How to choose a jurisdiction for a crypto project: comparison of popular countries
2026 comparison: MiCA CASP in the EU, FCA in the UK, VARA in Dubai, MAS in Singapore, FINTRAC in Canada, FinCEN in the US. Regulator, capital, timeline.
Short answer · checked 30 October 2026
Choose the market by where your clients are, then the country inside it. For clients in the EU the route is one MiCA CASP authorisation, valid across the EEA: own funds of €50,000, €125,000 or €150,000 by service class and 25 + 40 working days of regulator review. The UK, Dubai, Singapore, Canada and the US each license on their own terms.
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Crypto jurisdictions compared: regulator, timeline, capital
The table lists only figures set by law or published by the regulator. Each country page on our site names its source.
| Market | Regulator and route | Regulator’s timeline | Capital or fee |
|---|---|---|---|
| European Union | National competent authority, MiCA CASP authorisation; notification to serve other EEA states | 25 working days for completeness, 40 for the decision | Own funds €50,000 / €125,000 / €150,000 by service class |
| Estonia | Finantsinspektsioon, MiCA CASP | MiCA clock | Processing fee €3,000, plus MiCA own funds · 3 CASPs on the ESMA register |
| Malta | MFSA, MiCA CASP | MiCA clock | MFSA fee schedule, plus MiCA own funds · 23 CASPs on the ESMA register |
| Lithuania | Bank of Lithuania, MiCA CASP | MiCA clock | Bank of Lithuania fee rules, plus MiCA own funds · 6 CASPs on the ESMA register |
| United Kingdom | FCA, new cryptoasset regime expected from 25 October 2027 | Application window 30 September 2026 – 28 February 2027 | FCA fee schedule, by the permissions sought |
| Dubai (UAE) | VARA licence before operations in or from Dubai, all zones except DIFC; eight licensed activities | Set by VARA | Set by VARA |
| Singapore | MAS licence under the Payment Services Act 2019 for digital payment token services | Set by MAS | Base capital S$100,000 (SPI) or S$250,000 (MPI) |
| Canada | FINTRAC, MSB or foreign MSB registration | Within three months of a complete package | No FINTRAC fee · registration valid two years |
| United States | FinCEN MSB registration plus state money transmitter licences | 120 days after a complete application in states that follow the MTMA | MTMA model law: net worth from $100,000, surety bond from $100,000 per state |
| New York | NYDFS BitLicense | 90 days after a complete application, extendable | Application fee $5,000, capital set for each licensee |
| Japan | FSA registration as a crypto-asset exchange service provider | Set by the FSA | Capital at least ¥10 million |
Sources: ESMA interim MiCA register, CASPS.csv (counts on 30 October 2026); Regulation (EU) 2023/1114 (MiCA), Article 67 and Annex IV; FCA, new regime for cryptoasset regulation; VARA, licensed activities; MAS, Payment Services Act; FINTRAC, money services businesses; CSBS, Money Transmission Modernization Act; NYDFS, virtual currency businesses.
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+380 67 777 7230How the regimes differ in practice
European Union: one authorisation for the whole EEA
MiCA has applied to crypto-asset service providers since 30 December 2024. A CASP authorised in one member state can serve clients in the others after a notification to its home regulator (Article 65). The national VASP regimes ended with the transitional periods: in Lithuania on 31 December 2025, in Estonia and Malta on 1 July 2026. Inside the EU the choice of country comes down to where you can place resident management, an office and staff. On 30 October 2026 the ESMA register listed 392 CASPs in 27 countries, led by Germany (122), France (36) and the Netherlands (29). Details: MiCA CASP licence in the EU and how to check a firm in the CASP register.
United Kingdom: a fixed application window
The FCA accepts applications under the new cryptoasset regime from 30 September 2026 to 28 February 2027 and expects the regime to start on 25 October 2027. A firm that files inside the window can keep operating until the FCA decides. A firm that files after the window but before the regime starts is limited to pre-existing contracts with UK customers until the FCA decides. Details: crypto licence in the UK.
Dubai: a VARA licence before launch
VARA regulates virtual asset activities across the Emirate of Dubai, including free zones, with the exception of the Dubai International Financial Centre. A virtual asset service provider must apply for and receive a VARA licence before it begins operations in or from Dubai. VARA lists eight licensed activities: advisory, broker-dealer, custody, exchange, lending and borrowing, management and investment, transfer and settlement, and VA issuance. Firms in the DIFC are supervised by the DFSA, and firms in Abu Dhabi’s ADGM by the FSRA. Stages, free zones, office and bank account are covered on our page on crypto company registration and VARA licence in Dubai.
Singapore: a licence for clients in Singapore
Buying or selling digital payment tokens for customers, or running a platform to exchange them, is a DPT service under the Payment Services Act 2019 and needs a MAS licence: a standard payment institution with S$100,000 base capital or a major payment institution with S$250,000. Since 30 June 2025 a provider that serves only clients outside Singapore needs a separate licence, which MAS will generally not issue (MAS, 6 June 2025). Details: crypto licence in Singapore.
Canada and the United States: registration plus local layers
In Canada a business that deals in virtual currencies registers with FINTRAC as a money services business, or as a foreign MSB when it has no place of business in Canada. FINTRAC charges no fee, processes a complete file within three months, and the registration lasts two years; Québec adds its own licence, and trading platforms may fall under provincial securities law. In the US the base is FinCEN MSB registration plus money transmitter licences state by state; New York requires a BitLicense from NYDFS. Details: MSB registration in Canada, money transmitter licence in the US.
Which jurisdiction fits which business model
- Exchange, broker or custody for EU clients: MiCA CASP authorisation in the member state where you can build substance; the capital class follows the services.
- Clients in the UK: an FCA application inside the window that closes on 28 February 2027.
- Clients in the Gulf: a VARA licence for Dubai, or authorisation in the DIFC or ADGM.
- Clients in Singapore: a MAS licence under the Payment Services Act; an offshore-only model from Singapore is closed in practice.
- Clients in Canada: FINTRAC MSB or foreign MSB registration, plus Québec and securities law where they apply.
- Clients in the US: FinCEN MSB registration and state licences; a BitLicense for New York.
This page compares licensing regimes side by side. For a country-by-country overview of where to register a crypto company, including tax-oriented jurisdictions, read how to choose a jurisdiction: an overview of popular countries. Licences by activity (exchange, custody, broker) and their costs are on the hub crypto licence in 2026.
FAQ
Which country is best for a crypto company in 2026?
The country where your clients are and where you can build substance. For EU clients that is a member state with a MiCA CASP authorisation; on 30 October 2026 the ESMA register showed 122 CASPs in Germany, 36 in France and 23 in Malta. For clients in the UK, Dubai, Singapore, Canada or the US the local regulator decides.
How much capital does a crypto licence need?
In the EU, own funds of €50,000, €125,000 or €150,000 depending on the services. In Singapore, base capital of S$100,000 for a standard and S$250,000 for a major payment institution. In Japan, at least ¥10 million. In US states that follow the MTMA, net worth from $100,000 plus a surety bond. FINTRAC in Canada charges no registration fee.
How long does it take to get a crypto licence?
Under MiCA the regulator has 25 working days to check completeness and 40 to decide. Preparing a fileable application usually takes three to six months, and our clients typically plan four to twelve months from the first call. FINTRAC processes a complete MSB file within three months; NYDFS decides on a BitLicense within 90 days of a complete application.
Can I still get a national VASP licence in Estonia, Lithuania or Malta?
No. The national regimes ended with the MiCA transitional periods: in Lithuania on 31 December 2025, in Estonia and Malta on 1 July 2026. A company that serves EU clients now needs a MiCA CASP authorisation.
Can a Singapore company serve only clients outside Singapore?
Since 30 June 2025 such a digital token service provider needs a licence under the Financial Services and Markets Act 2022, and MAS said on 6 June 2025 that it will generally not issue one. Providers that serve clients in Singapore are licensed under the Payment Services Act.
Where should you apply? Tell us what you do with crypto-assets and where your clients are. You get the regime, the capital class and a written plan. Consultation: 30 min — €100; written opinion — from €200.
Checked on 30 October 2026 against the sources listed under the table. General information; requirements for a specific business depend on its model.