Slovenia CASP Update FAQ

• 1. What happens if I don't upgrade my VASP to CASP?

  From July 1, 2026, all VASP licenses will expire, and companies that have not completed license upgrades must cease operations, otherwise they will be considered unlicensed and face legal risks. To avoid business disruption and potential penalties, we recommend that licensed companies proceed with the upgrade of their CASP licenses as soon as possible to avoid the dilemma of operating without a license.

• 2. Does Slovenia have no transition period for the MiCA Act?

  Yes, Slovenia does not have a transition period. According to the MiCA Act, after July 1, 2026, all VASP licenses will automatically expire, and enterprises that have not completed the upgrade will not be able to continue to operate legally, otherwise they will be regarded as unlicensed operations.

• 3. Regulatory requirements for senior management or boards of directors

  Qualifying CASP licensed businesses must be managed by experienced individuals with multicultural backgrounds. The management or board of directors should be composed of teams with relevant experience in financial technology, information technology, risk control and operations management, which will greatly improve the success rate of obtaining licenses. We recommend that the board and management include at least two practitioners with fintech expertise.
  
  In addition, top management must provide the following materials:
  
  No criminal record and proof of non-bankrupt
  Detailed resume
  CV and Time Commitment to Licensed Enterprises

• 4. Does the applicant need to set up an IT system in advance?

  No, the license upgrade of CASP is only subject to written review. If the company already has a ready-made website or application at the VASP stage, it can write an ICT policy on the basis of the existing system.

• 5. Maintenance costs after upgrading the license to CASP

  The magnitude of maintenance costs will depend on your company's existing configuration. Expenses such as annual audits, quarterly reports, software subscriptions, employee salaries, office rent, utilities, etc. are all expenses to consider. If the relevant configuration has been established during the VASP license, the subsequent cost increase may not be very high; if the configuration is very different from the previous one, the maintenance cost may increase accordingly.

• 6. Who will be responsible for drafting documents?

  We will be solely responsible for the drafting of all necessary documents. All you need to do is assemble a small team to provide feedback and comments on the issues raised when we prepare the material (e. g. ICT policy).

• 7. What is the solution for opening a bank account?

  We work closely with a number of European banking channels and can assist you in opening a corporate operating account.

• What is the official language of Slovenia?

  Slovenian is the official language of Slovenia. All documents submitted to the Office for Money Laundering (Office for Money Laundering Prevention) must be in Slovenian, so there are translation costs involved in the process of upgrading the licence. Our team can communicate fluently in English and Chinese.

• 9. What are the common challenges in the application process?

  Personnel management is the most difficult part of project management, especially when team members come from different cultural backgrounds, regions, companies or departments, which can increase communication costs and make team management more complex. In addition, meeting the expectations of regulators will not be easy. Regulators' focus is usually on ensuring national financial security and stability, which is different from the entrepreneur's business goals. As a result, accurately understanding and meeting regulatory requirements becomes a major challenge. We will act as an intermediary to help coordinate the relationship between the parties and ensure the smooth progress of the project.

• 10. Who will maintain the CASP licence after it is granted?

  Our company has been in the compliance market for seven years and has accumulated experience in providing license maintenance solutions for more than 20 companies. You can think of us as a compliance team within your company, responsible for the follow-up of maintaining the license.

• 11. After obtaining a CASP license, what compliance obligations are the licensed enterprises required to comply?

  Once licensed, a licensed company is required to meet various compliance obligations, such as submitting regular operational reports (quarterly/annual reports), conducting customer due diligence, and ensuring compliance with anti-money laundering regulations. These obligations are designed to ensure that your operations meet regulatory requirements and reduce compliance risks.

• 12. What are the consequences if I refuse to comply with regulatory requirements?

  If a licensed company fails to comply with regulatory requirements, it may face penalties, including fines, or, in serious cases, license revocation. Therefore, it is essential to establish a qualified compliance team and equip the corresponding systems, which can help your company reduce compliance risks.

• 13. How can companies keep abreast of regulatory or regulatory changes?

  We recommend that you subscribe to the Information Notice of the Slovenian Anti-Money Laundering Department. In addition, we can provide ongoing insights and updates on regulatory changes that may affect your operations to ensure you are always up to date.

• What should the business plan contain?

  The business plan should include an executive summary, market analysis, product and service details, marketing strategy, operations plan, competitor analysis (SWOT), and a comprehensive financial forecast.

• 15. What should be included in the financial forecast?

  The financial forecast should include a detailed revenue forecast, cost structure and cash flow management over a three-year period. For licence applications, reliable financial forecasts should contain actual indicators, usually showing heavy losses in the first year, reduced losses in the second year, and flat or profitable gains in the third year. In addition, a good forecast should also cover different scenarios, including normal, best-case and worst-case scenarios, to fully understand potential financial performance.

• What should an ICT policy book contain?

  The ICT policy should contain comprehensive guidelines aimed at protecting digital assets and sensitive data from unauthorized access and cyber threats. It covers key areas such as access control protocols, data protection measures, incident response policies, employee training programs, and regular security audits to ensure effective protection against emerging threats.

• 17. What should a director's resume contain?

  A director's resume should include experience, including the company and position in which he or she has worked, and highlight his or her strengths to demonstrate his or her suitability for the position of director.

• 18. What should be included in the outsourcing policy?

  Outsourced service policies should include policy objectives, outsourcing scope, supplier selection criteria, contract management, risk management, service quality monitoring and compliance requirements.

• 19. What should be included in the fund custody policy?

  The fund receipt and management process, payment process, risk management, audit compliance and customer information protection, while the outsourcing service policy should include the purpose, scope of outsourcing, supplier selection criteria, contract management, risk management, service quality monitoring and compliance requirements.

• 20. What should conflict of interest resolution include?

  The resolution of conflicts of interest should include policy objectives, definition of conflicts of interest, disclosure requirements, assessment procedures, resolution, monitoring and audit mechanisms.

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