU market positioning and a credible Belgian operating footprint.

CASP
Jurisdiction
Belgium
Regulator
Financial Services and Markets Authority (FSMA)
Regime
CASP
Legal basis
Legal basis: MiCA CASP authorisation supervised in Belgium by the FSMA.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

CASP service scope in Belgium

The application should start with a narrow and defensible service perimeter. Exchange, custody, brokerage, wallet, advisory, staking and payment-adjacent models may be possible only when the control file matches the exact activity.

  • Exchange

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Conditional

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Included

    EU/EEA passporting available.

  • Startups

    Excluded

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

EU/EEA market access from Belgium

Belgium is an EU route, so approved MiCA CASP services can support an EU/EEA passporting strategy. That should be framed as a regulated market access plan tied to approved services, target countries and notification steps, not as automatic passporting.

  • Define target EU/EEA markets, client categories and language coverage before submission.

  • Map passporting plans to each CASP service and do not assume one approval covers every future activity.

  • Belgium is strongest when Benelux access, Brussels credibility or EU institutional positioning matters commercially.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Capital, governance and audit expectations

Belgium should be treated as a high-substance CASP route. The CSV snapshot indicates share capital from 50,000 EUR, approximate state and annual supervision fees, local staff, office and audit.

  • The board, senior management, compliance, AML and technology ownership should be credible and accountable.high
  • Capital planning should match the authorised service scope, especially for exchange, custody and fiat-heavy flows.high
  • Audit, reporting, outsourcing, cybersecurity and incident-management workflows should be budgeted as continuing obligations.high

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Belgium CASP application bottlenecks

Belgium bottlenecks are usually operating-model issues rather than form-filling issues. Scope, substance, AML, audit, governance and banking should be resolved before the filing is treated as a timeline exercise.

  • Unclear CASP service perimeter or overly broad EU expansion plan

    High

  • Insufficient Belgian substance, governance or regulator-facing accountability

    High

  • Weak custody, safeguarding, wallet or technology-control evidence

    High

  • Generic AML policies that do not match client geography, tokens, fiat flows and travel rule obligations

    High

  • Banking or PSP package prepared too late

    High

  • Route selection driven by low budget rather than EU passporting and FSMA-supervised operations

    High

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Conditional

Exchange activity may require additional scope or separate licensing.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Conditional

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Suitable

EU/EEA passporting available.

Startups
Not suitable

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Is Belgium CASP authorisation right for your project?

Best for

  • EU passporting and regulated CASP operations
  • EU/EEA market access

Not suitable for

  • Low-budget or fast offshore setup
  • Projects without a prepared banking strategy

Banking difficulty is high for this route. Prepare a banking strategy before committing to the Belgium route.

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalFrom 50 000 EUR
Required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local substance plan — Belgium

A credible local presence can be as important as the filing itself. Regulators, banks and payment providers may all review whether the company has real operating substance.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
22 300 EUR EURFixed
State fee
Approx. 5,000 EURFrom
Annual supervision feeRecurring annual cost after authorisation.
Approx. 3,000 EURFrom
Required share capitalMust be held, not an expenditure.
From 50 000 EURFrom
High ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — Belgium

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€22,300
State fee€1
Required share capitalMust be held, not an expenditure.€50,000

Summary

One-off costs
€72,301
Annual (year 1)
€0
Total year 1
€72,301

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. Belgium — From 6 months.

Total timelineFrom 6 months

  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in Belgium

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Financial Services and Markets Authority

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 6 months

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

High setup complexity
High

Setup complexity is rated high for Belgium. Company setup, governance and documentation take longer than average.

Likely impactAdd 4–8 weeks to the preparation phase.
MitigationStart company setup and governance planning immediately after scope confirmation.
Banking difficulty
High

Banking difficulty is rated high. Opening accounts for crypto businesses in Belgium requires extensive documentation.

Likely impactBanking can delay or block operations for 3–6 months after authorisation.
MitigationIdentify and pre-qualify banking partners before submitting the application.
High maintenance cost
Medium

Ongoing supervision, audit and compliance costs are above average. Budget for these separately from the application fee.

Likely impactRecurring annual cost significantly above the one-time service price.
MitigationModel annual compliance costs before committing to this route.
Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP strategy in Belgium

Belgium has a high regulatory reputation, but banking difficulty remains medium to high. Banking and PSP readiness should run alongside the authorisation strategy, especially for exchange, custody and fiat-heavy products.

Banking difficulty
High

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Prepare ownership, source-of-funds, flow-of-funds, client geography, token policy and AML evidence before approaching banks.
  • Explain safeguarding, reconciliation and fiat rails clearly for custody or exchange models.
  • Do not assume that FSMA authorisation will automatically unlock banking or PSP onboarding.

Business model fit — Belgium

Assess how well this route covers your planned activities.

Fit score

Good fit
0/6
Partial fit
6/6
Poor fit
0/6

Belgium may not cover your primary activities

Consider an alternative route that better matches your activity profile.

FSMA application profile

Regulatory authority · Belgium

Financial Services and Markets Authority (FSMA)

An FSMA-facing CASP file should read like a regulated financial services application: precise activities, accountable management, local substance, AML controls, safeguarding, outsourcing oversight and a realistic banking strategy.

Likely areas of scrutiny
  • Belgium is best suited to teams that value EU regulatory credibility and can evidence a real Belgian operating model.
  • Weak local substance, generic policies or unclear group outsourcing can create review friction.
  • AML, sanctions, travel rule, transaction monitoring and cybersecurity evidence should be tailored to client geography and token flows.
Regulatory reputation
High

Strong international recognition and established supervision track record.

Setup complexity
High

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
Medium

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 12 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Risk assessment

Main risk dimensions for the Belgium route.

Banking difficulty
High

Route risk rating — banking difficulty: Medium to high. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
High

Route risk rating — setup complexity: High.

Maintenance cost
High

Route risk rating — maintenance cost: High. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
High

Route risk rating — regulatory reputation: High.

Regulatory risk
Medium

Route risk rating — regulatory risk: Low to medium. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

Belgium CASP vs alternatives

Compare Belgium with the Netherlands for another Benelux CASP route, Luxembourg for financial-centre positioning, France for a large EU regulated crypto market, and Malta for an established MFSA/MiCA crypto authorisation profile.

Current

Belgium

CASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
High

Netherlands (CASP)

CASP

Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ Strong Benelux/EU positioning with a large fintech and payments ecosystem

− Still requires MiCA-grade substance, governance and compliance evidence

View route

Luxembourg (CASP)

CASP

Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ Financial-centre positioning for fund, custody and institutional models

− Substance, governance and banking expectations can be demanding

View route

France (CASP)

CASP

Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ High-profile EU crypto regulatory environment for France-led expansion

− Not a low-friction route for teams without mature compliance operations

View route

Malta (CASP)

CASP

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium to high
Reputation
High

+ Established MFSA/MiCA crypto regulatory profile

− Not a lighter alternative if the objective is low-cost setup

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Belgium vs other CASP routes

Compare key parameters across CASP authorisation routes.

Sort by:
BelgiumCurrent
Price22 300 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationHigh
Netherlands
Price—
Timeline—
BankingMedium to high
ReputationHigh
Luxembourg
Price—
Timeline—
BankingMedium to high
ReputationHigh
Malta
Price20 700 EUR
TimelineFrom 6 months
BankingMedium to high
ReputationHigh

Check your readiness for Belgium CASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

Share capital

From 50 000 EUR minimum capital required.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in Belgium.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

Belgium CASP authorisation under MiCA can support EU/EEA passporting for approved services, but it is not automatic. The passporting plan must match the authorised scope and follow the required notification process.

Usually no. Belgium is better for teams that can support high substance, governance, AML, audit, local staff, office and banking readiness. It is not a fast offshore setup.

Belgium can be useful for Benelux and EU positioning, Brussels credibility and a high-reputation FSMA-supervised operating model. The trade-off is higher setup complexity and continuing compliance burden.

Check service scope, Belgian substance, management accountability, AML and travel rule controls, audit readiness, banking or PSP feasibility, and whether payment, e-money, securities or derivatives rules are triggered.

Compare the Netherlands CASP, Luxembourg CASP, France CASP and Malta CASP routes. The right choice depends on target markets, regulator profile, banking strategy, local substance and long-term operating budget.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

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