Who licenses crypto, under what regime, and since when. One row per jurisdiction: the regulator, the licence a crypto-asset business needs, the status of the framework and its effective date. Maintained by the MSB Intel desk as regimes change.
| Jurisdiction | Regulator | Licence / regime | Status | Effective |
|---|---|---|---|---|
| 🇪🇺 European Union | ESMA + national NCAs | MiCA — CASP authorisation | LIVE | Dec 2024 |
| 🇳🇱 Netherlands | AFM | MiCA CASP | LIVE | Dec 2024 |
| 🇩🇪 Germany | BaFin | MiCA CASP | LIVE | Dec 2024 |
| 🇫🇷 France | AMF | MiCA CASP (ex-PSAN) | LIVE | Dec 2024 |
| 🇮🇪 Ireland | Central Bank of Ireland | MiCA CASP | LIVE | Dec 2024 |
| 🇲🇹 Malta | MFSA | MiCA CASP (ex-VFA) | LIVE | Dec 2024 |
| 🇱🇺 Luxembourg | CSSF | MiCA CASP | LIVE | Dec 2024 |
| 🇬🇧 United Kingdom | FCA | Cryptoasset registration → full FSMA regime | TRANSITION | 2026 phase-in |
| 🇨🇭 Switzerland | FINMA | DLT Act · banking / fintech licence | LIVE | Aug 2021 |
| 🇺🇸 United States | SEC · CFTC · states | State MTL / BitLicense · Clarity Act pending | PENDING | — |
| 🇦🇪 UAE — Dubai | VARA | VASP licence | LIVE | Mar 2022 |
| 🇦🇪 UAE — Abu Dhabi | ADGM FSRA | FSP — virtual assets | LIVE | Jun 2018 |
| 🇸🇬 Singapore | MAS | PSA — MPI licence · DTSP | LIVE | Jan 2020 |
| 🇭🇰 Hong Kong | SFC · HKMA | VATP licence · stablecoin issuer | LIVE | Jun 2023 |
| 🇯🇵 Japan | FSA | Crypto-asset exchange registration | LIVE | Apr 2017 |
| 🇰🇷 South Korea | FSC / FIU | VASP registration · VAUPA | LIVE | Mar 2021 |
| 🇮🇳 India | FIU-IND | AML registration only | PARTIAL | Mar 2023 |
| 🇧🇷 Brazil | Banco Central do Brasil | VASP authorisation (Law 14,478) | LIVE | Jun 2023 |
| 🇨🇦 Canada | CSA / provincial | Restricted dealer registration | LIVE | 2021 |
| 🇦🇺 Australia | AUSTRAC · Treasury | AML registration · platform licensing drafted | TRANSITION | — |
| 🇹🇷 Turkey | Capital Markets Board | CASP licensing (2024 law) | LIVE | Jul 2024 |
| 🇳🇬 Nigeria | SEC Nigeria | Digital asset licensing (ISA 2025) | LIVE | Mar 2025 |
| 🇿🇦 South Africa | FSCA | CASP licence (FAIS) | LIVE | 2024 |
| 🇧🇭 Bahrain | CBB | Crypto-asset licence | LIVE | Feb 2019 |
The Markets in Crypto-Assets Regulation is the world's largest single licensing regime: one CASP authorisation from any member-state regulator passports across all 27. Stablecoin (ART/EMT) rules applied from June 2024, the full CASP regime from 30 December 2024. National grandfathering windows for pre-MiCA firms largely closed during 2025-26.
Crypto businesses serving the Dutch market need MiCA CASP authorisation from the AFM, which replaced the old DNB crypto registration. The Netherlands ran one of the shorter national transition windows, pushing firms onto full MiCA authorisation ahead of most of the EU — one reason Dutch approvals have been a steady source of licensing news.
BaFin grants MiCA CASP authorisation, layered on Germany's earlier crypto-custody licence regime from 2020. Germany remains the EU's largest single market for authorised crypto custody and trading services.
France's PSAN registration regime seeded one of Europe's biggest CASP populations; PSAN firms transitioned onto MiCA authorisation with grandfathering into mid-2026. The AMF is among the most active MiCA authorisers.
The Central Bank of Ireland grants MiCA CASP authorisation, and Dublin's fund-industry base has made it a favoured EU entry point for US-headquartered firms seeking a passportable licence.
Malta's early VFA framework converted into MiCA authorisation, keeping the island's incumbent exchanges licensed. The MFSA was one of the first movers on MiCA approvals in early 2025.
The CSSF authorises CASPs under MiCA; Luxembourg's fund-servicing industry has made it a base for institutional-facing crypto and tokenization businesses.
UK crypto firms currently operate under FCA cryptoasset registration (AML). The full FSMA-based regime — bringing exchanges, dealing, custody and stablecoin issuance inside the regulatory perimeter with authorisation requirements — was legislated in 2025 with FCA rulebooks phasing through 2026.
Switzerland regulates by activity: banking or fintech licences for deposit-taking, securities-firm licences for trading venues under the DLT Act, and SRO membership for pure AML coverage. Zug and Zurich remain dense hubs of licensed crypto banks.
There is still no single US federal crypto licence. Firms stack state money-transmitter licences (and New York's BitLicense) with federal registrations where activities touch securities or derivatives. The GENIUS Act created a federal stablecoin-issuer framework in 2025; the Clarity Act — which would split spot-market oversight between the SEC and CFTC and create a federal registration path — remains pending in the Senate as of July 2026. The desk covers that cycle daily.
Dubai's Virtual Assets Regulatory Authority — the world's first standalone virtual-asset regulator — licenses VASPs by activity: exchange, broker-dealer, custody, advisory, lending. The UAE also added a central-bank framework for dirham-backed stablecoins, the payments layer for its 2030 tokenization agenda.
Abu Dhabi Global Market's FSRA has licensed virtual-asset activities since 2018 — one of the oldest comprehensive frameworks anywhere — and hosts regional headquarters for several global exchanges.
MAS licenses digital payment token services under the Payment Services Act (Major Payment Institution licence for scale providers), with conduct and custody rules layered on. From June 2025 the separate DTSP regime also captured Singapore-based firms serving only overseas customers.
The SFC's Virtual Asset Trading Platform regime (June 2023) licenses exchanges serving retail; the HKMA's stablecoin issuer ordinance took effect August 2025. Hong Kong has positioned licensing as the front door of its digital-asset hub strategy.
Japan's Payment Services Act registration for crypto-asset exchange providers is the oldest major licensing regime, live since April 2017, with segregated-custody and cold-storage requirements tightened after the 2018 exchange hacks. Reform work continues on moving crypto under the securities-law umbrella.
VASPs register with the financial intelligence unit under the Specific Financial Information Act — the regime that forced the real-name banking system — with the Virtual Asset User Protection Act adding market-abuse and custody rules from July 2024.
India has no licensing regime — exchanges register with FIU-IND for AML purposes and operate under a 30% gains tax and 1% TDS. Policy remains registration-plus-taxation rather than authorisation.
Law 14,478 made the central bank the crypto regulator; its implementing rules created a VASP authorisation regime, with the BCB processing the first licence cohort through 2025-26. Brazil is Latin America's largest licensed market.
Canadian platforms register as restricted dealers with provincial securities commissions under CSA guidance, with pre-registration undertakings binding platforms during onboarding. Custody and leverage limits are conditions of registration.
Exchanges register with AUSTRAC for AML; the Treasury's draft legislation would bring platforms under AFSL-style licensing. Until it passes, Australia remains registration-only.
Turkey's July 2024 capital-markets amendment created a licensing regime for crypto-asset service providers under the CMB, formalising one of the world's highest-adoption markets.
The Investments and Securities Act 2025 recognised digital assets as securities and put exchanges and VASPs under SEC licensing, formalising the regime piloted through the SEC's regulatory incubation programme.
South Africa declared crypto assets a financial product and began licensing CASPs under FAIS in 2024 — the first comprehensive licensing regime on the continent, with hundreds of firms authorised.
The CBB's crypto-asset module has licensed exchanges and custodians since 2019, making Bahrain the Gulf's earliest comprehensive licensing jurisdiction.
Method. Summaries reflect the primary framework a crypto-asset service provider needs to operate in each jurisdiction, reviewed against regulator publications. Regimes change; the desk updates this page as licensing news crosses the wire. This is a research reference, not legal advice. Corrections: @MSBIntel.
Related coverage: the MSB Intel newswire · Live protocol data: data desk.