Buy-side CASP acquisition · Denmark
Buy a CASP in Denmark: MiCA-authorised crypto licence
Finanstilsynet runs Denmark’s MiCA-CASP authorisation pipeline, and the early issuance to Lunar A/S as the first Scandinavian challenger bank with a CASP authorisation set the working benchmark for what a complete file looks like in Copenhagen. We broker change-of-control transactions on Finanstilsynet-supervised CASPs to acquirers who want regulator quality plus EU passporting from one of the EU’s smallest authorised pools.
Why Denmark
A small authorised pool, a credible supervisor, and a closing AML-register transition
Finanstilsynet (the Danish Financial Supervisory Authority) is the competent authority for crypto-asset service providers under Article 62 of Regulation (EU) 2023/1114. The supervisory dialogue runs in working English with Danish for formal correspondence; the Securities and Capital Markets directorate handles the substantive review and coordinates the AML/CFT assessment with Finanstilsynet’s Anti-Money Laundering division. Denmark applied MiCA on the EU calendar — Title III on 30 June 2024, Title V on 30 December 2024 — and the transitional period for prior AML-Act-registered crypto firms ends 30 December 2025.
The credibility signal sharpened when Lunar A/S, the Aarhus-headquartered Nordic challenger bank, secured the first MiCA-CASP authorisation issued in Scandinavia. The takeaway for an acquirer is what the headline confirms more than the headline itself: Finanstilsynet’s review apparatus works on complex applicants, the Article 83 dossier expectations are now visible in practice, and the resulting authorisation is recognised across the EEA without further notification beyond Article 65 passporting.
Denmark is a credibility play with scarcity. The authorised CASP pool is narrow because the supervisor’s bar is high and the country is small. Most live targets through 2026 are either fully authorised CASPs (a short list) or AML-Act registrants mid-conversion ahead of the December 2025 sunset. The acquirer who gets in early gets a Finanstilsynet-supervised entity with EU passport rights, which institutional counterparties read as first-tier.
What a Danish MiCA-CASP authorisation permits
Title V scope, Article 67 capital classes, and the obligations the buyer inherits
A Danish CASP authorisation is granted under MiCA Title V and unlocks the full menu of crypto-asset services: custody and administration of crypto-assets on behalf of clients, exchange of crypto-assets for funds, exchange of crypto-assets for other crypto-assets, execution of orders, placing of crypto-assets, reception and transmission of orders, advice, portfolio management, transfer services, and operation of a trading platform. Each service in scope is named in the authorisation, and adding a service post-issue requires an Article 64 modification.
Permanent minimum own funds sit at three classes under Article 67. Class 1 services (advice, reception and transmission of orders, transfers) are floored at EUR 50,000. Class 2 (execution, exchange of crypto-assets for funds or for other crypto-assets, placing) raises the floor to EUR 125,000. Class 3 (custody and administration, operation of a trading platform) takes it to EUR 150,000. The permanent minimum is the floor only; the binding figure is the higher of the floor and one quarter of the previous year’s fixed overheads. On a mature operating target the overheads test almost always sets the level, and Danish CASPs trend mature because most converted from AML-Act-registered firms with real revenue.
Article 75 requires segregation of clients’ crypto-assets from the CASP’s own holdings, with reconciliation discipline and clear contractual disclosures. Article 68 sets the prudential governance frame: at least two fit-and-proper executive directors with crypto-relevant experience, organisational structure proportionate to the service mix, internal control and compliance functions resourced to do their job, and a documented business continuity plan. DORA (Regulation 2022/2554) layers ICT risk management on top from January 2025, and the Travel Rule under Regulation 2023/1113 governs originator and beneficiary information on crypto-asset transfers. The acquirer inherits all of this at completion, including any open Finanstilsynet correspondence.
What we broker here
The Danish CASP files we work with
The Danish CASP book is small and the inventory is shallow, which is exactly why a buy-side mandate beats a public listing search. Our Denmark mandates fall into a few patterns: former AML-Act-registered crypto firms who completed (or will complete by 30 December 2025) the MiCA conversion and are exiting on the back of a strategic decision; greenfield entities that obtained a fresh CASP authorisation explicitly with an exit in mind; and Danish subsidiaries of foreign crypto-banking or fintech groups whose parent is restructuring the licence stack and divesting one node.
Our diligence gates on every Denmark file are banking continuity (the EU credit institution holding segregated client crypto-asset proceeds and the timeline to re-paper it post-completion), the AML programme under the Danish Anti-Money Laundering Act and MiCA Title V (transaction monitoring, sanctions screening, the MLRO’s seniority and replaceability), the substance pillar (Copenhagen-resident management, locally executed decision-making, and the support functions Finanstilsynet expects under its real-presence test), and the technology stack (custody architecture, key-management arrangements, and the third-party providers inside the audit perimeter). We do not list the same target with multiple acquirers, and we will not present an entity we have not personally diligenced against Finanstilsynet’s published expectations.
Acquisition path
Article 83 change-of-control, in practice
The acquisition mechanic for a Danish CASP is governed by Article 83 of MiCA. Any proposed acquirer of a qualifying holding (10%, 20%, 30%, or 50% thresholds, or any holding that confers control) must notify Finanstilsynet in writing before the transaction completes. The supervisor acknowledges the notification, opens the assessment window of up to 60 working days, and may extend it once by a further 30 working days when it requests further information. Assessment criteria mirror the prudential framework applied across Danish credit and investment-firm supervision: reputation of the proposed acquirer, suitability of incoming directors, financial soundness, ability to comply with MiCA on an ongoing basis, and AML/CFT risk.
What shortens the window is a complete dossier delivered with the initial notification, not after Finanstilsynet’s first request for additional information. We build that dossier with our acquirers before signing: UBO disclosure, sources-of-funds, group ownership chart, three-year prudential plan, governance arrangements at the target post-completion, and (where the target was an AML-Act registrant pre-MiCA) the status of the conversion file. See the acquisition process for the standing checklist.
Why Cadena
Where our buy-side CASP mandate beats the alternatives
- Finanstilsynet-fluent dossiers. Our acquirers’ Article 83 packages are written to the supervisor’s published assessment framework before signing, not retrofitted after the regulator pushes back. That converts a procedural 60-working-day window into a working one.
- Single-side mandate, every file. We act for the acquirer only. The Danish target’s adviser sits across the table from us on every CASP transaction — never on the same side. That removes the conflict-of-interest cloud that mixed-mandate brokers carry into a supervisor’s review.
- Transition-window arithmetic. The AML-Act-to-CASP conversion deadline of 30 December 2025 is the variable nobody is pricing well in early 2026. We track which Danish AML-registered targets actually have complete files at Finanstilsynet versus targets that look authorised but whose conversion is still incomplete. That distinction is the deal.
FAQ
Frequently asked — Danish CASP and MiCA acquisitions
Can I buy a CASP licence for sale in Denmark rather than apply de novo?
Yes, when the underlying entity holds a current Finanstilsynet authorisation under Article 63 of MiCA. The transaction is a change-of-control under Article 83: you notify Finanstilsynet of the proposed qualifying holding, the supervisor runs a fit-and-proper assessment of the acquirer and incoming directors, and the deal completes on the supervisor’s non-objection. We broker only entities whose authorisation is live (or whose conversion file from the AML-Act register is complete) and whose current management have signalled willingness to exit on a clean change-of-control basis.
What is the difference between a CASP and a MiCA licence in Denmark?
They are the same authorisation, named two ways. “MiCA licence” is the colloquial term acquirers use because the regulation creates the regime; “CASP authorisation” is what Finanstilsynet actually issues, because the authorised entity is a Crypto-Asset Service Provider. The licence text references Title V of Regulation (EU) 2023/1114. Both terms point at the same Danish FSA decision and the same passporting rights across the EEA.
Can a CASP licence in Denmark passport across the EU?
Yes. Article 65 of MiCA gives any authorised CASP an EEA-wide passport to provide its scoped services in any other EU member state through a notification rather than a fresh authorisation. The acquirer inherits Denmark’s passporting rights at completion. The passport covers exactly the Title V services named in the original Finanstilsynet authorisation; expanding into adjacent services after closing requires an Article 64 modification first.
How does Article 83 change-of-control approval work for a Danish CASP?
You file a written qualifying-holding notification with Finanstilsynet before the transaction closes. The supervisor has 60 working days from acknowledged-complete notification to assess, extendable by 30 working days where it requests further information. Assessment criteria are reputation, suitability of incoming directors, financial soundness, MiCA-compliance capability, and AML/CFT risk. The dossier mirrors what an acquirer would file for a qualifying-holding in a Danish credit institution under the CRD framework — Finanstilsynet calibrates the standard the same way.
Is buying a MiCA licence in Denmark different from buying one in Germany or France?
The MiCA framework is identical across member states; the supervisor and the candidate pool differ. Denmark’s CASP-authorised population is small, the supervisor moves at a measured but predictable pace, and the substance test is real (Copenhagen-resident management, local decision-making). Germany’s BaFin runs a more procedural review with a deeper file expectation; France’s AMF/ACPR pair adds a coordinated dual-track step. Compare the German CASP and EU CASP hub pages for the side-by-side. The choice is rarely about the licence itself — it is about which regulator’s reputation the acquirer wants stamped on the entity.
Will a Danish AML-registered crypto firm convert to CASP before 30 December 2025?
It depends on the firm. Denmark’s transitional period closes on 30 December 2025; AML-Act registrants who do not file a complete CASP conversion application by then lose the ability to provide crypto-asset services in or from Denmark. In practice, the population splits into firms with complete conversion files at Finanstilsynet (acquisition candidates), firms that have started conversion but whose file is incomplete (diligence-heavy), and firms that have decided to exit the Danish market rather than convert (these are sometimes acquisition candidates too, depending on the legacy book). The diligence question is whether the file at Finanstilsynet is genuinely complete — not whether the firm is currently authorised.
Next step
Open a buy-side mandate on Danish CASPs
If your acquisition thesis points at MiCA-CASP coverage with Danish regulator quality, send us your acquisition criteria. We come back with the targets that match: pre-vetted on Finanstilsynet standing, banking continuity, AML programme, AML-Act-to-CASP conversion file status where relevant, and Article 83 readiness. If Denmark turns out to be the wrong fit on diligence, the same engagement covers EU CASP comparables in adjacent member states.
