top of page
Writer's pictureSOTIRI Erwin

Luxembourg VASP registration: Is it worth the rush before 2025?


VASP in Luxembourg before 2025

As the crypto industry evolves, so does the regulation. In Luxembourg, a critical deadline approaches for Virtual Asset Service Providers (VASPs). With the registration window closing on December 30, 2024, many are asking: Is it still worthwhile to register as a VASP in Luxembourg? Let's explore the pros and cons to help you make an informed decision.


Key takeaways:

  • VASP registration in Luxembourg closes on December 30, 2024

  • Registered VASPs gain access to a transitional regime until July 1, 2026

  • Only 12 VASPs were registered in Luxembourg as of early 2024

  • The registration process involves a €15,000 annual fee and extensive documentation


The benefits of last-minute VASP registration

1. Transitional regime access

By registering before the deadline, VASPs can operate under a transitional regime until July 1, 2026, or until MiCAR (Markets in Crypto-Assets Regulation) decides on Crypto Asset Service Provider (CASP) authorization, whichever comes first.


2. Regulatory continuity

During this transition, registered VASPs will:

  • Maintain current regulatory requirements under the AML Act

  • Be treated as CASPs for Transfer of Funds Regulation (TFR) purposes


3. Competitive advantage

With only 12 registered VASPs in Luxembourg as of early 2024, joining this exclusive group could:

  • Provide a competitive edge

  • Demonstrate your commitment to compliance


4. Legal operation

Perhaps most crucially, registration allows you to legally provide virtual asset services in Luxembourg beyond December 2024.


Challenges and considerations

While the benefits are significant, there are hurdles to consider:

  1. Cost: An annual fee of €15,000 for registered VASPs

  2. Complexity: The application process requires extensive documentation, particularly around AML/CFT compliance

  3. Time Pressure: With the December deadline approaching, swift action is crucial


MiCAR and CASP authorization

It's important to note that VASP registration is not the final step. The transition to the MiCAR regime is inevitable, and the CSSF (Commission de Surveillance du Secteur Financier) is already encouraging dialogue about future CASP authorization.


Making your decision

For entities considering VASP registration in Luxembourg, carefully weigh the potential benefits against the costs and effort required. The opportunity to:

  • Operate legally

  • Enjoy transitional benefits

  • Potentially position yourself advantageously for the MiCAR regime

could be valuable for your business.


Time is of the essence

If you're considering VASP registration in Luxembourg, act quickly. Seek professional advice to navigate the complexities of the registration process. Your decision should align with your specific circumstances, long-term strategy, and readiness to embrace the evolving regulatory landscape of the crypto industry.


Remember, the clock is ticking. Will you seize the opportunity to register as a VASP in Luxembourg before 2025?

17 views0 comments

Recent Posts

See All

Comments


bottom of page