A crypto licence is the regulator's approval to provide services involving cryptoassets to customers: exchanging them for money or for other cryptoassets, holding them in custody, transferring them, running a trading platform, broking or issuing stablecoins. Without it, a business cannot lawfully serve customers in a regulated market, and banks, card schemes and payment providers will not open operating accounts for it.
The legal form differs by country. In some it is a registration for anti-money laundering purposes only; in others it is a full authorisation with capital, conduct and custody rules. The industry term is a virtual asset service provider (VASP) licence, taken from the Financial Action Task Force (FATF), the international body that sets anti-money laundering standards. FATF Recommendation 15 requires every country to license or register VASPs, and Recommendation 16, the travel rule, requires sender and recipient information to accompany cryptoasset transfers.
In 2026 the direction is clear. The EU's Markets in Crypto-Assets Regulation (MiCA) is fully in force, its transitional periods having ended on 1 July 2026 at the latest in every member state. The UK's application window for full FCA authorisation opened on 30 September 2026. The United States has a federal stablecoin law, and Australia's reformed anti-money laundering rules for virtual asset services took effect on 31 March 2026. Registration-only regimes are giving way to full authorisation.
A business generally needs a licence or registration if it does any of the following for customers:
Pure software providers, such as developers of non-custodial wallets that never control customer assets, are usually outside scope. Each regulator draws that line slightly differently, so the analysis starts with what the business actually does with customer assets and money.
| Licence type | What it covers | Examples |
|---|---|---|
| AML registration (VASP registration) | Anti-money laundering supervision of exchange and custody | UK MLR registration, Canada FINTRAC MSB, US FinCEN MSB, Australia AUSTRAC |
| Full crypto authorisation | Capital, conduct, custody, governance and market rules | EU MiCA CASP, UK FSMA regime from 2027, Dubai VARA, Hong Kong SFC |
| Payment or money transmission licence | Moving customer money or value, including stablecoin payments | US state money transmitter licences, Singapore payment institution licence, EU EMI |
| Securities or investment licence | Tokens that are financial instruments, derivatives and tokenised securities | MiFID investment firm, US broker-dealer, ASIC AFS licence |
| Stablecoin issuer licence | Issuing and redeeming fiat-referenced tokens | MiCA EMT or ART, UK qualifying stablecoin permission, US GENIUS Act issuers |
Many businesses need more than one. A stablecoin payments company may need an e-money licence for the fiat leg and a crypto authorisation for custody; an exchange offering derivatives needs an investment licence as well as its crypto authorisation.
The table summarises the regulator and licence in each of the main markets. The sections that follow give the requirements, capital and timing for each.
| Jurisdiction | Regulator | Licence |
|---|---|---|
| European Union | National competent authority in the home member state | MiCA crypto-asset service provider (CASP) authorisation, passported across the EU |
| United Kingdom | Financial Conduct Authority | MLR registration now; FSMA authorisation from 25 October 2027 |
| United States | FinCEN and state regulators | FinCEN MSB registration plus state money transmitter licences; New York BitLicense |
| Canada | FINTRAC; provincial securities regulators | MSB registration for dealing in virtual currency; securities registration for trading platforms |
| Australia | AUSTRAC; ASIC | AUSTRAC registration for virtual asset services; AFS licence for financial products |
| United Arab Emirates | VARA (Dubai); FSRA (ADGM); DFSA (DIFC) | Virtual asset licences by activity in each zone |
| Singapore | Monetary Authority of Singapore | Payment institution licence for digital payment token services |
| Hong Kong | Securities and Futures Commission | Virtual asset trading platform (VATP) licence |
| Switzerland | FINMA; self-regulatory organisations | SRO membership for AML; FinTech or banking licence for custody and deposits |
MiCA (Regulation (EU) 2023/1114) gives the EU one crypto licence. A firm authorised as a crypto-asset service provider by the regulator in its home member state can serve customers in every other EU and EEA country by notification, without further licences. National VASP registrations ceased to be a basis for operating when the transitional periods ended on 1 July 2026 at the latest.
| Class | Services | Minimum capital |
|---|---|---|
| Class 1 | Reception and transmission of orders, execution, placing, transfer services, advice, portfolio management | €50,000 |
| Class 2 | Class 1 services plus custody and exchange of crypto for funds or other crypto | €125,000 |
| Class 3 | Class 2 services plus operating a trading platform | €150,000 |
Own funds must be the higher of the class minimum and one quarter of the previous year's fixed overheads. Applicants also need a registered office and at least one director resident in the EU, a place of effective management in the EU, fit and proper management, and a full set of policies on governance, custody, complaints, conflicts, outsourcing, business continuity and anti-money laundering.
MiCA gives the regulator 25 working days to check that an application is complete and 40 working days to assess a complete application, with the clock paused while it waits for answers to its questions. That is around three months of regulator time; with information requests, firms plan on 6 to 8 months from submission. The choice of member state matters, and our MiCA CASP licence guide compares the main options.
The UK is between two regimes. Today, cryptoasset exchange providers and custodian wallet providers must register with the FCA under the Money Laundering Regulations before trading. The registration fee is £11,260.
From 25 October 2027, the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 require FSMA authorisation for operating a trading platform, dealing, arranging, safeguarding, staking and issuing UK stablecoins. The FCA's application window is open from 30 September 2026 to 28 February 2027. Existing firms that apply in the window can keep trading while their application is decided; registration does not convert into authorisation.
| UK activity | Permanent minimum capital |
|---|---|
| Dealing as principal | £750,000 |
| Issuing a qualifying stablecoin | £350,000 |
| Custody, trading platform or staking | £150,000 |
| Dealing as agent or arranging | £75,000 |
The FCA expects overseas groups to apply through a UK legal entity with real UK presence, with a UK branch accepted mainly for trading platforms. The FCA aims to decide every application made in the window before commencement. Our UK crypto licence guide covers the process in full.
The US has no single federal crypto licence. A business that exchanges or transmits virtual currency is a money services business (MSB) and registers with the Financial Crimes Enforcement Network (FinCEN). Registration is free, is completed online, and is renewed every two years. It brings federal anti-money laundering duties: a written AML programme, a compliance officer, suspicious activity and currency transaction reporting, and record keeping.
Most states treat custody and transmission of virtual currency for customers as money transmission and require a state licence, applied for through the Nationwide Multistate Licensing System (NMLS). Each state sets its own net worth, surety bond and application requirements, so a national launch is planned state by state. California has its own digital financial assets licensing law administered by its Department of Financial Protection and Innovation.
Any business carrying on virtual currency business activity involving New York or its residents needs a BitLicense from the New York State Department of Financial Services (NYDFS), or a New York limited purpose trust charter, which can also exercise fiduciary powers and conduct money transmission without a separate licence. Applications go through NMLS, and NYDFS begins its substantive review only once the application is complete.
The GENIUS Act, signed into law on 18 July 2025, creates a federal framework for payment stablecoin issuers. It takes effect on the earlier of 18 January 2027 or 120 days after the regulators issue final rules; the implementing rules are still at proposal stage.
Dealing in virtual currency is a money services business activity in Canada. It covers exchanging funds for virtual currency, virtual currency for funds or one virtual currency for another, and transferring virtual currency at a customer's request. The business must register with FINTRAC before it starts. FINTRAC charges no registration fee.
A business without a place of business in Canada that directs services at people in Canada and provides those services to them is a foreign MSB and must also register. Registration brings a compliance programme, a compliance officer, know-your-client checks, reporting of large virtual currency transactions and suspicious transactions, and the travel rule.
Crypto trading platforms that hold client assets are also within provincial securities law. The Canadian Securities Administrators require them to register as dealers or to operate under a pre-registration undertaking while they register. Our Canada crypto MSB guide sets out both steps.
Australian crypto businesses register with AUSTRAC, the anti-money laundering regulator, before providing services. The reforms to the Anti-Money Laundering and Counter-Terrorism Financing Act that took effect on 31 March 2026 widened the regime from digital currency exchange to a broader set of virtual asset services, bringing exchanges between virtual assets, transfers on behalf of customers and custody of virtual assets into scope alongside exchange with money.
Registered businesses need an AML/CTF programme, a compliance officer, customer due diligence, transaction monitoring, travel rule compliance and reporting to AUSTRAC. Where a crypto product is a financial product, such as a derivative or a managed investment, the business also needs an Australian financial services (AFS) licence from ASIC. Our AUSTRAC VASP registration guide covers the reformed requirements.
The UAE has three main crypto regimes, chosen by where the business is based:
Payment uses of tokens fall under the Central Bank of the UAE. Each regime expects local substance: an office, resident senior management and a compliance officer and MLRO in the UAE. Regulator fees and capital vary by activity; our Dubai VARA licence page sets out the activity list and process.
In Singapore, buying, selling or facilitating the exchange of digital payment tokens, and transferring or holding them for customers, are digital payment token services under the Payment Services Act 2019. They need a standard payment institution licence or, above set transaction thresholds, a major payment institution licence from the Monetary Authority of Singapore (MAS). Base capital is set by licence class.
MAS expects strong technology risk management, segregation of customer assets, consumer protection measures for retail customers and full AML/CFT controls, including the travel rule. Singapore-incorporated firms that serve only customers outside Singapore fall under a separate digital token service provider regime, for which MAS has said it will grant licences only in very limited cases. Singapore suits firms with real operations and management in the country.
A centralised virtual asset exchange operating in Hong Kong, or actively marketing to Hong Kong investors, needs a licence from the Securities and Futures Commission (SFC). The SFC's guidelines for virtual asset trading platform operators set the financial requirements:
| Requirement | Amount |
|---|---|
| Paid-up share capital | HK$5,000,000 at all times |
| Liquid capital | The higher of HK$3,000,000 and the basic amount under the Financial Resources Rules |
| Operating reserve | Liquid assets in Hong Kong, excluding virtual assets, covering 12 months of actual operating expenses |
Licensed platforms must also have responsible officers approved by the SFC, custody of client assets through a wholly owned subsidiary, token admission and review procedures, and market surveillance. Retail access is allowed for eligible tokens under the SFC's conditions. Details are on our Hong Kong VATP licence page.
Switzerland regulates crypto through its existing financial market laws. Trading in virtual currencies falls under the Anti-Money Laundering Act, and a business within its scope must join a self-regulatory organisation (SRO) recognised by FINMA. FINMA says every crypto business must check whether it also needs authorisation or supervision under financial market law, depending on its activities.
A business that accepts client deposits up to CHF 100 million or holds cryptoassets in collective custody needs a FinTech licence; larger deposit-taking needs a banking licence. Switzerland suits custody, asset management and tokenisation businesses that value its legal certainty on the treatment of cryptoassets in insolvency.
Although the rules differ, every regulator assesses the same seven areas.
A firm that builds these once, to the strictest standard it will face, can reuse most of the work across several jurisdictions.
The cost has four parts: regulator fees, capital, people and systems. Regulator fees range from nothing (FinCEN and FINTRAC registration) to five figures (the UK MLR registration fee is £11,260). Capital ranges from none for a registration to €150,000 for a MiCA trading platform, £750,000 for a UK dealer acting as principal and HK$5,000,000 of share capital for a Hong Kong platform.
| Cost item | What drives it |
|---|---|
| Regulator fees | Jurisdiction and activities; some registrations are free |
| Regulatory capital | Licence class and the volume of client assets and trading |
| Local office and staff | Substance rules: resident directors, MLRO and compliance officer |
| Compliance technology | Blockchain analytics, screening, transaction monitoring and travel rule tools |
| Security and audits | Penetration tests, custody audits and, where required, client asset audits |
| Legal and advisory work | Perimeter opinions, policies and the application file |
The largest ongoing cost in most jurisdictions is people: a credible local management team, an MLRO and a compliance function sized to the business.
| Jurisdiction | Regulator's published standard or planning figure |
|---|---|
| EU MiCA | 25 working days for completeness plus 40 working days for assessment; plan 6 to 8 months |
| UK FSMA regime | FCA aims to decide window applications before 25 October 2027 |
| UK MLR registration | Three months from a complete application |
| US FinCEN MSB | Online registration, completed in days |
| Canada FINTRAC MSB | Weeks to a few months |
| Australia AUSTRAC | Weeks to a few months |
| US state licences, BitLicense, VARA, SFC, MAS | Set by each regulator; plan several months to a year for full authorisation |
The variables are the completeness of the first submission, the speed of answers to the regulator's questions and how complex the group structure is. A full, consistent application is the main driver of a short review.
The right jurisdiction follows from the customers and the business model, not from speed or cost alone.
Many groups combine an EU MiCA licence, a UK authorisation and one Asian or Middle Eastern licence, built on a single control framework.
It is a regulator's approval to provide cryptoasset services such as exchange, custody, transfers or a trading platform. Depending on the country it is an anti-money laundering registration or a full authorisation with capital and conduct rules.
VASP is the FATF term for any crypto service provider that must be licensed or registered. MiCA CASP authorisation is the EU's specific licence, which replaced national VASP registrations once the transitional periods ended on 1 July 2026.
Registrations such as FinCEN, FINTRAC and AUSTRAC take days to a few months. Full authorisations such as MiCA typically take 6 to 8 months from submission.
Under MiCA it is €50,000, €125,000 or €150,000 depending on services. In the UK it ranges from £75,000 to £750,000 from October 2027, and in Hong Kong a platform needs HK$5,000,000 of paid-up capital.
No. The UK left the EU passporting system on 31 December 2020, so UK customers need FCA registration now and FSMA authorisation from 25 October 2027.
Registration regimes such as Canada and Australia are quicker than full authorisation regimes. The better question is which licence your customers and banking partners require.
Usually not, where the business never controls customer assets or keys. The position depends on the jurisdiction and on any exchange or transfer services linked to the wallet.
Buckingham Capital Consulting has obtained licences across the UK and Europe since 2013, including FCA EMI authorisations for Dzing Finance and Hryze and a Central Bank of Ireland EMI licence for Own Solutions, and prepares crypto applications under MiCA, the FCA regime and other major frameworks. It selects the jurisdiction, builds one control framework that serves several regulators and manages each application through to approval.
Speak to an expert: WhatsApp +44 7563 115980, Telegram @buckinghamcapital or info@buckinghamcapitalconsulting.co.uk.
This article is general information, reviewed against the regulator’s published requirements on the date shown. It is not legal advice; the regulator’s current publications take precedence.