Crypto Licence Jurisdiction Checker

Crypto-asset businesses face a different licensing answer in every market, and the same product can be regulated, conditionally regulated, or out of scope depending on the jurisdiction. This checker takes one service type and compares the licence position across the EU, UK, US, Singapore, and UAE so you can see where authorisation is needed.

The five regulatory regimes at a glance

EU — MiCA (Markets in Crypto-Assets Regulation): MiCA creates a single licensing regime across all EU member states under the “Crypto-Asset Service Provider” (CASP) authorisation. It covers exchanges, custody, portfolio management, advice, and transfer services for asset-referenced tokens, e-money tokens, and “other crypto-assets.” True DeFi protocols and genuinely unique NFTs are largely outside scope, but that perimeter is still being clarified by the European Securities and Markets Authority.

UK — FCA crypto-asset registration: Firms conducting crypto-asset activity in the UK must register with the Financial Conduct Authority under the Money Laundering Regulations. This is an anti-money-laundering registration, not a full CASP authorisation, but the FCA has applied a high bar in practice. The UK is also developing a broader financial-services framework for crypto that will sit within the Financial Services and Markets Act.

US — State MSBs + federal regulators: The US has no single federal crypto licence. Most exchanges must register with FinCEN as a money services business and obtain money-transmitter licences in each state where they operate (New York’s BitLicense is the most demanding). The SEC asserts jurisdiction over tokens it views as securities; the CFTC oversees crypto derivatives and may claim jurisdiction over spot markets. This fragmentation is why the US column is the most complex.

Singapore — MAS Payment Services Act: The Monetary Authority of Singapore licenses digital payment token (DPT) service providers under the Payment Services Act. Custody, exchange, and transfer of DPTs require either a Standard Payment Institution or Major Payment Institution licence depending on transaction volumes.

UAE — VARA (Virtual Assets Regulatory Authority): Dubai operates VARA, a dedicated virtual-asset regulator. A VARA licence is required to conduct any virtual-asset service in or from Dubai, covering exchanges, brokers, custody, and advisory services. Abu Dhabi has a parallel regime under ADGM (FSRA).

How the checker works

For each service the tool stores a per-jurisdiction cell with a requirement flag and a short explanation. The flags are normalised across all five regimes:

required     → a specific licence/registration is generally needed
conditional  → depends on structure (custody, securities status, decentralisation)
limited      → often outside the core regime (e.g. unique NFTs, pure protocols)

The grid then renders the five jurisdictions for the chosen service so you can compare them at a glance.

Service types compared

This table is a general map. Every cell depends on exact facts — particularly whether the assets are securities, whether you hold custody, and how decentralised the protocol genuinely is.

Key planning note

A crypto exchange is the clearest case: authorisation is required in every jurisdiction. A staking service carries notably high enforcement risk in the US, where staking-as-a-service has been treated as an unregistered securities offering by the SEC. NFT marketplaces sit in a grey zone in most jurisdictions — the question turns on whether the NFTs are fractionalised or function like securities. These perimeters move fast; treat the grid as a starting map and confirm with local regulators and qualified counsel. All processing stays in your browser.