Crypto licensing outside MiCA and the US: where you can actually get authorised in 2026

Almost everything written in English about crypto regulation is about two places. MiCA, or Washington. That is understandable — they are the two largest markets and the two loudest — but it leaves a working map of the rest of the world in surprisingly poor shape, and the errors in it are consistent enough to be worth naming. The most common one is treating a regime that has been legislated as a regime you can apply to. Those are frequently a year or more apart, and in the United Kingdom's case the law was made a full twenty months before the regime it creates takes effect.

This is a status check across eleven jurisdictions rather than an argument, current at the end of August 2026. It covers where a licence can actually be obtained today, where a law exists but the door is not yet open, where there is no door at all, and — the part almost nobody publishes — what proportion of applicants are getting through.

Two dates fall inside the next ninety days

If you take nothing else from this page, take these two. One is a door opening and one is a door closing, and the difference matters.

The United Kingdom's authorisation gateway opens on 30 September 2026. The Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026 — SI 2026 No. 102 — were made on 4 February 2026 and bring operating a qualifying cryptoasset trading platform, dealing as principal and as agent, arranging, qualifying stablecoin issuance, safeguarding and qualifying cryptoasset staking inside the FSMA perimeter, alongside a public-offers and market-abuse regime. The regime itself does not come into force until 25 October 2027, but applications open more than a year ahead of it. And an existing registration under the Money Laundering Regulations does not convert: the FCA states plainly that being registered under the MLRs does not guarantee authorisation under FSMA, and that an MLR registration form cannot be treated as an application for FSMA authorisation. Firms already registered apply again, from the beginning.

Brazil's filing deadline is 30 October 2026. Resolutions 519, 520 and 521 of the Banco Central do Brasil were published on 10 November 2025 and took effect on 2 February 2026, with 270 days for incumbent virtual asset service providers to file an authorisation request. Miss it and there are thirty days to wind down, and from the same date Brazilian financial institutions must stop dealing with unauthorised providers. Minimum capital, set by Joint Resolution 14 and BCB Resolution 517 of 3 November 2025, runs from R$10.8 million to R$37.2 million depending on the scope of activity, against the R$1–3 million floated at consultation. That is roughly ten times, and it reshaped the market before a single licence was granted.

Where a licence is actually being granted, and at what rate

Approval rates are published far less often than statutes, and they are the more useful number. Two jurisdictions release enough data to compare, and the contrast between them is the most instructive thing on this page.

South Africa is the outlier, in the direction nobody expects. Crypto assets were declared a financial product by the Financial Sector Conduct Authority in October 2022 and licensing opened on 1 June 2023. As at 31 March 2026 the FSCA had received 533 applications and approved 310, with 17 declined and 124 withdrawn. Declines turn largely on operational capability and on whether key individuals can demonstrate genuine competence in the sector. The FSCA has opened 81 investigations into unlicensed activity, 51 still open and 30 closed without enforcement action, mostly because the firm had already ceased trading or was dormant. So the high approval rate is not a low bar — it sits alongside an active supervisory perimeter, though one that has not yet produced published enforcement outcomes.

The United Kingdom's record on the AML register is the reverse. Across completed cases from January 2020 to 1 August 2026 there were 391 determinations, producing 68 registrations and 263 withdrawals. That is roughly 17% registered and 67% withdrawn, with formal refusals at about 4%. The most-quoted framing of this — that the FCA rejects crypto firms — is not quite right. The FCA refuses very few. What happens is that applicants give up, which is a different problem with a different solution. The recent trend is better: 13 registrations from 23 determinations in the most recent twelve months, though on a much smaller denominator. These figures come from one firm's analysis of FCA data rather than from an FCA publication, and are worth treating as indicative — the three categories do not sum to the total, and the analysis does not account for the remainder.

Hong Kong's stablecoin regime is the tightest gate here. The Stablecoins Ordinance commenced on 1 August 2025, requiring a Hong Kong Monetary Authority licence to issue fiat-referenced stablecoins in Hong Kong, to issue Hong Kong dollar-referenced stablecoins anywhere, or to actively market them to the Hong Kong public. Minimum paid-up capital is HK$25 million for anyone that is not already an authorised institution. Thirty-six applications arrived by the first-batch deadline of 30 September 2025. On 10 April 2026 the HKMA granted two — Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited — and the government told the Legislative Council in June 2026 that any further licences would be very limited in number.

The United Arab Emirates has been the fastest. Dubai's Virtual Assets Regulatory Authority issued its fiftieth VASP licence on 2 July 2026. The federal picture changed at the same time: Federal Decree-Laws 32 and 33 of 2025 took effect on 1 January 2026, renaming the Securities and Commodities Authority as the Capital Market Authority under a framework that is expressly extraterritorial — it catches any person targeting clients in the UAE even where the activity is conducted from a financial free zone. Minimum capital under the federal regime runs from AED 500,000 to AED 4,000,000 depending on which of eight licensable activities you conduct. ADGM and DIFC continue to run their own separate regimes, and compliance with one is not compliance with another.

Turkey has started licensing, and not where most coverage expects. Law No. 7518 brought crypto assets under the Capital Markets Board in 2024, and the operating communiqué appeared in the Official Gazette on 13 March 2025 with most provisions effective from 30 June 2025. Capital requirements are substantial — TRY 150,000,000 for platforms and TRY 500,000,000 for custody institutions. On 4 June 2026 the Board recorded in its weekly bulletin the grant of operating licences to Akbank, Türkiye Garanti Bankası and Yapı ve Kredi Bankası as crypto-asset custody institutions. Three banks, in custody. The same bulletin approved the establishment of two platform companies, Fiba and Goldtag — permission to incorporate, which is not permission to operate. We found no platform operating licence in that bulletin or since. The Board publishes a list of around fifty entities currently operating and states expressly that inclusion on it does not mean those firms are authorised, because they are running under a transitional provision.

Which regimes are law but not yet open

This is the category that causes the most wasted effort, because the announcements read as though the door is open.

Australia has no digital asset licensing regime in force. The Corporations Amendment (Digital Assets Framework) Act 2026 received Royal Assent on 8 April 2026 and commences on 9 April 2027, creating two new financial products — the Digital Asset Platform and the Tokenised Custody Platform — licensed through the existing Australian Financial Services Licence regime. What is live in the meantime is ASIC's updated INFO 225 from October 2025, which clarifies that many digital asset products are already financial products requiring an AFSL, together with a sector-wide no-action position extended on 25 June 2026 and now running to 30 September 2026. ASIC reported approximately thirty licence applications from digital asset businesses since that update.

Canada has legislated stablecoins and has not yet operationalised them. The Stablecoin Act received Royal Assent on 26 March 2026. Issuers of fiat-referenced stablecoins used interprovincially or cross-border must appear on a public Bank of Canada registry before issuing, hold reserves of at least one to one in the reference currency, unpledged and segregated with a qualified custodian, and are prohibited from paying interest or yield to holders. Supervisory provisions took effect on assent; the full framework is expected to be operational in 2027 after rulemaking. Separately, the restricted dealer route and pre-registration undertakings that carried the Canadian platform market are effectively closed to new applicants — the CSA has said it does not intend to continue the interim approach, with a carve-out for platforms already working actively with regulators — and existing firms are migrating to full CIRO investment dealer membership.

Japan has legislated the largest structural change of the year. The amended Payment Services Act came fully into force on 1 June 2026, set by Cabinet Order, adding a lighter-touch intermediary registration. The bigger move passed the House of Councillors on 15 July 2026: crypto-assets move out of the Payment Services Act and into the Financial Instruments and Exchange Act, bringing disclosure obligations, an insider trading prohibition and an ETF pathway. Core provisions commence on a date set by Cabinet order within a year of promulgation, so the practical start is most likely 2027. A parallel tax reform moves crypto to separate self-assessment at around 20%, but on its own timetable — reported as 1 January 2028, which is a different date from the one most coverage attaches to it. Existing exchange operators get a six-month grace period to obtain FIEA registration, extendable up to two years where applications are filed in time.

Where there is no licence to apply for

India has no crypto licensing regime and no bill. Virtual asset service providers are reporting entities under the Prevention of Money Laundering Act and must register with the Financial Intelligence Unit; fifty were registered as at 1 October 2025, when FIU-IND issued non-compliance notices to twenty-five offshore providers alongside takedown requests. That registration is an anti-money-laundering obligation. It is not a prudential or conduct licence and it confers nothing beyond itself. The Department of Economic Affairs discussion paper remains unpublished, and on 20 August 2026 Parliament's Standing Committee on Finance cancelled the oral-evidence hearing it had scheduled on the subject for 27 August.

Singapore has no stablecoin law. The Monetary Authority of Singapore finalised a single-currency stablecoin framework in August 2023 and it has never been legislated. It remains non-binding guidance. MAS indicated in November 2025 that it was ready to begin drafting, and as at the end of August 2026 we could find no bill introduced. Anyone describing Singapore as having a stablecoin regime is describing a consultation outcome.

Hong Kong has no dealing or custody licence yet. Consultation conclusions on virtual asset dealing and custodian licensing were published on 24 December 2025 and a further consultation on advisory and management closed in January 2026, with delivery planned through amendments to the Anti-Money Laundering Ordinance. The stated target is to introduce a bill to the Legislative Council during 2026, and as at the end of August 2026 we could find none introduced. Worth noting for anyone planning around it: no deeming or transitional arrangements are proposed, so every operator will need to be licensed before commencing or continuing — though an expedited approval route is proposed for firms already providing the service, and early pre-application engagement is encouraged.

The jurisdiction most people name first is the hardest one

Ask a room of fintech founders where to base a crypto business and someone will say Singapore. It is the answer that has aged worst.

Part 9 of the Financial Services and Markets Act 2022, with the Digital Token Service Providers Regulations 2025, commenced on 30 June 2025. It captures Singapore-incorporated entities and individuals providing digital token services exclusively to customers outside Singapore — the offshore-servicing model a large part of the industry was built on. MAS provided no transitional arrangements. Affected firms had to cease on that date or hold a licence, and MAS said in terms that it "has set the bar high for licensing and will generally not issue a licence."

Digital payment token services under the Payment Services Act 2019 remain available for firms serving Singapore customers. But the specific thing many people mean when they say "we'll set up in Singapore" stopped being possible fourteen months ago.

What the numbers actually tell you

Three things, and the first changes how you plan.

The statute is not the variable. The approval rate is. South Africa and the United Kingdom both run functioning regimes with published criteria, and one puts through more than three times the proportion of applicants that the other does — roughly 58% against 17%. Nothing in either statute predicts that. It is a function of how the process is run, how much of it is front-loaded onto the applicant, and how tolerant the regulator is of firms that are nearly ready.

Withdrawal, not refusal, is how most applications end. Two-thirds of completed UK cases ended with the applicant walking away. That is a signal about cost, duration and the gap between what an applicant thought was required and what actually was — not about the merits of the businesses involved. If you are budgeting for an authorisation anywhere, budget for the version of the process that runs twice as long as the guidance suggests, because that is what the withdrawal rate is measuring.

Capital requirements are moving in one direction, and quickly. Brazil landed at roughly ten times its consultation figure. Turkey requires TRY 500,000,000 of a custody institution. Nigeria's Securities and Exchange Commission published proposals on 20 August 2026 for ₦2 billion of minimum capital for digital asset exchanges and custodians — and that is a proposal, open for feedback, not law, a distinction several summaries have already lost. Where a number is still at consultation, assume the final one is higher.

What we could not verify

Seven things, flagged rather than smoothed over, because a reference page that hides its soft edges is worse than one that shows them.

The UK application window has no published closing date. The FCA's only stated date, 31 July 2027, is a warning rather than a deadline, and it concerns registration under the Money Laundering Regulations rather than FSMA authorisation: apply for MLR registration after it and the FCA says it is unlikely to decide before the new regime starts. Secondary coverage is losing both halves of that distinction. One law firm briefing cites an application window closing on 28 February 2027, which we could not corroborate. Check the FCA's authorisation pages before planning around any date.

Brazil's capital requirement is published as a range across the three licence categories, and we could not find a reliable public breakdown of which figure attaches to which. One English-language source gives the filing deadline as 2027; the Portuguese sources and the arithmetic — 270 days from 2 February 2026 — both give 30 October 2026, and we have gone with those.

The Turkish platform position is a negative drawn from absence. Custody licences are on the record. We searched the Board's bulletins and found no platform grant, but a bulletin we did not reach could change that. Treat it as our reading, not the Board's statement.

Both Hong Kong and Singapore entries above rest on the absence of a bill in searches to the end of August 2026. Negatives about fast-moving legislative files go stale faster than anything else on this page.

The South African figures reach us through secondary reporting of FSCA publications rather than from the FSCA's own site directly, and the sector's numbers move every quarter.

Nigeria's position is the least settled here. A recapitalisation directive reported in March 2026 and the digital-asset proposals of 20 August 2026 are being conflated in secondary coverage, and we could not verify the Central Bank's current guidance on banks serving licensed providers against a circular reference.

This page will decay. Everything above is dated so you can see how fast. If you are reading it more than a quarter after publication, check the two or three entries your decision actually depends on.

What to do with this

If you are choosing a jurisdiction, the useful question is not which regime is most favourable on paper. It is which regulator is currently authorising firms that look like yours, how long that took, and what proportion of the people who started gave up. Two of those three are usually published. The third you get by asking someone who has been through it.

If you already hold an authorisation somewhere, the thing worth checking this quarter is whether it survives. The UK's AML registration does not convert. Brazil's incumbents have until 30 October. Hong Kong proposes no deeming provisions for its next tranche, only an expedited route for incumbents. A licence obtained under a previous regime is not a licence under the next one, and that assumption has more money riding on it than any capital requirement above.

We hold no licence ourselves, which is worth saying on a page about licensing. HOPPA works with multiple licensed institutions rather than one, and our interest in this map is that clients keep asking us to read it. If we have a jurisdiction wrong, or you have been through one of these processes and the reality differed from the published version, we would rather hear it than keep publishing our version.