Czech Republic Financial Market Digitalisation Act (Act No. 31/2025 Coll.)

The act designates the Czech National Bank as the competent authority for both MiCA and DORA in the Czech Republic. The CNB is responsible for receiving MiCA notifications and applications and for exercising supervisory powers over CASPs, issuers and offerors within the categories covered by MiCA.

• CASPs and certain financial entities are brought under CNB supervision for compliance with the act and directly applicable EU digital-finance rules.
• The CNB may require remedial measures, request information and use specific supervisory powers provided under MiCA and DORA.
• The CNB must maintain electronic lists covering notified crypto-asset white papers, authorised issuers, authorised CASPs and entities allowed to provide crypto-asset services in the Czech Republic.

The act defines entrusted funds to include crypto-assets, access credentials or means of access to crypto-assets, and money entrusted to a CASP. Those entrusted assets are protected against enforcement against the CASP and are subject to special treatment if a CASP becomes insolvent. Custody providers must also arrange at least annual auditor verification of measures adopted to protect entrusted funds and provide the verification report to the CNB.

For asset-referenced tokens and certain e-money tokens, the act provides domestic rules around reserve assets. In particular, reserve assets and investment returns connected to the reserve are protected against enforcement against an issuer, subject to the act’s redemption-plan exception.

The law sets knowledge and skill expectations for persons providing crypto-asset advice, including knowledge of crypto-asset service regulation and the ability to explain the nature of crypto-assets and related services to customers. CASPs must submit audited financial statements to the CNB within four months after the end of the accounting period, while issuers and CASPs must provide information needed to assess prudential compliance.

The act creates Czech administrative-offense categories for conduct that breaches MiCA, including unauthorized public offers, unauthorized crypto-asset services, failures linked to qualifying holdings, disclosure of inside information, and market-abuse obligations. It also creates offenses tied to DORA operational-resilience obligations and CASP custody or reporting failures. The CNB hears offenses under the act.

The act included a grandfathering provision for persons that were authorised before December 30, 2024 to provide crypto-asset-related services under a trade licence. Those firms could continue operating only if they applied for MiCA CASP authorisation by July 31, 2025, and only until the CNB’s decision became final, with an outside deadline of July 1, 2026. That transitional period has now expired.