Where to get a crypto license - a comparison of jurisdictions

• Jurisdiction is determined not by the license price, but by the geography of your clients and the route of payment. First, it's determined who pays and through which payment system, and only then is a regulator selected.
• The MiCA transition period ended on July 1, 2026. It is now illegal to serve EU clients without CASP authorization, whether from an offshore or third-country jurisdiction.
• Hong Kong and Kazakhstan provide recognition and access to institutional counterparties, but require a physical office, staff, and capital of $200,000 or more.
• Canadian MSB registration is cheap to obtain and expensive to maintain: in 2026, FINTRAC will deregister crypto companies with weak AML programs en masse.
• El Salvador, Costa Rica, and Anjouan address the issue of speed of launch, not reputation. Their value is only realized when paired with a functioning banking or payment solution.
• Starting September 1, 2026, Russian residents must verify their foreign structure with the new law on digital currencies; otherwise, a legitimate foreign license will not resolve domestic issues.

The short answer is this: if your clients include EU residents, you have no choice but to obtain CASP authorization under MiCA; if you work with Asian institutional money, consider Hong Kong; if your audience includes Russian-speaking users, the CIS, and cross-border transactions, a working network is usually built around Kazakhstan or Canada; while El Salvador, Costa Rica, and Anjouan make sense as a quick start or as an additional element of the structure, but not as its foundation. Everything else in this article is details that either get projects off the ground in three months or stall for a year.

What's changed on the crypto license map over the past year

Previously, the choice was based on the principle of "cheapest and fastest." This is no longer the case: almost all significant jurisdictions have either tightened requirements or introduced them for the first time. Regulators have stopped treating crypto businesses as exotic and have begun applying familiar banking tools to them—on-site inspections, permit revocations, and fines.

Europe has closed its transition period

The transitional regime under Article 143 of MiCA expired on July 1, 2026, and all national permits previously in effect have ceased. Any company providing crypto services to EU clients without authorization is in violation of the regulation, regardless of its registered address. There are no plans for an extension, and this is a significant point: previously, the market lived in anticipation of deferrals; now there is nothing to be expected. At the same time, the European Commission opened a consultation on whether MiCA in its current form is adequate for its objectives: stablecoins, DeFi, offshore providers, and tokenization are being discussed. This means the rules will continue to change, and it's not worth assuming that the financial model will remain stable for five years.

Asia and the CIS are building their own regimes

Hong Kong has gone from isolated permits to a fully-fledged regulatory architecture in two years. The Hong Kong Monetary Authority issued its first stablecoin issuer licenses in April 2026, to HSBC and Anchorpoint Financial. Kazakhstan has taken its own path: it now has two parallel regimes, as discussed below.
The overall trend is clear. Jurisdictions that want to retain serious businesses are raising capital and presence requirements. Jurisdictions that trade speed remain in their niche, and banks treat them accordingly.

Offshore licenses are no longer neutral

Previously, a license from a small island regulator was perceived as a minimal proof of good faith. Now, payment providers and correspondent banks have their own lists, and the mere presence of such a document doesn't reveal anything. It's no longer a plus, but it's not a minus either—it's just that the weight of this argument has dropped to almost nothing.

The European Union under MiCA: Single Passport and Entry Fee

A CASP license is the only way to legally operate in European retail. Its value lies in its passporting: by obtaining permission in one country, you can serve the entire EU without separate approvals. This is both convenient and expensive.

What the regulator requires in practice

The minimum capital depends on the range of services: €50,000 for advisory and agency models, €125,000–€150,000 for trading platforms and custodial services. A virtual office is not accepted: a physical presence, actual on-site decision-making, and at least one EU-resident director are required. Executive directors must demonstrate expertise in cryptoassets and financial risk management, and beneficial owners with a stake exceeding 25 percent must disclose their ownership, along with proof of capital origin.
Practices vary significantly across countries. Lithuania, Poland, and the Czech Republic traditionally receive more applications from entrepreneurs from the CIS, Malta works with large platforms, and Croatia and Slovakia offer more flexible review times. We select the application country based on the ownership structure and the company's actual activities, not on a fancy presentation pitch. Detailed conditions for each option are summarized in the crypto licenses section, including Lithuania, Poland, the Czech Republic, and Malta.

Who is the EU suitable for?

It's suitable for projects with a European audience, plans for banking partnerships within the EU, and a willingness to maintain staff and undergo regular audits. It's not suitable for those expecting a budget of up to €100,000 for the entire launch and wanting to rely on a director on paper.
A separate category is for companies that need a license urgently. For them, a viable option is to acquire an existing company with an existing license, followed by a change of control by notifying the regulator. This procedure also has a timeframe, but it's significantly shorter than applying from scratch.

Hong Kong: An Expensive Gateway to Institutional Funds

Hong Kong isn't chosen for its low cost. It's chosen because it requires a status recognized by Asian banks, funds, and exchanges. Consequently, its requirements are at the same level as those of banks.

How Trading Platform Licensing Works

The primary instrument is a VATP license from the Securities and Futures Commission. The financial threshold is HK$5 million in paid-up share capital, HK$3 million in liquid capital, and a liquidity reserve sufficient to cover twelve months of operating expenses. Few permits have been issued: as of the end of 2025, the regulator had issued eleven such licenses.
The actual launch budget significantly exceeds the formal capital. The technological development, custodial solution, insurance, and compliance staff add up to costs incomparable to offshore scenarios. This isn't "obtaining a license"; it's building a financial infrastructure.

The scope of oversight is expanding

Separate regimes are being developed for virtual asset dealing, custody, consulting, and management, with a bill being submitted to the Legislative Council in 2026. No transitional waivers are envisaged; a fixed effective date remains in effect, but an accelerated procedure is available for already licensed entities. For custodians, the paid-in capital requirement is raised to HK$10 million.
Those considering Hong Kong would be wise to begin by registering an operating company and establishing a local presence early—we will discuss the requirements for Hong Kong companies and for Hong Kong crypto licenses separately.

Who would benefit from paying this price

Institutional brokers, custodians, and issuers of tokenized assets with Asian investors. For a retail exchange with a turnover of several million dollars per year, such a structure is not economically viable.

Kazakhstan: Two Different Regimes in One Country

Over the past year, Kazakhstan has become the most undervalued jurisdiction for Russian-language projects. The reason is simple: it offers clear, English-language laws, while also sharing the same time zone and language as the majority of our clients.

Astana International Financial Center

The AIFC has its own common-law legal system and its own regulator, the AFSA. A digital asset trading platform operator license requires a minimum capital of $200,000 or twelve months' worth of operating expenses, whichever is greater. Regulated digital asset activities require an additional application fee of $2,800, and liquid assets must consistently account for at least 25 percent of annual operating expenses. AFSA requires at least one Kazakhstan-resident employee, working from an office within the center.
The market there is not a sham. The volume of digital asset transactions within the AIFC in the first quarter of 2025 alone reached $1.7 billion, and licenses were issued to major international platforms.

National Regime Outside the Center

An important change has been made here. Effective May 1, 2026, licenses for unsecured digital asset exchange operators and registration of trading platform operators will be issued by the National Bank of the Republic of Kazakhstan. Oversight is divided: the National Bank is responsible for digital asset turnover outside the AIFC, the Financial Market Regulation Agency is responsible for digital financial assets, and the AIFC retains its own legal regime.
Practical conclusion: before submitting, you need to clearly decide whether you are operating within the center or outside it. These are two different sets of documents, two regulators, and two different project economies. We make this choice at the model analysis stage, before any payments are made. Details on crypto licenses in Kazakhstan and company registration are available on the relevant pages.

Why is this interesting for entrepreneurs from Russia and the CIS?

The absence of a language barrier, physical accessibility for in-person visits, the use of English common law in disputes, and a growing pool of local banks that have already learned to work with licensed market participants. At the same time, Kazakhstan is not an offshore zone in the traditional sense and is not perceived as such by counterparties.

Expert Opinion
"Over the past two years, we have handled approximately forty projects on cryptocurrency licensing. The pattern is consistent: approximately seven out of ten inquiries begin with the question "how much does a license cost in such-and-such a country?" and in about half of the cases, after analyzing the model, the client switches to a different jurisdiction than originally planned.
The reason is almost always the same. A license is not a document, but rather access to a specific payment system. If the bank or payment provider through which you plan to accept fiat does not work in your jurisdiction, the permit becomes an expensive frame on the wall. Therefore, we start not with the regulator, but with the question "through whom will the money flow?" and only then select the country that opens this route.
The second observation concerns timelines. The two to three months stated by the regulator almost never match reality, because the clock stops at every request for additional documents. Projects with a business plan and AML policy tailored to a specific model, rather than downloaded from a template, are reviewed approximately twice as quickly".

 

El Salvador: An Inexpensive Entry to the Latin American Circuit

El Salvador has ceased to be a story about a political experiment with Bitcoin and has become a working jurisdiction with its own regulator of digital assets. For startups, this is one of the few options with a low barrier to entry and at the same time with real supervision.

Two registers instead of one

The regulator is the National Digital Assets Commission, the central bank is responsible for Bitcoin services, and the financial intelligence unit is responsible for combating money laundering. If the platform only works with Bitcoin, registering a BSP is sufficient; as soon as any other assets appear - stablecoins, altcoins, NFTs, tokenized rights - a DASP license is required. The law does not provide for a combined option, and multi-asset exchanges have to maintain both statuses simultaneously.
Essential requirements: local company, proven financial solvency, business plan, AML and KYC policies, cybersecurity, risk management, custodial procedures and at least two compliance officers, one of whom is a resident. The regulator has up to twenty working days to review the complete set; the total procedure period usually takes from three to six months.

Taxes and practical value

Qualified digital asset activities are subject to zero corporate tax, capital gains tax and VAT rates. The minimum capital is $2,000, and the state fee is about $5,475. There are already more than seventy providers on the registry, including Tether, which has moved its headquarters there.
It makes sense to consider El Salvador as the primary jurisdiction for projects with a Latin American audience and as a second license for more mature structures. We update the conditions for the license in El Salvador as changes in the practice of the commission.

Canada MSB: Registration, Not a License

The Canadian version is often referred to as a license, although formally it is registration with the financial intelligence unit. The difference is not terminological: it determines both the cost and the risks.

What are the benefits of MSB and FMSB status?

Registration requires no government fee, minimum capital, or formal staffing requirements—obligations are assessed based on the business's risk profile. Since 2020, foreign companies providing services to Canadian clients are required to register as FMSBs even without an office or personnel in the country. A travel rule for crypto transfers of over 1,000 Canadian dollars has been in effect since 2021, and reporting for large transactions starts at 10,000. A realistic timeframe from initial registration to active registration is eight to sixteen weeks, with most of this time spent preparing an AML program and opening a bank account, rather than on regulatory procedures.
The value of this status lies in the public registry. Being registered significantly simplifies discussions with banks, payment institutions, and acquiring providers, for whom Canadian registration has long been a basic compliance requirement.

Why Maintaining a Canadian Structure Has Become More Complicated

The Act, which received Royal Assent on March 26, 2026, raised the maximum fine for anti-money laundering violations from C$500,000 to C$20 million, and a separate act created a regulatory regime for stablecoins, with the Bank of Canada as the supervisory authority. In 2026, the regulator cancelled approximately 47 cryptocurrency-related registrations, 23 of which were a single, coordinated action.
The conclusion for business owners is simple. Entering Canada remains inexpensive, but maintaining a Canadian structure requires a real compliance function with a live officer, testing of procedures, and regular risk assessment updates. We maintain this section separately from registration, as it determines whether a structure will survive beyond a year. The conditions for a Canadian MSB and for registering a company in Canada are described on the profile pages.

Costa Rica and Anjouan: Quick Start Tools

These two jurisdictions share the same goal: launching operations quickly and without major investments. It's important to understand what you're getting, so you don't get surprised by bank rejections later.

Costa Rica: Registration Instead of Permits

The country doesn't require a separate crypto license, but virtual asset service providers are required to register with the financial supervisory authority SUGEF under Article 15bis of Law No. 7786. This registration confirms compliance with basic financial security requirements, but does not constitute a permit to operate. Residency of founders and directors is not required; a registered agent and legal address are required, and income from foreign clients is generally not taxed under the territorial system. Penalties for ignoring registration are quite significant: fines are imposed for operating without being included in the register, and improperly recording transactions over $10,000 carries a fine of 5 to 50 percent of the amount of undeclared transactions, plus penalties. We register companies for this model using the standard procedure; the terms for Costa Rica are available on the website.

Anjouan: Speed ​​vs. Recognition

Anjouan issues a genuine license with a wide range of permitted activities, and does so quickly and affordably. However, international recognition of the Anjouan crypto license is limited and contested in 2026, leading some business owners to switch to alternatives like Poland, Costa Rica, or Panama. The regulator is small, the procedures are quick, but the recognition profile is narrower than that of the Seychelles or the British Virgin Islands. Local companies do not pay corporate tax or VAT on financial services, but are required to pay an annual renewal fee. We tell our clients honestly: an Anjouan license works where counterparties don't impose quality oversight requirements. When paired with a proven payment solution, it allows for a launch within a few weeks, and then the project either outgrows it or remains in its niche.

Where such solutions fail

The point of failure is almost always the same: a bank account and fiat currency acceptance. Therefore, we assemble the "jurisdiction plus bank plus processing" package as a whole, not piecemeal; options for banks and processing, as well as ready-made companies with open accounts, are tailored to the specific turnover model.

How to choose: the methodology we use

There's a sequence of questions that saves months. It's designed so that money is spent at the very end, not at the beginning.

Start with the money, not the flag

Determine where the fiat is coming from and where it's going. If these are cards belonging to European users, the issue is resolved in favor of the EU. If these are transfers from legal entities in Asia and the Middle East, the situation is fundamentally different. If the project works exclusively with crypto without fiat input, jurisdiction requirements are significantly relaxed.
Next, check which banks and providers accept clients from the selected country today, not last year. This list changes faster than legislation.

Check your client's passport

MiCA is applied based on the location of the client, not the company. The Canadian regulator has the same logic regarding foreign providers. Practical implications: offshore registration does not exempt you from European or Canadian regulation if you actively attract users there. We always ask to see where the traffic is coming from and what the acquisition funnel looks like. Sometimes, after this conversation, the jurisdiction changes even before the documents are submitted.

Calculate the cost of ownership over three years

The one-time cost of obtaining a permit is a smaller portion of the budget. The main expenses are the compliance officer's salary, audit, office maintenance, renewal, policy updates, and mandatory reporting. In our experience, the cost of ownership over three years for a European license is three to four times the cost of obtaining it, and for Canadian registration, it's five or more times the cost.
We always provide this figure before we begin work, along with a realistic schedule. The client should understand the full picture before the first payment, not after the third.

What should a Russian entrepreneur consider?

The Russian context is usually omitted from articles on licensing, although for our audience, it determines half the decisions.

The New Law and Your Foreign Structure

Federal Law No. 282-FZ on Digital Currencies and Digital Rights will enter into force on September 1, 2026, introducing professional intermediaries—digital depositories, brokers, managers, trade organizers, and exchange operators—to the market. The Bank of Russia will begin compiling registers of market participants and issuing permits. Starting July 1, 2027, operating exchangers and digital depositories outside the register will be a violation, and banks will block transfers to organizations not included in the register.
For the owner of a foreign crypto company, this means that issues of controlled foreign companies, currency control, and source of funds will have to be addressed in parallel with licensing abroad. We examine both aspects together, as separately they yield contradictory solutions.

Sanctions and Banking Compliance

The citizenship and tax residency of the beneficiary influence the bank's decision more than the company's jurisdiction itself. Some European banks do not open accounts for entities with Russian UBOs, regardless of their license; others do so subject to dual residency or confirmed business ties to the country. This is verified on a case-by-case basis, for each bank, before applying for a license.

How we manage such projects

The first stage is model analysis and a money flow map. The second is a shortlist of two or three jurisdictions, with budget and timeline calculations for each. The third is preparing documents for a specific regulator and parallel work within the banking system. The fourth is post-approval support, as this is where projects most often lose their status.
Moscow office, phone +7 495 001-22-29. We conduct meetings and model analysis in person or remotely, depending on your convenience. A catalog of available solutions is compiled in the licenses and crypto offshore sections.