Compliance · MiCA

MiCA compliance
for web3 games.

What it is. What it costs.
How we handle it.

MiCA is the EU's Markets in Crypto-Assets regulation. It requires most Web3 game developers serving EU players to register as a Crypto-Asset Service Provider. The full compliance burden runs €500,000 to €1 million in year one. Genesis Engine holds the licence centrally so developers do not have to.

The regulation

What MiCA actually is.

MiCA (Markets in Crypto-Assets) is EU regulation that came into effect in 2024. It governs who can offer crypto-asset services to people in the European Union and on what terms.

For Web3 games, MiCA matters because it covers most of the things Web3 games do natively: holding player funds, running a marketplace, transferring tokens, processing payments. If your game touches any of those activities and serves EU players, you fall within MiCA scope.

MiCA applies based on where your players are. Where your team is headquartered does not matter. A US developer, a UK developer, a Singapore developer — all subject to MiCA if EU players can access the game.

Scope

Does MiCA apply to your game?

Not every Web3 game falls under MiCA. The regulation triggers on specific activities. Most Web3 games hit at least one.

If your game does any of these for EU players, MiCA applies. Most Web3 games we speak to hit at least three.

Trigger conditions
Custodial wallets for players
In-game marketplace for tradable assets
Token transfers between players
NFT minting and secondary trading
Fiat-to-crypto or crypto-to-fiat conversion
Year-one burden

What the CASP licence costs.

The full year-one cost of holding a CASP licence is not the application fee. It is the operating apparatus the regulation requires around the licence.

Cost category Year-one estimate Notes
Application fees Low 4 – mid 5 figures Varies by country. Malta and Lithuania cheapest. Sweden, Germany, France higher.
Capital reserve €50K – €150K Class 1 / 2 / 3 or 25% of prior year fixed overhead, whichever is higher. Article 67 governs the rules.
Qualified staff €200K – €500K Compliance officer, AML officer, suitable board members.
Legal counsel €100K – €300K Application drafting, ongoing advisory, regulatory submissions.
External audits €50K – €100K/yr Required ongoing.
Total year one €500K – €1M+ Real-world burden for a single-developer licence.

The licence is not the expense. The apparatus around it is.

Application process

The timeline.

A CASP licence application takes 6 to 12 months from start to approval — assuming the application is filed correctly the first time.

Month 0–3

Preparation

Choose jurisdiction. Draft governance and risk frameworks. Hire compliance staff. Set up capital reserves.

Month 3–6

Submission

Submit the application to the National Competent Authority. Initial completeness review.

Month 6–11

Legal review

Once the application is deemed complete, the legal review period runs up to 5 months. Questions, supplementary submissions, conditions.

Month 11–12+

Decision

Approval, conditional approval, or rejection. Conditions usually involve additional capital, staffing, or governance changes.

Key provision

The capital reserve that catches developers out.

Article 67 of MiCA governs the capital reserve requirement. The reserve must be held as CET1 (Common Equity Tier 1) own funds or as a qualifying insurance policy from an authorised insurer.

That means Bitcoin does not count. Stablecoins do not count. Crypto reserves do not count. The reserve must be conventional capital, held in a way that satisfies traditional financial regulators.

For a Web3-native developer, this is often the most surprising part of the licence. The capital reserve cannot be drawn from the project's own treasury. It must be parked, locked, and unable to support operations.

Article 67 · MiCA

The capital reserve sits outside your treasury. Permanently.

The alternative

The Genesis Engine alternative.

Most Web3 game developers cannot carry the MiCA burden alone. Genesis Engine holds the licence at the platform level. Developers operate under our regulatory perimeter.

Going it alone Build on Genesis Engine
Year-one cost €500,000 to €1,000,000+ Platform usage fees
Time to launch 6–12 months Weeks
Capital reserve €50,000–€150,000 locked Held at platform level
Compliance staff Hire and retain Handled by Genesis Engine
Application risk Possible rejection Already underway
Ongoing audits Annual, on you Handled at platform level
Player KYC Build your own stack Sumsub integrated via SDK
Custody Build or buy AWS KMS hardware security modules

You build the game. We carry the regulation.

Your compliance-first positioning is powerful. You're building what trust looks like in blockchain gaming.

InvestGame · Web3 Gaming Analyst
Hashlock security audits
Blockchain Game Alliance member
Pursuing CASP licence in Sweden

Ready to skip the licence queue?

If you are building a Web3 game and want to reach EU players without spending a year on regulatory infrastructure, talk to us.

Questions

Compliance questions.

Does MiCA apply to my Web3 game if my team is outside the EU?
Yes. MiCA applies based on where your players are located, not where your team is headquartered. A US, UK, Singapore, or any other non-EU developer falls under MiCA scope when their game serves EU players and involves custodial wallets, in-game marketplaces, or token transfers.
What is a CASP licence?
CASP stands for Crypto-Asset Service Provider. It is the authorisation required under MiCA for entities offering crypto-asset services in the EU. Most Web3 games that handle player funds, run marketplaces, or process token transfers need either their own CASP licence or to operate under a licensed platform like Genesis Engine.
What does the CASP licence actually cost?
Year-one cost is typically €500,000 to €1,000,000 for a developer going it alone. Breakdown: application fees (low four to mid five figures, depending on country), capital reserve (€50,000–€150,000 minimum), qualified staff (€200,000–€500,000), legal counsel (€100,000–€300,000), external audits (€50,000–€100,000 annually).
Can my crypto treasury serve as the capital reserve?
No. Article 67 requires the reserve to be held as CET1 (Common Equity Tier 1) own funds or as a qualifying insurance policy. Bitcoin, stablecoins, and other crypto assets do not qualify. The reserve must be conventional capital, locked and unable to fund operations.
How long does the CASP application take?
6 to 12 months from preparation to approval. Once the National Competent Authority deems the application complete, the legal review period can run up to 5 months on its own. Conditions and supplementary submissions can extend this.
What happens if I serve EU players without MiCA compliance?
Enforcement varies by country, but consequences include fines from National Competent Authorities, ESMA action, inability to process payments through EU financial infrastructure, and forced platform shutdown for EU users. Continued non-compliance can lead to criminal liability for directors in some jurisdictions.
Does Genesis Engine cover compliance outside the EU as well?
Genesis Engine is built MiCA-first because MiCA is the most comprehensive crypto-asset framework in operation. We monitor adjacent frameworks (UK, US, Singapore, UAE) and build toward broader coverage. For now, the EU is the immediate problem we solve.
What is the Transfer of Funds Regulation (TFR)?
TFR is the EU regulation adjacent to MiCA that requires originator and beneficiary information for crypto transfers (similar to the FATF Travel Rule). It applies to most Web3 game token transfers above certain thresholds. Genesis Engine handles TFR compliance at the platform level.
Is Genesis Engine itself fully licensed today?
Genesis Engine is in the CASP application process in Sweden, with Finansinspektionen as the supervising authority. Developers joining the waitlist now will be onboarded as the licence comes through. Early developers are part of the launch cohort.
What about countries that have not yet implemented MiCA fully?
MiCA is a regulation, not a directive, meaning it applies directly across all 27 EU member states. National Competent Authorities are at different stages of operational readiness, but the underlying law applies uniformly. Transitional provisions exist for entities that held national crypto registrations before MiCA, but most Web3 games are out of scope of those provisions.