General information only. CryptoRegHub provides summaries for informational purposes and does not constitute legal or compliance advice. Always verify with official sources and consult qualified legal counsel before making compliance decisions.
Every major regime side by side — add or remove licences to build your own comparison. Back to all guides
European Union MiCA CASP Authorisation Live | United Kingdom FCA Cryptoasset Authorisation Gateway opens 30 Sep 2026 | UAE — Dubai VARA VASP Licence Live | Hong Kong SFC VASP (VATP) Licence Live | |
|---|---|---|---|---|
| Regulator | National competent authority (home member state); ESMA register on grant | Financial Conduct Authority (FCA) | Virtual Assets Regulatory Authority (VARA) | Securities and Futures Commission (SFC) |
| Licence type | Authorisation | Authorisation | Licence — 7 activity categories | Licence (dual: SFO + AMLO) |
| Activities | Exchange / trading · Custody · Broker / dealer · Transfer / payments | Exchange / trading · Custody · Broker / dealer · Stablecoin issuance | Exchange / trading · Custody · Broker / dealer · Transfer / payments | Exchange / trading · Custody |
| Capital | €50k–€150k by class | £75k–£750k by activity | AED 100k–1.5M by category | HK$5M paid-up + liquid requirements |
| Application fee | No EU-level fee — application fees are set nationally by each competent authority and vary by member state. | TBC — the FCA is confirming cryptoasset application fees in its September 2026 Handbook Notice. | Approximately AED 100,000 per activity for the major categories (Broker-Dealer, Custody, Exchange, Lending, Management) and AED 40,000 for Transfer & Settlement; additional activities in one application attract a Licence Extension Fee of 50% of the lower application fee. Figures from VARA's public fee schedule via secondary sources — confirm at application. | Approximately HK$4,740 per regulated activity (Type 1 + Type 7 ≈ HK$9,480), plus per-Responsible-Officer and per-representative fees — consistent with the standard SFC schedule; confirm in the VATP Licensing Handbook fee table. |
| Statutory clock | 25 working days completeness check, then 40 working days assessment from a complete file, decision notified within 5 working days (Art. 63). Suspendable or extendable in some member states. | FSMA standard clock expected to apply: determination within 6 months of a complete application (12 months absolute where incomplete). | None published | None published |
| Realistic timeline | Typically 4–12 months elapsed for a well-prepared file; the completeness phase has been running 45–60 days during the post-transition application rush (industry estimate). | No track record yet — the gateway is new. The FCA has signalled that firms must demonstrate embedded, operational compliance at the point of application, not planned compliance. | No statutory clock — a discretionary two-stage process. Stage 1 (Initial Disclosure Questionnaire to Initial Approval) commonly runs 6–12 weeks for a well-prepared file; the full path to an operational licence is typically quoted in months, not weeks. | Around 12 months in practice (industry estimate), including two phases of external assessor reports: phase 1 (design effectiveness) before approval-in-principle and phase 2 (implementation effectiveness) before the licence is granted. |
| Grace / transition | Transition period expired 1 July 2026 for most member states; remaining national tails run to end-2026. | Gateway 30 Sep 2026 – 28 Feb 2027; regime effective 25 Oct 2027. MLR-registered firms must apply within the window to continue lawfully past that date. | — | — |
| Passporting | EU-wide (27 member states) | None (UK only) | None (Dubai only; separate regimes apply federally and in ADGM/DIFC) | None |
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