Not always. In the EU, buying and selling crypto with clients from your own capital needs a crypto-asset service provider (CASP) authorisation only; the European Banking Authority advises that exchange is not a payment service. You need a payment licence, or a licensed partner, once you pay client money onward to third parties or, on the EBA's advice, transfer and hold e-money tokens for clients.
Four numbers to read before you build a ramp
Still choosing a licence type? Start with licence selection. This page answers one question for an on-ramp or off-ramp: when does the fiat side need its own authorisation?
The short version
- Under MiCA, exchanging crypto-assets for funds is a CASP service with a minimum capital of EUR 125,000.
- The EBA advises national authorities not to treat that exchange as a payment service.
- The EBA advises treating transfers and custody of e-money tokens for clients as payment services, with a payment licence or licensed partner due no later than 2 March 2026.
- Singapore puts both legs on one licence; the UK and US run two regimes.
On this page7 sections
Is exchanging crypto for fiat a payment service?
Not in the EU, on the EBA's reading. MiCA lists "exchange of crypto-assets for funds" as a crypto-asset service in Article 3(1)(16) and defines it in Article 3(1)(19) as concluding purchase or sale contracts with clients for funds by using proprietary capital. Under Article 59(1) it needs CASP authorisation or one of the other listed statuses.
The Commission's letter, cited in paragraph 69 of the EBA's No Action letter of June 2025, says exchange is not a payment transaction where the CASP acts in its own name as buyer or seller, not as an intermediary between a payer and a payee, and makes no other EMT transfers for clients; the EBA's own reason is that exchange uses the CASP's proprietary capital. On that reading, a client who pays you euros and receives tokens in their own wallet is a CASP matter. Annex IV puts exchange and custody in class 2 at EUR 125,000; other services you may trigger are in MiCA CASP scope.
When does the fiat side need PSD2 authorisation?
Once you pay client money onward to anyone other than the client. Under Article 70(4) of MiCA, a CASP may provide payment services related to its crypto-asset service itself or through a third party, only if it, or that third party, is authorised under the second Payment Services Directive (PSD2, Directive (EU) 2015/2366), and it must tell clients which of the two provides them (see where to apply for an EU payment licence).
Article 70(3) also requires a CASP to place clients' funds, other than e-money tokens, with a credit institution or a central bank by the end of the business day after receipt, in a segregated account; under Article 70(5) that does not apply to a CASP that is itself an e-money, payment or credit institution.
So the trigger is where the money goes next: settling a client's own purchase is exchange; paying proceeds to a merchant or supplier needs a payment licence on your side or your partner's.
What changed for stablecoin transfers on 2 March 2026?
MiCA calls a stablecoin that references one official currency an e-money token (EMT). The EBA advises treating three EMT activities as PSD2 payment services: EMT transfers on behalf of clients; custody and administration of EMTs; and, as a payment account, a custodial wallet in a client's name that can send EMTs to and receive them from third parties.
Paragraph 18 sets the date: once a firm holds a PSP licence or has a partnership with a PSP, "but no later than 2 March 2026". After that, authorities are advised to stop firms that have neither. In its press release the EBA states its longer-term view:
"EU law needs to avoid a dual authorisation under two pieces of EU law for the activity of transacting electronic money tokens"
Until legislators act, the EBA's advice treats an off-ramp that holds client stablecoins in a hosted wallet and sends them on to third parties as providing a payment service.
Can an EMI run the crypto side instead?
Only in a narrow lane. Under Article 60(4) of MiCA, an e-money institution (EMI) may provide custody and transfer services only for the e-money tokens it issues itself, after notifying its home authority at least 40 working days in advance. An EMI running a ramp therefore still needs CASP authorisation. Compare them in EMI vs API vs MPI.
Outside the EU: one licence, two, or a registration plus state licences
Outside the EU the count differs: Singapore uses one payment institution licence for both legs, the UK adds FCA cryptoasset registration to any e-money or authorised payment institution (API) licence, and the US pairs federal FinCEN registration as a money services business with state money transmitter licences.
The crypto leg and the fiat leg of an on/off-ramp in four jurisdictions
| Jurisdiction | Crypto leg (exchange) | Fiat leg (paying third parties) | Outcome |
|---|---|---|---|
| EU | CASP authorisation, EUR 125,000 floor for exchange | PSD2 authorisation, held by you or a third party | One authorisation for exchange alone; a second, or a partner, for onward payments and EMT transfers |
| Singapore | Digital payment token service | Cross-border (or domestic) money transfer service | Both services on one SPI or MPI licence |
| UK | FCA registration as a cryptoasset exchange provider | EMI or API | Two regimes; an EMI or API must still register |
| US | FinCEN money services business registration plus state licences | As left | Federal registration plus state licences |
In Singapore, under the Payment Services Act, dealing in digital payment tokens means buying or selling them for money or other tokens, and accepting money in Singapore to send to anyone abroad is a cross-border money transfer service. One standard (SPI) or major payment institution (MPI) licence can cover two or more such services; it must be an MPI licence once monthly average volume passes SGD 3 million for any one service, or SGD 6 million across two or more. See which Singapore crypto licence you need.
In the UK, Regulation 14A of the Money Laundering Regulations 2017 makes anyone exchanging cryptoassets for money, or money for cryptoassets, by way of business a cryptoasset exchange provider, and the FCA states that e-money and payment institutions must also register for it. As at 1 October 2026 the FCA had received 427 applications since January 2020 and determined 393, of which 68 (17%) were registered. More in the UK API licence and its crypto limit.
In the US, FinCEN's guidance on convertible virtual currencies says exchangers of virtual currency generally qualify as money transmitters. Money services business registration is due within 180 days of establishment and renewed every two years, and states license money transmission separately; per CSBS, thirty-one states have enacted the Money Transmission Modernization Act in full or in part. See MSO and MSB for crypto.
Your own payment licence, or a licensed partner?
Both routes are in the rules: Article 70(4) allows a third party to provide the payment services, and the EBA treats a PSP partnership as an alternative to the licence. For the wider map, see which licence a crypto exchange needs and banking for licensed crypto businesses.
- Licensed partner. No second application or capital floor, but client money moves through the partner's accounts, you must tell clients the payment service is theirs, and the partner sets the terms.
- Your own payment institution (PI) or EMI. You control the money flow, at the price of a second set of capital, AML and compliance obligations.
Frequently asked questions
Does a fiat-to-stablecoin on-ramp in the EU need a payment licence?
Not for the exchange itself: the EBA advises that exchanging crypto-assets for funds from your own capital is not a payment service. Paying client money onward to third parties needs PSD2 authorisation or a licensed partner, and on the EBA's advice so do transfers and custody of e-money tokens for clients.
Can an EMI licence cover crypto exchange?
No. Under Article 60(4) of MiCA an e-money institution may only provide custody and transfer services for the e-money tokens it issues; exchange still needs crypto-asset service provider (CASP) authorisation. In the UK an EMI must also register separately with the FCA.
Do I need two licences for an on/off-ramp in Singapore?
Not necessarily. A digital payment token service and a money transfer service can sit on one standard or major payment institution licence under the Payment Services Act; above the volume thresholds it must be the major one.
This page reflects MiCA, EBA, Singapore, UK and US publications as of October 2026 and is not legal advice. CryptoLicense is the licensing advisory brand of CL GLOBAL SDN BHD (1421939-T); its services include Latvia and Malta CASP, Latvia API/EMI, Singapore MPI, UK API/EMI, US MSB and bank account opening. Whether a licence is granted, and how long a regulator takes, is at the regulator's discretion; we promise neither. See fintech licences and entity proof.
Related reading: Jurisdictions.