Estonia Market in Crypto-Assets Act (2024)

The Estonian Act should be read alongside Regulation (EU) 2023/1114, the directly applicable EU MiCA Regulation. MiCA creates uniform EU market rules for crypto-assets, including transparency, disclosure, authorisation, supervision, and market-integrity requirements for issuers and crypto-asset service providers. Estonia’s Act fills the domestic implementation layer: it designates national supervisory arrangements, adds local procedural rules, and addresses areas that the EU regulation leaves to member-state law.

Finantsinspektsioon states that the Act brought the activities of participants in crypto-asset markets under its supervision. Its scope includes persons engaged in the issuance, offer, and admission to trading of crypto-assets, as well as providers of crypto-asset services within the meaning of MiCA. The regulator groups relevant crypto-assets into asset-referenced tokens, e-money tokens, and other crypto-assets, with service providers for the latter category commonly treated as CASPs.

The Act’s practical importance is the shift from Estonia’s earlier virtual currency service provider framework to MiCA-aligned financial supervision. The Riigikogu described the bill as bringing crypto-asset service providers and crypto-asset issuers, including asset-referenced token issuers, e-money token issuers, and issuers of other crypto-assets, under Finantsinspektsioon’s supervision.

• Licensing and authorisation: Applicants seeking to provide other crypto-asset services must meet MiCA Article 62 conditions and submit required information to Finantsinspektsioon; the regulator lists governance, prudential safeguards, risk controls, client-asset segregation, ICT documentation, complaints handling, and service-specific policies among required materials.
• Issuer and token rules: Asset-referenced token issuers and certain credit institutions must follow the MiCA authorisation or notification path. E-money token offers are tied to credit institutions or e-money institutions, white-paper notification, and MiCA publication requirements.
• Cross-border services: Finantsinspektsioon describes a notification process for crypto-asset service providers intending to provide services in more than one member state, reflecting MiCA’s EU passporting structure.

MiCA applied in phases: Finantsinspektsioon explained that e-money token and asset-referenced token issuance, offers, and admissions to trading had to comply from June 30, 2024, while other crypto-assets and multiple crypto-asset services became subject to MiCA from December 30, 2024. Estonia’s Act allowed legacy Financial Intelligence Unit authorisation holders to continue under the old virtual-currency-services framework until July 1, 2026.

That transitional period has now ended. In a June 30, 2026 notice, Finantsinspektsioon said that from July 1, crypto-asset services in Estonia may only be provided by companies holding an authorisation from Finantsinspektsioon or another EEA supervisory authority under MiCA. The Financial Intelligence Unit was to cancel the register data for the prior virtual currency service provider licences on July 1, 2026.