Who had to register as a CASP in Cyprus, and what has replaced the register?
The national CASP register under Article 61E of the AML/CFT Law, what it showed, when a firm could be removed, which changes needed CySEC's approval, and how the EU's MiCA Regulation, applying since 30 December 2024, fully replaced it on 1 July 2026.
By the ExamPass CY editorial teamLast reviewed 6 min read
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Short answer
Under Cyprus's national regime, a crypto-asset service provider (CASP) had to be entered in CySEC's CASP Register under Article 61E of the AML/CFT Law before providing services if it was established in Cyprus, provided services from Cyprus, or provided services in Cyprus without being registered for them in another Member State. Breaching that duty is an offence (up to 5 years and/or €350,000). The regime has been replaced by the EU's MiCA Regulation: since 1 July 2026 only firms authorised under MiCA, or financial firms that have notified under it, may provide crypto-asset services.
The CASP register at a glance
| Point | Rule |
|---|---|
| Legal basis | Article 61E of Law 188(I)/2007 and CySEC's Directive for the register of CASPs (R.A.D. 269/2021) |
| Who had to register | CASPs established in Cyprus; CASPs providing services from Cyprus, even if registered elsewhere in the EU; CASPs providing services in Cyprus, unless registered in another Member State (they notified CySEC and proved that registration instead) |
| When | Before providing any crypto-asset services; no turnover threshold or grace period |
| Public register | Name, trade name, legal form and LEI; physical address; services and activities; website |
| Removal | No services for six continuous months; registration on false statements or otherwise irregular; all services stopped; no longer required to register |
| Prior approval | Changes to services, crypto-asset addresses, Board or senior management, beneficiaries, or website |
| Offence (Article 61E(13)) | Breaching the registration duty (since Law 98(I)/2023): up to 5 years' imprisonment and/or a fine of up to €350,000 |
| Today | MiCA applies since 30 December 2024; the transitional period for registered CASPs ended on 1 July 2026; only MiCA-authorised or notified firms may provide services |
Source: Law 188(I)/2007, Article 61E, as amended up to 2026; CySEC Directive R.A.D. 269/2021, as amended; Regulation (EU) 2023/1114 (MiCA), Articles 59, 60 and 143; CySEC announcements of 17 October 2024 and 11 March 2025 and Circulars C674 and C790; R.A.D. 199/2025.
Who had to be on CySEC's CASP register?
In 2021 Cyprus brought crypto-asset service providers into its AML/CFT regime. Article 61E of the AML/CFT Law required CySEC to set up, keep and publish a register of CASPs, and CySEC issued its Directive for the register of CASPs (R.A.D. 269/2021) under that article.
The test was a link to Cyprus, not the size of the business. Since an amendment in October 2023 (Law 98(I)/2023), three kinds of provider had to be entered in the register before offering any service: CASPs established in Cyprus; CASPs established elsewhere that provided services on a professional basis from Cyprus, whether or not they were registered in another Member State; and CASPs established elsewhere that provided services in Cyprus, unless they were already registered in another Member State for those services, in which case they had to notify CySEC and prove that registration instead. CySEC, not the Central Bank or an EU body, kept the register.
Since the same 2023 amendment, breaching the duty to register has been a criminal offence: on conviction, up to five years' imprisonment, a fine of up to €350,000, or both. The offence is still in the Law.
Terms used in this note
- Crypto-asset service provider (CASP)
- A firm whose business is providing crypto-asset services, such as custody, exchange, trading or transfer of crypto-assets, to clients.
- CASP Register
- The public register of CASPs that CySEC kept under Article 61E of the AML/CFT Law for the national regime, which ended on 1 July 2026.
- MiCA
- Regulation (EU) 2023/1114 on markets in crypto-assets, which has governed the authorisation and conduct of CASPs across the EU since 30 December 2024.
What did the register show, and when could a CASP be removed?
The Directive required the public register to show the CASP's name and trade name, its legal form, its legal entity identifier (LEI), its physical address, the services and activities it could provide, and its website, and CySEC marked in it any suspension for suspected non-compliance. CySEC's register page also gave registration numbers and contact details. Bank details and information about clients were not part of the register.
CySEC could remove a CASP from the register if it provided no crypto-asset services for six continuous months, had been registered through false statements or some other irregularity, had stopped all its services and activities, or no longer fell within the duty to register. A CASP could also ask to be removed, with a plan for winding down its business within six months, which CySEC could extend by up to six more.
Some changes were treated as material and needed CySEC's prior approval: any change to the services or activities provided, to the CASP's crypto-asset addresses, to the members of the Board or senior management, to the beneficiaries, or to the website. CySEC approved a material change only if the CASP would continue to meet Article 61E and the rules made under it. Simpler changes are covered in How were changes reported?
What has replaced the national register?
The EU's Markets in Crypto-Assets Regulation (MiCA) has applied to crypto-asset service providers since 30 December 2024. Under MiCA, nobody may provide crypto-asset services in the EU unless authorised as a CASP under MiCA or allowed to do so as an already regulated financial entity, such as an investment firm that notifies its regulator. CySEC stopped accepting applications for the national register on 17 October 2024.
Cyprus kept MiCA's full transitional period. CASPs that were lawfully providing services under the national rules before 30 December 2024 could continue until 1 July 2026, or until their MiCA application was granted or refused, if sooner. CySEC set 27 February 2026 as the deadline for applying and required firms that did not apply to submit wind-down plans. The transitional period has now ended: since 1 July 2026, crypto-asset services in or from Cyprus may be provided only under MiCA, and in March 2025 CySEC said it expected to stop maintaining the national register from that date.
Under a notification of the Minister of Finance (R.A.D. 199/2025), CySEC is the competent authority under MiCA for most applicants in Cyprus, while the Central Bank of Cyprus covers banks, electronic money institutions and payment institutions. In 2025 the AML/CFT Law was also amended to use MiCA's definition of a CASP and to remove the provisions on applying to the register. The exam material still tests the national regime, so its rules remain worth knowing.
How to think about it
For exam questions on the national regime, apply the Cyprus-link test: established in Cyprus, providing services from Cyprus, or providing services in Cyprus without registration in another Member State, meant registering with CySEC before starting, under Article 61E. Size, turnover and grace periods are irrelevant, and the Central Bank, ESMA or the ECB are the wrong authorities. Remember the six-month figures (inactivity and, separately, CySEC's decision time) and the €350,000 fine. For the law today, add one step: since 1 July 2026 a firm needs MiCA authorisation, unless it is a financial firm that has notified under MiCA.
Common mistakes
Allowing a grace period or a turnover threshold. Registration was needed before any service was provided, whatever the size of the business.
Naming the Central Bank as the register's keeper. CySEC kept the CASP register under Article 61E.
Expecting bank or client details in the public register. It showed identifying and business details only.
Treating the national register as the current route into the market. Since 1 July 2026 crypto-asset services require MiCA authorisation or notification.
Legal references
- The Prevention and Suppression of Money Laundering and Terrorist Financing Law of 2007 (Law 188(I)/2007), consolidated Greek text on CyLaw (amendments up to Law 25(I)/2026) (opens in a new tab)
Article 2: definition of a CASP (since Law 96(I)/2025, by reference to MiCA) · Article 61E: CASP register and offence
- CySEC Directive for the register of crypto-asset service providers (R.A.D. 269/2021), as amended (opens in a new tab)
Register contents, deregistration and material changes
- Regulation (EU) 2023/1114 on markets in crypto-assets (MiCA) (opens in a new tab)
Article 59: authorisation requirement · Article 143(3): transitional period
- CySEC Circular C790: end of the MiCA transitional period (7 July 2026) (opens in a new tab)
- Minister of Finance notification R.A.D. 199/2025: competent authorities under MiCA (opens in a new tab)
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