It depends on how exactly the fund under Section 15 of the ZISIF (Czech Act on Investment Companies and Investment Funds) deals with crypto-assets.

If it manages crypto-assets solely for itself and its investors – such as holding, buying or selling them as part of asset management – and does not provide any services to third parties, authorisation under MiCA is not required.

However, if it provides services to third parties – such as custody and management of crypto-assets for others, operating an exchange or crypto bureau de change, or exchanging crypto-assets on behalf of clients – then these are considered "crypto-asset services" under MiCA. In such cases, authorisation from the Czech National Bank (CNB) is required as a so-called CASP (Crypto-Asset Service Provider).

In short: if the fund manages crypto-assets solely as part of its own investment activities and does not provide services to others, MiCA does not apply. But once it starts offering "extra" services to third parties, MiCA regulation becomes applicable.

Author: Lukáš Tománek