MiCA + PSD2 Dual Licence for Crypto Companies

Why this article?

In our Paybis Europe article and 2026-05-15 CASP status report, you saw the phrase "MiCA CASP + PSD2 EMI dual licence" and that Paybis Europe is the first Latvian company to receive both licences at the same time. But what does that mean in practice? This article is a short and straightforward explanation — why there are two separate licences, what each one gives you and why some companies are interested in holding both.

MiCA — "crypto passport"

MiCA (Markets in Crypto-Assets Regulation, EU Regulation 2023/1114) is the European Union's new rulebook for cryptocurrencies. It applies from 30 December 2024, with a transition period until 1 July 2026.

What does a MiCA CASP licence allow?

A CASP (Crypto-Asset Service Provider) licence lets you offer up to 9 different service categories (MiCA Article 75):

1. Custody and administration of crypto-assets on behalf of clients
2. Operation of trading platforms (order book)
3. Exchange of crypto-assets for fiat currency
4. Exchange of crypto-assets for other crypto-assets
5. Execution of client orders
6. Placement of crypto-assets
7. Reception and transmission of client orders
8. Provision of advice on crypto-assets
9. Transfer services for crypto-assets

In plain terms: with a MiCA licence, a company can buy, sell, hold and move crypto-assets (Bitcoin, Ethereum, USDC, NFTs and so on) on behalf of clients across 30 EEA countries.

Capital requirement: €50,000 to €150,000 depending on service class.

PSD2 — "money passport"

PSD2 (Second Payment Services Directive, EU Directive 2015/2366) is the European Union's rulebook for payment services — a directive that has been in force since January 2018. In 2026 it will be replaced by PSD3 + PSR, but PSD2 licences will remain valid.

Within PSD2, there are two main licence categories:

• EMI (Electronic Money Institution) — can issue electronic money (stablecoins, prepaid card balances) and provide payment services
• PI (Payment Institution) — can only provide payment services (without issuing electronic money)

What does a PSD2 EMI licence allow?

1. Issue electronic money — for example, stablecoins pegged to EUR or USD
2. Execute payments to and from payment accounts (IBAN)
3. Accept SEPA Instant transfers
4. Offer card balance management services
5. Manage client funds in segregated accounts

In plain terms: with a PSD2 EMI licence, a company can handle traditional money (EUR, USD) and issue its own electronic money across the EU market.

Capital requirement: €350,000 (EMI) or €20,000–€125,000 (PI), depending on service volume.

Why are these two separate licences?

The simplified answer — each one regulates different types of assets:

The critical point — EMT (electronic money tokens):

Stablecoins pegged to a single fiat currency (USDC, EURC, USDT) are defined as electronic money under PSD2 by the European Banking Authority (EBA). This means if a company wants to:

• Issue its own stablecoin → needs a PSD2 EMI licence
• Hold a client's USDC → needs a MiCA CASP licence (custody)
• Transfer a client's USDC to another address → MiCA CASP (transfer)
• Convert USDC to EUR and send it to a bank account → needs both licences

The EBA announced in February 2026 that the transition period for EMT services ends on 2 March 2026 — after that date, any service touching both EMT and a fiat IBAN requires ownership of both licences.

What Dual Licensing Offers — Practical Benefits

Companies that obtain both licences within a single legal entity (such as Paybis Europe) gain the following advantages:

1. Complete Product Integration

Without PSD2, CASP customers must deposit funds using a third-party bank or EMI partner. This means:

• Additional transaction fees (typically 0.5–2% per transaction)
• Slower UX (multiple steps, multiple confirmations)
• Risk that the partner discontinues the service

With dual licensing, everything is in one place. A customer opens an account, makes a SEPA transfer directly to the CASP, buys crypto, sends it to their own address or sells it and withdraws funds directly to their IBAN.

2. Stablecoin Issuance Capability

If a company plans to issue its own stablecoin (as we explained in our stablecoin guide, this is a growing market segment — EUR-linked stablecoins have grown by +1200% since MiCA), that can only be done with a PSD2 EMI licence. A CASP licence, meanwhile, allows you to hold and transfer this stablecoin on behalf of clients.

Examples in the Baltics:

• BLUE EMI (Lithuania) — BLUEUR e-money token
• Newrails (Lithuania) — AMBR EURO (EURW)
• Paybis Europe (Latvia) — has publicly announced stablecoin infrastructure development as a strategic direction

3. B2B2C White-Label Business Model

With both licences in one legal entity, a company can offer API solutions to other businesses (retailers, fintech companies and neobanks) so they can integrate crypto services into their own applications, using Paybis backend infrastructure. This is Paybis Europe's openly declared strategy following its 2026-05-12 licence acquisition.

4. Cross-Border Operations with Streamlined Compliance

Cross-border operations (EU passporting) work for both licences across the same 30 EEZ countries, but with dual licensing you only need one notification series for passporting to a single competent authority (the Bank of Latvia). Without dual licensing — two separate notifications, which typically means double the costs for legal and compliance services.

Capital Requirements Combined

Important note: if a company is simultaneously both a CASP and an EMI, capital requirements are added together (cumulative), rather than the higher of the two licences being applied. The EBA clarified in its 2026 statement:

• MiCA CASP minimum capital: €50,000 to €150,000 (depending on services)
• PSD2 EMI minimum capital: €350,000
• Total: €400,000 to €500,000 initial capital

This means dual licensing is not cheap — it requires serious capitalisation. But it also serves as a signal of company stability.

Which Companies Does Dual Licensing Make Sense For?

Simple principle: if a company's operations require simultaneously holding client crypto and moving client money to/from an IBAN account — dual licensing is the most efficient path. If you only need one of these activities — a single relevant licence is sufficient.

Connection to This Paybis Story

Paybis Europe is a prime example of a B2B2C company that wants to:

1. Hold client USDC, USDT, BTC (MiCA custody) — ✅ MiCA CASP allows this
2. Accept SEPA Instant payments directly to account — ✅ PSD2 EMI allows this
3. Sell USDC for EUR and distribute funds to client's IBAN account — ✅ Both licences simultaneously
4. Provide services to non-crypto fintech partners (white-label) — ✅ Both licences allow this
5. Potentially issue its own EUR-linked stablecoin in future — ✅ PSD2 EMI allows this

This is why Paybis Europe's 2026-05-12 licence acquisition is so significant — it opens possibilities that would not have been available with just one licence alone.

Regional Context

Other Baltic/Nordic MiCA-licensed players and their dual licensing status:

Historically, Lithuania has been the largest B2B2C payments hub in the Baltics — which is why the highest number of dual licences are located there. Latvia is now entering this trend with Paybis.

Summary

MiCA CASP licence answers the question: "Is the company permitted to handle crypto?"

PSD2 EMI licence answers the question: "Is the company permitted to handle electronic money and process payments?"

Dual licence allows you to answer the question: "Is the company permitted to fully integrate crypto and fiat money flows in its product without third-party intermediaries?"

It's not mandatory for every CASP company — but for firms planning a hybrid fintech-crypto product (such as Paybis's B2B2C solution, or stablecoin issuers), it's a strategic advantage that competitors cannot easily replicate without a similar regulatory foundation.

Related

• Paybis Europe — Latvia's third MiCA CASP: detailed analysis
• CASP status in the Baltics and Nordic countries 2026-05-15
• What is a stablecoin? Complete guide 2026
• Complete list of MiCA-licensed exchanges
• Complete CASP register

Sources

• EBA — Opinion on the interplay between PSD2 and MiCA (Feb 2026)
• Plesner — EBA clarifies interplay between PSD2 and MiCA
• Noewe — MiCA and PSD2: Dual Licensing for EMT Services
• Morgan Lewis — EBA Supervisory Priorities as PSD2–MiCA Transition Ends
• Central Bank of Cyprus — Dual Licensing of CASPs under PSD2
• Latvijas Banka — Paybis Europe announcement (2026-05-13)