How Long a MiCA CASP Licence Takes: The Real 2026 Timeline

The question with a misleading easy answer

“How long does a MiCA CASP licence take?” is the first question almost every founder asks. The easy answer — “25 plus 40 working days” — is technically a real number from the Regulation, and practically misleading. It describes a clock that only starts after a milestone most applicants underestimate: the regulator declaring the file complete.

Understanding the difference between the statutory clock and the real timeline is the difference between a realistic launch plan and a plan that slips by months.

How the statutory clock works

MiCA’s statutory authorisation clock sets the formal procedure for assessing a CASP application:

Stage	The statutory authorisation clock rule
Completeness check	Within 25 working days of receiving the application, the regulator assesses whether it is complete
Substantive assessment	Within 40 working days of receiving a complete application, the regulator adopts a fully reasoned decision granting or refusing authorisation
Information requests	The regulator may request further information during assessment, generally no later than the 20th working day
Decision notification	The applicant is notified of the decision within 5 working days of it being taken

Two features matter most:

1. The 40-day assessment clock starts on completeness, not on filing. The completeness check is a separate, earlier 25-working-day window. If the file is not complete, the regulator does not start the 40-day clock — it goes back to the applicant.

2. The formal 40-day clock is not paused by information requests. During the assessment the regulator can ask for more information, generally by the 20th working day, without formally stopping the clock — though in practice the completeness determination is where most iteration happens.

Add it up and the statutory clock for a complete file is roughly 65 working days — about three months.

Why the real timeline is longer

The statutory three months assumes a complete, well-evidenced file arriving at the regulator. The real timeline — practitioner-reported commonly at 4 to 8 months filing-to-decision — is longer because of three factors the statutory numbers do not capture.

1. The pre-completeness phase

This is where most calendar time goes. Before the 40-day clock starts, the file has to be complete. A file that arrives thin triggers a cycle: the regulator identifies gaps, the applicant fills them, the regulator re-checks. Each cycle is weeks. A strong file clears completeness fast; a weak one can spend months there.

2. Information-request turnaround

During the assessment, the regulator can request further information. The clock may not formally pause, but the applicant’s response speed is entirely within the applicant’s control — and it directly drives total time. A firm that answers each request in days keeps things moving; a firm that takes weeks per response stretches the real timeline well beyond the formal clock.

3. Supervisory pace by jurisdiction

The statutory clock is EU-wide. Supervisory practice is not. Different national competent authorities move at different real-world speeds on clean files, depending on their CASP caseload and capacity. The clock is the same; the experience is not.

Cited expert

In addition, [ESMA](/glossary/esma/) is actively contributing to MiCA's effective implementation, in close cooperation with the European Banking Authority and National Competent Authorities, including through intense supervisory convergence efforts, information sharing, and guidelines.

What actually makes an application fast

The single biggest determinant of timeline is file quality at filing. The fastest applications are not the ones filed earliest — they are the ones filed complete. Specifically:

1. A genuinely complete file — all the documentary set MiCA requires, populated with the firm’s own specifics rather than templates, so the completeness check passes quickly.

2. Pre-application engagement — where the regulator offers pre-application dialogue, using it surfaces gating issues (substance, business model, governance) before the formal review rather than during it.

3. Fast, complete information-request responses — a prepared applicant with its documentation organised answers requests in days, not weeks.

4. Realistic jurisdiction choice — choosing a home regulator on the basis of the firm’s actual readiness and the regulator’s real practice, not on an advertised “fastest” claim.

A realistic planning model

For planning purposes, a sensible model is:

• Preparation — 2 to 4 months to build a genuinely complete, well-evidenced file (this is work, and rushing it costs more time later than it saves)
• Completeness phase — weeks if the file is strong, longer if it is thin
• Formal assessment — the ~40-working-day statutory window once complete
• Decision and notification — within 5 working days of the decision

The honest headline for a founder: plan for the better part of a year from “we decide to do this” to “we hold the licence”, with the preparation phase being the part you most control.

Working with counsel on the timeline

The diagnostic for counsel: ask not “how fast can you file” but “how do you get a file to complete without multiple completeness cycles” — and whether they use pre-application engagement. Counsel that promises a fast timeline by filing quickly has the incentive backwards. The firms in our index with documented multi-file CASP experience are listed below.