Financial Services Licences in Austria | FMA & MiCA

The licence an Austrian financial-services firm needs depends entirely on the activity: banking, payments, e-money, investment services, fund management, insurance intermediation and crypto-asset services each sit under a different act, with a different minimum capital, all supervised by the Financial Market Authority (FMA). Some firms need no Austrian licence at all — an EU-passported firm can often operate here on notification alone. This page sets out the capital figures we could verify for 2026, the crypto transition deadline most competitors still get wrong, and when Austria is not the right jurisdiction at all.

Licence Categories and Minimum Capital

The Financial Market Authority (FMA) supervises seven main categories of regulated financial activity in Austria, each governed by its own act.

ActivityMinimum initial capitalGoverning act
Credit institution (banking)EUR 5,000,000BWG § 5
Payment institutionEUR 20,000 / 50,000 / 125,000, depending on which payment services are providedZaDiG 2018 § 16
E-money institutionEUR 350,000 (hard core capital, held permanently)E-GeldG 2010 § 11
Investment firmEUR 75,000 / 150,000 / 750,000, tiered by service — see the note below the tableWPFG § 13
Alternative investment fund manager (AIFM)EUR 300,000 (internally managed) / 125,000 (externally appointed), plus an add-on above EUR 250m under management, capped at EUR 10,000,000 totalAIFMG § 7
UCITS management companyEUR 2,500,000, plus an add-on above EUR 250m in fund assetsInvFG 2011 § 6
Insurance intermediaryNo capital requirement — professional indemnity insurance instead (see below)GewO § 137c

The investment-firm row needs unpacking, because the tier follows what the firm is permitted to do rather than how large it is. EUR 750,000 applies where the business covers dealing on own account, or underwriting and placing instruments on a firm-commitment basis — and equally where the firm runs an organised trading facility and its authorisation includes dealing on own account. EUR 75,000 applies to a firm that receives and transmits orders, executes orders for clients, manages portfolios, advises on investments, or places instruments without a firm commitment, and is not permitted to hold client money or client financial instruments. That last condition is part of the tier rather than a footnote to it: the same list of services performed by a firm that does hold client assets falls to EUR 150,000, which is the residual figure for every case the other tiers do not cover.

Two citation traps sit behind this table, and both are common in material written before 2023. Capital for investment firms has not been set by the Wertpapieraufsichtsgesetz 2018 since 1 February 2023 — WAG 2018 § 3 Abs. 6 now points at WPFG § 13, so any source quoting an amount out of WAG 2018 is out of date. For UCITS management companies, the figure EUR 125,000 circulates widely; that is the baseline in the EU UCITS Directive, not the Austrian requirement. An Austrian management company holds a credit-institution authorisation, which puts its initial capital at EUR 2,500,000 — with additional core capital of 0.02% of fund assets above EUR 250 million, no top-up required until that calculation exceeds EUR 2,375,000, and a ceiling of EUR 7.5 million on the add-on.

Insurance Intermediaries

Insurance intermediaries in Austria face no minimum-capital rule at all; instead, the Gewerbeordnung (GewO) § 137c requires professional indemnity insurance at a minimum sum that is periodically adjusted at EU level.

The statutory base figures are EUR 1,250,000 per claim and EUR 1,850,000 in aggregate per year. The figure actually in force — and applicable throughout 2026 — is higher: EUR 1,564,610 per claim and EUR 2,315,610 in aggregate per year, set by Commission Delegated Regulation (EU) 2024/896 and applicable from 9 October 2024. Insurance substitutes for capital here because most intermediaries advise on and arrange cover rather than hold client funds — a different risk profile from a firm that takes deposits or executes payments.

Crypto-Asset Service Providers and MiCA

MiCA (Regulation (EU) 2023/1114) became fully applicable across the EU, including Austria, on 30 December 2024, and moved supervision of crypto-asset service providers to the FMA.

Austria chose a transitional grandfathering period of twelve months under MiCA Article 143(3) for firms previously registered under the FM-GwG — not the eighteen months some commentary states. That means Austria's transitional window closed on 30 December 2025, which has already passed. The EU-wide backstop date of 1 July 2026 that some sources quote as Austria's deadline is the outer limit for member states that chose the full eighteen months; it was never Austria's own date. We checked this directly against ESMA's own published list of Article 143(3) notifications, and the Austria row reads twelve months with no caveat attached.

The practical consequence: a firm still relying on a pre-MiCA FM-GwG registration today, with no live CASP authorisation and no application filed in time to benefit from the transitional arrangement, has no lawful basis to continue providing crypto-asset services in Austria.

Own-funds requirements under MiCA itself are tiered by the services provided:

CASP classServices coveredMinimum own funds
Class 1Execution of orders, placing of crypto-assets, transfer services, reception and transmission of orders, advice, portfolio managementEUR 50,000
Class 2Class 1 services plus custody and administration, or exchange for funds or other crypto-assetsEUR 125,000
Class 3Class 2 services plus operating a trading platformEUR 150,000

These figures come from MiCA's own Article 67 and Annex IV — an EU regulation that applies directly in Austria, without separate transposition into national law.

EU Passporting

An EEA-authorised credit institution does not need a separate Austrian licence to operate in Austria — it uses a notification procedure instead, under BWG § 9.

The home-state supervisor notifies the FMA, and the firm then operates through a branch or under the freedom to provide cross-border services, to the extent its home-state authorisation covers the activity. The same single-market logic extends to EEA-authorised payment institutions, e-money institutions, investment firms and alternative investment fund managers under their own respective EU directives — each uses the equivalent notification route in its own sectoral law rather than a fresh Austrian application.

Telling a prospective client they do not need an Austrian licence at all is, more often than a competitor's page will admit, the right answer. Passporting only fails to apply when the activity genuinely is not covered by the firm's home-state authorisation, or when the firm has no EEA authorisation to passport in the first place.

Fees and Processing Times

FMA fees are set by regulation, not published here as a flat figure.

A fee schedule exists — the FMA-Gebührenverordnung — and applies for every grant of an authorisation, but the specific euro amount per licence type sits in a tariff annex we were not able to extract during this review, and fma.gv.at itself was unreachable throughout our research. We also did not find a confirmed statutory processing-time deadline specific to FMA licence applications. Fees and any indicative timeline are quoted per application once we know the licence type and the firm's circumstances.

When Austria Is the Wrong Jurisdiction

Austria is not always the right place to hold a financial-services licence, and we would rather say so than sell an engagement that does not fit.

Licensing demand across Europe concentrates in a handful of jurisdictions — Lithuania, Malta, Estonia and Ireland among them — and a firm whose only requirement is a passportable EU licence often has cheaper and faster options there than in Austria. Austria makes more sense when the business itself has an Austrian or DACH-region rationale: an Austrian client base, an Austrian banking relationship, or a group structure that already runs through Austria. A licence chosen purely for jurisdiction-shopping reasons, with no underlying Austrian business case, is usually better placed elsewhere.

What We Do

Our financial-licensing work in Austria starts with matching the business model to the correct licence category, since the capital, governing act and regulator process differ by activity.

  1. Licence-category assessment — confirming which Austrian licence, if any, the business actually needs, including whether EU passporting already covers it.
  2. Capital and structure planning — working out the entity, ownership and capital structure the chosen licence category requires.
  3. Application preparation — compiling the file the FMA expects, coordinated with the firm's own compliance and legal teams.
  4. FMA liaison — handling correspondence and follow-up requests during the review.

Most enquiries on this page come from founders and firms based outside Austria who need EU market access rather than an Austrian client base specifically — see the jurisdiction question above before assuming Austria is the right starting point. This service sits alongside our Austrian company formation and corporate bank account services, both of which any licence holder needs regardless of licence type, and our broader corporate services in Austria.

Frequently Asked Questions

Does a crypto exchange operating in Austria still need MiCA authorisation?

Yes, and the deadline to obtain it has already passed. Austria's MiCA transitional period for firms previously registered under the FM-GwG ran for twelve months from 30 December 2024 and closed on 30 December 2025. A firm still relying on its old FM-GwG registration today has no lawful basis to continue.

What is the minimum capital for an Austrian payment institution licence?

It depends on the services provided: EUR 20,000 for money-remittance business only, EUR 50,000 for payment-initiation services only, or EUR 125,000 for any of the core payment services under the Zahlungsdienstegesetz 2018.

Do I need an Austrian licence if my firm is already authorised elsewhere in the EU?

Often not. An EEA-authorised credit institution, payment institution, e-money institution, investment firm or fund manager can generally operate in Austria on a notification basis under EU passporting rules, without a separate Austrian licence, provided the activity is covered by the home-state authorisation.

How much does an FMA licence application cost?

A fee schedule exists in Austrian regulation, but we could not confirm the specific euro amounts for each licence type during our most recent review, and fma.gv.at was unreachable throughout that research. Fees are quoted once we know the licence type and the application's specifics.

Is Austria a good place to get an EU crypto-asset service provider authorisation?

It depends on the business. Austria works well where there is already an Austrian or DACH-region rationale. A firm whose only requirement is a passportable EU CASP authorisation, with no Austrian business case, often finds Lithuania, Malta, Estonia or Ireland faster and less expensive.

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