Licensing Guide

Your LicensingRoadmap

Compare jurisdictions across four licensing tracks — Crypto/VASP, Forex/FX, Payment/EMI, and Hong Kong Securities/SFC (Type 1/4/7/9) — to find the best fit for your business model and budget.

What is a VASP Licence?

A Virtual Asset Service Provider licence authorises businesses to offer crypto exchange, transfer, custody, or related services under regulatory supervision.

  • Crypto exchanges (CEX)
  • Crypto custodians
  • Crypto payment processors
  • Token issuers

Key Considerations

  • Capital requirements vary widely by jurisdiction
  • AML/KYC programme is mandatory in all cases
  • EU MiCA now harmonises rules across all EU states
  • Offshore licences may have limited banking access
JurisdictionRegulatorTimelineComplexityNotes
LithuaniaFNTT3–5 moMediumFastest EU entry; full MiCA passporting
EstoniaFIU4–6 moMediumEstablished EU VASP market; higher scrutiny post-2022
Czech RepublicFAÚ3–5 moLowRegistration-based; low cost entry point
PolandMF2–4 moLowFast registration; growing market
Dubai (VARA)VARA6–12 moHighPrestigious; strong banking access; high capital
Hong KongSFC / HKMA12–18 moHighTier-1 licence; premium status; complex process
SeychellesFSA2–4 moLowCost-effective offshore; limited banking options
GeorgiaNBG3–6 moLowEmerging hub; favourable tax environment
El SalvadorBCR3–5 moLowBitcoin-friendly; unique regulatory framework

What is an FX Licence?

A forex or investment dealer licence authorises a firm to provide foreign exchange trading, CFD brokerage, or investment intermediary services to retail and institutional clients.

  • Forex brokers (retail & institutional)
  • CFD / derivatives brokers
  • Introducing brokers (IB)
  • Fund managers with FX exposure

Tier 1 vs Offshore

  • Tier 1 (FCA, CySEC): Higher cost, longer timeline, premium brand value
  • Offshore: Lower cost, faster, suitable for non-EU client base
  • EU licences allow passporting across all 27 member states
JurisdictionRegulatorTimelineComplexityNotes
CyprusCySEC6–9 moHighEU passport; well-known FX hub; strong banking
UKFCA6–12 moHighGold standard; no EU passport post-Brexit
MaltaMFSA6–10 moHighEU passport; English-speaking regulator
VanuatuVFSC2–4 moLowFast, cost-effective; popular offshore choice
SeychellesFSA2–4 moLowFlexible regulation; good for Asian markets
MauritiusFSC4–6 moMediumWell-regarded; good for African & Asian client bases
LabuanLabuan FSA3–5 moMediumMalaysian jurisdiction; Asia-focused
GeorgiaNBG3–6 moLowEmerging; low tax; growing reputation

What is an EMI Licence?

An Electronic Money Institution licence allows a company to issue electronic money, hold client funds in payment accounts, and execute payment transactions — similar to a bank but lighter regulation.

  • Fintech / neobanks
  • E-wallet providers
  • Payroll & B2B payment platforms
  • Cross-border remittance services

EU EMI: Lithuania First

  • Lithuania is the most popular EU EMI jurisdiction
  • Bank of Lithuania processes applications faster than most EU peers
  • Full EU passporting under PSD2
  • €350,000 minimum initial capital for full EMI
JurisdictionRegulatorTimelineComplexityNotes
LithuaniaBank of Lithuania4–7 moMediumFastest EU EMI; full PSD2 passport; popular fintech hub
LatviaFCMC5–9 moMediumSolid EU option; strong Baltic banking
MaltaMFSA8–14 moHighEU passport; strong regulatory framework
PolandKNF6–10 moMediumLarge EU market; growing fintech scene
IrelandCBI12–18 moHighEnglish-speaking EU; premium banking access
UKFCA12–18 moHighGold standard; no EU passport; strong brand
GeorgiaNBG3–6 moLowFast, low cost; good for non-EU operations
Hong KongHKMA6–12 moHighSVF licence; strong Asia presence required
SingaporeMAS12–18 moHighPremium Asia licence; MPI licence framework

What are the SFC Type 1/4/7/9 Licences?

Hong Kong's Securities and Futures Commission (SFC) licenses firms by "regulated activity." Types 1, 4, 7 and 9 are the most common combination for securities and asset-management businesses — brokers, advisers, electronic trading platforms and fund/asset managers.

  • Type 1 — Dealing in securities (brokers, placing)
  • Type 4 — Advising on securities (investment advisers, research)
  • Type 7 — Providing automated trading services (electronic platforms)
  • Type 9 — Asset management (funds, discretionary accounts, family offices)

Key Considerations

  • At least two Responsible Officers (ROs) per regulated activity, one an executive director resident in Hong Kong
  • ROs must meet the SFC "competence" requirements: relevant experience + HKSI licensing exams (or exemptions)
  • Compliance, risk and AML/KYC frameworks required, plus appointed Managers-In-Charge (MICs)
  • Capital depends on whether client assets are held — see table (Financial Resources Rules)
  • Overall timeline ~6–12 months, depending on complexity and team readiness
LicenceRegulated ActivityWho It's ForPaid-up / Liquid CapitalNotes
Type 1Dealing in securitiesBrokers, dealers, placing/underwritingHK$5M / HK$3MApplies if holding client assets; intro-only can drop to HK$500K liquid
Type 4Advising on securitiesInvestment advisers, research houses— / HK$100KNot holding client assets; often paired with Type 9
Type 7Automated trading servicesElectronic trading platforms, ATSHK$5M / HK$3MElectronic matching/trading of securities or futures
Type 9Asset managementFund managers, discretionary, family offices— / HK$100KNot holding client assets; common for private funds & SFOs

Capital figures per the SFC Financial Resources Rules; final requirements depend on licence conditions and whether client assets are held.

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