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.
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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 application fee: MiCA does not prescribe one, and each national competent authority (NCA) sets its own fee, if any, under national law. Check the home-state NCA's fee schedule before filing. | Application fee set by activity (FEES 3 Annex 1, Cryptoasset Activities (Periodic and Application Fees) Instrument 2026, FCA 2026/58, in force 30 September 2026): GBP 2,820 (Category 4) for arranging deals in qualifying cryptoassets, dealing as agent and qualifying cryptoasset staking; GBP 11,260 (Category 6) for dealing as principal, safeguarding qualifying cryptoassets and issuing qualifying stablecoin; GBP 28,150 (Category 7) for operating a qualifying cryptoasset trading platform. A firm applying for FSMA authorisation and MLR registration together pays a single fee, the highest applicable (FEES 3.2.2G; Handbook Notice 144, Sept 2026, para 3.38). | AED 100,000 | HKD 14,220 |
| Statutory clock | Receipt acknowledged within 5 working days (Art. 63(1)). Completeness assessed within 25 working days of receipt, with a deadline set for any missing information (Art. 63(2)). A fully reasoned decision within 40 working days of a complete application, notified to the applicant within 5 working days (Art. 63). The 40-day period is suspended while one request for further information is outstanding, for at most 20 working days; later requests do not suspend it. ESMA is told of every grant or refusal within 2 working days. | FSMA s.55V clock for Part 4A applications: determination within 6 months of a complete application, or within 12 months of receipt where the application is incomplete. | None published | None published |
| Realistic timeline | No EU-wide processing statistics are published: elapsed time depends on the NCA and on completeness, since the 40-day clock starts only from a complete file and pauses for information requests. The transitional period is over: CASPs operating under national law before 30 December 2024 could continue until 1 July 2026 at the latest (Art. 143(3); member states could shorten it). ESMA's register is the current list of authorised CASPs (Art. 109). | No track record yet. The application window opens 30 September 2026 and closes 28 February 2027 for firms relying on the transitional arrangements; the regime commences 25 October 2027 (PS26/18, 16 Sep 2026). Existing MLR registrations and permissions do not convert automatically. The FCA expects applicants to demonstrate embedded, operating compliance at the point of application. | No published processing time and no statutory clock. Two-stage discretionary process: Initial Disclosure Questionnaire, then Approval to Incorporate, then the full application with VARA feedback, meetings and interviews (vara.ae Licence Applications page; Regulations IV.A.2 says the process is 'as prescribed'). No VARA figure for elapsed time has been located; the Public Register lists licensed VASPs. | No published processing time. The Handbook (para 6.7.1) lists what lengthens it: the services and products proposed, the adequacy of internal controls, the quality and completeness of the application and supporting documents, later changes to business scope, ownership, Responsible Officers or MICs, employment visas, the time taken to inject capital, other regulators' vetting responses, the applicant's own response time and the SFC's caseload. Because the external assessment is performed on the deployed platform after the application is lodged, build and staffing must be complete before grant. |
| 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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