Why YOUR CRYPTO BUSINESS SRL is MiCA-Compliant

1. Legal Basis – MiCA Regulation (EU) 2023/1114 and Romanian GEO 10/2025 (OUG 10/2025):

• YOUR CRYPTO BUSINESS SRL is established in Romania and operates under the national VASP registration regime, aligned with MiCA Title V for transitional CASPs.
• Under Article 143(3) of the MiCA Regulation, VASPs lawfully operating under national regimes before 30 December 2024 may continue to provide services throughout the Union during the transitional period (until July 2026), provided they notify their intent to continue operations and align progressively with MiCA standards.
• Romania has adopted Government Emergency Ordinance (OUG) no. 10/2025, transposing and enabling the MiCA transitional regime. It recognizes crypto-asset service providers registered with the Romanian authorities prior to the MiCA application date as valid CASPs under the transitional framework.

2. YOUR CRYPTO BUSINESS SRL Registration & Compliance:

• The company was lawfully incorporated in Romania and pre-registered for VASP activities under the local regime.
• Although no crypto asset services were provided to clients, the entity maintained clean operational history, with no liabilities, no sanctions, and a limited expense trail—ensuring ease of due diligence and no regulatory backlog.
• Internal compliance documentation and policies (AML/CFT, internal control, and data protection) are in place and can be handed over for continuity or adapted to your project’s needs.

3. Strategic value:

YOUR CRYPTO BUSINESS SRL gives you direct access to the EU crypto market with immediate legal presence under MiCA’s transitional framework.

• Romania is currently one of the most favorable EU jurisdictions for CASPs, with:
  
  • No licensing required for basic crypto-asset services (custody, exchange, transfer),
  • Minimal setup: just a local director and AML officer,
  • Favorable interpretation of financial intermediation exclusions (especially relevant for DeFi, tokenization, and Web3 models),
  • ASF as the competent authority for non-banking CASPs.

Packages available:

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Basic - €5,500 (one-off)

- Shareholder and director change

- Corporate documentation transfer

- No registered office

- No local director

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Full-Compliance - €15,900/1st year & 14,400 per year as of the 2nd year

- All of the above

- Local director appointment (MiCA requirement)

- Registered office address in Romania

- Annual corporate maintenance and compliance supervision

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Note: If you intend to use YOUR CRYPTO BUSINESS SRL to provide MiCA-regulated services during the transitional period (until July 2026), we strongly recommend the Full Compliance Package to ensure alignment with the Romanian AML authority’s requirements and MiCA’s Article 59, 61, and 67 provisions.

Key Milestones:

1. By 30 November 2025: Notify the Romanian FSA (ASF – Autoritatea de Supraveghere Financiară) of your intent to continue operations under the transitional MiCA regime.
2. Between December 2025 – July 2026: Submit the formal MiCA license application to ASF.
3. Post-July 2026: Only MiCA-licensed CASPs may operate in the EU. Transitional registrations will automatically expire.

ASF Timeline for MiCA License (Romania)

The ASF has published its MiCA implementation framework and preliminary licensing process under GEO 10/2025, positioning Romania among the fastest and leanest licensing regimes in the EU.

Estimated ASF Timeline (based on current experience with ASF’s crypto oversight):

Phase & Duration

-Internal preparation (legal, compliance docs) 2–4 weeks

-ASF review of application 60–90 days

-Clarifications & final approval 30–45 days

‍Total time to license ~3-4 months

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ASF has a more pragmatic and pro-business approach compared to more bureaucratic regulators like Malta's MFSA, especially for applicants with pre-existing registrations (like YOUR CRYPTO BUSINESS SRL).

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Why you should choose Romania over Malta for MiCA licensing:

Regulatory posture:

‍Romania – innovation-driven, flexible.

Malta – risk-averse, compliance-heavy.

Speed:

Romania – 3–4 months (realistic).

Malta – 6–9 months+ (delays common).

Costs:

Romania – lower regulatory and advisory fees.

Malta – €50,000–€100,000+ in total setup/licensing.

Local substance:

‍Romania – only a local director is mandatory.

Malta – full local staff often required.

Tax & legal:

‍Romania – 3% micro-tax (under €500k revenue), no corporate tax burden.

Malta – 35% corporate tax (unless structured via tax credits).

Reputation:

Romania – ASF is an EU-level regulator, rising as a credible alternative.

Malta – MFSA under ESMA scrutiny for fast-tracking questionable licenses.

Language & admin:

Romania – multilingual, faster corporate processes.

Malta – delays and additional licensing layers common.

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Side note: ESMA has publicly warned against Malta's “fast-track” approvals and launched investigations into certain VASP licenses. Romania’s more measured and transparent approach provides greater credibility and less regulatory risk for EU market entry.

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Summary

• YOUR CRYPTO BUSINESS SRL positions the buyer to benefit from a fully compliant MiCA transition regime in Romania, with minimum cost and effort.
• Applying for a MiCA license through ASF offers speed, lower cost, and regulatory predictability, with real operational runway until 2026.
• Malta, despite being well-known, carries significant licensing delays, increased scrutiny, and higher capital and staffing requirements.

Should you decide to proceed, we can initiate the share transfer and update the corporate records within 5–7 business days. Upon request, we can also assist with:

• MiCA license application post-transition (2026),
• Business model tailoring and token structuring,
• AML onboarding and internal compliance systems.

Please let me know if you require the draft share transfer agreement, NDA, or corporate documents for review. I remain at your disposal for a call to discuss any strategic or technical aspects.

Other sources of law FYI:

https://legislatie.just.ro/Public/DetaliiDocumentAfis/295399

https://mfinante.gov.ro/acasa/transparenta/proiecte-acte-normative

https://mfinante.gov.ro/static/10/Mfp/transparenta/proiectOUGMICA_23052025.pdf (80% drafted by my associate and I)

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