Guide
Malta crypto licence cost: the MFSA fees, and the ones nobody publishes
Updated
Malta publishes more of its crypto licensing cost than almost any other EU regulator. What it does not publish, and nor does anyone else, is what the advisers will charge you.
What the MFSA charges
Every figure is in the Markets in Crypto-Assets Act (Fees) Regulations, subsidiary legislation 647.01, made by Legal Notice 295 of 2024. Our fee table lists all of them. The three that dominate a budget are the application fee of EUR 10,000, EUR 20,000 or EUR 25,000 by class, the annual supervisory class element of EUR 10,000, EUR 25,000 or EUR 50,000, and the EUR 2,000 charged for every service the licence covers.
Two details in the small print
- The first supervisory payment is prorated, twice. Regulation 6(6) makes the first annual supervisory fee the sum of two prorated slices: the period from authorisation to the end of that calendar year, and the period from the start of the following year to the date the next fee is due. Regulation 6(7) makes every subsequent fee payable on 30 July.
- Nothing is refundable. Regulation 7 states the fees are not refundable and, apart from the first supervisory payment, are not prorated. A withdrawn application does not get its fee back.
- The transaction element only bites later. The 0.05% of transaction volume, capped at EUR 250,000, is calculated from the preceding year's annual return, so a first-year applicant has no volume to report.
- Adding services is cheaper than starting again. Regulation 6(3) charges the ordinary application fee less 25% to extend an authorisation; regulation 6(4) charges a flat EUR 1,000 to drop a service.
Capital, which is not a fee
Annex IV to Regulation (EU) 2023/1114 requires permanent minimum capital of EUR 50,000 for class 1 services, EUR 125,000 once custody or exchange is included, and EUR 150,000 once a trading platform is operated. Article 67 requires the higher of that and one quarter of the preceding year's fixed overheads, and allows an insurance policy on prescribed terms in place of own funds. This money stays on your balance sheet.
The part with no published price
Legal drafting, compliance consultancy, audit sign-off, ICT assurance and the salaries of the local directors, Compliance Officer and MLRO the file commits you to are usually larger than the MFSA fees, and no regulator or trade body publishes them. We do not publish a range for them, because any number we picked would be a guess dressed as a benchmark. What we can tell you is what moves the figure: the number and class of services, whether a trading platform is in scope, the custody model, how many people need fit and proper evidence, and how many rounds of MFSA questions follow submission.
Get at least two written quotes against the same scope: the exact services you will apply for, the custody model, and whether the adviser handles the pre-licensing conditions as well as the application. That is a comparison. A single all-in figure is not.