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Slovenia

Crypto License in Slovenia (2026)

EU MiCA (CASP)Last reviewed 2026-08-24

Do you need a crypto license in Slovenia?

Yes. Providing crypto-asset services professionally in Slovenia requires CASP authorization from the Securities Market Agency (ATVP), and issuing e-money tokens requires separate authorization from Banka Slovenije as an electronic money institution or a bank. Every transition date reported for legacy providers has now passed, so there is no grandfathered route left open.

Read this before you plan an application

Slovenia's grandfathering window for legacy providers is reported two ways: a national transitional regime that ended on 1 July 2025, and the standard 18-month MiCA window under Article 143(3) that ended on 1 July 2026. Both dates have now passed, so the practical position is identical either way. Operating without a CASP authorization is not lawful today, and a business still leaning on a legacy registration should confirm its status with the ATVP before trading another day.

Slovenia transposed MiCA through its own Act Implementing the Regulation on Markets in Crypto-Assets, Official Gazette No. 95/2024, in force on 23 November 2024, a month before the EU's own 30 December 2024 application date. Authorization is split between two regulators. The ATVP, the Agencija za trg vrednostnih papirjev or Securities Market Agency, authorizes and supervises crypto-asset service providers. Banka Slovenije authorizes issuers of e-money tokens, who must already hold status as an electronic money institution or a bank. Four Slovenian firms sit on the ESMA register as of August 2026, three service providers and one token issuer, which makes this a small market running a fully live regime rather than a paper one.

Key facts

Regime
EU MiCA (CASP)
Regulator
Securities Market Agency (ATVP) and Banka Slovenije
Framework
EU Markets in Crypto-Assets Regulation (MiCA) (2023)
Minimum capital
EUR 50,000 for Class 1 services, EUR 125,000 for Class 2 and EUR 150,000 for Class 3, under MiCA Article 67
Time to license
25 working days for the ATVP to confirm the application is complete, then a 40 working day substantive assessment under MiCA Article 63; allow four to five months end to end once information requests are counted
Foreign owners
MiCA places no nationality restriction on who may own a crypto-asset service provider. The applicant must be a legal person established in Slovenia with management in the EU, and the authorization then passports into all 27 member states without a second application.

The framework

The Act Implementing the Regulation on Markets in Crypto-Assets, Official Gazette No. 95/2024, entered into force on 23 November 2024, ahead of MiCA's own EU-wide application date of 30 December 2024 for the full crypto-asset service provider regime. Slovenia therefore had its national implementing law in place before the regulation started to bite, which is not true of every member state.

Who authorizes what

The ATVP authorizes and supervises crypto-asset service providers: order handling, execution, placing, transfer services, advice, portfolio management, custody, exchange and the operation of a trading platform. Banka Slovenije authorizes and supervises issuers of e-money tokens, who must hold status as an electronic money institution or a bank, and who must notify it at least 40 working days before offering tokens to the public and 20 working days before publishing a white paper. The two roles do not overlap, so the first question an applicant has to answer is which of the two regulators it is actually going to.

Capital and service classes

MiCA Article 67 sets the own-funds floors and they are identical in every member state: EUR 50,000, EUR 125,000 or EUR 150,000 depending on the services provided. Slovenia adds nothing on top. Class is set by activity rather than by size, a firm providing services from more than one class is held to the highest floor that applies to it, and the safeguard is the higher of that floor or one quarter of the preceding year's fixed overheads.

Timeline

Under MiCA Article 63 the ATVP confirms whether an application is complete within 25 working days of receiving it, then runs a substantive assessment of 40 working days. Requests for further information pause that clock, which is why four to five months end to end is a more realistic plan than the 65 working days the articles add up to.

Who is authorized today

The ESMA register lists three Slovenian crypto-asset service providers as of August 2026: Ilirika, authorized on 20 September 2025, Incrementum on 6 November 2025, and Orcabay on 10 November 2025. Dinaro, an electronic money institution licensed by Banka Slovenije, joined the register in August 2026 as Slovenia's first e-money token issuer.

The transition window has closed

Slovenia's grandfathering period for legacy providers is the one date here worth checking rather than assuming. Published accounts split between a national transitional regime that expired on 1 July 2025 with no simplified conversion path, and the standard 18-month MiCA window under Article 143(3) closing on 1 July 2026. Both dates are behind us, so the practical answer is the same either way: a CASP authorization is required to operate in Slovenia now, and no legacy registration stands in for one. Anyone still relying on a legacy registration should confirm their position with the ATVP directly.

License classes in Slovenia

License classes, the activities each covers, and their fees and capital requirements where published.
ClassCoversFeeCapital
Class 1Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services for crypto-assets, advice on crypto-assets, and portfolio managementNot publishedEUR 50,000
Class 2Custody and administration of crypto-assets on behalf of clients, exchange of crypto-assets for funds, and exchange of crypto-assets for other crypto-assetsNot publishedEUR 125,000
Class 3Operation of a trading platform for crypto-assetsNot publishedEUR 150,000

What the application requires

  • A legal person established in Slovenia, with a registered office and effective management in the country
  • Own funds at the MiCA Article 67 floor for your highest service class, or one quarter of the preceding year's fixed overheads if that is greater
  • At least one director resident in the EU, and fit and proper clearance for the management body and qualifying shareholders
  • An AML and counter-terrorist financing programme meeting Slovenian and EU standards, including the travel rule on crypto transfers
  • ICT risk management, testing and incident reporting under DORA
  • A business plan, governance arrangements, and segregation of client crypto-assets and client funds
  • Complaints handling, conflict of interest and outsourcing policies as required by MiCA Title V
  • For e-money token issuers: authorization as an electronic money institution or a bank from Banka Slovenije, with notification 40 working days before a public offer and 20 working days before white paper publication

The application process

  1. Establish the Slovenian entity

    Incorporate a Slovenian legal person with a registered office and real management substance in the country, since MiCA authorization attaches to the establishment rather than to the group.

  2. Decide which regulator you are going to

    Crypto-asset services go to the ATVP. Issuing an e-money token goes to Banka Slovenije and requires electronic money institution or bank status first.

  3. Fix your service classes and capital

    Map each service you intend to provide onto MiCA Annex IV, then hold own funds at the highest class floor that applies, or one quarter of fixed overheads if greater.

  4. Compile the application dossier

    Business plan, governance, fit and proper evidence, AML and travel rule procedures, DORA documentation, custody and client asset segregation arrangements.

  5. File with the ATVP

    The ATVP confirms whether the application is complete within 25 working days under MiCA Article 63, and returns it for completion if it is not.

  6. Substantive assessment

    A 40 working day assessment follows, paused by any request for further information, which is where most of the real elapsed time goes.

  7. Authorization, register entry and passporting

    On approval the firm is entered in the ESMA public register and may notify its way into the other 26 member states without a second authorization.

Costs and taxation

The capital floors are EU law and identical across every MiCA member state, so a Slovenia-specific figure that differs from EUR 50,000, EUR 125,000 or EUR 150,000 is simply wrong. Fees are the softer number. Figures circulating for a Slovenian CASP application range from roughly EUR 5,000 to EUR 25,000, but those are licensing consultancies pricing their own packages rather than a published ATVP tariff, so confirm the supervisory fee with the ATVP before you budget against them.

Who is licensed today

Authorized Slovenian firms appear on the ATVP's own MiCA pages and in the ESMA public register of crypto-asset service providers. As of August 2026 that is three service providers, Ilirika, Incrementum and Orcabay, plus one e-money token issuer, Dinaro. Third-party trackers sometimes show a different count depending on when they last refreshed, so treat the ESMA register as the authority. See the official register.

Planning a license application in Slovenia?

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Frequently asked questions

Do you need a crypto license in Slovenia?

Yes. Providing crypto-asset services professionally in Slovenia requires CASP authorization from the ATVP under MiCA and the national implementing act, Official Gazette No. 95/2024. Issuing an e-money token is a separate track and requires authorization from Banka Slovenije as an electronic money institution or a bank.

Who regulates crypto exchanges in Slovenia?

The Securities Market Agency, known as the ATVP, authorizes and supervises crypto-asset service providers, including exchanges, custodians and trading platforms. Banka Slovenije handles e-money token issuers only. The two mandates do not overlap.

How much capital do you need for a Slovenian CASP license?

EUR 50,000 for Class 1 services, EUR 125,000 for Class 2 and EUR 150,000 for Class 3, under MiCA Article 67. The safeguard is the higher of that floor or one quarter of the previous year's fixed overheads. These are EU-wide figures and Slovenia adds nothing on top.

How long does ATVP authorization take?

The ATVP has 25 working days to confirm the application is complete, then 40 working days for the substantive assessment under MiCA Article 63. Requests for further information stop the clock, so four to five months end to end is the realistic plan.

Which crypto firms are licensed in Slovenia?

The ESMA register lists three Slovenian crypto-asset service providers as of August 2026: Ilirika, authorized on 20 September 2025, Incrementum on 6 November 2025, and Orcabay on 10 November 2025. Dinaro joined in August 2026 as the country's first e-money token issuer, licensed by Banka Slovenije.

Has Slovenia's MiCA transition period for legacy providers ended?

Yes. Accounts differ on whether the window closed on 1 July 2025 under a national transitional regime or on 1 July 2026 under the standard 18-month MiCA period, but both dates have passed. A CASP authorization is required now, and anyone still operating on a legacy registration should confirm their position with the ATVP.

Sources

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