Licensing guide

Three licence tracks.
Every jurisdiction.

A practical guide to crypto VASP, forex and payment/EMI licensing — covering jurisdiction options, timelines, capital requirements and key considerations for each route.

Crypto / VASP
Forex / FX
Payment / EMI

Crypto & VASP
Licensing

Virtual Asset Service Provider licences cover exchanges, wallets, custodians, crypto brokers and payment processors. The regulatory landscape has matured significantly — MiCA now provides an EU-wide framework, while jurisdictions like Dubai VARA, Hong Kong and Lithuania offer credible regulated routes for crypto businesses of all sizes.

20+
Jurisdictions we operate in for crypto licensing
2–9
Months typical timeline from engagement to licence
MiCA
EU-wide framework covering all 27 member states from 2024
Europe — regulated jurisdictions
EU and EEA options offering the strongest market access and banking relationships.
Jurisdiction
Timeline
Complexity
Capital req.
Key advantage
MiCA / CASP (EU-wide)
Any EU competent authority
4–8 months
Very high
Varies
Passportable — all 27 EU states
Lithuania
Bank of Lithuania
2–3 months
Medium
Minimal
Fastest EU route, CASP transitional
Czech Republic
Trade Register
2 months
Low
None
Simple registration, EU base
Poland
GIIF
4–6 weeks
Low
None
VASP registration, fast approval
Estonia
FIU Estonia
8 weeks
High
€100k+
Strong EU reputation
UK
FCA
2–4 weeks
Medium
None
FCA VASP registration
Middle East & Asia
Leading regulated hubs for crypto businesses targeting global markets.
Jurisdiction
Timeline
Complexity
Capital req.
Key advantage
Dubai (VARA)
VARA
6–12 months
Very high
$50k–$1M+
Leading MENA crypto hub
Hong Kong (VASP)
SFC
5 weeks
High
HK$5M+
Asia's top regulated exchange venue
Georgia
NBG
8–12 weeks
Medium
Minimal
Cost-effective, EU-adjacent
Offshore & Americas
Lower-cost options — note that offshore registrations are not true licences and carry banking limitations.
Jurisdiction
Timeline
Complexity
Capital req.
Key advantage
Seychelles (FSA)
FSA
5+ months
Medium
Minimal
Mid-tier offshore, banking access
BVI
FSC
4+ months
High
$100k+
VASP Act 2022 — credible offshore
Canada (FINTRAC)
FINTRAC
1–6 weeks
Medium
None
MSB registration, North America access
El Salvador
BCR
12 weeks
Medium
$50k
Bitcoin-friendly, BCR regulated
MiCA is now the gold standard for EU operations
The EU's Markets in Crypto-Assets regulation (MiCA) came into full effect in 2024. A CASP licence under MiCA is passportable across all 27 EU member states — one application, one regulator, entire European market access.
Offshore registrations ≠ regulated licences
SVG, Panama and Costa Rica registrations are not true VASP licences — there is no regulatory oversight. Banking access is severely limited and they are not accepted by most institutional counterparties.
UBO disclosure is mandatory everywhere serious
All reputable jurisdictions require full beneficial owner disclosure, AML/KYC framework approval and appointment of a qualified AML Officer. These cannot be avoided on credible licence routes.
Post-licensing obligations are ongoing
Every crypto licence carries ongoing requirements — transaction monitoring, suspicious activity reporting, annual compliance reports and licence renewal fees. Bruno Consulting can manage these on a retainer basis.

Forex & FX
Licensing

Forex broker authorisation ranges from full MiFID II compliance for EU market access to faster offshore options for global operations. The right choice depends on your target market, capital position and operational timeline — EU licences offer the strongest credibility but require the most preparation.

3–12
Months typical timeline for forex licence approval
€125k
Minimum capital for CySEC Category 2 (most common EU route)
MiFID II
The EU standard — passportable across all EEA member states
Regulated EU & equivalent
Full regulatory substance — best for client trust, institutional access and long-term operations.
Jurisdiction
Timeline
Complexity
Min. capital
Key feature
Cyprus (CySEC)
CySEC — MiFID II
6–12 months
Very high
€125k–€730k
Most popular EU forex licence
UK (FCA)
FCA
12–18 months
Very high
£730k+
Gold standard — highest credibility
Malta (MFSA)
MFSA — MiFID II
8–14 months
Very high
€125k–€730k
EU passport rights, English-speaking
Georgia (NBG)
NBG
3–6 months
Medium
Low
Cost-effective, EU-adjacent
Offshore & mid-tier
Faster approval and lower capital — suitable for global retail operations where EU access is not the priority.
Jurisdiction
Timeline
Complexity
Min. capital
Key feature
Vanuatu (VFSC)
VFSC
4–8 weeks
Low
$50k
Fastest offshore, popular globally
Seychelles (FSA)
FSA
6–10 weeks
Low
$50k
Good banking access
Mauritius (FSC)
FSC
3–5 months
Medium
$250k
Investment Dealer — credible mid-tier
Labuan (Malaysia)
Labuan FSA
3–5 months
Medium
$300k
Asia access, credible substance
Segregated client funds are non-negotiable
All reputable forex jurisdictions require segregated client accounts. This is not optional — failure to implement proper fund segregation is the most common reason for licence suspension.
MiFID II requires qualified management
EU licences (CySEC, MFSA, FCA) require a qualified Compliance Officer, Risk Manager and CEO with demonstrable financial services experience. CVs are scrutinised thoroughly.
Offshore ≠ unregulated — substance matters
Vanuatu and Seychelles are legitimate regulated jurisdictions but carry less institutional credibility. Counterparties, PSPs and liquidity providers may require EU-regulated entities.
MT4/MT5 infrastructure must be ready
Most regulators require evidence of IT infrastructure before granting a licence. MT4/MT5 licensing, server setup and client portal readiness should be prepared in parallel with the application.

Payment & EMI
Licensing

PSD2 authorisation covers payment processors, e-wallet operators, remittance businesses, acquiring services and Banking-as-a-Service providers. An EU EMI licence — particularly Lithuanian — is passportable across all 27 EEA states, making it the most strategically valuable licence Bruno Consulting can help you obtain.

27
EEA states accessible from a single Lithuanian EMI licence via passporting
€20k
Minimum capital for a Payment Institution (PI) licence
EMI
Allows issuing IBANs and e-money — PI is more limited (processing only)
EU — PSD2 regulated
All EU licences are passportable across the EEA. Lithuania is the most popular entry point due to speed and approval rate.
Jurisdiction
Timeline
Complexity
Min. capital
Key feature
Lithuania
Bank of Lithuania
3–6 months
High
€20k–€350k
Fastest EU EMI — highest approval rate
Latvia (FCMC)
FCMC
6–10 months
High
€20k–€350k
Strong EU option, credible regulator
Malta (MFSA)
MFSA
6–12 months
High
€20k–€350k
English-speaking, EU passport
Poland (KNF)
KNF
4–8 months
High
€20k–€350k
Large EU market, growing fintech hub
Ireland (CBI)
Central Bank of Ireland
12–18 months
Very high
€20k–€350k
Premium EU licence — most selective
UK (FCA)
FCA
12–18 months
Very high
£20k–£350k
Post-Brexit — UK-only, not EEA
Asia & other jurisdictions
Jurisdiction
Timeline
Complexity
Min. capital
Key feature
Georgia (NBG)
NBG
3–6 months
Medium
Low
Payment Service Provider licence
Hong Kong (HKMA)
HKMA
12+ months
Very high
HK$25M
Stored Value Facility licence
Singapore (MAS)
MAS
12+ months
Very high
S$250k+
Major / Standard Payment Institution
EMI vs PI — which do you need?
A Payment Institution can process payments and facilitate transfers. An EMI licence additionally allows issuing electronic money — meaning you can issue IBANs and hold client funds as e-money. If you want to offer wallets or virtual IBANs, you need an EMI.
Safeguarding is mandatory and critical
All EU payment licences require client funds to be safeguarded — either in a dedicated bank account or covered by an insurance policy. Setting up the safeguarding account with a bank is often harder than getting the licence itself.
DORA applies from January 2025
The Digital Operational Resilience Act (DORA) applies to all EU-regulated payment institutions. This introduces new requirements for IT risk management, incident reporting and third-party service provider oversight.
Lithuania is the fastest EU route — for now
The Bank of Lithuania has the highest approval rate and fastest processing time of any EU regulator. However, scrutiny has increased — applications require genuine substance, qualified MLRO and a credible programme of operations.
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