How Key2Law secured MiCA transitional status for a Czech CASP without business interruption

In the Czech Republic, the MiCA regulatory framework entered into force under a unique transitional regime. According to the transitional period rules:

“Crypto-asset service providers that provided their services in accordance with applicable law before 30 December 2024 may continue to do so until 1 July 2026, or until they are granted or refused authorisation pursuant to Article 63, whichever is sooner”.

However, to be able to benefit from the aforementioned transitional period, applicant should apply for a MiCA license until 31.07.2025.

This created both an opportunity and a strict deadline for all existing crypto-asset businesses operating in the Czech market.

For our client, it was crucial to submit a complete and compliant CASP licence application on time to preserve the legal right to continue providing crypto-asset services without interruption. Any delay or incomplete filing could have resulted in the immediate loss of operational capacity, regulatory non-compliance, and the inability to serve clients.

Key2Law was engaged to ensure that the company successfully entered the transitional regime, maintained uninterrupted service delivery, and advanced through the MiCA authorisation process with full regulatory confidence.

Client

A mid-size Czech crypto-asset service provider offering exchange, custody, and on-ramp/off-ramp solutions. The company sought to continue its operations legally under EU MiCA and Czech national rules while preparing for full CASP licensing.

The client approached Key2Law shortly before the MiCA transitional deadline.
They needed to:

1. Submit a fully compliant MiCA CASP license application to the Czech National Bank (ČNB),
2. Create AML/CT and internal controls documentation to align with MiCA, AMLD, ESMA/EBA standards, and Czech law,
3. Prepare to the ČNB’s complex questions during the assessment phase;
4. Create business plan;
5. Create ict docs;
6. Preserve the transitional regime allowing them to continue operations until 31 June 2026.

The main obstacles included: regulatory uncertainty, high documentation requirements, complex business model, tight deadlines, and the risk of losing the ability to legally provide crypto-asset services.

Key2Law delivered a complete regulatory and compliance solution tailored to MiCA and Czech regulatory expectations:

1. Full MiCA CASP application preparation

We prepared and submitted the entire licensing package, including:

1. Business Plan aligned with MiCA;
2. Comprehensive AML/CTF framework;
3. ICT policies;
4. Custody, segregation, commercial, internal governance and risk policies;
5. Client-facing disclosures and Terms & Conditions.

2. Regulatory correspondence & Representing the client before ČNB

We supported the client during two full rounds of regulator’s written inquiries, preparing:

• Detailed legal arguments;
• Clarifications on operational setup;
• Additional financial, ICT, AML and governance documentation.

3. Ensuring transitional regime eligibility

We verified regulatory deadlines, ensured correct timing of submission, and structured the application so that the client:

• Remains fully compliant with MiCA transitional rules;
• Retains the right to continue providing crypto services until 31 June 2026;
• Avoids legal interruptions in service delivery.

What steps did we take to support the client?

Step 1. Regulatory & Gap analysis

We assessed the client’s existing operational model, documentation and AML/internal controls to identify gaps against MiCA and Czech requirements.

Step 2. Drafting & Rebuilding documentation

Key2Law drafted more than 30 regulatory documents, including AML, ICT documents, Business plan, complaints handling, custody, risk management, governance and commercial policies.

Step 3. CASP application submission

We prepared and submitted the full application to ČNB before the established deadline.

Step 4. Regulator communication

We managed to answer to both rounds of ČNB inquiries, addressing compliance, operational and technical requirements.

Step 5. Ongoing monitoring

We continue to support the client with compliance monitoring and policy updates.

What benefits did the client gain?

1. Transitional status secured: the client legally continues providing crypto-asset services in the Czech Republic under MiCA transitional rules until 31 June 2026.
2. Successful passage of two inquiry rounds: all requests from the regulator were answered professionally and on time.
3. Zero business interruption: the client has not experienced any service limitations and remains fully compliant.
4. Full MiCA-ready documentation package: the firm now operates under a robust compliance and security framework aligned with MiCA, AMLD, ESMA/EBA and Czech national rules.
5. Ongoing regulator confidence: the applicant remains in good standing with ČNB while awaiting final CASP authorization.

If you want to secure your MiCA transitional status, prepare your CASP application, or communicate effectively with your national regulator - Key2Law is ready to help you at every step. Contact us to schedule a consultation and get expert support for your licensing process.