Latvia issues no instrument called a crypto licence. What you apply for is authorisation as a crypto-asset service provider under MiCA, decided by Latvijas Banka, and the file-review fee is a one-off EUR 2,500. An e-money institution licence is a separate instrument answering a separate question — whether you may issue electronic money.
Four numbers from the register and the fee sheet
Four things to hold on to
- The authority is Latvijas Banka. The Financial and Capital Market Commission was absorbed into it on 1 January 2023.
- The two routes price differently: EUR 2,500 to review a crypto-asset file against EUR 5,000 for an e-money institution, and a 25 against 15 working-day completeness check.
- Capital is not simply the Annex IV figure. You hold the higher of that figure and a quarter of last year's fixed overheads.
- Of Latvia's 12 registered providers, none holds a Latvian e-money institution licence and five hold a payment institution licence.
On this page8 sections
What does Latvia's register actually show?
Twelve firms hold crypto-asset service provider status in Latvia, every one supervised by Latvijas Banka. The figures come from the register ESMA publishes under MiCA (CASPS.csv, last modified 16 October 2026, downloaded and counted for this article on 18 October 2026).
That file carries 378 entries across the EU and EEA covering 375 distinct legal entity identifiers. Twelve give Latvia as the home Member State. The earliest is BlockBen SIA, dated 3 December 2025; the most recent two, Atrya Technologies SIA and Noah LV SIA, are dated 30 September 2026. Latvijas Banka's own Financial Market Participants Register listed the same twelve that day, so the registers corroborate each other.
What those twelve are registered to do is more useful than the headline count. Ten are registered for custody and administration of crypto-assets, ten for exchange of crypto-assets for funds, nine for exchange of crypto-assets for other crypto-assets and nine for transfer services. Exactly one operates a trading platform. Read those service lists against Annex IV and a budgeting point falls out: all twelve carry at least one service that Annex IV places in Class 2 — custody and administration, exchange for funds, or exchange for other crypto-assets — and one of them, SIA AlphaRoute, also operates a trading platform and so reaches Class 3. None is registered for Class 1 services alone. On that reading, nothing in Latvia sits at the EUR 50,000 tier. One limit travels with the mapping: the register's legal-basis field is blank for all twelve Latvian rows, so it does not record whether any of them entered by Article 63 authorisation or by Article 60 notification, and Article 60(10) disapplies Article 67 — and with it Annex IV — to entities on the notification route. That blank is the norm rather than the exception: of the 378 entries on the file only 199 record a route at all, 123 of them Article 60 notifications against 76 Article 63 authorisations.
What else those firms hold is the decision-relevant part. Matching the twelve by name against the Latvian records in the European Banking Authority's PSD2 register the same day, not one holds a Latvian electronic money institution licence. Five hold a Latvian payment institution licence: SIA "Paybis Europe" on ESMA's register and Paybis Europa SIA on the EBA's — the same firm, one letter apart — together with "Trek Technologies" SIA, Neverless SIA, Nodu Digital, SIA and Noah LV SIA. Four of those five carry the same date on both registers: Paybis on 12 May 2026, Trek Technologies on 27 May, Nodu Digital on 8 July, Noah LV on 30 September. From the other side, Latvia has eleven licensed e-money institutions and none appears on the crypto-asset register. The match is on entity names, so a licence held by a differently-named group company would not show up. Where to file on the payments side, and in which tier, is set out in EU Payment Licence: What the Country Decides.
Those company names are public register entries, not CryptoLicense clients. One of them makes the division of labour concrete in the other direction: on ESMA's e-money token register Latvia has a single entry, SIA GR8 PAY, a licensed e-money institution that does not appear on the crypto-asset register at all.
Not sure which side you fall on?
Send your business model, where your clients are and who holds the keys to Telegram @fever23 and you will get a view back: which of MiCA's ten services your activity falls under, whether the payments side needs assessing too, and which document to start on first.
Who authorises a crypto business in Latvia?
Latvijas Banka, and only Latvijas Banka. In the release announcing the merger it stated that "As of 1 January 2023, the Financial and Capital Market Commission (FCMC) will be integrated into Latvijas Banka", under a Saeima decision of 23 September 2021 (Latvijas Banka's merger release). Santa Purgaile — then Chairwoman of the FCMC, and Deputy Governor of Latvijas Banka from 1 January 2023 — said in the same release that "1 January 2023 will mark the beginning of a new stage in the supervision of Latvia's financial sector". One authority now licenses crypto-asset service providers, payment institutions and electronic money institutions alike.
Worth confirming before you read on, because material selling Latvian licences gets this wrong: one guide calls the FCMC Latvia's financial intelligence unit. It is neither that nor the current regulator, and fktk.lv now returns a permanent redirect to bank.lv.
Which authorisation does your model actually need?
The two instruments govern different things. A crypto-asset service provider authorisation governs what you do with clients' crypto-assets; an e-money institution licence governs whether you may issue electronic money. MiCA Article 59(1) allows crypto-asset services in the Union only from a person authorised under Article 63, or from one of the already-regulated entities listed in Article 60.
Which you need turns on whether you intend to issue your own stablecoin. MiCA Article 48(1) provides that nobody may offer an e-money token to the public in the Union unless they are the issuer and are "authorised as a credit institution or as an electronic money institution", with a white paper notified and published under Article 51 — though the same paragraph lets another person offer the token with the issuer's written consent, and Article 48(4) lifts that paragraph alone rather than the Title: "Paragraph 1 of this Article shall not apply to issuers of e-money tokens exempted in accordance with Article 9(1) of Directive 2009/110/EC." Article 48(7) then puts the white paper back — an issuer relying on that exemption must still "draw up a crypto-asset white paper and notify such crypto-asset white paper to the competent authority in accordance with Article 51". So issuing a euro stablecoin requires credit-institution or e-money-institution status, not a crypto-asset authorisation; and neither does anything for a firm that only custodies, exchanges or transfers assets for clients.
Do you need both an EMI licence and a CASP authorisation in Latvia?
Whether an existing EMI must apply separately is a question in its own right, taken service by service in After the MiCA Transition: Which CASP Services You Trigger. The Latvian footnote is that Latvijas Banka runs that route itself: its page for already-licensed participants states that electronic money institutions may obtain authorisation for the services in points (17) and (26) of Article 3(1), applying "at least 40 business days" before they first provide them. Point (17) is custody and administration of crypto-assets for clients; point (26) is transfer services for clients. Two limits travel with that route and both matter. Exchange for funds, exchange for other crypto-assets, order execution and operating a trading platform are outside it and need full Article 63 authorisation. And MiCA Article 60(4) confines even those two services to the institution's own token: an electronic money institution "shall only provide custody and administration of crypto-assets on behalf of clients and transfer services for crypto-assets on behalf of clients with regard to the e-money tokens it issues" on that notification. Holding a client's bitcoin is not on this route.
How much capital does a Latvia crypto licence require?
On the crypto side Annex IV sets three figures by service type, and its heading is explicit that these are the "Minimum capital requirements under Article 67(1), point (a)" — one leg of the test, not the test itself. Article 67(1) requires prudential safeguards at all times of at least the higher of the Annex IV amount and a quarter of last year's fixed overheads.
The regulation puts the second leg as "one quarter of the fixed overheads of the preceding year, reviewed annually". Once a firm is spending at any scale, that leg overtakes the Annex IV figure.
Capital: the three Annex IV tiers, and the leg that can overtake them
| Tier / licence | Amount | What triggers it |
|---|---|---|
| Annex IV Class 1 | EUR 50,000 | Execution of orders, placing, transfer services, reception and transmission of orders, advice, portfolio management |
| Annex IV Class 2 | EUR 125,000 | Any Class 1 service plus custody and administration, exchange for funds, or exchange for other crypto-assets |
| Annex IV Class 3 | EUR 150,000 | Any Class 2 service plus operating a trading platform |
| Article 67(1)(b) | One quarter of last year's fixed overheads | Take whichever is higher; reviewed annually |
| EMI initial capital | EUR 350,000 | EMD2 Article 4; the same figure in Latvia's own Section 12(2) |
On substance, the crypto route's rule is MiCA Article 59(2): a registered office in a Member State where the firm carries out at least part of its services, its place of effective management in the Union, and at least one director resident in the Union. The jurisdiction-by-jurisdiction comparison is in Local Substance Requirements Explained.
What is the minimum capital for a Latvian EMI licence?
EUR 350,000, in place on the day the licence decision is taken. Latvia's Law on Payment Services and Electronic Money requires at Section 12(2) that an electronic money institution "shall ensure that on the day when the decision to issue an electronic money institution operating licence is taken, its initial capital is at least EUR 350 000", matching EMD2 Article 4.
Own funds for the issuing business are then calculated under EMD2 Article 5(3)'s Method D at no less than 2% of average outstanding electronic money. Section 7(1) of the same Law adds that "the executive board and legal address (official seat) of an institution licensed in Latvia shall be situated in the Republic of Latvia". For an institution merely entered in the register rather than licensed, the Latvijas Banka pages cited here publish no separate capital figure.
What goes into the application, and what does it cost?
Latvijas Banka charges a one-off EUR 2,500 to review a Latvian crypto-asset authorisation file. An e-money institution file costs EUR 5,000, payable on official submission, dropping to EUR 450 where the applicant intends to offer only an innovative service in the field of electronic payments. Both are examination fees for the file itself, charged once.
Latvijas Banka's crypto licensing page asks for the completed application plus everything required by Article 62 of MiCA and the technical standards made under it. Within Article 62(2), point (e) requires proof of the Article 67 prudential safeguards and point (d) a programme of operations.
Four documents are required in every Latvian CASP application, whatever services you offer:
- an internal control system for money laundering, terrorism and proliferation financing and sanctions risk, with a detailed assessment of the risks inherent in the services offered;
- segregation of client crypto-assets and funds from the firm's own;
- a complaints-handling procedure;
- a policy for supervising and controlling outsourced functions, where any are outsourced.
Others are service-triggered — platform rules and market-abuse detection for a trading platform, a pricing methodology for exchange, an execution policy for order execution. The e-money institution file adds evidence of the initial capital and a description of the measures safeguarding the money of payment service users and e-money holders. Worth using: Latvijas Banka "provides free pre-licensing support for businesses that have already decided to obtain authorisations in Latvia", and tells applicants to take that advice before filing (Latvijas Banka, services for fintechs). If card issuing or stablecoin payments are in scope, Which Licence for Stablecoin Payments and Card Issuing maps those separately.
What are the statutory time limits?
Neither clock starts when you first file. On the crypto side Latvijas Banka runs a completeness check "within 25 working days", then decides within 40 working days of confirming the file is complete. On the e-money side it is 15 working days for completeness and a decision within 3 months of that confirmation.
The bank is explicit that the first stage is not an assessment: during the completeness check "a substantive assessment of the application has not yet been initiated". Only after the file is confirmed complete does the substantive review begin and the decision to issue or refuse authorisation follow.
MiCA Article 63 reads the same way: acknowledgement within five working days, completeness within 25, and a fully reasoned decision within 40 working days of receipt of a complete application. Two qualifications travel with those numbers. Latvijas Banka states that "the review deadline for the application may be extended for objective reasons if the information provided in the application is insufficient to take a decision". And a statutory period is a working deadline on the regulator, not a delivery date anyone can promise. Whether an authorisation is granted is at the regulator's discretion, nobody can guarantee the outcome, and we do not offer one.
What do you have to keep doing after authorisation?
Authorisation starts an obligation rather than ending one. MiCA Article 68(9) requires records of all services, activities, orders and transactions to be kept for five years, and up to seven where the competent authority asks before the five elapse. The Article 67 safeguards must be met "at all times", so the capital requirement climbs as the business grows.
The recurring duties are set out in Crypto Licence Annual Obligations, and how to check any firm's entry yourself in How to Check a Crypto Licence Is Real.
Frequently asked questions
Is there a cheaper small e-money institution route in Latvia?
Yes, but it is a Member State option rather than a right, and Latvia sets its ceiling low. Section 5.1(1) of Latvia's Law on Payment Services and Electronic Money lets an electronic money institution start on registration alone only where "the average outstanding electronic money within the scope of commercial activity conducted by the electronic money institution does not exceed two million euros".
That sits well inside what EMD2 Article 9(1) permits a Member State to set — a ceiling that "amounts to no more than EUR 5 000 000" — and the Directive requires "both of the following": that ceiling, and no person responsible for managing the business convicted of money laundering, terrorist financing or other financial crimes. Latvian law is stricter again on what a merely registered institution may then do: Section 7(2) confines its commercial activity to Latvia and bars it from serving clients outside Latvia or using international payment systems.
What happens to the 40-working-day clock if the file is incomplete?
It has not started. The 40 working days in Article 63(9) run from receipt of a complete application, and the completeness check is a separate 25 working days on top. The cost of a thin filing is therefore not a few days' delay — the clock simply never started, and the regulator sets its own deadline for the missing material.
Does being on the register mean a firm can do what I need?
Not necessarily. ESMA's register records each provider's permitted services in MiCA's own wording, such as "providing custody and administration of crypto-assets on behalf of clients" or "exchange of crypto-assets for funds". Two firms on the same register can be allowed to do quite different things. What matters is the service list after the name, not the presence of the name.
Does the Article 60 notification route avoid fees altogether?
Not the ongoing ones. Latvijas Banka lists no document-examination fee on that page, but a supervised participant authorised under Article 60 — excluding credit institutions, investment firms, central securities depositories and regulated market operators — "pays Latvijas Banka up to 0.6% (inclusive) of the annual gross income from the provision of crypto-asset services". The page states no minimum amount.
Next step
Latvia EMI and CASP is one of the four licensing lines CryptoLicense names, alongside Switzerland SRO membership, El Salvador BSP and DASP, and New Zealand FSP registration, — 10+ Jurisdictions Covered, 100+ Companies Served. We draft the application documents rather than only reviewing them, and we source what the application requires — the bank account, the local address, the local personnel. Message us on Telegram and you will get a view back.
This article is general information, not legal advice. CryptoLicense is an advisory firm, not a regulator and not a law firm. Whether any authorisation is granted is at the regulator's discretion, and no one can guarantee the outcome.
Part of a guide series: the full guide is at Licence Selection.