Self-custodial wallet / non-custodial software in Slovenia
Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.
Self-custodial wallet is conditionally permitted in Slovenia without local incorporation, subject to AML obligations and none licensing burden.
Verdict Details
- Permitted
- conditional
- Local entity required
- No
- Licensing burden
- None
- Last updated
- 2026-07-13
AML Obligations
- No AML/CTF obligations attach to the publisher of self-custodial wallet software, because the publisher never holds, controls, or has access to user funds or private keys — the VASP definitions under ZPPDFT-2 and ZPPML-1 cover only entities that hold or safeguard private keys on behalf of clients (custodial services), not software publishers.
- If the wallet software includes any fiat on-ramp/off-ramp, exchange, or transfer functionality where the publisher intermediates custody, then VASP registration with FURS (under ZPPML-1) and AML obligations under ZPPDFT-2 would attach.
Key Restrictions
- The publisher must not hold, safeguard, or have access to users' private keys in any manner — doing so would trigger VASP classification.
- The publisher must not intermediate any exchange, transfer, or fiat-conversion services involving crypto assets — such services would require VASP registration with FURS.
- If the wallet software includes a swap/fiat gateway integrated as a service (not just a UI to third-party providers), the publisher may be deemed a VASP.
Key Risks
- Regulatory ambiguity: a wallet publisher that merely provides wallet software (non-custodial) is not currently captured as a VASP, but if the regulator (FURS/UPPD) views certain integrated features (e.g., swaps, staking, dapp browser) as 'services for the transfer of virtual currencies' the publisher could be retroactively deemed a VASP.
- MiCA future risk: Under MiCA (Regulation (EU) 2023/1114, effective 2025-2026), wallet software publishers may face broader CASP definitions — 'transfer services for crypto-assets' or 'execution of orders' could encompass self-custodial wallet features, requiring a CASP license.
- Enforcement precedent: No known enforcement actions against pure non-custodial wallet publishers in Slovenia to date, creating uncertainty about regulatory interpretation of software-only models.
Evidence
This verdict synthesizes the following facts. Each fact links to its primary source(s).
VASP Registration: Entities providing services of safeguarding private cryptographic keys on behalf of clients, or holding, storing, and transferring virtual currencies, are classified as "virtual asset service providers" (VASPs) under ZPPDFT-2.
Activities Covered: Services that hold or administer virtual currencies on behalf of third parties, or provide safekeeping services for private cryptographic keys on behalf of clients to hold, store, and transfer virtual currencies.
Activities Covered: Providing platforms or services where users can buy/sell virtual currencies with fiat currencies (e.g., EUR, USD) or exchange one virtual currency for another (e.g., BTC for ETH).
Requirement: Registration with FURS under ZPPML-1.
Current Regime (ZPPML-1): Registration. Slovenia currently requires VASPs to register with FURS before they can operate. This is a registration for AML/CTF purposes, focusing on preventing illicit financial activities, rather than a full operational license that would typically cover aspects like prudential requirements, consumer protection, or market integrity comprehensively.
Providers of services for the exchange between virtual currencies and fiat currencies.
Obligation to Register: VASPs must register with the Office for Money Laundering Prevention (UPPD). This is a registration requirement, not a full prudential licensing regime akin to banks or investment firms, but it entails strict AML/CFT compliance obligations.
Zakon o preprečevanju pranja denarja in financiranja terorizma (ZPPDFT-2) – Prevention of Money Laundering and Terrorist Financing Act (2017, with subsequent amendments, consolidating 5AMLD and 6AMLD):
Authorization: CASPs offering custody services will require authorization from a national competent authority (e.g., ATVP in Slovenia). This is a much more stringent licensing process than the current AML registration.
Verdict Attribution
- Source:
- AI-Generated · Unreviewed
- AI synthesized:
- 2026-07-13 (deepseek-chat)
- Last updated:
- 2026-07-13
- Confidence:
- medium
This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.
Conditional — a publisher of non-custodial (self-custodial) wallet software does not currently trigger VASP classification or AML obligations in Slovenia because it never holds, safeguards, or controls user private keys or funds, but adding any custodial intermediary services (swap, transfer, fiat on-ramp) would require VASP registration with FURS, and MiCA's future CASP framework may broaden the scope to cover certain software services.
Questions this verdict aims to answer
- Does software publishing trigger VASP / MSB classification?
- Do AML obligations attach when no custody exists?
- What disclosure or consumer-protection rules apply?