Crypto and fintech licensing: VARA license, MiCA
We will work out which regime catches your product and which one you should choose, then run the licence application through to the regulator's decision.
MiCA transition
MiCA, переход
closed 1 July 2026
закрыт 1 июля 2026
MiCA decision
MiCA, решение
40 working days
40 рабочих дней
VARA, Dubai
VARA, Дубай
8 activity types
8 видов деятельности
SFC, Hong Kong
SFC, Гонконг
4 licence categories
4 категории лицензий
When you need a crypto or fintech license

Your EU users are still onboarding
The MiCA transitional period closed on 1 July 2026. Serving EU clients without authorisation breaches EU law, whatever your home licence says.
A bank asks for your license
Banks, payment providers and listing venues ask which licence you hold before opening the account. They open it against an issued licence.
You are choosing where to incorporate
The address you sign for decides which regulator reads your file, and regimes inside one country can differ. The choice is cheapest to make before anything is filed.
You are not sure what is caught
Custody, exchange and issuance are separate regulated activities. A product can cross several at once, and each one is added to the licence.
A token launch is coming
Issuance is its own category with its own whitepaper review. Publishing first and asking afterwards is the expensive order.
What you get
- Your perimeter, activity by activity
- The regime and the category chosen
- An application filed and paid
- The licence and supervision year
- A compliance calendar
What a VARA license or a MiCA authorisation requires

Regimes ask about the same things in their own words: a company the regulator can see; people it approves; capital and client money; controls written to its depth. The licence sits on top of a company, so registration and a bank account come first.
What the choice depends on
- What the product does: custody, exchange, lending, transfers, advice and issuance are separate regulated activities, and some products cross several at once.
- Where your clients live, because a regime can catch you through the client wherever your address is.
- Where you incorporate: the regulator follows the address, and one country can hold several regimes with different perimeters.
- What the regime costs in capital, in people who must sit in the country, and in the regulator's time.
A company inside the perimeter
- A company incorporated where your regulator has authority: the address decides it, not where the team sits.
- An office and presence matching the activity: the regulator looks at where decisions are taken.
- A shareholding chart to the ultimate owners, with identity documents and source of funds.
- A regulatory business plan: the product, the client base, how money and assets move, and a model.
People the regulator approves
- Senior management assessed individually, with evidence of the experience claimed.
- A compliance officer and a money laundering reporting officer, whose seniority and residency the regime sets.
- A board that can show it understands what it supervises.
- Whether any of these roles may be outsourced — one of the real differences between regimes.
Capital and client money
- Paid-up capital: how much depends on the set of activities — one regime adds the requirement up per activity, another takes one floor for the whole class.
- Client assets segregated from the firm's own, under a custody arrangement the regulator accepts.
- Whether custody may be delegated at all: a regime can require the entity holding the assets to be authorised itself, which rules out a group company abroad.
Controls the file rests on
- AML and sanctions policies with named owners, and the client-facing document set that matches them.
- Technology, custody and cyber-security described to the depth the rulebook asks for, keys and access included.
- A whitepaper where a token is issued, reviewed separately from the licence application.
- A wind-down plan: regulators ask how the firm stops before letting it start.
Where your clients are
- Residents of the EU pull you into MiCA wherever the company is incorporated and wherever the team sits.
- Marketing can be a permission of its own, separate from the licence: a regime may let you market without one and still bar you from onboarding local clients.
- Onboarding by country needs a control you can enforce and evidence; a sign-up checkbox is not one.
- The client's own exclusive initiative is construed narrowly: ESMA says contractual terms or disclaimers cannot override the facts.
Where a licence is needed
Dubai — VARA
Eight types of virtual asset activity in or from Dubai, licensed one type at a time. The perimeter follows the address, and the Dubai International Financial Centre (DIFC) is outside it.
European Union — MiCA
Crypto-asset services for clients in the EU, authorised by the competent authority of one member state, which has 40 working days to decide on a complete application. The transitional period ended on 1 July 2026, so there is nothing left to wait out.
Hong Kong — SFC
Four categories of licensed intermediary: trading platforms, fund management, dealing and advising, and the distribution of virtual asset products. The regulator states the principle as same business, same risks, same rules.
Sources: the perimeter and the activity types are the VARA FAQ; the end of the MiCA transitional period is the ESMA statement of 17 April 2026, and the 40 working days to decide are Article 63 of the Regulation in the ESMA rulebook; the narrow reading of a client's own exclusive initiative is the ESMA guidelines on reverse solicitation. Hong Kong: the SFC on virtual assets.
Stages of work
Perimeter review — 3–5 working days.
We will map what the product does against the rulebook definitions. You get the activities you need and the ones you can drop.
Choosing the regime — 1 week.
We will compare the regimes that fit on cost, capital, presence and regulator speed — this is where a crypto lawyer earns the fee.
The comparison is written down: what each regime costs and what it closes off. You choose from it.
The pre-application stage, where a regime has one.
Some regulators open the file before the company exists and let you incorporate on the strength of it; others take an application only from a registered company.
We will check which of the two applies before the first payment: the order decides whether you register first or ask first.
Company, people and policies — 3–6 weeks.
We will incorporate, appoint the officers and write the AML, custody, technology and wind-down documents to the rulebook's depth.
Full submission and regulator questions.
We will file the complete application, answer the regulator's questions and sit through the interviews with your senior management. The queue at the regulator sets the speed.
Licence and the first supervision year.
We will pay whatever the regime charges before issue, and collect the licence. Where a regime offers a legacy permit, we will say whether you still qualify.
Life after the licence — ongoing.
Reporting, the notifications on the regime's list of changes, and the annual payments to the regulator — their size and the way they are counted differ by regime. You get a calendar: what goes to the regulator, and when.
A change of owners or of the approved officers goes through the regulator in advance: somewhere that is written approval, somewhere a prior notice it may block. Announcing it afterwards closes nothing.
Our other work in the Emirates sits on the UAE page.
Our case studies
FAQ
It follows from two things: what the product does and where its clients live. A product rarely stays inside one regulated activity, and each is licensed on its own — so each is added to the licence with its own demands on capital and people. The address you incorporate at decides which regulator reads the file and which perimeter you land in. That is why the perimeter is mapped before the country is chosen: dropping an activity is cheapest before anything is filed.
Outside the narrow exception of reverse solicitation, no. ESMA states that entities established outside the EU may not provide MiCA services to EU investors or solicit EU clients, and that this applies business to business as well. The exception is construed narrowly: contractual terms and disclaimers cannot override the facts, and any marketing or onboarding closes it. That leaves two routes — an authorisation in one member state, or a country control you can enforce and show the regulator.
Then the wind-down plan is the live document. ESMA expects that any unauthorised provider had implemented its plan by 1 July 2026, and national regulators are told to act against services provided after that date. Applying is still open, but only as a new applicant: the transitional shelter is gone, and the regulator has 40 working days to decide on a complete application. The question is not when you file — it is what you do with EU clients until it arrives.
Only where the entity holding the assets is itself authorised. Under MiCA a provider may not delegate custody to a company that is not an authorised provider, so a group company outside the EU cannot hold client assets. That leaves two routes: the group entity is authorised in its own right, or custody moves to a licensed provider while you keep the duty to segregate client assets. Regimes differ here, and it is one of the questions the choice turns on.
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