Why Choose Vanuatu for Crypto Licensing?
Vanuatu is a Pacific offshore jurisdiction with a single licensing authority for virtual asset service providers (the VFSC), a zero corporate tax regime, and a recently rebuilt licensing framework purpose-built for virtual asset businesses. The 2025 VASP Act adds a five-class VASP licence to a Financial Dealers Licence regime whose Class D already covers dealing in digital assets. Running two statutes side by side makes the jurisdiction structurally different from Seychelles or BVI.[1][30]
A Modern, FATF-Aligned VASP Framework
The Virtual Assets Services Providers Act No. 3 of 2025 was assented on and commenced on .[1][18] The Act was drafted with input from an international AML/CFT specialist and aligns the regime with FATF Recommendation 15 and the 2021 FATF Updated Guidance on Virtual Assets.[2] Unlike older Pacific frameworks, the Act explicitly covers exchange, transfer, custody, issuance, and bank-operated activities in five distinct licence classes plus a separate ITO licence.
Zero Corporate Tax with Operational Substance
Vanuatu imposes no corporate income tax, no capital gains tax, no withholding tax, and no personal income tax.[3] What it does impose is genuine economic substance: a physical office, a Manager, a Director and a Chief Technology Officer who each undertake to spend twelve consecutive months on-island from appointment. Unlike pure paper-jurisdictions in the same fee band, the regime requires a real office and real people, and it holds the undertaking rather than waiting for the year to elapse.
One Licensing Authority
The VFSC is the sole licensing authority for virtual asset activity under the VASP Act and the Financial Dealers Licensing Act [CAP 70].[4] The Reserve Bank of Vanuatu is engaged only for Class D.4 (bank-operated) applicants. Applicants deal with the VFSC from intake to ongoing prudential supervision, while AML/CFT reporting runs to the Vanuatu Financial Intelligence Unit. Stablecoin issuance is heading for a separate regime: Parliament records the Stablecoins Bill from its Second Ordinary Session of 2025 as passed;[38] the published bill creates a Stablecoin Supervisory Commission chaired by the Reserve Bank Governor, with the VFSC Commissioner as deputy chair,[31] and a Commissioner of Stablecoins was reported appointed in July 2026;[35] confirm the Act’s commencement before planning an issuer on either footing.
Practitioner Note: the 2025 Regime Is Not the Legacy FDL Regime
In practice, the most common reason a Vanuatu evaluation fails today is that the operator is comparing the 2025 VASP Act against the pre-2022 Financial Dealers Licence regime that gave the jurisdiction its “fast and cheap” reputation. Those days are over. Government fees are USD 150,000 per class in Year 1 and USD 100,000 every year after; the base capital floor is VT 200,000,000 before any risk add-on; the FDL classes may be needed first, a sequence to confirm with the VFSC; and named individuals must undertake to reside on-island for twelve consecutive months from appointment. Operators who model Vanuatu against the legacy regime walk away from the wrong jurisdiction.
Regulatory Framework
Virtual asset activity in Vanuatu is regulated by the VFSC under two stacked statutes: the Financial Dealers Licensing Act [CAP 70] as amended (FDL Act) and the Virtual Assets Services Providers Act No. 3 of 2025. The Financial Markets Association of Vanuatu, an industry association, describes the VASP Act as an extension of the FDL framework rather than a replacement.[2]
The framework rests on three primary statutory pillars and one operational rulebook layer:
- Virtual Assets Services Providers Act No. 3 of 2025 is the principal Act. Assented ; commenced .[1]
- Financial Dealers Licensing Act [CAP 70], as amended by the Financial Dealers Licensing (Amendment) Act No. 9 of 2021 and Amendment Act No. 5 of 2024, establishes Classes A (foreign exchange and debt securities), B (shares, precious metals, and commodities), C (futures and other derivatives), and D (digital assets); Class D issues only to holders of Classes A, B, and C.[30]
- Anti-Money Laundering and Counter-Terrorism Financing Act No. 13 of 2014 governs AML and CFT obligations and the Vanuatu Financial Intelligence Unit (VFIU), the national financial intelligence body that receives STR, CTR, and IFTI filings.[5][19]
- VFSC guidelines issued under section 59: the VASP and ITO Application Guidelines of June 2025; the VASP Capital Adequacy Guidelines of ; December 2025 guidelines on fit and proper criteria, cybersecurity, and the Travel Rule; a 2026 set that revised the first two in January 2026 (the cybersecurity guideline as Cybersecurity and Operational Resilience) and added guidelines on AML/CTF/PF compliance, custody, market conduct, quarterly reporting, and Travel Rule compliance; and, in August 2026, cybersecurity requirements for applicants and licensees.[6][33] A revised “Requirements for Licence Application as a VASP” was published .[7]
Some offshore regimes prescribe a single self-contained digital-asset statute. Vanuatu takes a different approach, with two stacked statutes. The FDL Act already requires a Class D licence to deal in digital assets and issues it only to holders of Classes A, B, and C,[30] and the Financial Markets Association of Vanuatu, an industry association, describes VASP licences as going only to holders of all four FDL classes.[2] Neither the VASP Act nor the VFSC application documents state that condition, so the sequence for the proposed activities is confirmed with the VFSC. Where the FDL classes do come first, they add 3 to 6 months and take the end-to-end timeline from about 8 to 13 months to 11 to 19 months.
Recent Regulatory Milestones
Recent regulatory milestones, as of :
- : FDL Amendment Act No. 9 of 2021 introduces digital assets as Class D.
- : Deadline for existing Financial Dealers licensees to re-apply under the 2021 amendment, which requires a licensed manager or an office in Vanuatu with a manager or director normally resident there for six months a year.[30]
- : FDL Amendment Act No. 5 of 2024 reinforces that FDL Class D issues only to A/B/C holders.
- : Parliament passes the VASP Act.
- / : Assent and commencement.
- : VFSC publishes the VASP, ITO, and Fintech Sandbox application guidelines and convenes its second industry symposium on virtual assets and financial dealers.[21]
- : Government launches its national AML/CTF/CPF strategy, National Risk Assessment, and Mutual Evaluation Technical Team, having temporarily suspended the Citizenship by Investment programme earlier in the year.[9]
- : The VFSC’s virtual-asset risk assessment records no licensed VASP domiciled in Vanuatu at the time of the report.[29]
- Second Ordinary Session 2025: Parliament records both the Stablecoins Bill and the VASP Amendment Bill as passed. The VFSC’s consolidated Act identifies Act 44 of 2025 as the amendment removing the section 66(2) fee minima.[37][38]
- : VASP Capital Adequacy Guidelines issued.[24]
- : Order No. 9 of 2026 gazettes the dollar fee schedule.[23]
- : Revised Requirements for Licence Application published.[7]
- : OECD Global Forum upgrades Vanuatu to Largely Compliant on tax transparency.[10]
- : APG Mutual Evaluation onsite scheduled.[11]
License Types and Activities Covered
Vanuatu’s VASP Act creates five licence classes (D, D.1, D.2, D.3, D.4) covering exchange, transfer, custody, issuance-related financial services, and bank-operated activities, plus a separate Initial Token Offering (ITO) licence for issuers. A company may hold several classes, but the Application Guidelines require a separate application, with its own application and licence fee, for each class; only Class D.4 needs Reserve Bank of Vanuatu approval, which the bank or its subsidiary must obtain before applying.[6][1]
Class D: Exchange
Exchange between virtual assets and fiat currencies, or between virtual assets in different forms. Covers centralised and decentralised exchange operators, on-ramps, and off-ramps, and OTC trading desks.
Class D.1: Transfer
Transfer of virtual assets on behalf of another person. Covers wallet providers, transmitter services, and bridge operators.
Class D.2: Custody
Safekeeping and control over virtual assets or the instruments enabling such control. Covers institutional custodians, qualified custodians, and hot or cold storage providers. In practice, capital adequacy expectations scale aggressively with assets under custody, and the VFSC’s June 2025 Guidelines specifically reference assets-under-custody as a calibration factor.[6]
Class D.3: Issuance-Related Financial Services
Financial services connected to an issuer’s offer and sale of a virtual asset. Covers ITO advisory, intermediation, placement, and underwriting-style activities. A Class D.3 licence is distinct from the ITO licence itself: the issuer needs an ITO licence; the intermediary needs Class D.3.
Class D.4: Bank Operating Exchange and Custody
A bank licensed by the Reserve Bank of Vanuatu may, with VFSC approval, conduct exchange and custody activity. A Class D.4 licensee does not also need Classes D.1, D.2 or D.3, and the bank or its subsidiary must obtain Reserve Bank approval before applying (section 11(2)).[1]
ITO Licence: Initial Token Offering
A separate Part 5 authorisation for token issuers. Only companies may issue tokens. The white paper must contain the 23 prescribed components in Appendix 2 of the VFSC Application Guidelines.[6]
Fintech Sandbox
A 12-month testing approval, renewable under section 9(9), for virtual asset products that are not yet ready for full licensing, decided within three months under section 9(7). At least one year of relevant industry experience is required.[6] The June 2025 Guidelines put the application fee at VT 200,000; the sandbox guidelines revised in state no fee at all, and Order No. 9 of 2026 prices the licence classes only, so confirm the current charge with the VFSC before budgeting it.[23]
Requirements
A Vanuatu VASP applicant must be a Vanuatu-incorporated company with minimum unimpaired paid-up capital of VT 200,000,000, a physical office in Port Vila, and three named individuals (Manager, Director, and CTO) each undertaking to reside on-island for 12 consecutive months from appointment; whether it must first hold FDL Classes A to D is confirmed with the VFSC, as set out under Process below. Applications must be presented through a licensed Company and Trust Services Provider, and section 13(2)(g) requires the applicant itself to have at least two years’ experience in providing virtual asset services.[6][1] A newly formed Vanuatu company has no such record of its own, so confirm at scoping how the VFSC applies the test to it, for instance whether it counts the group’s or the key persons’ experience.
Corporate Form
The applicant must be a company registered under either the Companies Act No. 25 of 2012 (domestic) or the International Companies Act [CAP 222]. Because the licensee must maintain a physical office and on-island staff, most applications use the domestic-company form.[7] A registered office in Vanuatu and a licensed CTSP are mandatory.
Key Persons and Fit-and-Proper
Three on-island roles are mandatory: a Manager with five or more years of VASP or ITO experience; a Director with two or more years; and a Chief Technology Officer with a degree in engineering or computer science and at least one year of VASP-relevant management experience.[6]
All key persons undergo fit-and-proper assessment: criminal-record screening, UN and foreign-sanctions screening, financial soundness, competence, and integrity.[6] An AML/CTF Compliance Officer must be separately registered under section 34 of the AML&CTF Act 2014.[5]
Residency Proof
The common mistake is underestimating the residency evidentiary burden. Where a key person already meets the residence requirement, the Application Guidelines ask for a written undertaking, co-signed by that person, backed by twelve months of telephone bills and of bank statements showing cash withdrawals in Vanuatu, and a twelve-month lease or proof of owning a residence. Where the key persons do not yet meet it, the applicant gives a written undertaking for each that they will, and states how; the VFSC normally treats a breached undertaking as a fit-and-proper failure.[6] Recruitment can therefore run alongside the application, but the three people must be identified early and must actually relocate.
Capital Adequacy
Section 64 of the Act requires a licensee to maintain the minimum capital “as prescribed by the Regulations”, and no VASP Regulations have been made, so the operative figure comes from guidance issued under section 59. The VASP Capital Adequacy Guidelines of set required capital as the greater of a VT 200,000,000 base floor (about USD 1.7M) and three months of fixed overheads, plus a risk add-on by class: about VT 50,000,000 for a Class D exchange, VT 150,000,000 for Class D.2 custody, and a further VT 100,000,000 where leverage or margin is offered.[24]
A separate bond equal to three months of overheads is deposited with the Commission and does not count toward capital. Capital is evidenced by a bank statement, and source of funds must be documented to AML standards;[6] the VFSC’s May 2025 industry briefing adds that capital may be held externally at a recognised financial institution if an external auditor certifies it.[34]
Compliance Documentation
Required at submission: AML/KYC manual; cybersecurity policy; business continuity and disaster recovery plans; risk management policy; technology audit report covering DLT, smart-contract and protocol assurance; insurance policies for professional indemnity and cybercrime; three-year financial projections; white paper (ITO applicants only); custody arrangement details; and a Director Statement of financial standing with indemnity cover.[6]
Full compliance documentation checklist
- AML and KYC manual.
- Customer Acceptance Policy.
- Transaction monitoring procedure.
- Risk management policy.
- Cybersecurity policy.
- Business continuity plan.
- Disaster recovery plan.
- Technology audit report (DLT, smart-contract, protocol assurance).
- Custody arrangement details.
- Professional indemnity insurance policy.
- Cybercrime insurance policy.
- Three-year financial projections.
- Capital adequacy framework.
- Source-of-funds documentation.
- Comprehensive funding and contingency funding plan.
- Director Statement of financial standing with indemnity cover.
- White paper (ITO applicants only).
- Group-Wide Procedure Manual.
Jagelski & Partners scopes each of these workstreams against the operator’s actual business model. Where AML or cybersecurity policies need to be drafted to VFSC expectation, the independent specialist’s compliance team drafts them to publication standard rather than to minimum compliance.
Application Process
A Vanuatu VASP application runs in five stages over about 8 to 13 months: company formation and CTSP engagement, FDL Class A/B/C/D authorisation where the VFSC requires it first (which extends the path to 11 to 19 months), on-island substance build, VASP application submission, and VFSC review with a statutory decision window of 90 working days. Banking architecture must be sourced in parallel, not after licensing.
Company Formation and CTSP Engagement
Forming a Vanuatu entity is the first step: a domestic company under the Companies Act No. 25 of 2012, a registered office, and a licensed Company and Trust Services Provider to present the application. Company formation considerations are covered in detail in our Vanuatu company formation guide →.
FDL Classes, Where Required
Application for FDL Classes A (foreign exchange and debt securities), B (shares, precious metals, and commodities), C (futures and other derivatives), and D (digital assets) under the Financial Dealers Licensing Act [CAP 70], which requires a Class D licence to carry on the business of dealing in digital assets and issues Class D only to holders of Classes A, B, and C.[30] The VASP Act and the VFSC’s application guidelines do not themselves list an FDL as a precondition; the Financial Markets Association of Vanuatu, an industry association, stated in May 2025 that VASP licences will be issued only to holders of all four classes, so confirm at scoping whether the proposed activities need this step.[2] Where they do, planning on the FDL grant before the VASP package adds its 3 to 6 months and moves every later stage back by the same amount; preparing the package while the FDL application is under review recovers part of that.
Substance Build
Physical office, three on-island key persons whose 12-month residence runs from appointment, insurance procurement, technology audit engagement, AML, and cybersecurity manuals drafted to VFSC expectation. This stage is the operational bottleneck, but it is not a twelve-month wait: the residency obligation runs from appointment under sections 5(5)(a) and 7(5)(a), and the VFSC’s Application Guidelines provide for a written undertaking where the key persons do not yet meet the residence requirement.[6]
VASP Application Package
Submission through the CTSP after 3 to 6 months of preparation, by month 4 to 8. The 42-item documentation pack includes the operator’s white paper (for ITO classes), three-year financials, the capital adequacy framework, the technology audit report, all compliance manuals, key-person fit-and-proper packs, and the bank statement evidencing VT 200,000,000 paid-up capital, as listed in Appendix 1 of the Application Guidelines.[6]
VFSC Review
Statutory decision window of 90 working days, about 4 to 5 months, from receipt of the application, not from receipt of a complete one.[1] The VFSC publishes no typical elapsed time, and its November 2025 risk assessment recorded no licensed VASP domiciled in Vanuatu, so the statutory window is the planning figure.[29] A licensee that has not started the licensed business within 12 months of grant can be served a notice of non-compliance and, ultimately, suspended (section 18(1)(f)).[1]
After Stage 5, the licensee enters ongoing compliance: quarterly reporting, annual audited financials, annual DLT audit, AML programme maintenance, and Travel Rule transmission for cross-border transfers of USD/EUR 1,000 or more.[1][12]
Jagelski & Partners’ role: written stage scoping, FDL/VASP sequencing, substance recruitment needs, and banking pre-qualification, followed by a CTSP or licensing specialist introduction. You contract directly with the independent specialist, who owns delivery across all five stages. Our role ends at the introduction.
Required Documents
Vanuatu VASP applications require a 42-item documentation pack across corporate, personnel, financial, technical, and compliance categories. The pack is structured by Appendix 1 of the VFSC’s VASP Application Guidelines (June 2025) and the Revised Requirements for Licence Application (January 2026).[6][7] All documents are submitted through a licensed CTSP.
The required documentation falls into six categories:
| Category | Required Items |
|---|---|
| 1. Corporate | Certified certificate of incorporation; memorandum and articles of association; certified register of members and directors; UBO declarations; resolution appointing the Representative of the Principal |
| 2. Key persons | For each Manager, Director, CTO, AML/CTF Compliance Officer, and beneficial owner: CV, certified passport, police clearance, proof of address, fit-and-proper questionnaire, signed personal declaration, and Director Statement of financial standing |
| 3. Financial | Three-year financial projections; capital adequacy framework; bank statement evidencing VT 200,000,000 unimpaired paid-up capital; source-of-funds documentation; comprehensive funding and contingency funding plan; Director Statement of financial standing with indemnity cover |
| 4. Technical | Technology audit report covering DLT, smart-contract, and protocol assurance from an external auditor; cybersecurity policy; business continuity plan; disaster recovery plan; custody arrangement details; insurance policies for professional indemnity and cybercrime cover |
| 5. Compliance and AML | AML and KYC manual; risk management policy; Customer Acceptance Policy; transaction monitoring procedure; AML/CTF Compliance Officer registration form under section 34 of the AML&CTF Act 2014; Group-Wide Procedure Manual |
| 6. Issuer-specific (ITO only) | White paper containing the 23 prescribed components in Appendix 2 of the Application Guidelines |
Compliance Documentation Drafting
The independent specialist’s compliance team drafts the AML, cybersecurity, BCP/DR and risk policies to VFSC publication standard rather than to minimum-compliance level. The VFSC may request additional information after submission and may decline an application where requirements are not satisfactorily met, so drafting depth is the part of the review timeline an applicant controls.[7]
Costs and Pricing
Vanuatu’s fees changed shape in and most published budgets have not caught up. The Virtual Asset Service Providers Order No. 9 of 2026, gazetted on , re-denominated the schedule in United States dollars and flattened it: USD 50,000 to apply and USD 100,000 for the licence, for every class from D to D.4, with USD 100,000 payable on each anniversary.[23]
Year 1 therefore splits in two. The statutory charge is USD 150,000 for one class, fixed and published. The build, what it costs to satisfy the licence conditions, is about USD 515,000 to 910,000 and is an estimate priced per case. The VT 200,000,000 capital floor sits outside both.
Government Fees
Per the VFSC Public Notice on the fees gazetted under Order No. 9 of 2026, checked against the live notice on .[23]
| Licence class | Application fee | Licence fee | Annual fee |
|---|---|---|---|
| Class D (exchange between virtual assets and fiat, or between virtual assets) | USD 50,000 | USD 100,000 | USD 100,000 |
| Class D.1 (transfer of virtual assets) | USD 50,000 | USD 100,000 | USD 100,000 |
| Class D.2 (safekeeping of virtual assets, or control over them) | USD 50,000 | USD 100,000 | USD 100,000 |
| Class D.3 (financial business related to an issuer’s offer and sale, tagged “ITO” in the Order) | USD 50,000 | USD 100,000 | USD 100,000 |
| Class D.4 (a bank operating exchange and safekeeping) | USD 50,000 | USD 100,000 | USD 100,000 |
| Director, manager, or chief technology officer, on a change or replacement only | VT 200,000 ≈ $1,700 | — | — |
Statutory Cost, Year 1
| Statutory charge | Year 1 (USD) |
|---|---|
| VFSC application fee, one class | 50,000 |
| VFSC licence fee on grant, one class | 100,000 |
| Statutory cost, Year 1, one class | 150,000 |
Both lines are set by Order No. 9 of 2026 and can be checked against the VFSC’s published notice.[23] From Year 2 the statutory charge is the USD 100,000 annual fee, payable on each anniversary of grant under section 17, and it is charged per class, so an operator holding D and D.2 pays twice.
Section 65 imposes a late-payment penalty of 10% of the licence fee for each day it is late, which on a USD 100,000 fee is severe enough to be worth a diary entry.[1]
Capital Floor
The VFSC capital-adequacy guidance sets required capital as the greater of the VT 200,000,000 base floor (about USD 1.7M) and three months of fixed overheads, plus a risk add-on by class, and a bond equal to three months of overheads is deposited with the Commission on top and does not count toward capital.[24]
A plain Class D exchange therefore lands nearer VT 250,000,000 than the floor, and a custody model further above it again. Capital is held rather than spent and is excluded from both tables here.
Typical Build, Year 1 (Quoted Per Case)
| Cost category | Year 1 range (USD) |
|---|---|
| Licensed CTSP: company formation and the mandatory application channel | 10,000–20,000 |
| Registered agent and registered office in Vanuatu (annual) | 5,000–10,000 |
| Office in Port Vila, lease and fit-out (annual) | 60,000–100,000 |
| Resident manager, resident director, and chief technology officer, fully loaded (annual) | 250,000–400,000 |
| AML/CFT, cybersecurity, business-continuity and risk policy suites | 50,000–80,000 |
| Technology and DLT audit (annual from grant) | 30,000–60,000 |
| Professional indemnity and cybercrime insurance (annual) | 25,000–50,000 |
| External audit of the annual accounts, section 63 (annual) | 25,000–40,000 |
| Legal and advisory fees: the application file and project management | 60,000–150,000 |
| Base capital floor (held, not spent) | VT 200,000,000 ≈ $1.7M |
| Typical build, Year 1 (quoted per case, excludes capital) | 515,000–910,000 |
| Typical build, annual from Year 2 (excludes capital) | 395,000–660,000 |
Two lines in that build are worth separating from the rest, because Vanuatu compels the role and not its price. Section 5(5)(a) requires at least one manager who will reside in Vanuatu for twelve consecutive months, and section 7(5)(a) the same of at least one director; the three-person on-island team, and the chief technology officer specifically, come from the Application Guidelines rather than the Act.[1][6]
What those people are paid is negotiated with them, and no honest table can fix it in advance. The same is true of the CTSP, through whom every application must be filed.
Adding the two totals gives a Year-1 outlay of about USD 665,000 to 1,060,000 before capital, but they are not the same kind of number and this page keeps them apart for that reason. The statutory half is fixed, published, and identical for every applicant. The build half moves with the model: a single-class operator with a lean team sits at the floor, a multi-class exchange with custody sits above the ceiling.
Vanuatu is materially cheaper to enter than the superseded vatu schedule suggested, but the substance requirement, three named individuals who undertake to live on-island for twelve consecutive months from appointment, has not moved at all, and it remains the real commitment.
Timeline
The realistic end-to-end timeline for a Vanuatu VASP licence is about 8 to 13 months: company formation and CTSP engagement (1–2 months), the VASP application package (3–6 months, with the substance build alongside), and a VFSC decision due within 90 working days of receipt (about 4–5 months). Where the VFSC requires the FDL classes first, their 3–6 months come before the package, for 11 to 19 months in all.
| Stage | Elapsed | Runs in parallel? |
|---|---|---|
| Company formation + CTSP engagement | Month 1–2 | Sequential start |
| FDL Classes A/B/C/D, where the VFSC requires them first | +3–6 months | Before the package; shifts later stages |
| Substance build (residence runs from appointment) | Month 2–8 | Alongside the package |
| VASP application package | Month 2–8 | Filed by month 4–8 |
| VFSC decision (90 working days from receipt) | Month 5–13 | Sequential |
| Total end-to-end | 8–13 months | |
| Total with the FDL classes first | 11–19 months |
The statutory decision window under section 12(8) of the VASP Act is 90 working days from receipt of the application. The words run from receipt, not from receipt of a complete file: the complete-application deeming device in the Act sits at section 5(8) and section 7, which govern manager and director approvals, not the licence decision.[1] Outside the statutory window, the time an applicant controls is the preparation: the package and the substance build set out under Requirements above, which means identifying, hiring, and relocating the three key persons and fitting out the Port Vila office, work that a written undertaking lets run alongside the file rather than ahead of it. Once the licence is issued, the licensee has 12 months to commence the licensed business before the Commissioner can serve a notice of non-compliance under section 18(1)(f).[1]
An operator that already holds the FDL classes, or whose activities the VFSC confirms need no FDL step, follows the 8 to 13 month path.
Taxation
Vanuatu imposes no corporate income tax, no capital gains tax, no withholding tax, no personal income tax, no inheritance tax, and no wealth tax.[3][27] VAT at 15% applies to domestic supplies of goods and services. There is no crypto-specific tax. The structural zero-tax position is a defining feature of the jurisdiction.
For operating VASPs, this means:
- Net trading profits, custody fees, and exchange spreads earned by the Vanuatu entity are untaxed in Vanuatu.
- VAT obligations apply only where the VASP supplies services to Vanuatu residents.
- Rent tax of 12.5% applies to gross rental income, generally from long-term residential property; commercial rent is subject to VAT instead unless the landlord is below the VAT registration threshold.[28]
Important International Tax Caveats
Tax residence of UBOs, controlled foreign company (CFC) rules in home jurisdictions, the OECD Common Reporting Standard (CRS), and FATCA will all need to be managed. Vanuatu signed the CRS multilateral competent authority agreement on and exchanges on a non-reciprocal basis, because it levies no income tax.[36][27] The jurisdiction’s upgrade to Largely Compliant on the OECD Global Forum’s EOIR peer review materially strengthens its tax-information-exchange standing.
EU Non-Cooperative Jurisdiction Status
Vanuatu sits on the EU’s Annex I list of non-cooperative tax jurisdictions, last confirmed .[13] Annex I listing triggers EU Member State counter-measures including withholding taxes, non-deductibility of payments to Vanuatu entities, CFC inclusion, and DAC6 reportable arrangements. The EU posture toward Vanuatu has hardened on the visa side as well: the Council ended the Schengen visa exemption for Vanuatu passport holders in , citing the security and migration risks of its investor citizenship scheme, which the Government temporarily suspended in 2025 pending a review.[20][9]
Operators with material EU shareholders or EU customer-facing structures should model these counter-measures into post-tax projections rather than treating the Vanuatu 0% rate as the end of the analysis.
Ongoing Compliance & Post-Registration
A licensed Vanuatu VASP carries quarterly reporting to the VFSC, annual audited financial statements, an annual DLT and technology audit, AML/CFT obligations including the Travel Rule for cross-border transfers of USD/EUR 1,000 or more, beneficial ownership disclosure, and a designated AML/CTF Compliance Officer with annual Group-Wide Procedure Manual filing to the VFIU.[6][12]
Reporting and Audit Obligations
- Quarterly reports to the Commissioner under section 54 of the VASP Act.[1]
- Annual audited financial statements under section 63.
- Annual technology and DLT audit report by an external auditor (VFSC Guidelines section 7.7).[6]
- Annual filing of the Group-Wide Procedure Manual to the VFIU by 31 March.[5]
- Penalty for late filing: VT 100,000 per day per report.[6]
AML and CFT Obligations
- Risk-based customer due diligence and enhanced due diligence for higher-risk customers and transactions.
- Suspicious Transaction Reports (STRs), Cash Transaction Reports (CTRs), and International Funds Transfer Instructions (IFTIs) to the VFIU.
- FATF Recommendation 16 Travel Rule: transmission of originator and beneficiary information for cross-border transfers of USD/EUR 1,000 or more, under section 27(2) of the Act and the VFSC Travel Rule Guidelines.[1][12]
- Beneficial ownership registration with the VFSC under Vanuatu’s UBO legislation.
Governance Obligations
- Written notice to the Commissioner within 14 days of a change in a key person, in a key person’s fit-and-proper circumstances, or in the source of funds for the capital (section 21), and the Commissioner’s prior approval for a transfer of shares or beneficial interest or a change of key persons (section 26).[1]
- Client asset segregation under section 62.
- Proper books and records under section 60, as prescribed by regulations.
- Capital maintenance: the unimpaired paid-up capital floor must be maintained continuously.
Penalty Exposure Under the Act
The heaviest penalties sit in section 10: carrying on VASP business without a licence exposes an individual to a fine of up to VT 200,000,000 or 30 years’ imprisonment and a body corporate to a fine of up to VT 300,000,000. Under section 56, a false or misleading representation carries up to VT 50,000,000 or 20 years for an individual and up to VT 250,000,000 for a body corporate, and a director or manager who knowingly authorised a corporate offence faces up to VT 150,000,000 or 30 years.[1]
The VASP licence is perpetual subject to ongoing fee payment and compliance, but the Commissioner retains discretionary suspension and revocation powers under sections 18 and 19.[1]
ICT Risk Management & Operational Resilience
Vanuatu does not have an EU-style harmonised ICT rulebook, but the VFSC’s cybersecurity guideline (, revised as Cybersecurity and Operational Resilience in ), its cybersecurity requirements for applicants and licensees, the mandatory annual DLT audit, and the technology audit report requirement at application set a coherent ICT risk-management framework that applicants must build to from day one.[33][6]
ICT Governance
A documented cybersecurity policy approved at board level, a risk register identifying ICT-related risks and the controls in place, and a defined incident-response procedure. The CTO is the responsible officer. The VFSC’s cybersecurity guideline and its August 2026 requirements set the baseline that the policy framework must meet.[33]
Technology Audit
At application: an external DLT, smart-contract, and protocol audit. On an ongoing basis: an annual technology audit by an external auditor covering wallet management (hot and cold segregation), key management, custody architecture, transaction monitoring infrastructure, and disaster recovery testing.[6]
Third-Party ICT Risk
Critical ICT outsourcing arrangements (custody software, exchange engines, KYC vendors) must be documented in the application pack and remain auditable. Section 51 lets the Commissioner inspect the licensee’s premises and take copies of its books and documents, so outsourcing contracts and the records they generate should be available on request.[1]
Portability of EU ICT Artefacts
While lighter than the EU operational-resilience regime, the Vanuatu framework is functionally aligned. EU-licensed operators considering a Vanuatu entity will find the policy artefacts portable: an ICT risk register, business continuity plan, and third-party register prepared to EU standards translate directly into VFSC expectations.
Banking
Banking is the hardest operational hurdle for a Vanuatu-licensed crypto entity. The EU AML high-risk listing obliges EU banks to apply enhanced due diligence to Vanuatu relationships, and in practice EU correspondent access is largely closed; viable banking architecture combines local Vanuatu operating accounts with mid-tier EMI and PSP relationships in jurisdictions outside the EU’s enhanced-due-diligence perimeter. Banking must be sourced before licensing investment is committed.
The Structural Picture
The combined effect of the EU AML high-risk listing (continuous since ),[14] the EU Annex I tax listing (retained ),[13] and the broader de-risking of Pacific correspondent banking (a 60% drop in Pacific correspondent banking relationships since 2011, “double the world average” per the World Bank’s Pacific feature)[15] means that Tier-1 European and US correspondent banks do not, as a rule, onboard Vanuatu VASPs directly.
Banking archetypes available to a Vanuatu VASP, in descending order of accessibility:
- Vanuatu local banks. Local-currency operating accounts for payroll, tax payment, and supplier settlement. Limited correspondent reach.
- Specialist crypto-aware EMIs and payment institutions in mid-tier jurisdictions outside the EU enhanced-due-diligence perimeter. Onboarding feasible with a complete AML pack, but expect pricing above standard commercial rates (a premium of about 50 to 200 basis points on our planning estimate) and ongoing enhanced due diligence.
- Caribbean and African specialist banks that service offshore VASP licensees. Accessible but with concentration and counterparty risk worth monitoring.
- Tier-1 European banks. In practice closed to direct Vanuatu corporate banking, because the EU high-risk listing makes enhanced due diligence mandatory for EU banks. Possible only via group entities outside the EU listing perimeter.
What the VASP licence does not cover is bank onboarding. The VFSC issues regulatory permission to operate; banks decide independently whether to accept a Vanuatu VASP as a customer. In our assessment, the realistic answer for an EU-customer-focused operator is that Vanuatu banking architecture cannot sustain that business model: capital should go to a CASP authorisation in an EU Member State instead.
Jagelski & Partners’ banking partner network includes 90+ institutions across the offshore, mid-tier EMI, and specialist crypto banking tiers. We pre-qualify banking for Vanuatu opportunities before licensing capital is committed: learn about our Banking service →
With Tier-1 European correspondent rails effectively closed under the EU listings, Vanuatu placements run through local banks for domestic operations, specialist crypto-aware EMIs in mid-tier jurisdictions outside the EU enhanced-due-diligence perimeter, and offshore specialist banks, pre-qualified before licensing capital is committed. Jagelski & Partners scopes banking options in writing and introduces an independent specialist before a licence application is filed. You contract directly with the specialist; account approval remains the financial institution's decision.
Explore Banking SolutionsFATF Status & International Standing
Vanuatu is FATF-clear: it was removed from the FATF grey list on and remains off both the grey and black lists after the Plenary.[16][25] It is, however, on the EU’s AML high-risk third-country list and the EU’s Annex I list of non-cooperative tax jurisdictions: facts more decision-relevant for crypto operators than the FATF status itself.
FATF Position
Vanuatu was placed on the FATF grey list in following the 2015 Asia/Pacific Group on Money Laundering Mutual Evaluation. 30 AML/CTF-related Bills passed in 2017; an ICRG onsite visit took place in ; Vanuatu was removed at the FATF Plenary of .[16] The position has been stable since: Vanuatu was on neither list after the Plenary.[25]
The Two Listings That Matter
Most offshore-tier comparators are not on the EU AML high-risk list, although the British Virgin Islands joined it on .[14] Vanuatu’s commercial constraint is the EU. Two specific listings:
| Listing | Status | Date stamp | Source |
|---|---|---|---|
| EU AML high-risk third-country list (Commission Delegated Regulation 2016/1675, as amended) | Listed: entry into force , still listed | Latest amendments | [14] |
| EU Annex I non-cooperative tax jurisdictions | Listed: confirmed alongside American Samoa, Anguilla, Guam, Palau, Panama, Russian Federation, Turks and Caicos Islands, US Virgin Islands, Viet Nam | [13] |
APG Mutual Evaluation
Vanuatu’s fifth-round APG mutual evaluation is under way: its technical-compliance submission was due on , the onsite visit is scheduled for , and the report is scheduled for the 2027 APG Plenary.[26][27][22] The outcome will shape whether Vanuatu enters the next FATF cycle with grey-list risk or with a strengthened position.
OECD Global Forum Upgrade
On , the Global Forum on Transparency and Exchange of Information for Tax Purposes upgraded Vanuatu to Largely Compliant on EOIR (from Partially Compliant).[10] This materially improves the tax-transparency standing without yet unlocking Annex I delisting.
EU Market Access
A Vanuatu VASP licence does not confer EU passporting rights. MiCA contains no third-country equivalence regime: there is no mechanism for the European Commission to recognise a non-EU licence as equivalent to a Markets in Crypto-Assets authorisation. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative.
ESMA’s Guidelines on reverse solicitation under MiCA (ESMA35-1872330276-2030), published and applicable from , list signs that a firm is likely to be regarded as soliciting EU clients, judged on all the facts: EU-targeted and geo-targeted advertising, EU country-code domains, sponsorship of EU events, EU-based influencers, mobile apps offered to EU users, and a website in an EU language that is not customary in international finance. A firm that solicits EU clients cannot rely on the exemption.[17]
Marketing further crypto-assets or services of the same type is permitted only in the context of the original transaction; ESMA uses one month as an illustration of when that context has lapsed, not as a ceiling on the original service. The exemption offers no route to systematic EU market access. For full detail on what constitutes solicitation and the documentation requirements, see Reverse Solicitation Under MiCA →.
Banking for Crypto and Fintech Businesses
90+ institutions across offshore, EMI, and specialist crypto banking tiers. Pre-qualified before licensing capital is committed.
Crypto Licensing: VASP, CASP, MiCA
Worldwide licensing options scoped against your target market and capital envelope.
Advantages and Limitations
Vanuatu offers a 0% tax base, FATF-clear status, a modern five-class VASP framework, and a single licensing authority. It carries above-tier capital and substance costs, an EU AML high-risk listing that constrains banking and EU customer access, and an APG mutual evaluation whose onsite visit is due in November 2026, with the report due at the 2027 APG Plenary.
- Zero corporate tax. No corporate income tax, no capital gains tax, no withholding tax. The structural tax position is a defining feature.
- Modern VASP framework. The 2025 VASP Act covers five licence classes plus ITO, with FATF Recommendation 15 alignment baked in.
- Single licensing authority. The VFSC licenses and supervises VASPs under the VASP Act; AML/CFT reporting runs to the Vanuatu Financial Intelligence Unit.
- FATF-clear status. Removed from the grey list in 2018, not on the black list. Strengthens banking onboarding relative to grey-listed Pacific peers.
- Recent OECD upgrade. Largely Compliant on tax transparency since April 2026, reflecting real institutional improvement.
- No EU passporting. A Vanuatu licence confers no EU market access rights. Mitigation: Operators targeting EU clients can obtain a separate CASP authorisation in an EU Member State (full market access via passporting) or, for services provided at the client’s own exclusive initiative only, may fall within the narrow reverse solicitation exemption under MiCA Article 61.
- EU AML high-risk listing. Continuous since September 2016. Triggers EU obliged-entity enhanced due diligence and, from 10 July 2027, blocks outsourcing of AML functions to Vanuatu service providers under the AMLR. Mitigation: Structure EU-facing functions through entities outside the listing perimeter; document non-EU customer focus to defend EU “wholly artificial arrangement” challenges.
- EU Annex I tax listing. Triggers Member State counter-measures including withholding taxes, non-deductibility, CFC inclusion. Mitigation: Model counter-measures into post-tax projections; consider parallel EU structuring for EU shareholder distributions.
- High licensing cost-of-entry. Government fees are USD 150,000 per class in Year 1 and USD 100,000 annually thereafter, on top of a VT 200,000,000 capital floor and twelve months of on-island residence for three named key persons from their appointment. Mitigation: use the Fintech Sandbox for early-stage product validation before committing to the full licence, and apply only for the classes the business model needs, since each class requires its own application and carries its own licence and annual fee.
- Banking complexity. EU correspondent access is effectively closed; viable architecture combines local Vanuatu accounts with mid-tier EMI and PSP relationships outside the EU enhanced-due-diligence perimeter. Mitigation: Pre-qualify banking before licensing investment is committed; plan for multi-rail architecture from day one rather than single-banking-relationship dependency.
- APG Mutual Evaluation pending. The onsite visit is due in November 2026 and the report at the 2027 APG Plenary; its outcome could shift the FATF risk picture in either direction. Mitigation: Monitor the APG outcome and the subsequent FATF ICRG review; build the AML programme to standards above the current Vanuatu floor to insulate from any future grey-list risk.
How Vanuatu Compares
Vanuatu sits in the Emerging Offshore peer cluster alongside Marshall Islands, Comoros (Anjouan) and Saint Lucia. Of the four, Vanuatu has the most substantive regulatory framework and the highest cost base. For operators wanting a higher-credibility Asia-Pacific licence, Labuan is the cross-tier reference.
The Emerging Offshore cluster groups lower-barrier offshore propositions, but not every column is a recognised licensing route. Marshall Islands offers DAO LLC and IBC structuring with no active VASP licensing regime, so third-party custody and exchange are not legally operable there. Comoros (Anjouan) has no recognised VASP permission: the Banque Centrale des Comores says the private Anjouan Offshore Finance Authority has no legal authorisation.
Saint Lucia licenses virtual asset business under the VABA 2022 through the FSRA. It undercuts Vanuatu on cost and timeline but does not match Vanuatu’s regulatory depth (five licence classes, a full operational rulebook, capital-adequacy guidelines, and quarterly supervision). Marshall Islands and Comoros are structural comparators, not lower-cost substitutes for a recognised VASP permission.
| Factor | Vanuatu | Marshall Islands | Comoros (Anjouan) | Saint Lucia |
|---|---|---|---|---|
| Licence Type | VASP licence (5 classes) + ITO, VASP Act 2025 | DAO LLC / IBC; no active VASP licence | No recognised VASP permission; private AOFA crypto certificate | Virtual Asset Business Licence (VABA 2022) |
| Regulator | VFSC | RMI Registrar / Banking Commissioner | BCC: AOFA has no legal authorisation | FSRA |
| Third-Party Custody & Exchange | Licensed (Classes D–D.4) | Not legally operable; dormant VASP definition | Not authorised by a recognised regulator | Licensed (VABA s.2) |
| Timeline | About 8–13 months (11–19 with FDL classes first) | No VASP authorisation timeline; DAO LLC charter in about 30 days | No regulator timeline; private document processing only | About 5–8 months |
| Min. Capital | VT 200,000,000 base floor (~USD 1.7M) | No fixed minimum | No regulatory floor; private agent terms only | No statutory floor; FSRA expects EC$300k–1.3m by activity; 15% escrow |
| Year 1 fees (scope shown per cell) | USD 150,000 (build quoted per case) | USD 9,500 commercial MIDAO package, including administrator services and government fees; government share not separately disclosed (build USD 6k–15k quoted per case) | None; private build USD 19k–49.5k quoted per case | About USD 6.4k–6.7k |
| Corporate Tax | 0% | DAO tax treatment from 1 October 2026 requires confirmation; no blanket 0% or 3% rate | 35% on taxable Comoros-source profits; 1.5% turnover minimum (3% if accounts are kept at a foreign head office) | 30% Saint Lucia-source; foreign-source exempt |
| Local Presence | Office + 3 key persons resident 12 months from appointment | Registered agent only | No recognised regulator requirement; private agent asks for a registered agent | Office + place of business; resident principal representative if registered abroad |
| Supervision & Reporting | Quarterly VFSC reports + annual financial and DLT audits | Annual report to MIDAO | No recognised VASP supervision | Audited financials + quarterly reports (s.12(5)); no licence issued yet |
| Banking Access | Difficult; local accounts + offshore EMI/PSP rails | Difficult; domestic banking unavailable, bank offshore | Difficult; payment-agent workaround standard | Difficult; multi-provider stack required |
| EU Passporting | No | No | No | No |
| FATF Status | Clear (since 2018) | Clear; APG MER Nov 2024 | Clear; GIABA MER 2024 medium-high ML risk | Clear (CFATF C/LC 35/40) |
| Best For | Capitalised Asia-Pacific operators with institutional clients wanting a statute-based offshore VASP licence | DAO governance wrappers and token issuers, not third-party VASP services | IBC or corporate-wrapper use only; not evidence of regulated VASP status | Operators wanting a written Caribbean VASP rulebook below the premium cost band |
Compare every crypto jurisdiction side by side →
Cross-tier reference: Labuan (Malaysia). For operators evaluating Vanuatu but with the capital and timeline tolerance for a more institutionally-credible Asia-Pacific licence, Labuan offers a higher-substance, more banking-friendly alternative under the Labuan Financial Services and Securities Act framework: see the full Labuan licensing guide →.
When Vanuatu Is the Right Choice
Choose Vanuatu if:
- Your target customer base is Asia-Pacific or Pacific institutional, not EU retail
- You have capital readiness of about USD 2.4m to 2.8m on our planning estimate (the VT 200,000,000 base capital floor, Year-1 fees, and the Year-1 build; a class risk add-on and the overheads bond come on top)
- The FATF-clear status and modern five-class framework matter for institutional counterparty onboarding
- You can place a manager, a director, and a chief technology officer on-island for 12 consecutive months from their appointment
Consider alternatives if:
- Your customer base is materially EU-exposed (consider Estonia or Cyprus for MiCA CASP)
- You want lower-cost offshore licensing with a recognised rulebook (consider Saint Lucia)
- You want a higher-credibility Asia-Pacific jurisdiction with easier banking (consider Labuan or Hong Kong)
- You need a faster path to market under 6 months (consider El Salvador; the Marshall Islands forms a DAO LLC in about 30 days but issues no VASP licence)
Not sure which column is you? Ask Emma. She compares these jurisdictions in seconds, in your language.
Common Mistakes in Vanuatu Applications
The Application Guidelines and the January 2026 Revised Requirements set the documentary bar for Vanuatu applications. The five failure modes below follow from those documents and from the sequencing and fee rules set out above.[6][7]
- Underestimating the evidentiary burden of the residency undertaking. The 12-month consecutive residency requirement for the Manager, Director, and CTO is documentary, not aspirational, with the evidentiary burden set out under Requirements above. The obligation runs prospectively from appointment and the Application Guidelines accept a written undertaking, so the correct approach is to identify the three named individuals early and evidence the undertaking to the standard set out in the Application Guidelines, not to treat the year as a waiting period that can be left unevidenced.
- Leaving the FDL sequence unconfirmed. As set out under Process above, the FDL Act requires a Class D licence to deal in digital assets and issues it only to holders of Classes A, B, and C, and an industry association describes an FDL-first route, while the VASP Act and the VFSC application documents do not state one. The correct approach is to confirm with the VFSC at scoping whether the proposed activities need the FDL classes first, and to plan on the 11 to 19 month path until it answers.
- Budgeting against legacy or third-party fee figures. As set out under Costs above, Order No. 9 of 2026 is the binding fee schedule, in US dollars, superseding the vatu schedule in the VFSC’s June 2025 Guidelines. Operators planning against older figures budget against numbers that no longer apply. Validate every fee figure against Order No. 9 of 2026 and the January 2026 Revised Requirements.
- Drafting AML and cybersecurity policies to minimum compliance rather than to publication standard. The January 2026 Revised Requirements call for AML/CTF/PF programme documentation covering the risk assessment, CDD and EDD, transaction monitoring, the Travel Rule approach and sanctions screening, and the VFSC may request additional information or decline an application where requirements are not satisfactorily met.[7] A generic manual invites that request, and every round adds time to the review. The correct approach is to draft to a standard that survives a regulatory inspection, not a desk review.
- Ignoring the EU AML high-risk listing in the business case. As set out under Banking and International Standing above, operators who model Vanuatu around the FATF-clear status without modelling the EU AML and Annex I listings consistently overestimate banking access and EU customer revenue potential. The correct approach is to model the banking architecture and the EU counter-measure impact before committing licensing capital, not after.
Frequently Asked Questions
Yes. A Vanuatu VASP applicant must be a Vanuatu-incorporated company (under either the Companies Act No. 25 of 2012 or the International Companies Act [CAP 222]). The domestic company form fits because the licensee must maintain a physical office and on-island staff. Whether the applicant must also hold the Financial Dealers Licence classes (A/B/C/D) before the VASP licence is issued is confirmed with the VFSC: the FDL Act requires a Class D licence to deal in digital assets, and an industry association describes an FDL-first route, but the VASP Act and the VFSC application documents do not state one.
Company formation typically takes 2 to 5 business days; the VASP licensing, and any FDL step, sit on top of that. Forming the entity is Stage 1 of the five-stage process.
Non-resident ownership is permitted. Non-resident directors are permitted except for the three named on-island roles: Manager, Director, and Chief Technology Officer, each of whom must reside in Vanuatu for 12 consecutive months. The obligation is prospective, not a pre-filing gate: sections 5(5)(a) and 7(5)(a) of the Act require that the person 'will, after he or she is appointed, reside in Vanuatu' for that period, and the VFSC Application Guidelines expressly provide for a written undertaking where the key persons do not all yet meet the residence requirement.
Residence is evidenced by telephone bills, bank statements and lease documents. UBOs (whether resident or not) undergo fit-and-proper assessment under the Act, including criminal record screening, sanctions screening, and source-of-funds documentation. The VFSC’s beneficial-ownership register is government-access only, not public.
About 8 to 13 months end-to-end: 1 to 2 months to form the company and engage the CTSP, 3 to 6 months to prepare the application package with the substance build alongside, and a VFSC decision due within 90 working days of receipt, about 4 to 5 months. Where the VFSC requires the Financial Dealers Licence classes first, their 3 to 6 months come before the package, for 11 to 19 months in all. The 90 working days run from receipt of the application, not from receipt of a complete one. The 12-month residency obligation on the three key persons runs from appointment and can be undertaken rather than completed before filing, so it is a commitment to plan around rather than a gate to wait out.
The law does not settle it, so confirm the sequence with the VFSC at scoping. The FDL Act requires a Class D licence to deal in digital assets and issues it only to holders of Classes A, B, and C, and the Financial Markets Association of Vanuatu, an industry association, stated in May 2025 that VASP licences will be issued only to holders of all four classes; the VASP Act and the VFSC application documents do not state that condition. Until the VFSC confirms the sequence for the proposed activities, plan on forming the company, then the FDL classes (typically 3 to 6 months), then the VASP package (3 to 6 months) and the decision window of 90 working days, 11 to 19 months in all.
Two numbers, and they are different kinds of number. The statutory cost is fixed and published: USD 50,000 application plus USD 100,000 licence, so USD 150,000 for one class in Year 1, under the Virtual Asset Service Providers Order No. 9 of 2026 gazetted on . The typical build, what it takes to satisfy the licence conditions, runs about USD 515,000 to 910,000 in Year 1: the Port Vila office, the resident manager, director, and chief technology officer, the policy suites, the technology audit, insurance, the statutory audit, and the CTSP through whom every application must be filed.
The VT 200,000,000 capital floor, about USD 1.7m, sits outside both, because it is held rather than spent, and the VFSC’s capital-adequacy guidance adds a risk component on top of it. From Year 2 the statutory charge is the USD 100,000 annual fee per class.
Because they use the vatu schedule in the June 2025 Application Guidelines, VT 20,000,000 application and VT 100,000,000 licence, the minima in the original section 66(2), since removed by Act 44 of 2025.[37] The VFSC has published a Public Notice, signed by the Commissioner, confirming that the fees prescribed by the VASP Act No. 3 of 2025 were gazetted on under the Virtual Asset Service Providers Order No. 9 of 2026.
The dollar schedule applies across all five classes. The VFSC consolidated Act, 2026 edition, confirms that Act 44 of 2025 amended section 66(2) and removed the former fee minima; the amendment is no longer merely a bill.[37] Two things follow: the Class D.4 banking discount is gone, and the annual renewal now equals the initial licence fee rather than half of it.
No. Vanuatu was removed from the FATF grey list on and remains off both the grey and black lists after the June 2026 Plenary. The next APG Mutual Evaluation onsite is scheduled for November 2026, with the outcome shaping Vanuatu’s FATF risk picture for the following cycle.
Two separate listings are more decision-relevant for operators: the EU AML high-risk third-country list (continuous since 2016) and the EU Annex I non-cooperative tax jurisdictions list (retained February 2026). Neither is a FATF listing.
Difficult, particularly for EU correspondent access. The combination of the EU AML high-risk listing, EU Annex I tax listing, and the broader de-risking of Pacific correspondent banking (60% drop since 2011 per the World Bank) means Tier-1 European and US correspondent banks do not, as a rule, onboard Vanuatu VASPs directly.
Realistic banking architecture combines local Vanuatu operating accounts with specialist crypto-aware EMIs and payment institutions in mid-tier jurisdictions outside the EU enhanced-due-diligence perimeter. Banking should be sourced before licensing investment is committed.
A Vanuatu licence does not grant EU market access or passporting rights. MiCA contains no third-country equivalence regime. MiCA Article 61 permits third-country firms to serve EU clients only when the client initiates contact entirely on their own initiative; ESMA’s February 2025 guidelines list signs that a firm is likely to be regarded as soliciting, such as EU-targeted marketing, geo-targeted advertising, or EU-based influencers, judged on all the facts; a firm that solicits EU clients cannot rely on the exemption.
Further marketing of the same type is confined to the context of the original transaction. Operators seeking systematic EU market access should obtain a separate CASP authorisation in an EU Member State.
Quarterly reports to the VFSC Commissioner under section 54 of the VASP Act; annual audited financial statements under section 63; an annual technology and DLT audit by an external auditor under Guidelines section 7.7; annual filing of the Group-Wide Procedure Manual to the VFIU by 31 March; Travel Rule transmissions for cross-border transfers of USD/EUR 1,000 or more; STRs, CTRs, and IFTIs to the VFIU as triggered; notice to the Commissioner within 14 days of a change in key persons or in the source of funds for the capital under section 21; and prior approval of any transfer of shares or change of key persons under section 26. Late filing carries a penalty of VT 100,000 per day per report.
No. The Virtual Asset Service Providers Act 2025 expressly excludes securities, so a token that is a security falls under conventional securities law, not the VASP licence, and there is no dedicated tokenisation framework. Where the vehicle is a fund, route via fund licensing.
Considering Vanuatu for Your Crypto Licensing?
Jagelski & Partners scopes Vanuatu opportunities against the wider offshore landscape, records the sequence of the FDL and VASP applications, and pre-qualifies banking before licensing capital is committed.
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References
Show all references
- Republic of Vanuatu, Virtual Assets Services Providers Act No. 3 of 2025, vfsc.vu, accessed .
- Financial Markets Association of Vanuatu (industry association), Vanuatu’s VASP Act is pioneering digital finance regulation, (describes the VASP Act as an extension of the FDL framework and states that VASP licences will be issued only to holders of FDL Classes A to D), fma.vu, accessed .
- Vanuatu Foreign Investment Promotion Agency, Low tax jurisdiction, investvanuatu.vu, accessed .
- Vanuatu Financial Services Commission, Home / About VFSC, vfsc.vu, accessed .
- Vanuatu Financial Intelligence Unit, AML and CTF Acts, fiu.gov.vu, accessed .
- Vanuatu Financial Services Commission, VASP Application Guidelines (June 2025), vfsc.vu, accessed .
- Vanuatu Financial Services Commission, Requirements for Licence Application as a Virtual Asset Service Provider (VASP), Revised January 2026, vfsc.vu, accessed .
- Republic of Vanuatu Parliament, Bill for the Virtual Assets Services Providers Act No. of 2024 (draft), parliament.gov.vu, accessed .
- Office of the Prime Minister of Vanuatu, Vanuatu Takes Bold Step Towards Protecting Financial System and Restoring Global Reputation, pmo.gov.vu, accessed .
- OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, Global Forum releases new peer reviews on transparency and exchange of information on request for tax purposes for Belize, Cambodia, El Salvador, Gabon, Guinea, Montserrat, Niue, and Vanuatu, oecd.org, accessed .
- Asia/Pacific Group on Money Laundering, APG Strategic Mutual Evaluation preparation visit to Vanuatu, apgml.org, accessed .
- Financial Centre Association of Vanuatu, Clarifying the new rules on digital assets and cryptocurrencies, VFSC Release, fca.vu, accessed .
- Council of the European Union, Taxation: Council updates the EU list of non-cooperative jurisdictions for tax purposes, consilium.europa.eu, accessed .
- European Commission, Anti-money laundering and countering the financing of terrorism at international level, finance.ec.europa.eu, accessed .
- World Bank, Safeguarding Financial Lifelines in the Pacific, worldbank.org, accessed .
- Financial Centre Association of Vanuatu, Vanuatu’s removal from the FATF Grey List: a concerted country team effort, fca.vu, accessed .
- European Securities and Markets Authority, Guidelines on reverse solicitation under MiCA (ESMA35-1872330276-2030), , esma.europa.eu, accessed .
- Financial Centre Association of Vanuatu, Vanuatu Passes Virtual Asset Service Providers (VASP) Act, fca.vu, accessed .
- Vanuatu Financial Intelligence Unit, About the FIU, fiu.gov.vu, accessed .
- Council of the European Union, Vanuatu: Council ends visa exemption, consilium.europa.eu, accessed .
- Financial Markets Association of Vanuatu, Recap of the 2nd VFSC Symposium on Virtual Assets and Financial Dealers, fma.vu, accessed .
- Financial Centre Association of Vanuatu, Vanuatu Prepares for Global Assessment of its Anti-Money Laundering Measures in 2026, fca.vu, accessed .
- Vanuatu Financial Services Commission, Public Notice: Virtual Asset Service Providers Act No. 3 of 2025, fees gazetted 16 January 2026 under the Virtual Asset Service Providers Order No. 9 of 2026. Application USD 50,000 and licence USD 100,000 for classes D, D.1, D.2, D.3 (ITO) and D.4; annual fee USD 100,000 per class; director, manager, and chief technology officer VT 200,000 each on a change or replacement only; all fees payable in USD except key-person changes, vfsc.vu, accessed . The notice carries an internal date of 19 May 2025 that is an evident template carry-over, since it describes a January 2026 gazettal.
- Vanuatu Financial Services Commission, VASP Capital Adequacy Guidelines (6 January 2026), issued under s.59: required capital is the greater of a VT 200,000,000 base floor and 25% of fixed annual overheads, plus a risk add-on by class, with a separate bond deposited with the Commission that does not count as eligible capital, vfsc.vu, accessed .
- Financial Action Task Force, Jurisdictions under Increased Monitoring, 19 June 2026 (Vanuatu not listed; nor on the call-for-action list of the same date), fatf-gafi.org, accessed .
- Asia/Pacific Group on Money Laundering, APG Global Fifth Round Mutual Evaluation Schedule (Vanuatu: 2027 Plenary; technical-compliance submission due 31 March 2026), apgml.org, accessed .
- OECD Global Forum on Transparency and Exchange of Information for Tax Purposes, Vanuatu 2026 (Second Round, Supplementary Report), adopted (no tax on corporate or individual income; CRS exchanged on a non-reciprocal basis; mutual evaluation scheduled for November 2026), oecd.org, accessed .
- Department of Customs and Inland Revenue, Rent Tax (Rent Tax Act [CAP 196]: 12.5% on gross rental income, generally long-term residential rent; commercial rent subject to VAT), vanuatucustoms.gov.vu, accessed .
- Vanuatu Financial Services Commission, Virtual Asset Service Providers and Initial Token Offering Risk Assessment, , para. 26.1 (no licensed VASP domiciled in Vanuatu when the report was made), vfsc.vu, accessed .
- Republic of Vanuatu, Financial Dealers Licensing Act [CAP 70], Consolidated Edition 2026 (s.2(1): Classes A to D; s.4(5): Class D only for holders of Classes A, B, and C; s.5(1): VT 5,000,000 deposit), Vanuatu Financial Services Commission, vfsc.vu, accessed .
- Parliament of the Republic of Vanuatu, Bill for the Stablecoins Act No. of 2025 (Second Ordinary Session 2025; Part 1A: Stablecoin Supervisory Commission chaired by the Reserve Bank Governor, VFSC Commissioner deputy chair), parliament.gov.vu, accessed .
- Parliament of the Republic of Vanuatu, Bill for the Virtual Assets Services Providers (Amendment) Act No. of 2025 (Second Ordinary Session 2025: deletes the section 66(2) fee minima), parliament.gov.vu, accessed .
- Vanuatu Financial Services Commission, Virtual Asset Service Provider (list of guidelines and forms, including the January 2026 revised set and the August 2026 cybersecurity requirements), vfsc.vu, accessed .
- Vanuatu Financial Services Commission, Virtual Asset Services Providers (VASP) Act No. 3 of 2025: presentation to industry, , slide 15 (capital may be held externally at a recognised financial institution and certified by an external auditor), vfsc.vu, accessed .
- Finance Magnates, Compliance specialist at Exness becomes Vanuatu’s stablecoin commissioner, (news report of the July 2026 appointment of a Commissioner of Stablecoins under the Stablecoins Act), financemagnates.com, accessed .
- OECD, Signatories of the CRS Multilateral Competent Authority Agreement (status 13 March 2025: Vanuatu signed 22 June 2018), oecd.org, accessed .
- Vanuatu Financial Services Commission, Virtual Assets Services Providers Act No. 3 of 2025, Consolidated Edition 2026, section 66(2) and Table of Amendments (Act 44 of 2025 removed the former fee minima), vfsc.vu, accessed .
- Parliament of Vanuatu, Bills, Second Ordinary Session 2025, entries 10 and 13 marked Passed (VASP Amendment and Stablecoins Bills; passage alone does not establish commencement), parliament.gov.vu, accessed .