CMS Expert Guide to Crypto Regulation in Czech Republic
- How is crypto regulated?
- What are the steps taken by the regulator to adopt MiCAR?
- Are the following activities regulated or unregulated in your jurisdiction? ― Direct sales of tokens by issuers Exchange (buy/sell) ― Custody (hold) ― Borrowing/lending ― Yield/staking services — Staking on proof of stake consensus mechanisms(please indicate if NFTs are treated differently from fungible cryptoassets for each activity)
- Can offshore business provide services to local customers on either active solicitation or reverse solicitation basis?
- How long would establishing a cryptoasset business/obtaining a license in your jurisdiction take?
- What would be the approximate overall cost of obtaining a licence?
- What is the probability (%) of success in obtaining a licence?
- What other limitations are there in your jurisdiction when looking to set up a cryptoasset business? E.g., Compliance requirements and physical presence
jurisdiction
Disclaimer: This chapter was last updated on 3 September 2026 and does not reflect any subsequent developments. The information provided is intended for general informational purposes and should not be construed as legal advice.
1. How is crypto regulated?
| AML Regulation | Any other regulation |
MiCA applies directly in the Czech Republic. The Czech national framework has been supplemented by Act No. 31/2025 Coll., on the implementation of EU legislation in the area of financial market digitalisation, which entered into force on 15 February 2025 and designates the CNB as the competent authority for MiCAR in the Czech Republic. Following the expiry of the Czech transitional period on 1 July 2026, crypto-asset services falling within the scope of MiCAR can no longer be provided in the Czech Republic on the basis of the previous trade licence regime. | Providers of crypto-asset services are subject to the Czech AML Act (Act No. 253/2008 Coll., as amended). The Financial Analytical Office is the designated national supervisor under the Czech AML framework for virtual asset service providers falling outside the scope of MiCAR. This supervisory framework operates alongside the CNB's role as the competent authority under MiCAR. In addition, the Financial Analytical Office operates a separate authorisation regime under § 29ba of the Czech AML Act for a residual category of virtual-asset services not covered by MiCA or any other legal regime, established Czech providers of which must obtain a specific Financial Analytical Office authorisation. |
2.What are the steps taken by the regulator to adopt MiCAR?
The CNB has been accepting CASP authorisation applications under MiCAR and, as of mid-2026, has granted CASP licences to a first cohort of providers.
The Czech Republic adopted the full 18-month transitional period permitted under MiCAR, running from 30 December 2024 to 1 July 2026. During this period, businesses lawfully providing virtual-asset services under the previous regime (trade licence) could continue operating pending a CASP decision, provided they submitted a complete application by the Czech deadline of 31 July 2025. New market entrants could not rely on the former Czech trade-licence regime and were required to comply with MiCAR from the outset.
The transitional period expired on 1 July 2026. Firms that have not obtained (or have been refused) CASP authorisation are no longer entitled to rely on the transitional regime and may not lawfully continue providing in-scope crypto-asset services without authorisation.
3. Are the following activities regulated or unregulated in your jurisdiction? ― Direct sales of tokens by issuers Exchange (buy/sell) ― Custody (hold) ― Borrowing/lending ― Yield/staking services — Staking on proof of stake consensus mechanisms(please indicate if NFTs are treated differently from fungible cryptoassets for each activity)
| AML Regulation | Any other regulation |
Direct sales of tokens by issuers The issuance and offering of crypto-assets are regulated under MiCAR, but the issuance or offering of an issuer's own crypto-assets does not in itself constitute the provision of a crypto-asset service requiring CASP authorisation. The applicable MiCAR requirements depend on the type of crypto-asset and the capacity in which the person is acting. Exchange (buy/sell) The provision of crypto-asset exchange services to clients is regulated under MiCAR and requires CASP authorisation where the relevant activity falls within the MiCAR service categories. No material Czech-specific deviation has been identified. Custody (hold) The custody and administration of crypto-assets on behalf of clients is regulated under MiCAR and requires CASP authorisation. No material Czech-specific deviation has been identified. Borrowing/lending Crypto-asset lending and borrowing are not, as such, listed as crypto-asset services under MiCAR. Depending on the structure of the arrangement and the parties involved, other Czech regulatory regimes, including the Czech Consumer Credit Act, may apply. The regulatory treatment should therefore be assessed on a case-by-case basis. Yield/staking services The regulatory treatment of staking and yield-generating arrangements depends on their structure. Where the activity constitutes a crypto-asset service within the meaning of MiCAR, CASP authorisation may be required. Arrangements falling outside the MiCAR service categories are not subject to CASP authorisation solely by virtue of being described as staking or yield services. Staking on proof of stake consensus mechanisms Pure proof-of-stake validating or mining activities, where carried out on the provider's own account and without providing crypto-asset services to clients, are outside the scope of MiCAR. NFTs Genuinely unique and non-fungible crypto-assets generally fall outside MiCAR. However, the MiCAR exclusion does not apply where assets presented as NFTs are in substance fungible or otherwise fall within MiCAR's scope. Providers of NFT-related services who are established in the Czech Republic and fall outside the scope of MiCA are, in practice, the main category expected to fall within the residual authorisation regime under § 29ba of the Czech AML Act. This authorisation is required only for Czech-established providers (not for those operating under freedom to provide services) and is not required by holders of a MiCA CASP authorisation. | The Czech AML framework applies to persons falling within the relevant categories of obliged persons under the Czech AML Act. Such persons are subject to applicable AML/CTF requirements, including customer due diligence, enhanced due diligence, internal AML/CTF policies and suspicious activity reporting obligations. Pure mining or validating activities may also be subject to general Czech business and trade-licensing requirements depending on the circumstances. |
4. Can offshore business provide services to local customers on either active solicitation or reverse solicitation basis?
| AML Regulation | Any other regulation |
No Czech-specific deviation from the MiCAR position on active solicitation and reverse solicitation has been identified. A third-country provider may provide crypto-asset services to a client in the Czech Republic on a reverse-solicitation basis only where the service is provided at the client's own exclusive initiative and the relevant conditions under MiCAR are satisfied. Active solicitation or marketing into the Czech Republic cannot be treated as reverse solicitation. The reverse-solicitation exemption is limited in scope and should not be interpreted as permitting a third-country provider to expand the range of services or products provided on the basis of an initial client-initiated contact. | N/A |
5. How long would establishing a cryptoasset business/obtaining a license in your jurisdiction take?
| AML Regulation | Any other regulation |
| For CASP authorisation, CNB practice to date suggests realistic timelines of roughly 3–6 months from submission to decision, and 6–12 months or more (for complex or multi-service applications) once preparation and iterative CNB information requests are factored in — longer, in practice, than the EU-wide statutory clocks would suggest on their face. | Beyond MiCA CASP authorisation, the Financial Analytical Office grants a separate authorisation under § 29ba of the Czech AML Act for a residual category of virtual-asset services not covered by MiCA or any other legal regime — in practice, this primarily concerns NFT services. This authorisation is required only for providers established in the Czech Republic (not for those operating under freedom to provide services) and is not required by holders of a MiCA CASP authorisation, including for NFT-related services. New applicants are subject to a 120-day statutory decision period. Beyond this residual authorisation, a provider of virtual-asset-related services more broadly becomes an AML-obliged entity by operation of law once it carries out activities falling within the relevant AML categories in the Czech Republic, and must have its AML/CTF policies and controls in place from the outset. |
6. What would be the approximate overall cost of obtaining a licence?
| AML Regulation | Any other regulation |
For CASP authorisation, the minimum own-funds requirements under MiCAR depend on the crypto-asset services provided. The applicable minimum thresholds are EUR 50,000, EUR 125,000 or EUR 150,000, depending on the relevant service category, with the highest applicable threshold prevailing where a CASP provides services falling under multiple classes. On an ongoing basis, a CASP must hold own funds equal to the higher of the applicable threshold or one quarter of its fixed overheads for the preceding year. These are regulatory own-funds requirements rather than an application fee. In addition, applicants should budget for legal and compliance advisory costs, governance and organisational implementation costs, IT and operational costs and, where applicable, translation and other costs associated with preparing and maintaining a MiCAR-compliant application and business. The overall cost varies significantly from case to case, depending on factors such as the CASP class sought, the complexity of the business model, the scope of services provided and the applicant's existing organisational and compliance infrastructure, and there is no publicly available benchmark figure for the Czech Republic. | Applicants for the Financial Analytical Office's § 29ba authorisation must lodge a security deposit of CZK 250,000 with the Financial Analytical Office, generally no later than the date of filing the application. |
7. What is the probability (%) of success in obtaining a licence?
| AML Regulation | Any other regulation |
There is no publicly available Czech-specific success rate for MiCAR applications. The CNB assesses applications on a case-by-case basis against the requirements of MiCA and the Czech implementing legislation. As of 1 July 2026, the CNB had assessed 251 applications and notifications relating to the provision of crypto-asset services and had granted authorisation to 11 entities. The published figures should not be interpreted as a formal application success rate, since the 251 figure includes different types of regulatory submissions and does not represent a denominator consisting solely of finally determined CASP applications. | N/A |
8. What other limitations are there in your jurisdiction when looking to set up a cryptoasset business? E.g., Compliance requirements and physical presence
| AML Regulation | Any other regulation |
CASPs established in the Czech Republic must satisfy MiCAR requirements concerning governance, organisation, internal controls, risk management and operational capacity, and the CNB may scrutinise whether the applicant's arrangements are substantive and adequate for the proposed business model. The CNB, in line with the supervisory approach under MiCAR, may expect a meaningful level of local substance for Czech-established CASPs, including appropriately located management and key staff and adequate operational and control arrangements, rather than a purely nominal presence. EU-established CASPs may, subject to the applicable MiCAR passporting framework, provide crypto-asset services in the Czech Republic on a cross-border basis without necessarily establishing a Czech subsidiary or branch. The appropriate establishment and cross-border model should be assessed based on the applicant's status and the services to be provided. | The Czech AML framework imposes the usual requirements applicable to obliged entities, including ML/TF risk assessment, customer due diligence, enhanced due diligence and internal AML/CTF policies and procedures. |
