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Verify recommended:28 July 2026·Source →

CBB Crypto-Asset Licence

BahrainExchange / tradingCustodyBroker / dealerLive
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General information only — not legal advice

CryptoRegHub provides plain-English summaries of crypto regulations for informational purposes only. This does not constitute legal, compliance, or financial advice. Regulations change frequently — always verify information with official sources and consult qualified legal counsel before making any compliance decisions.

One of the first crypto licensing regimes in the Middle East, running since February 2019 under the CBB's CRA Module with four ascending categories: advisory (Category 1), agent trading, custody and portfolio management (Category 2), principal trading (Category 3), and operating an exchange (Category 4, which must be a B.S.C. company). The tier table is the cleanest in the region — fixed paid-up capital per category — with a BD 100 application fee per the rulebook itself.

Capital requirements

TierCapitalCovers
Category 1BHD 25,000Advice and order reception; no client assets
Category 2BHD 100,000Plus trading as agent, custody, portfolio management
Category 3BHD 200,000Plus trading as principal and digital token advisor
Category 4BHD 300,000
Must be a B.S.C. company; matched-principal restrictions
Operating a crypto-asset exchange (+ custody, digital token advisor)

Application process

1
Fix the category and services, then meet the CBB
Choose one of Categories 1 to 4 and list every CRA-1.1.6 service applied for (CRA-1.1.8; services added later need prior approval, CRA-1.1.6A). Request the pre-application meeting in writing with a summary of the business; the Licensing and Regulatory Policy Directorate normally expects at least one before an application (CRA-1.2.16 to 1.2.17).
2
Submit Form 1 with the CRA-1.2.4 pack
Form 1 (Application for a License) under a cover letter signed by an authorised signatory to the Director, Licensing and Regulatory Policy Directorate, with Form 2 per 5%+ shareholder, Form 3 per board director and Appendix FP-2 senior management function, the CRA-1.2.6 business plan, commercial registration, certified board resolution, group non-objection and three years of audited accounts where applicable, the draft memorandum and articles, and the BD 100 fee (CRA-1.2.1 to 1.2.8; Form 1 checklist).
3
Completeness review and 60-day decision
The CBB may request further information within 30 days of receipt; the 60-calendar-day statutory clock runs only once every CRA-1.2.4 item is in (CRA-1.2.11). Applicants must satisfy the CRA-2 licensing conditions by the date of grant (CRA-1.1.22) and must not hold themselves out as licensed before the CBB Resolution (CRA-1.2.18; Article 42). A refusal carries at least 30 days to appeal (CRA-1.2.21).
4
Pay in the capital and receive the Resolution
Before final approval a Bahrain retail bank confirms to the CBB that the minimum paid-up capital - BD 25,000 / 100,000 / 200,000 / 300,000 by category - has been paid in (CRA-1.2.22, 3.1.2). Grant is notified in writing and published in the Official Gazette and two newspapers at the licensee's cost; the first annual fee (category floor) is payable on issue (CRA-1.2.19, 1.4.1 to 1.4.2, 1.6.10).
5
Readiness assessment and pre-commencement items
With prior CBB approval, appoint an independent third party to perform a readiness assessment covering risk management, capital, organisation, manuals, IT, information security, policies and internal controls and submit its report (CRA-1.2.23 to 1.2.24). Provide the CRA-1.2.26 items - premises, contacts, auditor acceptance, capital deposit certificate, PI insurance policy where client assets are handled, notarised M&A, bilingual CR, bank confirmation of corporate and client money accounts - and file the board-approved listing policy (CRA-4.3.7) and any custodial arrangement for approval (CRA-8.2.1).
6
Commence within six months
Commercial operations must begin within 6 months of grant or the CBB may cancel the licence (CRA-1.2.27). From then on: annual audited accounts within 3 months and reviewed quarterly accounts within 45 days (CRA-4.2.3, 4.2.5), quarterly complaints and top-100 client reports, annual PIIR and liquidity-partner reports, six-monthly client-asset audits for licensees holding client assets (CRA-10.1).

Ongoing obligations

Prudential maintenance — category capital, the three-month liquid-asset cover, and PI insurance maintained continuously.
Proprietary dealing cap — proprietary crypto dealings limited to 50% of paid-up capital or net equity, whichever is lower.
Annual fees and reporting — the 0.25% operating-expense fee, CBB reporting and AML/CFT obligations.

Common rejection & delay reasons

Category 4 corporate form
Exchange operators must be B.S.C. companies — restructuring late is expensive.
Resident management gaps
The CEO/CO/MLRO residency expectations are assessed substantively.

What's changing

CRA Module iterations — confirm current fee text (CRA-1.6) at application
· in force

Frequently asked questions

At a glance
JurisdictionBahrain
RegulatorCentral Bank of Bahrain (CBB)
TypeLicence — 4 categories
CapitalBD 25k–300k by category
Application feeBHD 100
Ongoing feesAnnual licence fee of 0.25% of relevant operating expenses within a floor and cap by category: Category 1 BD 2,000-6,000; Category 2 BD 3,000-8,000; Category 3 BD 4,000-10,000; Category 4 BD 5,000-12,000 (CRA-1.6.3). First fee = the category floor, payable when the licence is issued (CRA-1.6.10); thereafter due 1 December for the following year by direct debit (Form ALF by 15 October, Direct Debit Authorisation by 15 September; CRA-1.6.1, 1.6.8, 1.6.9).
Statutory clock60 calendar days from the application being deemed complete (CRA-1.2.11; CBB Law Articles 44-47). The CBB has 30 calendar days from receipt to request further information (CBB Guide to Licensing).
Realistic timelineThe CBB Guide to Licensing states 3 to 6 months on average for the whole process, with the completeness and in-principle stage taking from days to months depending on scale and responsiveness. No crypto-specific statistics are published. Commercial operations must start within 6 months of grant or the CBB may cancel the licence (CRA-1.2.27).
PassportingNone
Last verified28 Jul 2026
Local presence

Bahrain incorporation (W.L.L. or B.S.C.; Category 4 must be B.S.C.), 100% foreign ownership allowed; Bahrain office with resident core management (CEO, Compliance Officer, MLRO); shareholders of 5%+ pass CBB suitability.

Primary source
https://www.cbb.gov.bh →
Related
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Disclaimer

This guide is for general informational purposes only and does not constitute legal advice. Figures change — always verify with the regulator and consult qualified counsel before applying.