| Abu Dhabi (ADGM) | ADGM FSRA Financial Services Permission (FSP) | USD 50,000 to USD 4,000,000 base for PRU Categories 2/3A/3B/3C/4; higher EBCM or risk capital may apply; a virtual-asset MTF also holds 6 months of operating expenses plus a buffer of up to 6 more. Categories 1 and 5 (USD 10m base) are outside this range | USD 810,000-2,945,000 by permission class (statutory FSRA application fee plus up to a full year of supervision, the first year pro-rated, 35,000-255,000 under FEES VER20; build 775,000-2,690,000). Excludes base capital, which is held, not spent | 9–19 months | 9% | Clear |
| Antigua and Barbuda | Digital Asset Business licence for named activities (Class A, or Class B for a defined period) + six-month Sandbox licence | No fixed paid-up share capital in the Act for the company. Schedule II statutory deposit, to be deposited with the Commission, by category and annual turnover: EC$50,000-100,000 (~US$18,500-37,000) for Category A; EC$100,000-300,000 (~US$37,000-111,000) for an exchange. Separately, minimum risk capital set in the application by client assets under management (reg. 8(1)(a)), evidenced by cash at an acceptable bank, a bank line of credit, liability insurance, or a deposit with the Commission (reg. 2) | USD 34,100-64,100 for the non-exchange smallest band, excluding the statutory deposit, which is held rather than spent (application fee EC$10,000, due diligence EC$6,800 per principal for two to four principals, the Year-1 annual licence fee EC$20,000, IBC formation with registered agent, professional and advisory work, and the s.21/s.22 principal office and compliance officer). | 3–6 months | 25% | Clear |
| Argentina | PSAV (Virtual Asset Service Provider) registration with the CNV; mandatory, 5 activity categories | Minimum net worth by category: USD 150,000 (Cat. 1, 2, 4); USD 75,000 (Cat. 3); USD 35,000 (Cat. 5). Halved to USD 75,000 (Cats. 1 and 2), USD 37,500 (Cat. 3) and USD 75,000 (Cat. 4) where the provider is under USD 2,500,000 over the prior 12 months - TRANSACTED volume for Cats. 1 to 3, CUSTODIED volume for Cat. 4. Category 5 is excluded from the reduction by CNV NORMAS Title XIV Chapter III Article 9, so USD 35,000 applies at any volume. A provider registered in two or more categories meets the most demanding threshold. Client virtual assets are segregated and excluded from net worth (Article 16) | USD 26,270-55,900 all-in Year 1: statutory USD 9,270-10,900 (incorporation or Article 118 registration, about USD 570-2,200: IGJ tasa and trámite, the Boletín Oficial notice, and the apostille and sworn-translation chain for documents executed abroad; plus the first-year CNV tasa of about USD 8,700) and a typical build of USD 17,000-45,000 quoted per case | Not published | 35% | Clear |
| Australia | AUSTRAC VASP registration (ex-DCE, auto-rolled 31 Mar 2026) + ASIC AFSL + DAP/TCP (from 8 Apr 2027) | None (AUSTRAC); AFSL: no general capital floor; where RG 166 section C applies, AUD 50,000 surplus liquid funds when client money or property is AUD 100,000 or more; custodial requirements separate | AUD 186,249-505,453 known-fee and build subtotal; add variable ASIC/AUSTRAC levies, additional AFCA charges and capital lock-up. Includes AFSL application 2,233-7,537, AFCA 2026-27 registration 415.57 including GST (where membership applies), and build 183,600-497,500; AUSTRAC registration nil | 2–12 months | 30% | Clear |
| Bahamas | Digital asset business registration under DARE (2 fee classes: digital asset exchange; all other digital asset businesses) plus token offering filings | No fixed statutory minimum; risk-based financial requirements set by the SCB per registrant or category (DARE s.15) | 48,000–171,000 USD | 3–6 months | 0% | Clear |
| Belize | Digital Asset Services Licence | No digital-asset capital figure: SI 162/2025 sets none, and the Schedule to the FSC (Capital Requirement) Regulations 2023, which repealed the 2020 Regulations, lists no digital-asset service; the FSC may attach licence conditions (SI 162/2025 reg. 7(2)). No crypto-specific paid-up capital figure published as of 24 September 2026. Circulating USD 75,000-500,000 figures belong to other financial services in that Schedule, not the digital asset licence | Known government-fee floor: USD 20,000 (USD 5,000 application + USD 15,000 licence under SI 162/2025 Schedule). Mandatory registered-agent, compliance and economic-substance costs are additional and quoted per case; no defensible Belize-specific all-in benchmark is established. Regulatory capital is separate, held rather than spent. | 4–8 months | 0% | Clear |
| Bermuda | DABA Digital Asset Business Licence (Class T / Class M / Class F) | USD 100,000 baseline net assets (Class M, Class F); USD 10,000 (Class T); BMA discretion to direct materially higher amounts based on activity, scale, and risk (Class T USD 10,000 is a time-bound test licence, not an operating floor) | USD 377,266-1,610,266 Class F (statutory BMA application plus grant fee 17,266-452,266, from the standard-activity minimum to the cap; the first annual fee is due by 31 March of the year after licensing on actual client receipts and is excluded; build 360,000-1,158,000). Class T is materially cheaper: statutory USD 2,000 at licensing, build 85,000-218,000 | 6–12 months | 0% | Clear |
| British Virgin Islands | VASP Registration | None | USD 45,000–161,000 (statutory 17,500–65,000 including FSC approval fees, plus typical build 27,300–96,000) | 4–6 months | 0% | Grey-listed |
| Bulgaria | MiCA CASP authorisation | Lowest Annex IV class floor: EUR 50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (CET1 after deductions), an insurance policy or comparable guarantee, or a combination (MiCA Art 67(4)); no locked or segregated cash deposit required | EUR 74,818-270,221 excluding the MiCA Article 67 safeguards (statutory 5,318-46,221: FSC authorisation fee 5,113-30,678 by class plus the first-year supervision fee, the sum of the per-service fixed fees 205-15,543; build 69,500-224,000) | 4–9 months | 10% | Grey-listed |
| Canada | Dual-track: CSA securities registration (restricted dealer / investment dealer) + CIRO membership, plus FINTRAC money services business (MSB) registration; no single unitary crypto licence | None for a FINTRAC-only MSB that does not trade crypto contracts; CAD 50,000 for a restricted dealer (NI 31-103); a CIRO-member investment dealer meets CIRO Form 1 capital rules instead (NI 31-103 s.9.3) | CAD 208,100-489,359 excluding capital (statutory 46,100-63,358.97 on the investment-dealer route: CIRO CTP entrance 40,000, CIRO annual-fee balance on admission 0-12,500 by admission quarter after the 6,250 application review deposit is credited, OSC new-firm registration 1,300, OSC exemptive relief 4,800-7,000, Bank of Canada PSP approximately 2,558.97 in 2026 where applicable (RPAR s.25: 2,500 x 164.9/161.1; payment-portal rounding unverified); FINTRAC registration is nil; excludes the CIRO Restricted Fund payment on admission of 0.5% of expected initial capital, which depends on the capital planned; build 162,000-426,000) | 12–24 months | 26.5% | Clear |
| Cayman Islands | VASP Registration or Licence (dual-track) | None (statutory) | Statutory USD 4,878-37,806 (Registration) / 79,268-189,024 (Custody) / 189,025-371,951 (VATP), per Schedule 2 of the VASP Amendment Regulations 2025; build USD 175,000-1,520,000 quoted per case | 4–14 months | 0% | Clear |
| Comoros (Anjouan) | No recognised VASP licence; AOFA crypto certificates have no Union-level legal authorisation | No recognised statutory VASP capital framework | USD 19,000-49,500 build, quoted per case. NO VERIFIED STATUTORY COST IS TOTALLED HERE: the AOFA is reported to charge USD 5,500-25,000 for its crypto certificate and about 300 for the IBC, but these are agent-quoted and no official fee schedule verifies them, and the Banque Centrale des Comores names that authority among fictitious structures claiming to issue financial licences. They are shown as agent-quoted figures only and are not added into the total | Not published | 35% | Clear |
| Costa Rica | No crypto licence; mandatory SUGEF VASP AML registration under Article 15 quater of Law 7786 (Ley 10961, in force since 19 September 2026); registration is not an authorisation to operate | No fixed minimum (nominal CRC 10,000–100,000 declared in practice) | USD 5,653-21,007 (statutory about 553-707: Registro Nacional constitution CRC 46,220, book legalisation CRC 13,400 and cedula juridica CRC 2,000, the CRC 5,000 education-and-culture stamp, the first-year Law 9428 tax pro rata up to CRC 69,330, and CRC 181,500 for the notarial incorporation deed at the binding arancel art. 95(a) minimum (Decreto 43704-JP-MEIC, which had made it discretionary, was annulled on 16 February 2024), converted at the canonical 28 August 2026 FX rate; capital-scaled stamps, the La Gaceta extract and IVA on the notary fee excluded; SUGEF APNFD inscription under Acuerdo SUGEF 11-18 carries NO fee and is expressly not an authorisation to operate; build 5,100-20,300 quoted per case). No resident agent is required: Ley 10.597 (published 3 December 2024, applied from 4 June 2025) repealed art. 18(13) of the Codigo de Comercio and replaced it with a registered corporate email address | 3–7 months | 30% | Clear |
| Cyprus | MiCA CASP authorisation | Lowest Annex IV class floor: €50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (Common Equity Tier 1 after deductions), an insurance policy or a comparable guarantee, or a combination (MiCA Article 67(4)) | EUR 217,000-462,000 setup subtotal (statutory 28,000-64,000 CySEC application fees by service; build 189,000-398,000 quoted per case), plus pro-rata first-year MiCA and DORA annual fees, which depend on the start month, authorised services, entity size and turnover and are not included in this range | 8–14 months | 15% | Clear |
| Czech Republic | MiCA CASP authorisation | Annex IV class floors: €50,000 (Class 1) / €125,000 (Class 2) / €150,000 (Class 3) per MiCAR Annex IV. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (CET1 after deductions), an insurance policy or comparable guarantee, or a combination (MiCA Art. 67(4)); where own funds are used by a company being incorporated, the application includes a credit institution's statement that the funds are deposited (Delegated Reg. 2025/305 Art. 3) | EUR 232,000-604,000 excluding the MiCA Article 67 prudential safeguards (statutory CZK 20,000-30,000, about EUR 830-1,240: CNB application state fee CZK 20,000, s.r.o. registration CZK 0-6,000 (CZK 2,700 by a notary, CZK 6,000 by the court, or nil for a model memorandum), UBO register entry CZK 0-4,000; build 231,000-603,000 quoted per case) | 9–18 months | 21% | Clear |
| Dominica | Virtual Asset Business certificate of registration (single type) | No fixed minimum capital. The 2024 Regulations (reg 6) require capital and liquidity adequate to the nature, size, and complexity of the business; the FSU may require additional capital/liquidity by written notice on the risk profile. Quasi-capital protections: 40% of total client funds in escrow with a registered trust/custodial provider (Act s11); custodian must hold more of each virtual asset than its client obligations (reg 10); mandatory insurance on FSU terms (reg 25) | Government fees EC$43,200 (application EC$10,800 + registration EC$32,400) ~USD 16,000; professional costs (formation, resident representative, AML build, insurance, banking) separate; no public benchmark found | 3–7 months | 25% | Clear |
| El Salvador | CNAD Digital Asset Service Provider (DASP / PSAD) registration | USD 2,000 fully subscribed for an S.A.; at least 5% of each cash contribution paid at incorporation (USD 100 on the minimum capital), balance within one year of registration of the incorporation deed. Non-cash contributions paid in full. CNAD resource requirements apply separately | USD 53,800-150,600 (statutory 6,286-6,336: CNAD initial DASP registration USD 6,132, fifteen minimum wages of USD 408.80 payable in USD or BTC within ten days of a favourable resolution, plus CNR registry charges USD 154.26; build 47,500-144,300 quoted per case) | 3–6 months | 0% | Clear |
| Estonia | MiCA CASP authorisation | Lowest Annex IV class floor: €50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Prudential safeguards under MiCA Art 67(4): own funds (CET1 items), an insurance policy covering the Union territories where services are provided or a comparable guarantee, or a combination | EUR 131,750-308,500 fully outsourced (statutory 3,250-4,500: Finantsinspektsioon application processing fee EUR 3,000 plus the capital part of the supervision fee, 1% of the MiCA Annex IV amount, EUR 500-1,500, halved when authorised in the second half of the year; build EUR 128,500-304,000 quoted per case). A minimal configuration lands near EUR 80,000 | 6–12 months | 0% | Clear |
| Georgia | Virtual Asset Service Provider (VASP) registration with the National Bank of Georgia, by activity | GEL 150,000 (exchange, including kiosks, and/or transfer) to GEL 350,000 (trading platform); GEL 250,000 for other services; stablecoin issuer at least GEL 500,000 under the March 2026 stablecoin rule. Minimum supervisory capital under Article 7(2) of the NBG registration rule, added by Order No. 207/04 of 26 August 2026 (in force 27 August 2026); VASPs registered before then comply by 1 September 2027. Separately, general company law requires a JSC to have GEL 100,000 subscribed capital (25% paid in), but an LLC has no minimum. | USD 15,000-43,000 (statutory about 2,000-2,100 at the NBG rate of 28 August 2026: NBG VASP registration GEL 5,000 plus company registration GEL 200-400; build 13,000-41,000; total rounded to the nearest thousand). No annual state fee: statutory Year 2 is nil. Minimum supervisory capital (GEL 150,000-350,000 by activity; stablecoin issuer at least GEL 500,000) is held, not spent, and excluded | 3–7 months | 0% | Clear |
| Gibraltar | DLT Provider Licence (custodial) / Virtual Asset Arrangement Provider Licence (non-custodial, from 27 October 2025) | No fixed statutory minimum; risk-based under Principle 3; market practice £100,000–£250,000+ for low-complexity firms, £1m+ for full custodial exchanges | GBP 355,454-883,154 (GFSC firm-level fees 89,454-182,154: application 45,000, base fee 12,254, additional fee 28,183, AML fee 4,017 and the volume fee up to 92,700; the GFSC also charges GBP 407 a year for each approved regulated individual; build 266,000-701,000) | 9–12 months | 15% | Clear |
| Hong Kong | SFC VATP licence (SFO Type 1 + Type 7 + AMLO Part 5B) | HKD 5m paid-up capital; required liquid capital is the higher of HKD 3m and the basic amount | All-in HKD 6,392,660-17,253,400 (statutory 42,660-53,400: SFC and AMLO application and approval fees for a dual-regime platform with two responsible officers; typical build 6,350,000-17,200,000, the sum of the page's ten build lines, quoted per case). Capital is held rather than spent: HKD 5,000,000 paid-up share capital, alongside required liquid capital equal to the higher of HKD 3,000,000 and the basic amount; the two tests are separate and cannot be totalled into a fixed floor | 12–18 months | 16.5% | Clear |
| Ireland | MiCA CASP authorisation (Class 1/2/3) | Lowest Annex IV class floor: EUR 50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (Common Equity Tier 1 items under Arts 26-30 of Regulation (EU) 575/2013, after deductions; not crypto on the balance sheet), an insurance policy or comparable guarantee, or a combination (MiCA Art 67(4)-(6)); no locked or pre-deposited cash requirement | EUR 260,000-710,000 by CASP class, including a EUR 30,000 full-year levy provision at the latest published rate (S.I.348/2026, levy period 2025); build EUR 230,000 Class 1, EUR 430,000 Class 2 and EUR 680,000 Class 3. Actual initial levy is prorated for the authorised period and billed in arrears; future levy rates require confirmation. | 12–18 months | 12.5% | Clear |
| Kazakhstan | AIFC Digital Asset Service Provider (DASP) authorisation | USD 10,000 (Advising on Investments / Arranging Deals / Arranging Custody) to USD 250,000 (Providing Custody, Dealing as Principal) | USD 94,300-283,900 (statutory 13,300-105,900: FEES table 1.1 activity fee, the digital-asset add-on where charged, Approved Individual applications, AIFC registration and change of control; the initial supervision fee, set by formula on grant, comes on top; build 81,000-178,000) | 6–12 months | 20% | Clear |
| Kyrgyzstan | Virtual Asset Exchange Operator (AVA) / Virtual Asset Trading Operator (ATOC) authorisation | KGS 40,000,000 (~USD 460,000) for AVA exchange office; KGS 300,000,000 (~USD 3.4M) for ATOC trading operator from 01 July 2026 under Presidential Decree No. 112 of 13 March 2026. Resolution No. 514's own floor (paragraph 48, KGS 10bn) was repealed by Resolution No. 516 of 30 July 2026 | USD 33,000-60,000 (build, quoted per case; statutory: state duty of 10 calculation indices, KGS 1,000, about USD 11, for issuing the licence under Government Resolution No. 159 of 15 April 2019, item 17). Authorisation is indefinite, so statutory Year 2 is nil | 2–4 months | 10% | Clear |
| Labuan (Malaysia) | Money Broking Business with Digital Asset activity (primary); also Credit Token, STO Issuer, Securities Licensee, Fund Manager, Section 134 Exchange, Payment System Operator | RM 300,000 (Fund Manager working funds); RM 500,000 (public STO issuer); RM 1,000,000 (Credit Token / Securities Licensee); RM 1,500,000 (Money Broker DA, primary pathway) | USD 98,500-245,000 (statutory 10,500-12,000: application processing 500 plus the Money Broker (Digital Asset) annual licence fee 10,000, and fast-track 1,500 where taken; build 88,000-233,000, including the Labuan company's registration fee) | 4–6 months | 3% | Clear |
| Latvia | MiCA CASP authorisation | Annex IV class floors: EUR 50,000 (Class 1) / EUR 125,000 (Class 2) / EUR 150,000 (Class 3). Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Prudential safeguards as own funds (CET1 items), an insurance policy or a comparable guarantee, or a combination (MiCA Art 67(4)); proof filed with the application (Art 62(2)(e)); no separate locked cash deposit | EUR 180,500-440,500 (statutory 5,500, assuming the supervisory levy at its 3,000 minimum: Latvijas Banka application fee 2,500 plus the first-year levy 3,000; build EUR 175,000-435,000) | 6–9 months | 0% | Clear |
| Lithuania | MiCA CASP authorisation | Lowest Annex IV class floor: €50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Prudential safeguards as own funds, an insurance policy or a comparable guarantee, or a combination (MiCA Art 67(4)); own funds are the usual route; proof filed with the application (Art 62(2)(e)) | EUR 75,925-268,425 by service class (statutory 5,425 on every class: the 2,425 state fee to issue the CASP licence plus the Bank of Lithuania Year-1 supervision fee at its 3,000 floor; build EUR 70,500-263,000 from Class 1 to Class 3), excluding Article 67 safeguards (higher of the EUR 50,000/125,000/150,000 class floor and 25% of previous-year fixed overheads; projected first-12-month overheads for a new firm); if funded as own funds, held not spent | 4–8 months | 17% | Clear |
| Malta | MiCA CASP authorisation | Lowest Annex IV class floor: €50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). ESMA Q&A 2349 (Commission answer of 18 February 2026): calculate from all overhead expenses, fixed and variable, deducting only Article 67(3)(a)-(d). Art 67(4): own funds (CET1 items per Arts 26–30 CRR, Reg 575/2013, after full Art 36 deductions; founder loans and uncalled capital do not count), an insurance policy or comparable guarantee, or a combination; MiCA requires no cash held in a segregated account | Typical Class 2/3 build EUR 490,000-EUR 1,075,000, quoted per case; statutory application and prorated first-supervision fees are described separately (excludes Article 67 safeguards (higher of the EUR 125,000/150,000 Class 2/3 floor and 25% of previous-year fixed overheads; projected first-12-month overheads for a new firm); if funded as own funds, held not spent) | 9–18 months | 35% | Clear |
| Marshall Islands | No active VASP licensing regime; DAO LLC, standard LLC, and IBC are entity-formation routes only | No fixed minimum | USD 15,500-24,500 (USD 9,500 MIDAO commercial package covering the certificate of formation, FIBL, first-year registered agent and the initial BOIR filing, with the RMI government fees included but not separately stated, plus USD 6,000-15,000 of build quoted per case) | Not published | Not confirmed | Clear |
| Mauritius | VASP licence (Classes M, O, R, I, S) + ITO issuer registration | Class M MUR 2,000,000 (~USD 43,000); Class R MUR 5,000,000 (~USD 110,000); Class S MUR 6,500,000 (~USD 140,000); Classes O and I and ITO issuer have no fixed floor (sufficient working capital, Class O on a 12-month forward test) | All-in ~USD 65,900-218,000 for a single VASP class licence, depending on the class and build, excluding paid-in class capital: statutory FSC fees USD 2,900-8,000 (one class's processing fee plus a full first annual fee, GN 119 of 2026; the first annual fee is prorated by the quarter of grant under rule 8(2) of the 2008 Rules) plus the typical build on our planning estimate (legal, structuring and application drafting 20,000-60,000; compliance build 8,000-30,000; resident risk functions and directors 25,000-90,000; office, audit and professional indemnity insurance 10,000-30,000). Fees attach to each licence held, so a multi-class build needs its own budget | 6–9 months | 15% | Clear |
| Nevis (Federation of Saint Kitts and Nevis) | VASP Registration (federation regime; no Nevis-specific instrument) | None fixed in the Act; client-asset coverage required (s.9(1)) or undertaking for out-of-jurisdiction assets (s.9(2)); 15% client-fund escrow with a registered trust company or another trust or custodial provider (s.9A, 2021 amendment) | XCD 256,000-324,000 (statutory 189,000 gazetted under SRO 47 of 2021: application fee 54,000 plus first-year registration 135,000; build 67,000-135,000 quoted per case), excluding any per-principal due-diligence amount: SR&O 13 of 2026 repealed the prior XCD 21,600 fee and the current Schedule refers only to a prescribed fee, so confirm the current amount with the FSRC | 4–9 months | 25% | Clear |
| New Zealand | FSPR registration + DIA AML/CFT supervision (no dedicated crypto licence) | None | All-in NZD 41,048–126,048 (statutory NZD 1,048: FSPR application 345, FMA registration levy 690 and one criminal history check 13, incl. GST; typical build NZD 40,000–125,000, quoted per case, the sum of legal advisory and AML/CFT compliance documentation) | 4–6 months | 28% | Clear |
| Oman | Interim VASP registration (AML/CFT); full VASP licence under the VARF pending | No published VASP minimum capital figure as of September 2026. The VARF, which would set capital tiers, remains in draft; minimum capital was a 2023 consultation question but no number has been set | USD 5,000-15,000, and that figure is the BUILD ALONE: Omani entity formation, legal, the AML build, and audit readiness. NO STATUTORY FIGURE CAN BE ADDED TO IT, because none is published: the interim VASP registration fee has not been released and the VARF, which would set licence and annual fees, remains in draft. So the published number is a build with no statutory half, and it will rise when the VARF is made | Not published | 15% | Clear |
| Panama | No dedicated crypto licence (structured under general corporate + AML law) | No fixed minimum. Standard S.A. authorised capital USD 10,000 (not required to be paid in) | USD 10,560-39,110 (indicative 510-760: Registro Publico qualification and inscription about 60 on the customary USD 10,000 authorised capital, notarial fees 150-400, the Year-1 tasa unica 300, and the Aviso de Operacion 15 or 50 where the entity operates inside Panama; build 10,050-38,350 quoted per case, the sum of its five page lines), excluding banking application and per-account costs; there is no licensing fee, because there is no licence | Not published | 25% | Clear |
| Poland | MiCA CASP authorisation (no domestic Polish route as of 4 September 2026) | Annex IV class floors: €50,000 (Class 1) / €125,000 (Class 2) / €150,000 (Class 3) under MiCA Annex IV. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Permanent minimum capital by service class; same EU-wide thresholds in every member state (Poland adds no national overlay), so an operator authorising elsewhere meets the identical capital bar. Met by own funds, an insurance policy or a comparable guarantee, or a combination (MiCA Art. 67(4)); held as own funds it is retained, not consumed. | ~€74,000 (Class 1) / ~€156,000 (Class 2) / ~€273,000 (Class 3) excl. Article 67 safeguards: at least the higher of the Annex IV class floor (EUR 50,000/125,000/150,000) and 25% of the previous year’s fixed overheads (projected first-12-month overheads for a new firm), met by qualifying own funds, insurance or a comparable guarantee, or a combination; held rather than spent when funded as own funds, indicative of a MiCA CASP authorisation via an operational EU regime; no Polish CASP fees existed as of 4 September 2026 | Not published | 19% | Clear |
| Portugal | MiCA CASP Authorisation | Annex IV class floors: €50,000 (Class 1) / €125,000 (Class 2) / €150,000 (Class 3). Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (CET1), an insurance policy or a comparable guarantee, or a combination (MiCA Article 67(4)); no locked or pre-deposited cash is required | €80,500–€281,000 (Year-1 build subtotal; no Banco de Portugal application or maintenance fee and no CMVM charge for CASPs; excl. Article 67 safeguards: at least the higher of the Annex IV class floor (EUR 50,000/125,000/150,000) and 25% of the previous year’s fixed overheads (projected first-12-month overheads for a new firm), met by qualifying own funds, insurance or a comparable guarantee, or a combination; varies by service class) | 6–12 months | 19% | Clear |
| Romania | MiCA CASP authorisation | Annex IV class floors: EUR 50,000 / EUR 125,000 / EUR 150,000 by MiCA Annex IV class. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (CET1 items under Articles 26-30 of Regulation (EU) 575/2013, after deductions), an insurance policy or comparable guarantee, or a combination (MiCA Article 67(4)); not the same as company share capital | No registry or regulator fee so far (trade-register operations carry no fee under Law 265/2022 art. 44; no ASF authorisation fee or ADR certification fee is set, because the enabling ordinance is unadopted); the Monitorul Oficial publication of the incorporation extract is charged at the Gazette tariff (RON 152 per manuscript page in 2026); estimated notarial and ancillary formation expenses about EUR 100-300; build EUR 96,000-208,000 quoted per case | Not published | 16% | Clear |
| Saint Kitts and Nevis | VASP Registration | None prescribed: SR&O 13 of 2026 (made under s.18, published 22 June 2026) sets no numerical floor; reg 6 imposes an adequacy duty and lets FSRC require more by written notice | XCD 256,000-324,000 (statutory XCD 189,000 under SRO 47 of 2021: application fee 54,000 plus first-year registration 135,000; build XCD 67,000-135,000 quoted per case, including Saint Kitts or Nevis entity formation and first-year corporate services), excluding any per-principal due-diligence charge not prescribed by a current instrument | 4–9 months | 25% | Clear |
| Saint Lucia | Virtual Asset Business Licence | No floor in the Virtual Asset Business Act or SI No. 37 of 2025: regulation 10 lets the FSRA require capital and liquidity by written notice on the risk profile, in addition to the s.12(1) escrow, and requires capital adequate to the nature, size and complexity of the business. The FSRA's Licensing Process presentation (22 October 2025, published on fsrastlucia.org) states minimum paid-up capital by activity: EC$300,000 issuance or sale, EC$350,000 transfer, EC$400,000 VA-to-VA exchange, EC$500,000 fiat-to-VA exchange, EC$750,000 custody, EC$1,300,000 more than one activity (EC$140,000 for merchants and agents), plus a special reserve of 20% of paid-up capital held with a Saint Lucia-licensed bank and pledged to the FSRA, citing its 2025 Guidelines (circulated in draft October 2025, not published). These are the regulator's stated expectation, not figures in the gazetted instruments | About USD 34,000-59,000 (statutory about 6,430-6,730: VABA application fee EC$1,000 and the flat licence fee EC$15,000 under SI No. 37 of 2025 Schedule 2, plus IBC incorporation (US$100-400 by quarter, SI 2024 No. 147) and the first US$400 IBC annual fee; build 27,600-52,300 quoted per case, including the registered agent's beneficial-ownership filing, an agent charge estimated at 100-300), excluding regulatory capital, which is held rather than spent. Multi-principal and custody-heavy scopes run higher and are not priced by this band | 5–8 months | 30% | Clear |
| Saint Vincent and the Grenadines | Virtual Asset Business (VAB / VASP) registration | EC$300,000 registered share capital, of which EC$50,000 (~USD 18,500) must be paid up; minimum paid-up capital of EC$50,000 maintained on an ongoing basis. Separate statutory deposit of EC$100,000 (~USD 37,000) or 25% of financial obligations to clients, whichever is greater (refundable) | About USD 27K-50K (statutory EC$16,000, displayed as about USD 5,900: FSA application fee EC$4,000 plus the registration fee EC$12,000, published schedule; build USD 21,500-44,000 quoted per case), excluding the EC$100,000 statutory deposit and EC$50,000 paid-up capital, which are held rather than spent, and the advisor-reported per-officer levy, which no published or gazetted schedule carries. The widely quoted USD 50,000-80,000 is NOT this figure: it adds the deposit, which is refundable capital, and the ungazetted levies | 5–7 months | 28% | Clear |
| Seychelles | VASP Licence (four categories: Virtual Asset Wallet Provider, Virtual Asset Exchange, Virtual Asset Broking, Virtual Asset Investment Provider) | USD 25,000–100,000 paid-up by category (Schedule, SI 72 of 2024), held for each authorised category (reg. 5(4)): Wallet Provider USD 75,000, Exchange USD 100,000, Broking USD 50,000, Investment Provider USD 25,000; from the beginning of year 3 the minimum is 2.5% of annual turnover from licensed services (FSA Paid-Up Capital Guidance Note, 20 July 2026) | Statutory about USD 15,000-36,000 FSA fees for one activity at a full-year fee (licence application SCR 75,000 + annual base fee SCR 75,000 + annual activity fee SCR 75,000-375,000 by category, VASP Act 2024 Second Schedule); build USD 42,500-122,000 quoted per case. The 1.5% Seventh Schedule rate is a TAX, not a fee, and is in neither figure | 4–27 months | 1.5% | Clear |
| Singapore | MAS Payment Services Act DPT service licence: Standard Payment Institution (SPI) or Major Payment Institution (MPI); plus FSM Act 2022 Part 9 Digital Token Service Provider (DTSP) regime for Singapore-based providers serving only overseas customers | SGD 100,000 base capital (SPI); SGD 250,000 base capital (MPI), plus SGD 100,000-200,000 MPI security (Payment Services Regulations 2019, regs. 8, 12 and 13). Under PSA 2019 s.6(5), SPI transaction-based services including DPTs must stay at or below both applicable limits: average monthly transactions over a calendar year of SGD 3m for any one service and SGD 6m across two or more services. Separate e-money thresholds apply | SGD 1,031,000-2,696,500 (statutory up to 6,000 (SPI) or 11,500 (MPI) in the year of grant: the MAS application fee of 1,000 or 1,500 plus the annual licence fee of 5,000 or 10,000 for a DPT-only licence, less where the first annual fee is pro-rated from the grant date to 31 December; build 1,025,000-2,685,000 quoted per case), excluding base capital of 250,000 and the MPI security deposit of 100,000-200,000, which are maintained rather than spent | Not published | 17% | Clear |
| Slovakia | MiCA CASP authorisation | Lowest Annex IV class floor: €50,000. Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds; insurance policy or equivalent guarantee permitted (MiCA Article 67), combinations allowed; share capital itself €5,000+ minimum for the s.r.o. | Statutory EUR 2,700-6,400 (NBS application fee EUR 1,700 / 2,500 / 3,400 by scope of services under Opatrenie NBS 5/2021 as amended by 8/2024, plus the first twelve months of the supervisory contribution, budgeted at the full annual rate); build EUR 36,500-73,500 quoted per case | 5–10 months | 21% | Clear |
| South Africa | Crypto Asset FSP authorisation (FAIS Category I; Category II for discretionary) | No fixed monetary minimum for Category I advice-only | ZAR 733,600-2,903,600 (statutory 43,600-93,600: FSCA Category I and II application fees of ZAR 19,010 less up to the 10% multi-category discount 17,100-19,000, key individual approvals 1,500-14,600 at ZAR 1,460 each for one to ten, and FSCA, ombud, and tribunal levies 25,000-60,000, a Year-1 planning estimate for a staffed Category I and II firm with modest client investments; the compliance officer approval fee of ZAR 866, plus ZAR 1,671 where Phase I approval is needed, is excluded; build 690,000-2,810,000 quoted per case), excluding commercial working capital | 14–22 months | 27% | Clear |
| Spain | MiCA CASP Authorisation | Annex IV class floors: EUR 50,000 (Class 1) / EUR 125,000 (Class 2) / EUR 150,000 (Class 3). Prudential safeguards at all times equal at least the higher of the applicable Annex IV class floor and 25% of the previous year's fixed overheads. A new firm uses projected fixed overheads for its first 12 months; the permitted deductions apply (MiCA Article 67(1)-(3)). Own funds (CET1 after deductions), a qualifying insurance policy or comparable guarantee, or a combination (MiCA Article 67(4)). MiCA requires no locked cash and does not equate the safeguard with share capital. | Commercial build estimate EUR 103,000-348,000 quoted per case; no fixed statutory CNMV CASP application or first-year supervision fee was validated; Article 67 safeguards: at least the higher of the Annex IV class floor (EUR 50,000/125,000/150,000) and 25% of the previous year’s fixed overheads (projected first-12-month overheads for a new firm), met by qualifying own funds, insurance or a comparable guarantee, or a combination excluded; if funded as own funds, held not spent | 5–9 months | 25% | Clear |
| Switzerland | No single crypto licence. Activity-based, five authorisation routes: SRO affiliation under AMLA (AML only, no FINMA licence); FinTech licence (Banking Act Art. 1b); securities-firm licence (FinIA); DLT trading facility licence (FinMIA Arts. 73a ff); full banking licence (Banking Act). FinIA reform (Federal Council consultation 22 October 2025 to 6 February 2026) would replace the FinTech licence with new Payment Institution and Crypto Institution categories; no dispatch to Parliament had been published by 28 September 2026, so no entry-into-force date is set | Route-dependent. SRO/AML route: none fixed (adequate operating funds still required). FinTech licence: 3% of public deposits and collectively held crypto-based assets accepted, at least CHF 300,000 (BankV Art. 17a). Securities-firm licence: CHF 1.5 million. DLT trading facility: CHF 1m (no custody/settlement/clearing), CHF 5m (with them), CHF 500,000 floor for small facilities. Banking licence: CHF 10 million (often higher in practice) | CHF 29,000-915,000 or more, by route. No statutory figure can be stated: FINMA charges authorisation and Year-1 supervision on cost recovery under FINMA-GebV, hourly at CHF 100-500 under Art. 8(4) with a surcharge of up to 50% under Art. 9 for urgent or out-of-hours work, publishes no flat crypto tariff, and its fees are additional to every figure here. The SRO route carries an SRO tariff of 14,000-45,000 or more, which is not a state charge; build 15,000-60,000 on the SRO route and 315,000-915,000 on a FINMA-licensed route. Excludes regulatory capital of 300,000 for a FinTech licence up to 10,000,000 for a bank, which is held not spent | 3–24 months | 11.7% | Clear |
| United Arab Emirates | VARA VASP / ADGM FSP / DFSA Crypto Token routes; federal CMA and CBUAE payment-token permissions also apply according to activity | AED 100,000 (VARA Advisory floor) | AED 1.33-7.26m (USD 362k-1.98m) on the VARA route (statutory AED 120,000 Advisory and VA Transfer, AED 300,000 for Broker-Dealer, Custody, Lending, VA Management and Exchange; build quoted per case). ADGM FSRA USD 810,000-2,945,000 by permission class (Abu Dhabi record); DFSA build USD 0.97-2.05m plus DFSA fees by activity (application fee plus pro-rated initial annual fee at most USD 30,000-80,000 for a single activity, before endorsements, a trading venue and the supplement under FER 2.1.1(3)) | 6–22 months | 9% | Clear |
| United Kingdom | FCA cryptoasset registration under the Money Laundering Regulations 2017 (live now, AML-only); FSMA authorisation for regulated cryptoasset activities from 25 October 2027 | None for the live MLR registration. Final FSMA permanent minimum requirements (PMRs), effective 25 October 2027: £75,000 dealing as agent / arranging deals; £150,000 custody, trading platform or staking; £350,000 qualifying stablecoin issuance; £750,000 dealing as principal. The highest applicable PMR applies. Own funds equal the highest of PMR, fixed overhead requirement and K-factor requirement (FCA PS26/12, CRYPTOPRU 4.2.1R). | GBP 196,860-574,360 on the MLR registration route (statutory 11,360: FCA cryptoasset registration 11,260 at Pricing Category 6 plus Companies House incorporation 100; build GBP 185,500-563,000 quoted per case), excluding the FSMA route (FCA application fee GBP 2,820, 11,260 or 28,150 by permission, in force from 30 September 2026; one fee at the highest applicable category), and FSMA own funds (PMR tiers GBP 75,000-750,000 from 25 October 2027; the higher-of calculation can require more), which are held rather than spent | 9–18 months | 25% | Clear |
| Uzbekistan | NAPP crypto licence (activity-specific: crypto-exchange / crypto-store / crypto-depository / mining-pool) | 5,000 BRV (bazovaya raschyotnaya velichina) for crypto-exchange, of which 3,000 BRV must be reserved in a separate account at an Uzbek commercial bank at the date of application (Ministry of Justice reg. 3380, point 10). At the BRV of UZS 440,000 in force since 1 September 2026 (Presidential Decree UP-115 of 23 June 2026; UZS 412,000 before, under UP-91) that is UZS 2,200,000,000, with 3,000 BRV = UZS 1,320,000,000. No numerical charter-capital floor is set for crypto-store, crypto-depository or mining-pool | USD 234,100-3,320,800 by licence category (statutory 156,600 for a mining-pool to 3,067,800 for a crypto-exchange: a one-time state duty plus twelve monthly operational fees at the BRV of UZS 440,000 in force since 1 September 2026 and the CBU rate of 28 August 2026, both set in BRV so both move with the indexed unit; build 77,500-140,000 for a mining-pool and 139,500-253,000 for a crypto-exchange, quoted per case), excluding charter capital of 5,000 BRV, about 186,400, which is deployed rather than spent. Ranked by Year-1 all-in: mining-pool, crypto-store, crypto-depository, then crypto-exchange far above them | 3–6 months | 0% | Clear |
| Vanuatu | VASP Licence (Classes D, D.1, D.2, D.3, D.4) + ITO Licence | VT 200,000,000 (≈ USD 1.7m at the Reserve Bank of Vanuatu rate of 28 August 2026) | USD 665,000-1,060,000 for one class (statutory 150,000: application 50,000 plus licence 100,000, FLAT ACROSS CLASSES D to D.4 under Virtual Asset Service Providers Order No. 9 of 2026, gazetted 16 January 2026, which SUPERSEDES the vatu schedule and removes the Class D.4 banking discount; build 515,000-910,000 quoted per case). Excludes the capital floor, which is held not spent. Act 44 of 2025 removed the former s.66(2) fee minima, as confirmed by the VFSC consolidated Act, 2026 edition | 8–19 months | 0% | Clear |