Bare Bitcoin has received MiCA approval from Norway's Finanstilsynet. The bitcoin-focused exchange with three employees shows that MiCA is not reserved for the big players — and that the licence can open doors the company isn't knocking on today.
Bare Bitcoin is among the smallest crypto exchanges in Norway, with just three employees. The company has now secured a MiCA licence — the European crypto regulation that came into force at the turn of the year — following months of close dialogue with Norway's financial regulator, Finanstilsynet. Co-founder Torkel Rogstad acknowledges that the licence is not just a mark of trust, but also a matter of survival.
On Friday, a message arrived at Bare Bitcoin from Finanstilsynet confirming the company had received its MiCA licence. Torkel Rogstad (pictured) told Kaupr in an interview over the weekend that he is delighted with the outcome.
– Without this, we would have had to shut down. And we think that would have been a huge tragedy, says Rogstad.
For the co-founder, the licence also carries longer-term significance — the ability to one day engage with banks or institutional investors on equal footing with larger players, should they come knocking.
– You can go to a bank or a fund manager and say that we have the licence. That means a lot in that world, says Rogstad.
With just three employees, Bare Bitcoin is the smallest operator to have received a MiCA licence in Norway. The company's size created concrete challenges in the application process: MiCA requires that different functions — such as compliance and anti-money laundering responsibilities — are held by different individuals. The solution largely came down to carefully mapping out who was responsible for what. The company expanded its board, increased AML staffing and brought in external auditors. In late May and early June, it also engaged external legal counsel to handle outstanding matters in the final stretch.
Rogstad is consistently positive about Finanstilsynet's handling of the process, describing a willingness to engage that he did not take for granted.
– Finanstilsynet has been very pragmatic in finding solutions together with us. That is not something I expect from a public body, but they have done it, says Rogstad.
This stands in contrast to experiences reported in other European countries, where operators have received little response from national regulators, and where many had still not received approval just days before the MiCA deadline.
Despite his positive experience with Norway's Finanstilsynet, Rogstad is critical of the MiCA framework itself. Pan-European rules implemented by 27 different national authorities create what he describes as a duplication of effort without corresponding harmonisation.
– The model is a bit strange. You have a common rulebook, but it is up to 27 different countries to implement it. In practice, you end up with 27 parallel processes, where some do it well and others don't, says Rogstad.
He argues that a single European supervisory authority would have been the logical approach, and asks rhetorically whether the problem lies with the companies — or whether the rules are simply too complex.
So far in 2026, Bare Bitcoin has recorded exchange volume of 360 million Norwegian kroner, compared with around 800 million for the full year of 2025. The company has no immediate plans for European expansion and intends to consolidate its position in the Norwegian market.
For Bare Bitcoin, the MiCA licence is above all proof that a small company can achieve what larger players take for granted — and that credibility does not always require scale.
Sources: Interview with Torkel Rogstad, Bare Bitcoin
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