Service
Trade mark protection
Protect the brand once the company exists; until authorisation, its name must not suggest crypto-asset service provider status. Trademark Registration with OSIM in Romania
Crypto License in Romania under MiCA
We form the Romanian company, provide its registered office and coordinate the authorisation file you prepare with your lawyers. The authority decides.
- MiCA in full since 30 December 2024
- EU registered office, one EU-resident director
- Safeguard of at least EUR 50,000, 125,000 or 150,000 by class
- No Romanian authority act adopted by 17 October 2026
How we work on a MiCA authorisation file
RomaniaRegist works for founders and groups outside Romania who want a Romanian crypto-asset service provider. From our Bucharest office we form the company, provide its registered office and coordinate the authorisation file that you write with your lawyers and compliance staff. The work is administrative: the competent authority decides, and nobody can guarantee the grant.
The company comes first, so the first step is to open a company in Romania whose object covers the services. The status matters as much: Regulation (EU) 2023/1114 (MiCA) has applied in full since 30 December 2024 (art. 149(2)), yet no Romanian act designating the competent authority had been adopted by 17 October 2026.
Where Romanian authorisation stands today
What is settled (MiCA and the AML and reporting rules), what exists only as a May 2025 draft, and what nobody has published yet.
| Item | Status | Source |
|---|---|---|
| MiCA | Law. Applies in full from 30 December 2024 | Regulation (EU) 2023/1114, art. 149(2) |
| EU-wide transitional period | Law. Ended on 1 July 2026. Art. 143(3) let existing providers continue until that date or a decision, and let member states shorten or switch off the regime. ESMA, relayed by the ASF, says unauthorised providers must stop taking new clients | ASF, relaying ESMA; MiCA art. 143(3) |
| Romanian act designating the competent authority | Open. None adopted on the record as of 17 October 2026: the ASF said in 2023 that one is needed; a Government letter to the Senate of 28 September 2026 still lists the ordinance as a draft and records that, in the current interim-government context, the executive cannot adopt acts with the force of law to transpose or apply EU law | ASF press release, 2023; Government letter, 28 September 2026 |
| Which Romanian authority | Draft, May 2025. The draft names the ASF (Autoritatea de Supraveghere Financiară, Financial Supervisory Authority) for crypto-asset services and the BNR for EMT issuance only; no adoption found | Ministry of Finance draft of 23 May 2025, art. II(1), (2) |
| ASF application procedure | Open. No crypto procedure on the ASF authorisation page (13 October 2026) and no MiCA section in its legislation index (14 October 2026) | ASF website, authorisation and legislation pages |
| ADR technical opinion on the IT systems before filing | Draft, May 2025. Not a requirement in force | Draft of 23 May 2025, art. XI(1) |
| Other draft provisions: a national end date for the transitional regime, a tax-arrears condition for the applicant, a filing window for existing providers, a monthly fee | Draft, May 2025. Shown as drafts only; none is law | Draft of 23 May 2025, art. X, XXXIV, XL |
| AML, resilience and reporting rules for crypto-asset service providers | Law. Law 129/2019 defines them by reference to MiCA and sets due diligence from 1,000 euro; DORA covers them; DAC8 reporting to ANAF from 1 January 2026 | Law 129/2019 art. 2 lit. t2), 13(22); Regulation (EU) 2022/2554; OUG 71/2025 |
What's included
Administrative work around an application that you and your lawyers write; the sixth card sets the limits.
Scope check support
A document checklist, and liaison with a partner Romanian lawyer who maps your business model to the ten crypto-asset services and an Annex IV class.
The Romanian company
We file the Romanian limited liability company at the ONRC, object covering the services (art. 7 lit. c) Law 31/1990, text of January 2024), and provide its registered office. A partner lawyer drafts bespoke articles.
The application file assembled
You and your lawyers prepare the content. We collect the programme of operations, the ICT documentation and criminal-record proof for the management body and qualifying holders, arrange translations and track the file.
Liaison with the authority
Once the route is confirmed, we liaise with the competent authority, the partner lawyer and the compliance specialist who drafts the policies. You sign every document.
Our own checks
Before any filing we check identity and beneficial-owner documents, as a service provider notified to ONPCSB. We may decline a client.
Where our service stops
We hold, buy and sell no licence and are not a crypto-asset service provider. No legal, tax or accounting advice, no director for hire, no promised grant or date.
How the process works
The sequence is MiCA's, because the ASF publishes no crypto procedure; the one draft step is marked.
Scope check · CLIENT, PARTNER LAWYER, US
The partner Romanian lawyer maps your model to the ten services and an Annex IV class, and checks whether an existing licence opens the art. 60 notification route. We supply the checklist.
Company and presence · US, PARTNER LAWYER, CLIENT
We file the company and provide its registered office; a partner lawyer drafts bespoke articles; you appoint real directors, one EU-resident. Contracts made on condition of the authorisation leave liability with the company, not the founders (art. 53(2) Law 31/1990, text of January 2024).
Capital and safeguard · CLIENT, ACCOUNTANT
You hold own funds at your class level, or an insurance policy (art. 67(1), (4) MiCA). Your own accountant prepares the projected fixed overheads; we keep no books.
ADR technical opinion, draft only · DRAFT, NOT LAW
The May 2025 draft would have ADR (Autoritatea pentru Digitalizarea României, the digitalisation authority) give a technical opinion on the IT systems before filing. It is not law.
Application file · CLIENT, PARTNER LAWYER, US
The partner lawyer and compliance specialist draft the policies and you sign. We assemble the art. 62(2) items, arrange the translations and submit them on your instruction. A no-tax-arrears condition exists only in the draft.
Authority clocks · COMPETENT AUTHORITY
Acknowledgement within 5 working days, completeness check within 25, decision within 40 of a complete file, notice within 5, suspension up to 20 (art. 63 MiCA). No overall time can be promised.
Start and passport · AUTHORISED COMPANY
Services start only after the grant. To serve another member state, the company notifies and may start at the latest on the 15th calendar day after (art. 65(4)).
Ongoing duties · AUTHORISED COMPANY
Keep the safeguard, run due diligence from 1,000 euro, apply DORA, report under DAC8, use the authorisation within 12 months (art. 64). Holders reaching 20, 30 or 50 percent notify in advance (art. 83).
How a MiCA authorisation file moves, by actor
Client and partner lawyer
RomaniaRegist
Competent authority
1Scope check
Client and partner lawyerPartner lawyer maps the model to the ten services and an Annex IV class
RomaniaRegistSupplies the checklist
2Company and presence
Client and partner lawyerPartner lawyer drafts bespoke articles; you appoint real directors, one EU-resident
RomaniaRegistFiles the company and provides its registered office
3Capital and safeguard
Client and partner lawyerOwn funds at your class level, or an insurance policy; your accountant prepares the projected fixed overheads
4ADR technical opinion, draft only
Competent authorityDraft, not law: ADR, the digitalisation authority, would give a technical opinion on the IT systems before filing
5Application file
Client and partner lawyerPartner lawyer and compliance specialist draft the policies; you sign
RomaniaRegistAssembles the art. 62(2) items, arranges translations, submits on your instruction
6Authority clocks
Competent authorityAcknowledges, checks completeness, decides and notifiesTerm 6
7Start and passport
Client and partner lawyerServices start only after the grant; to serve another member state the company notifiesTerm 7
8Ongoing duties
Client and partner lawyerKeep the safeguard, run due diligence from 1,000 euro, apply DORA, report under DAC8Term 8
- Term 6Parallel clocks, never a sum. From receipt of the application: acknowledgement within 5 working days (art. 63(1)), completeness check within 25 working days (art. 63(2)). From receipt of a complete application: decision within 40 working days (art. 63(9)), suspension up to 20 working days (art. 63(12)). From the decision: notification within 5 working days (art. 63(9)). No overall time is published.
- Term 7cross-border start from receipt of the communication, or at the latest from the 15th calendar day (art. 65(4))
- Term 8use the authorisation within 12 months (art. 64(1)(a))
Step 4 is a draft of 23 May 2025 (art. XI(1)), not law, and the only draft step. The authority's clocks run from different starting points and are not added together; no overall time is published.
Want to know which items your MiCA file needs?
Tell us your services and where the directors live; we send the checklist and introduce a partner Romanian lawyer.
Documents you will need
- Identity document for each director
- Identity document for each qualifying holder
- Clean criminal-record proof for every member of the management body and every qualifying holder
- The business model and the programme of operations
- ICT documentation, with a description in non-technical language
- Proof of the safeguard: own funds or an insurance policy
- Projected fixed overheads, prepared by your accountant
- Identity and beneficial-owner documents for our own checks
- Translations of foreign documents, certified where the authority requires it
- Proof of an existing authorisation, only if the art. 60 route is checked
- Tax-record proofs: a draft, May 2025 item, not yet required
What MiCA requires, and what it asks you to hold
The regulation's rules with their articles, then the capital that MiCA sets apart from the company's share capital.
| Requirement | Rule | Source |
|---|---|---|
| Authorisation | No crypto-asset services in the Union without authorisation or the art. 60 route; ten services count | MiCA art. 59(1), 3(1)(16) |
| Existing financial entities | Notify the home authority at least 40 working days before starting, instead of applying | MiCA art. 60 |
| Reverse solicitation | Not available to a third-country firm that solicits clients in the Union | MiCA art. 61(1) |
| Registered office | In a member state where part of the services is provided | MiCA art. 59(2) |
| Management and director | Place of effective management in the Union; at least one director resident in the Union | MiCA art. 59(2) |
| People | Directors: good repute, competence, sufficient time; qualifying holders: good repute and no money-laundering or terrorist-financing convictions; criminal-record proof for every member of the management body and every qualifying holder | MiCA art. 68(1), (2), 62(3)(a), (c) |
| Name and marketing | No name, corporate name or marketing suggesting crypto-asset service provider status before authorisation | MiCA art. 59(5) |
| Qualifying holdings | Advance notification when a holding reaches 20, 30 or 50 percent; 60 working days to assess | MiCA art. 83(1), (4) |
| Withdrawal | If unused within 12 months, or if no service is provided for nine consecutive months | MiCA art. 64(1)(a), (c) |
| Company law | The articles state the object of activity; contracts made on condition of the authorisation leave liability with the company, not the founders; a missing authorisation required for incorporation is a ground of nullity | Law 31/1990, text of January 2024, art. 7 lit. c), 53(2), 56 lit. e) |
| Item | Amount or rule | Source |
|---|---|---|
| Class 1: orders, placing, transfers, reception, advice, portfolio management | EUR 50,000 | MiCA Annex IV |
| Class 2: adds custody and exchange | EUR 125,000 | MiCA Annex IV |
| Class 3: adds operation of a trading platform | EUR 150,000 | MiCA Annex IV |
| The amount that applies | The higher of the class amount and one quarter of the previous year's fixed overheads, reviewed annually | MiCA art. 67(1) |
| How it may be held | Own funds, an insurance policy covering the territories served or a comparable guarantee, or a mix | MiCA art. 67(4) |
| For comparison, not the safeguard: share capital of a newly formed SRL | 500 lei | Law 239/2025 art. VI(2) |
The MiCA safeguard by class
Safeguard
Class 1: EUR 50,000Class 2: EUR 125,000Class 3: EUR 150,000Services
Class 1: Orders, placing, transfers, reception, advice, portfolio managementClass 2: Adds custody and exchangeClass 3: Adds operation of a trading platform
MiCA Annex IV. The amount that applies is the higher of the class amount and one quarter of the previous year's fixed overheads, reviewed annually (art. 67(1)). Off the scale: 500 lei, share capital of a newly formed SRL, not the safeguard (Law 239/2025 art. VI(2)).
Problems we solve
The questions founders ask first, and how each is handled.
Is the authority accepting applications, and under which act?
No Romanian act designating it had been adopted by 17 October 2026; the ASF, named only in the May 2025 draft, publishes no crypto procedure. Confirm the route with the ASF Innovation HUB before filing.
I was operating before MiCA
The EU transitional period ended on 1 July 2026, and unauthorised providers must stop taking new clients (ASF, relaying ESMA). The draft's own end date is only a draft, so we plan a full application.
Can you promise the licence or a date?
No. The decision period of 40 working days runs from a complete file, and an information request can suspend it for up to 20 working days. We track the file against the art. 62(2) list; the authority decides.
Can I buy a company that already holds a licence?
Not as a shortcut: a qualifying holding is assessed and an unused authorisation is withdrawn. You can buy a ready-made Romanian SRL, but no authorisation comes with it.
I live outside the EU
You may own the company, subject to a repute check on qualifying holders; it needs EU effective management and an EU-resident director of good repute who commits the time. We supply no name-only director.
Does your model fall outside these points?
Ask before anything is filed; we put your question to a partner Romanian lawyer and come back with what the file needs.
Why work with RomaniaRegist
Victor Georgescu, licensing and founder immigration lead, works from our Bucharest office in Romanian, English and German.
RomaniaRegist, a trust and company service provider notified to ONPCSB, checks identity and beneficial-owner documents before any filing (Law 129/2019 art. 2(l), 5(1)(g)).
From our practice
The client writes the file with its own lawyers; we track it against the art. 62(2) list and handle registration, registered office and filings.
Frequently asked questions
Can you guarantee that the authority will grant the licence, or say exactly how long it takes?
No. The authority decides. MiCA gives it 5 working days to acknowledge the application and 25 to check completeness; the 40 working days to decide run only from a complete file, and a request for information can suspend them for up to 20 (art. 63). No overall time is published, so we promise none.
Can I buy a Romanian company that already holds a crypto licence?
Not as a shortcut. A qualifying holding reaching 20, 30 or 50 percent must be notified in advance, and the authority has 60 working days to assess it (art. 83). An authorisation not used within 12 months is withdrawn. Authorisation attaches to the applicant, so we offer no licensed company for sale.
Is the ASF already accepting MiCA applications, and under which Romanian act?
We found no adopted Romanian act designating the competent authority as of 17 October 2026. The ASF said in 2023 that one is needed, and a Government letter of 28 September 2026 still lists the ordinance as a draft. The ASF is named only in a May 2025 draft. Confirm the route with the ASF Innovation HUB first.
I do not live in the EU: can I own and run a Romanian crypto company?
You can own it, subject to the authority's repute check on qualifying holders (art. 68(2)). To run it, the company needs its place of effective management and at least one director resident in the Union (art. 59(2)). Directors must be of good repute, competent and able to commit sufficient time, so a name-only director does not qualify.
Do I need a director who lives in Romania, or is any EU resident enough?
MiCA requires at least one director resident in the Union; the texts we read do not narrow that to Romania. What the Romanian authority adds in practice depends on a procedure it has not published, and the ASF website shows none. We refer that question to the partner Romanian lawyer before anyone is appointed.
How much capital does a crypto-asset service provider need in 2026?
The higher of the Annex IV amount for your class and one quarter of the previous year's fixed overheads (art. 67(1)). Class 1 is EUR 50,000, Class 2 is EUR 125,000 and Class 3 is EUR 150,000. The partner Romanian lawyer reads from the regulation which class your services fall into.
Can the capital requirement be covered by insurance instead of cash?
MiCA allows own funds, an insurance policy covering the territories of the Union where the services are provided or a comparable guarantee, or a mix of the two (art. 67(4)). Whether a particular policy qualifies is a legal question, which the partner Romanian lawyer answers before the application file is prepared.
My business was operating before 30 December 2024: can I still rely on a transitional period?
The EU-wide transitional period ended on 1 July 2026. ESMA, relayed by the ASF, asked unauthorised providers to wind down in an orderly way and to stop taking new clients. The end date of 30 November 2025 in the Romanian May 2025 draft is a draft, not law.
I already hold a licence in another EU country: do I need a Romanian one?
The notification route in art. 60 covers only the listed financial entities. An authorised provider that notifies may start a cross-border service from receipt of the home authority's communication, or at the latest from the 15th calendar day after submitting the information (art. 65(3), (4)). Whether you also need a Romanian entity is a question for the partner Romanian lawyer.
Which services fall under MiCA, and does advice or portfolio management count?
Ten services count, among them advice, portfolio management and transfer services (art. 3(1)(16)). The regulation lists them, and mapping your business model onto that list is legal work for the partner Romanian lawyer. We collect the documents that the mapping needs and keep the application file in order.
Is a 500 lei SRL enough to start a crypto business in Romania?
Not on its own. 500 lei is the minimum share capital of a newly formed SRL (Law 239/2025 art. VI(2)). It is not the MiCA safeguard, which starts at EUR 50,000 by class, or one quarter of the previous year's fixed overheads if higher. Insurance may serve instead of cash.
Which AML rules apply to a crypto business in Romania today?
Law 129/2019 defines a crypto-asset service provider by reference to MiCA and requires customer due diligence from the lei equivalent of 1,000 euro. A provider from another member state working in Romania other than through a branch appoints a single point of contact. DORA also covers these providers.
How do I get a crypto exchange licence in Romania, and how is a crypto business set up?
Exchange and trading-platform services are among the ten crypto-asset services, and no one may provide them without authorisation. The order is a scope check, a Romanian company with an EU-resident director, the safeguard, the application file and the authority's decision. Our process section sets out each step and who does it.
What is the ADR technical opinion and is it required?
It appears only in the May 2025 draft, which would have ADR, the digitalisation authority, give a technical opinion on the IT systems before the application is filed. The draft is not adopted, so we do not state it as a requirement. Ask the ASF Innovation HUB whether it applies.
How is crypto taxed in Romania, and who answers that?
This page gives no tax advice: tax on crypto income is a matter for a CCF tax consultant. A crypto-asset service provider reports to ANAF under DAC8 from 1 January 2026, which is a reporting duty, not a tax rate. For the company's ordinary tax on profits, see our guide to the Romanian profit tax.
Ready to plan your MiCA file?
Tell us where the founders live, which services the company will offer and whether it holds an authorisation elsewhere.
Phone +40 21 312 3456 · Email info@company-registration-in-romania.com · Monday to Friday, 09:00 to 18:00, Bucharest time