Crypto License: What Each Regulator Actually Charges

Every regulator builds its taxonomy on the same axis: what you do with someone else’s asset. That is the only stable comparison across four otherwise incompatible regimes.

India’s five virtual digital asset activities, brought under the Prevention of Money Laundering Act by a 2023 Finance Ministry notification, are the FATF definition transposed almost word for word. That convergence is why the table works as a map rather than a menu.

One disqualifier, and it matters more than anything else here. If you trade only your own money, none of this applies to you. Licensing regulates businesses that handle other people’s assets.

Four points, and the ordering matters. Read the table first, then the “where it must sit” column, which is the one that changes decisions.

Sources: VARA Company Rulebook Part VI · Regulation (EU) 2023/1114, Annex IV and Article 67 · NYDFS.

Class 2 is custody and exchange. Class 3 is operating a trading platform. Annex IV is explicit. Several widely-read guides, including the page currently ranking first in India, reverse these two. If you are building a trading venue and budget for Class 2, you have under-provisioned.

The MiCA floor is a floor, not the answer. Article 67(1) requires the higher of the Annex IV amount or one quarter of the preceding year’s fixed overheads. Any business with more than roughly EUR 600,000 of annual fixed overheads is governed by the overheads limb, not by the headline figure. A firm not yet trading a full year uses projected overheads from its application.

Dubai capital is per activity and cumulative. Hold two licences and you hold both capital sums, reconciled monthly. It does not merge.

It is not working capital. VARA requires it in a trust account with a UAE-licensed bank naming VARA as beneficiary, or a surety bond with no end date naming VARA. You cannot trade on it, pay salaries from it, or count it as runway. The one commercial lever available: appointing a VARA-licensed custodian roughly halves the floor, and takes Exchange Services from AED 1,500,000 down to AED 800,000.

Dubai. An Initial Disclosure Questionnaire to Dubai Economy and Tourism, then VARA’s own documentation. VARA’s process page states that you pay the initial fees required to commence the application review, typically 50% of the licence application fee, with the balance and the first year’s supervision fee due at the licence stage. Read that as a commercial fact: roughly half the application fee is spent before anyone assesses you.

India. The fullest published document list of any regime here, and it is not reproduced anywhere in the field:

• a note on the nature of the service offered
• the corporate structure, including significant beneficial ownership
• incorporation documents, annual return, balance sheet and profit and loss account as filed with the Ministry of Corporate Affairs for the last 3 financial years
• GST returns for the last 3 financial years, plus GST registrations in every state of operation
• income tax returns, and Forms 26Q, 26QF and 26QE for tax deducted at source on virtual digital asset transactions
• copies of any agreements with entities inside or outside India
• a self-declaration of no pending Enforcement Directorate or law-enforcement proceedings

There is also a step nobody publishes: FIU-IND calls the applicant to an in-person meeting at its office, which the Designated Director and the Principal Officer must both attend.

The consequence follows directly and is rarely drawn. A requirement for three financial years of MCA and GST filings means a newly incorporated Indian entity cannot practically register. If India is your market, that shapes the structure before anything else does.

United States. Applications go through the Nationwide Multistate Licensing System.

1. You tell us the activity and the customer base. Which of the activities in the routing table you will perform, and where your customers are. This determines everything else.
2. We scope jurisdiction against activity, and set out the regulator fee, the capital requirement and the published timeline for each realistic option, from the regulator's own documents.
3. You choose the jurisdiction. We tell you where we think the answer is, and where the honest answer is that you need locally admitted counsel instead.
4. We introduce you to the licensed local filing agent or counsel, and hand over the scoping work so you are not paying twice for the same analysis.
5. They file. You pay the regulator directly. Regulator fees are set by instrument and are the same whoever files, so they never pass through us.
6. You keep the obligations. Capital maintenance, reporting and any change of control stay with the licensed entity for as long as it holds the permission.

What you get

• A written jurisdiction and activity scope: which permission your model needs, and which it does not.
• A cost breakdown per shortlisted jurisdiction, separating the regulator fee, the capital you must lock up, the annual fee, and the corporate layer underneath it.
• The document list for the jurisdiction you choose, taken from the regulator's own published requirements.
• An introduction to the filing agent or counsel who will act, with the scoping work handed across.
• Where you also need a company or a bank account, the same scoping across our company formation and bank account work.

We do not provide the licence, the legal opinion, or the filing. Those come from the regulator and from the counsel who files.

We compare on permission and scope rather than on price, for a reason: no law firm ranking on these terms publishes a fee. Stating that is more useful than inventing a typical lawyer cost we cannot source.

The saving we can actually evidence is not a discount. The regulator fee and the capital requirement are fixed by instrument and identical whoever files. The only variables are the advisory layer and the cost of choosing wrong. A founder who applies for Dubai Exchange Services when Advisory Services would have suited their model pays AED 60,000 more to apply, AED 120,000 more every year, and locks up roughly AED 1.4 million more in capital. That is arithmetic from the two tables above, and it is the strongest argument on this page for taking advice before you file.

A licence in one country does not settle your obligations in another. Structure lawfully, and report where you are resident.

India

Registration with FIU-IND is a pre-requisite, and failure to register is itself non-compliance under section 13(2) of the PMLA. Outbound structuring engages FEMA and the Reserve Bank of India’s Liberalised Remittance Scheme master direction. Virtual digital asset income is taxed under section 115BBH, with tax deducted at source under section 194S: the Forms 26Q, 26QF and 26QE in the FIU-IND document list are that same trail.

United States

US persons report foreign accounts on the FBAR and foreign entity interests on Form 5471 or Form 8938, and controlled foreign corporation rules may attribute the entity’s income to you. A foreign licence does not displace state money transmitter law where you have US customers.

United Kingdom

Registration under the Money Laundering Regulations is not authorisation. Registered crypto firms are not thereby covered by the Financial Services Compensation Scheme or the Financial Ombudsman Service for crypto activity. This is the most commonly misunderstood point in the UK market. The new FSMA regime is expected to commence on 25 October 2027, and it will require authorisation rather than registration.

You still report to HMRC, and which rule reaches you depends on how the licensed entity is held. If a UK company you control holds it, the controlled foreign company rules in Part 9A of TIOPA 2010 can attribute its profits to that UK company. If you moved assets into the structure as an individual, the transfer of assets abroad rules in sections 714 to 751 of the Income Tax Act 2007 can tax its income on you instead.

United Arab Emirates

The UAE levies 9% federal corporate tax. A 0% rate on qualifying income is available to a Qualifying Free Zone Person, but it is conditional on tests that a licensed virtual asset business will not automatically meet. Do not plan on it without advice.