LICENSING IN THE CRYPTO-ASSET MARKET IN KOSOVO: WHAT BUSINESSES NEED TO PREPARE FOR BY DECEMBER
October 17, 2025
On November 22, 2024, Kosovo took a major step toward regulating the crypto-asset market by adopting Law No. 08/L-295 on Crypto-Assets. This law establishes the first legal framework for a sector that had so far operated without clear oversight and often in the shadow of the financial regulatory system.
At its core, the law stipulates that all operators engaged in the issuance, distribution, trading, or custody of crypto-assets must be licensed and placed under the supervision of the competent authorities, namely the Central Bank of Kosovo (CBK), the Tax Administration of Kosovo, and the Financial Intelligence Unit. This means that no individual or legal entity may operate in this field without regulatory oversight by these institutions.
Accordingly, acting under the authority granted by the Law on Crypto-Assets, the CBK adopted the Regulation on the Licensing of Crypto-Asset Service Operators Offering Crypto-Asset Exchange Services on August 29, 2025. This Regulation sets out the conditions, requirements, procedures, and timeframes for licensing crypto-asset service operators engaged in:
- Exchange of crypto-assets for fiat currency (including crypto ATMs); and
- Exchange of crypto-assets for other crypto-assets.
No person may provide crypto-asset services unless they are a legal entity licensed by the CBK as a Crypto-Asset Service Operator. Licensed operators may trade only in crypto-assets that are permitted for trading under European Union legislation.
Licensing Application Process
The license application is not merely a formal file. While the Law prescribes several general licensing criteria, the CBK Regulation sets out additional specific requirements that every business wishing to operate in the crypto-asset market must meet, as well as the full procedure for application and licensing.
According to this Regulation, the licensing application must include a series of documents and information deemed essential by the CBK. The main documents required include the business registration certificate, the company statute, an operational program describing the crypto-asset services to be offered, a description of the governance structure, and details regarding the shareholders and key management.
Operators must also submit an internal control and risk-management plan, including measures against money laundering and terrorist financing, as well as proof of paid-in capital and payment of the licensing fee.
Beyond Paperwork: Three Determining Elements for Licensing
The Regulation goes beyond documentation requirements and identifies three critical factors that determine whether an operator will be granted a license:
1. Minimum Capital Requirement – 125,000 Euro
Each applicant must maintain a minimum capital of 125,000 Euro, plus an additional reserve fund of at least 20% of that amount to cover startup, operating, and administrative costs.
This capital must be paid in cash, properly documented, and serve as a guarantee of the operator’s financial stability. Importantly, the funding source cannot originate from loans or debts.
2. Corporate Governance and Internal Organization
Applicants must demonstrate sound governance and a transparent organizational structure with clearly defined lines of responsibility. This includes well-established processes for risk identification, management, monitoring, and reporting, supported by strong internal controls ensuring operational stability and reliability.
The operator’s board of directors must consist of at least three members, the majority of whom are independent and non-executive. Each director must hold a university degree in economics, law, or a relevant field, have at least three years of professional experience in the financial or banking sector, and meet other criteria outlined by the CBK.
Additionally, the operator must establish at least one internal committee for audit or risk management, designed to support the board in its oversight role.
The Audit Committee, in particular, must include at least one external expert in accounting or auditing to ensure transparency, impartiality, and high professional standards in internal reporting and control.
3. Shareholders’ Reputation
The CBK places particular emphasis on the reliability of significant shareholders, those owning more than 10% of the company’s shares. These individuals must have a clean record, no convictions related to money laundering or terrorist financing, and must not have been responsible for the bankruptcy of any business entity.
If a shareholder’s influence poses risks to the operator’s stability, the CBK may take corrective action, including suspending voting rights associated with that shareholder’s shares.
Why You Should Act Now?
The new Regulation takes effect 90 days after its adoption, meaning it will become fully enforceable at the end of November 2025. From that point, both existing operators and new entrants to the crypto-asset market will have an additional 90 days to submit their license applications to the CBK.
If you already operate in the crypto market or plan to enter it soon, Vokshi & Lata Law Firm is your trusted partner throughout this process.
We assist clients in preparing or auditing licensing files, reviewing and structuring governance frameworks, and developing AML/CFT compliance policies, ensuring every step of the process is handled with precision, professionalism, and full compliance with the Regulation.
Author: Diart Gashi