Updated October 2026. This article first appeared in May 2022, when Banco de Portugal registered the first bank as a virtual asset service provider. The national registration regime it described no longer exists; the page now compares what a crypto licence means in Portugal under MiCA with the Turkish regime under the Capital Markets Law, for teams deciding where to build or whether they need both.
What “crypto licence in Portugal” means today
Since 30 December 2024, crypto-asset service providers in the European Union need authorisation as a CASP under Regulation (EU) 2023/1114 (MiCA). Portugal’s national registration of virtual asset service providers with Banco de Portugal, the regime this article originally covered, was replaced by that framework. Under Portugal’s implementing law (Law No. 69/2025 of 1 December), applications for CASP authorisation are submitted to Banco de Portugal, which acts in coordination with the securities regulator CMVM, and providers registered before 30 December 2024 could continue under the old regime only until 1 July 2026.
The first Portuguese bank to receive CASP authorisation was, as in 2022, Bison Bank: it announced on 23 June 2026 that it had become the first bank in Portugal to operate directly as a crypto-asset service provider, covering custody, exchange and advisory services. For new entrants the practical meaning is simple: a Portuguese CASP authorisation is a MiCA authorisation, and once granted it can be passported to every other Member State under Article 65.
Portugal (MiCA) and Türkiye (CMB) side by side
Türkiye is not an EU Member State and MiCA does not apply there. Crypto-asset service providers serving Turkish residents need permission from the Capital Markets Board (CMB) under Law No. 6362 as amended by Law No. 7518, with the detailed conditions in Communiqués III-35/B.1 and III-35/B.2. The two regimes answer the same questions differently.
| Question | Portugal under MiCA | Türkiye under the Capital Markets Law |
|---|---|---|
| Regulator | Banco de Portugal, in coordination with CMVM | Capital Markets Board (SPK) |
| Legal basis | Regulation (EU) 2023/1114 (MiCA), applying to CASPs since 30 December 2024 | Law No. 6362 Arts. 35/B, 35/C, 99/A, 109/A (Law No. 7518, Official Gazette 2 July 2024); Communiqués III-35/B.1 and III-35/B.2 (13 March 2025) |
| Who needs it | Anyone providing one or more of the ten crypto-asset services in the Union on a professional basis (Art. 3(1)(15), Art. 59) | Platforms, custodians and other institutions designated by the CMB that serve persons resident in Türkiye (Art. 3(1)(cc), Art. 35/B) |
| Minimum capital | Annex IV: EUR 50,000 (Class 1), EUR 125,000 (Class 2, adds custody and exchange), EUR 150,000 (Class 3, adds operating a trading platform), or one quarter of the previous year’s fixed overheads if higher (Art. 67) | For 2026: TRY 250,000,000 for platforms and TRY 630,000,000 for custodians (CMB Bulletin 2025/68; III-35/B.2 Art. 34 and Art. 53), paid in full in cash |
| Process | Single authorisation: completeness check within 25 working days, reasoned decision within 40 working days of a complete file (Art. 63) | Two stages: establishment permission, then an operating permission application within six months, extendable by the CMB up to one year in total (III-35/B.1 Art. 17) |
| Where the licence works | Across the EU after a passport notification; services may start on receipt of the home authority’s communication or at the latest 15 calendar days after submitting it (Art. 65) | Türkiye only; there is no passporting arrangement |
| Serving the other market without a licence | Only where an EU client acts at its own exclusive initiative (Art. 61); any promotion aimed at EU clients removes the exemption | A workplace in Türkiye, a Turkish-language website, or promotion directly or through Turkish residents makes the activity directed at Türkiye and therefore unlicensed provision (Art. 99/A) |
| Transition | Grandfathering for existing providers ended in Portugal on 1 July 2026 | Existing providers had to file a declaration with the CMB by 2 August 2024, within one month of the law entering into force, undertaking to apply for permission or to wind down (Provisional Art. 11); the window has closed |
| Unlicensed activity | Administrative sanctions under national law implementing MiCA | Imprisonment of three to five years and a judicial fine of 5,000 to 10,000 days (Art. 109/A) |
What this means for a founder choosing between the two
The capital gap is the headline difference. A Class 2 CASP in Portugal needs EUR 125,000 of prudential safeguards, which may even be met with an insurance policy; a Turkish custodian needs TRY 630,000,000 of paid-in capital for 2026. The gap reflects what each licence buys: a MiCA authorisation opens 27 markets, while the Turkish permission opens one, but a very large one that no EU licence can reach.
The second difference is sequencing. MiCA is one application with a defined clock. Türkiye requires an established joint-stock company with the full capital in place before the operating permission can even be applied for, and the general manager must be resident in Türkiye and employed full time (III-35/B.1 Art. 14). Teams that plan the Turkish entity, its capital and its management before approaching the CMB avoid the most common delays.
The third difference is the reverse-solicitation question, which both regimes answer the same way: no. A Portuguese CASP cannot serve Turkish residents through a Turkish-language site or local marketing without CMB permission, and a Turkish platform cannot serve EU clients without a CASP authorisation if its site, app-store listing, ads or affiliates reached them. A group that wants both markets therefore needs two regulated entities: an EU company authorised under MiCA and a Turkish joint-stock company holding the Turkish CASP licence.
How Portugal got here
Portugal’s earlier regime was a registration with Banco de Portugal for anti-money-laundering purposes rather than a full licence. The first registrations went to two exchanges, Criptoloja and Mind the Coin, in 2021. In March 2022 the on-chain payments company Utrust received approval for all service categories, and on 14 March 2022 Banco de Portugal registered Bison Bank, owned by a Hong Kong based private equity group, as the first bank permitted to provide custody and trading of virtual assets. That national regime was absorbed into MiCA, and the same bank became the country’s first MiCA CASP in June 2026.
Frequently asked questions
Does a MiCA authorisation from Portugal allow a platform to serve users in Türkiye?
No. MiCA does not apply in Türkiye. Activity directed at persons resident in Türkiye, which includes a Turkish-language website or marketing in Türkiye, requires CMB permission under Law No. 6362 (Art. 99/A).
Can a Turkish exchange obtain a MiCA licence from Portugal?
Only through an EU entity. The CASP must have its registered office in a Member State where it carries out at least part of its services and its place of effective management in the Union (Art. 59). The usual structure is an EU subsidiary of the Turkish group, authorised in one Member State and passported to the others.
Which is faster to obtain?
MiCA sets a clock of 25 working days for completeness and 40 working days for the decision once the file is complete (Art. 63). The Turkish process has two stages and no statutory decision deadline, but it does impose a deadline on the applicant: the operating permission must be applied for within six months of establishment permission (III-35/B.1 Art. 17).
What is the minimum capital for a crypto exchange in Portugal and in Türkiye in 2026?
Portugal: EUR 150,000 for a provider operating a trading platform (MiCA Annex IV, Class 3), or one quarter of fixed overheads if higher. Türkiye: TRY 250,000,000 for a platform and TRY 630,000,000 for a custodian under CMB Bulletin 2025/68.
Sources: Regulation (EU) 2023/1114 (MiCA), Articles 3, 59, 61, 63, 65, 67, 143 and Annex IV; Portugal, Law No. 69/2025 of 1 December (Diário da República, 22 December 2025) implementing MiCA; Bison Bank announcement of 23 June 2026; Capital Markets Law No. 6362, Articles 3, 35/B, 35/C, 99/A, 109/A and Provisional Article 11; CMB Communiqués III-35/B.1 and III-35/B.2 (Official Gazette 13 March 2025, No. 32840); CMB Bulletin 2025/68. This article is general information as at October 2026, not legal advice; capital amounts in Türkiye are reset annually.
