MiCA regulation in Austria: Licensing, implementation, and what crypto firms need to know

Imagine a harmonised rulebook for crypto-assets across 27 EU countries—no more patchwork of national laws, no more uncertainty when you expand. That’s exactly what the Markets in Crypto-Assets Regulation (MiCA) delivers, and it landed on 29 June 2023. 

If you’re running an exchange, wallet service, broker, or issuing tokens, MiCA reshapes how you operate, report, and protect clients. In Austria, MiCA applies directly, but the local MiCA-Enforcement Act (MiCA-VVG) and FMA guidelines give you the play-by-play on implementation. 

In this article, I’ll walk you through the licensing requirements, critical deadlines, dossier essentials, and practical steps so you can turn this regulatory shift into a strategic advantage with clear guidance.

You need a CASP licence if you handle crypto services

If you “professionally provide” any crypto-asset service, MiCA Article 62 says you need CASP authorisation. That covers exchanges and trading venues, custodial-wallet providers, brokers, asset-referenced and e-money token issuers, and crypto-fiat payment services. 

Even if you only store keys or execute orders, you fall under MiCA’s umbrella.

PRO TIP

Inventory every service line in your business—no matter how niche—to confirm which ones trigger CASP authorisation under MiCA.

Key dates you can’t ignore

Here’s your timeline for locking down authorisation and keeping operations running without a hitch:

PRO TIP

Plug these dates into a shared compliance calendar and set automated reminders—missing one stops you cold.

Building your authorisation dossier with confidence

MiCA demands proof of your fitness, governance structure, and financial health. The FMA’s Circular flags these must-haves:

• Program of Activities: Spell out exactly what you do, who you serve, and how you make money.
  
• Governance Framework: Show an org chart, clear roles, outsourcing policies, and a “Let’s Talk Supervision” summary of third-party deals.
  
• Risk Management & Controls: Detail your AML/KYC steps, travel-rule messaging, transaction monitoring, and suspicious-activity workflows.
  
• Technical & ICT Specs: Include system diagrams, cybersecurity measures, penetration-test reports, and resilience plans.
  
• Capital & Resources: Prove you hold €50 000–€150 000 in your own funds, plus cold-wallet insurance and client-asset segregation.
  
• Fit & Proper Assessments: Upload CVs and integrity attestations for key staff with clean records.
  
• White Paper & Disclosures: For token issuers, standardise governance, fees, and redemption mechanism disclosures.
  

PRO TIP

Use a project-management dashboard to tick off each dossier component against the FMA’s checklist—visibility equals fewer surprises.

What you must tackle beyond the licence

MiCA isn’t a one-and-done form-filling exercise. You’ll need to:

Engage the FMA early

I always recommend booking bilateral meetings with the FMA well before submission deadlines. These sessions help you clarify dossier ambiguities, set realistic timelines, and understand any Austria-specific expectations. Early dialogue reduces the risk of time-consuming follow-up questions and accelerates your path to authorisation.

Align AML/KYC and Travel-Rule messaging

MiCA’s travel-rule requirements add another layer to Austria’s existing AML framework. You’ll need to weave MiCA messaging seamlessly into your current KYC processes, ensuring data flows comply with both regimes. A unified policy prevents overlapping controls that confuse staff and auditors alike.

Cultivate a robust compliance culture

Regulation isn’t just about forms; it’s about mindset. A dedicated compliance function reporting directly to your board demonstrates commitment at the highest level. Document conflict-of-interest policies and outsourcing arrangements clearly to show the FMA you’ve baked governance into your DNA.

Bolster technical resilience and security

MiCA expects you to detail cybersecurity controls, penetration-testing reports, and operational-resilience plans. Regular pen tests and redundant infrastructure are non-negotiable. Equally important is an incident-response protocol that outlines clear reporting lines and timelines, so you can meet MiCA’s notification requirements without scrambling.

Plan for passporting and expansion

One of MiCA’s big perks is EU passporting: once authorised in Austria, you can offer services across Member States without new licences. To leverage this, map out target markets, translate key disclosures, and confirm local investor-protection nuances. Early planning lets you hit the ground running post-authorisation.

Budget for transition costs

Between supervisory fees, higher capital buffers, and external audits, MiCA compliance has a price tag. Building these costs into your annual budget now avoids last-minute cash-flow crunches. Think of it as an investment: strong compliance translates to client trust and lower regulatory risk.

Tailor your token-issuer white paper

For asset-referenced and e-money token issuers, the white paper is your disclosure cornerstone. Beyond the MiCA template, weave in Austrian investor-protection highlights, such as local redemption rights or supervisory safeguards. A customised white paper signals dedication to both EU and domestic standards.

Prepare for penalties and enforcement

MiCA’s enforcement teeth are sharp: fines up to 5% of annual turnover or €5 million per breach, plus up to €1 000 000 under MiCA-VVG for procedural slip-ups. Treat compliance gaps as business risks and maintain a tracker of open action items. Regular audits ensure you catch issues well before inspectors do.

PRO TIP

Use scenario-based tabletop exercises to rehearse enforcement and breach-notification workflows, so your team reacts swiftly under pressure.

Your roadmap to MiCA-ready operations

To get ahead of the curve, follow this action plan:

1. Gap Analysis: Compare your processes with MiCA’s requirements—start with AML, governance, and ICT.
   
2. Dossier Assembly: Gather policies, blueprints, and financials per FMA templates.
   
3. FMA Engagement: Schedule pre-application sessions and share draft questions with your timeline.
   
4. Internal Training: Roll out workshops on MiCA duties, reporting, and breach-notification protocols.
   
5. Stay Updated: Watch for ESMA and EBA RTS/ITS to refine your procedures as delegated standards land.
   

PRO TIP

Hold monthly “MiCA Standups” with legal, IT, risk, and ops teams to keep momentum and clear blockers fast.

Streamline MiCA Compliance with CyberUpgrade

Meeting MiCA’s rigorous requirements—from whitepaper filings to ongoing governance and transparency—often means endless manual tracking and audit prep. CyberUpgrade automates your MiCA workflows with prebuilt templates and real-time Slack or Teams prompts, keeping policies, risk assessments, and evidence audit-ready in one central hub.

Beyond MiCA, CyberUpgrade also supports DORA, ISO 27001, and NIS 2 frameworks, letting you “map once, prove many” across multiple regulations. Automated data extraction, vulnerability scans, and KPI dashboards feed each regulator’s portal seamlessly, reducing manual work by up to 80 %.

With fractional CISO services guiding your continuous monitoring and customizable compliance workflows, you’ll secure faster approvals, avoid fines, and adapt as MiCA and related frameworks evolve—turning compliance from a hurdle into a strategic advantage.

Ready to turn regulation into opportunity?

MiCA is your chance to build rock-solid controls, earn client trust, and unlock EU passporting. By leaning in now—engaging with the FMA, shoring up AML/KYC, and refining your governance—you’ll transform MiCA from a hurdle into a competitive advantage. What’s your first move?