Will a Switzerland SRO Membership Still Be Enough After the FinIA Reform?

Today, many crypto firms in Switzerland operate with one thing: a Switzerland SRO membership. SRO means self-regulatory organisation. It is a private body, approved by the state, that checks a firm’s anti-money-laundering (AML) work.

That may change. On 22 October 2025, the Swiss Federal Council opened a consultation on a new law. The consultation ran until 6 February 2026. The proposal creates a new licence from FINMA, the Swiss financial regulator, for "crypto institutions". Firms that do crypto custody or trading for clients under an SRO today would need that licence.

If you hold an SRO membership, or plan to get one, here is what the draft says and what to do while it is still a draft.

What an SRO membership does today

Under Swiss AML law, a firm that holds or transfers other people’s money or crypto as a business is usually a "financial intermediary". It must either be supervised by FINMA or join an approved SRO.

For many crypto businesses, the SRO route is enough today. A broker that buys payment tokens such as bitcoin for clients can often operate with SRO membership alone. A wallet service that holds clients’ crypto needs a closer look, because some ways of holding it count as taking deposits. The SRO checks its AML rules, its client checks and its reporting. FINMA does not license the firm directly.

The SRO route does not cover everything. A firm that takes deposits like a bank, or deals in securities, needs a FINMA licence already. The detail of each route is on the Switzerland SRO membership page.

What the FinIA reform proposes

FinIA is the Financial Institutions Act. The Federal Council’s draft adds two new types of licensed firm.

The first is a crypto institution. Law firms that have read the draft say it covers custody of crypto for clients, trading for clients and some trading on the firm’s own account. That is the core of what many crypto firms do.

The second is a payment instrument institution. It would replace the current fintech licence and could issue stablecoins tied to one currency.

Both would be supervised by FINMA directly, not by an SRO. So a crypto broker or custodian that does this work under an SRO today would move to FINMA.

How an SRO membership and a FINMA licence differ

The two are very different in weight. Knowing the gap now helps you plan the budget and the time.

The right-hand column describes the draft and common FINMA practice. The final rules may differ once Parliament has voted.

What a FINMA file asks for that an SRO file does not

An SRO mainly wants to see that you know your clients and report suspicious activity. A FINMA licence asks a wider set of questions.

Expect to show a full business plan for the next few years. Expect to show how you keep client assets apart from your own. FINMA’s January 2026 guidance on the risks of holding crypto for clients shows how it thinks about this, although it is not a checklist for the new licence. Expect to show who in Switzerland runs the firm day to day, and how the board checks them. And expect to show risk controls for technology, including how private keys are protected.

None of this can be written in a week. A firm that starts collecting it now will be better prepared when the law passes.

What happens to firms that are SRO members now

The draft has a transition rule. It is for firms that already do the new crypto institution work, such as custody or trading for clients, under an SRO. They would have one year from the start of the new law to apply for the FINMA licence. While the application is pending, they could keep working, as long as they stay in an SRO.

That point matters. It means your SRO membership is not wasted. It is the thing that lets you keep operating while your FINMA application is checked. A firm that drops its SRO too early could lose that protection.

This is the draft, not the final law. Parliament can change the transition period and the scope.

When it could happen

No start date has been set. The draft leaves it to the Federal Council to decide. The Federal Council plans to send its formal proposal, called a dispatch, to Parliament in the second half of 2026. Parliament then debates it, which usually takes more than a year.

Several Swiss law firms expect the new rules in 2027 at the earliest. That is their estimate, not an official date. Treat any firm date you hear with care until Parliament has voted.

What to do now if you hold a Switzerland SRO membership

You do not need to change your structure today. You do need to be ready.

1. Keep your SRO membership in good order. Pass your audits and report on time. It is your bridge to the new regime.
2. List what you actually do. Custody, trading for clients, exchange and short-term trading on your own account are the kinds of work law firms say the draft covers. A pure advisory business may not be.
3. Look at your capital and your people. A FINMA licence will ask more of both than an SRO does. Start planning where the extra capital and experienced managers will come from.
4. Talk to your SRO. Most SROs follow the reform closely and will tell members what they expect.
5. Watch for the dispatch. It will show how the Federal Council changed the draft after the consultation.
6. Check your bank and your clients. Both will ask how the reform affects you. A short written plan, showing that you know the draft and when you would apply, answers them before they worry.

If you are about to buy a Swiss company with an SRO membership, ask one more question. What does the company actually do today? A company whose business falls under the draft crypto institution rules will face the FINMA step soon after you buy it. Include the cost of that step in the price you agree. Also make sure the seller hands over clean AML records and SRO audit reports.

Should you still get an SRO membership now?

For many firms, yes. The new law is not in force, and it may not be for some time. Until it is, SRO membership is the normal route for a crypto intermediary that does not take deposits or deal in securities.

The question is how you plan to grow. A firm that wants to hold large amounts of client crypto should plan for a FINMA licence from the start. A firm that needs to start trading this year may still begin with an SRO, and use the transition rule later.

Some buyers look at a company that already holds a membership. The membership does not simply pass with the shares: the SRO checks the new owners and managers, and it can end the membership. There are sometimes Swiss companies with SRO membership for sale. For firms asking whether a crypto exchange can run under an SRO at all, see which Switzerland crypto license a crypto exchange needs. For the full set-up steps from Asia, see how Hong Kong founders get a Switzerland crypto license.

Frequently asked questions

What is a Switzerland SRO membership?

It is membership of a self-regulatory organisation approved under Swiss AML law. The SRO supervises the firm’s anti-money-laundering duties instead of FINMA doing it directly.

Is the FinIA crypto institution licence in force?

No. The consultation closed on 6 February 2026. The Federal Council plans to send its proposal to Parliament in the second half of 2026, and no start date has been set.

Will SRO members have to stop working when the new law starts?

Not under the draft, if they are in scope. Firms that already do crypto institution work under an SRO would have one year to apply for the FINMA licence. They could keep working while the application is pending, as long as they stay in an SRO.

Does every crypto firm need a FINMA licence after the reform?

Not every firm. The draft targets services such as custody, exchange and trading for clients. A firm that does none of these may still only need an SRO.

Should I wait for the new law before setting up in Switzerland?

Waiting has a cost, because the law may be years away. Many firms start with an SRO membership now and plan for the FINMA step.

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*Sources: State Secretariat for International Finance press release of 22 October 2025; draft amendment to the Financial Institutions Act, October 2025; Federal Council objectives for 2026.*

How Hong Kong Founders Get a Switzerland Crypto License in 2026

A Hong Kong team that wants a European base often looks at Switzerland first. The country has clear crypto rules, stable banks and a long history of regulated finance. But a Switzerland crypto license is not one document you apply for. It is a set of steps, done roughly in this order, mostly in Switzerland.

This guide walks through those steps for a team starting from Hong Kong. It also covers one change this year. On 12 January 2026, FINMA, the Swiss financial regulator, published new guidance on holding crypto for clients.

Step 1: Decide what your business will do

Everything depends on this. Swiss law treats crypto businesses differently based on the activity, not the label.

Write down, in plain words, each service you will offer. For example:

• buying and selling crypto for clients
• holding clients’ crypto or their private keys
• running a platform where clients trade with each other
• issuing a token
• giving advice only

A broker of payment tokens, such as bitcoin, often starts under anti-money-laundering (AML) rules only. Holding clients’ crypto is where founders slip. If you pool it, or can use it as you like, it can count as taking deposits, and that needs a FINMA licence. A business that deals in tokens that act like securities, or runs a trading venue, also needs a FINMA licence. Getting this wrong at the start is the most expensive mistake a founder can make.

Step 2: Choose your route

For most crypto firms, there are two routes today.

The first is membership of a self-regulatory organisation, or SRO. An SRO is a private body, approved by the state, that supervises a firm’s AML work. It is the usual route for brokers of payment tokens and for payment firms. It covers AML only, not deposits or securities. The details are on the Switzerland SRO membership page.

The second is a licence from FINMA itself, such as a banking or securities firm licence. It is needed for heavier activities and takes much longer.

A third route is coming. Switzerland plans a new FINMA licence for "crypto institutions". It is still a draft. Our guide on whether a Switzerland SRO membership will still be enough after the FinIA reform explains what the draft means for a new firm.

Step 3: Set up the Swiss company

You will need a Swiss company. Most crypto firms choose a GmbH, a limited liability company, or an AG, a company limited by shares. Your adviser will explain which suits your plan and your investors.

Three points catch Hong Kong teams out:

• Swiss company law requires at least one person who can sign for the company to live in Switzerland. Your Hong Kong directors cannot fill this role from Hong Kong.
• You need a real Swiss address. A regulator and a bank will both want to see where the business is run.
• Documents from Hong Kong, such as company records and passports, usually need certified copies. Many also need an apostille, which is an official stamp that proves a document is genuine abroad.

Plan for the time these take. Collecting certified documents from Hong Kong, and sending them to Switzerland, adds weeks.

Step 4: Open a Swiss bank account

This is often the slowest step. Swiss banks ask detailed questions about crypto businesses. They want to know who owns the company, where the money comes from, who your clients are and which regulator covers you.

Start talking to banks early, while you are still setting up the company. Have a clear business plan, a list of your owners and a draft of your AML policy ready. A bank that sees a well-prepared file is more likely to say yes.

Your SRO membership, or your plan to get one, helps here. It shows the bank that someone will supervise your AML work.

Step 5: Build your AML set-up

Whichever route you choose, AML sits at the centre. You will need:

• an AML policy written for crypto, not copied from a bank
• a named AML officer who knows Swiss rules
• a process to check each client’s identity
• a process to check where crypto comes from, often with a wallet screening tool
• a way to report suspicious activity to the Swiss authorities

The SRO will review all of this before it accepts you. FINMA does the same for a licence.

Step 6: Plan how you will hold client crypto

If you will hold clients’ crypto, read FINMA’s January 2026 guidance on the risks of holding crypto for clients. FINMA says it "sets out the rules that institutions must abide by in order to keep cryptobased assets safe". It is written for supervised institutions, but it shows what FINMA looks for in any custody set-up.

In practice, that means clear answers to a few questions. Who controls the private keys? Are clients’ assets kept apart from the firm’s own? What happens to clients’ crypto if the firm fails? A plan that answers these makes both the SRO and the bank more comfortable.

Step 7: Apply, then keep up

With the company, bank, AML set-up and custody plan in place, you apply to your SRO or to FINMA. After you are accepted, the work does not stop. SRO members face regular AML audits, and FINMA firms face wider audits.

If you already hold a Hong Kong licence

Some teams already run a licensed business in Hong Kong, such as a Money Service Operator (MSO). That licence does not carry over to Switzerland. Each country licenses the firms that work inside it, so the Swiss company starts its own process.

Your Hong Kong history still helps. A team that has run an AML programme under a Hong Kong licence has some track record to show. Be clear about what that licence covers. An MSO licence from Customs is for money changing and remittance, not for crypto, so present it as AML experience and nothing more. Give the SRO or FINMA a copy of the licence and your AML audit results.

Be ready for one question in particular: how the two companies connect. If the Swiss company will serve clients that the Hong Kong company brings in, explain who does the client checks, and where the records are kept. A clear answer here saves a round of questions later.

How long does it take from Hong Kong?

No Swiss authority publishes a standard time for this whole process. The answer depends on your route, your bank and how ready your documents are. An SRO route is usually much faster than a FINMA licence. Any adviser who gives you a fixed number of weeks should tell you what it assumes.

Some founders look at buying a company that already has an SRO membership. The membership does not simply pass to you with the shares. A new owner is a change of control, so the SRO checks the new owners and managers again, and it can end the membership. You can see current Swiss companies with SRO membership for sale. If your plan is a crypto exchange, read which Switzerland crypto license a crypto exchange needs first, because exchanges face different rules.

Frequently asked questions

Can a Hong Kong company get a Switzerland crypto license?

Not directly. You set up a Swiss company, with at least one signing person living in Switzerland, and that company joins an SRO or applies to FINMA.

Do I need to live in Switzerland to run a Swiss crypto company?

You do not, but someone who can sign for the company must live there. Many founders appoint a Swiss resident director.

Is SRO membership a crypto license?

No. It is anti-money-laundering supervision, not a licence. It is the usual route for brokers of payment tokens. Taking deposits, including some ways of holding client crypto, or dealing in securities needs a FINMA licence.

What did FINMA publish about crypto custody in 2026?

On 12 January 2026, FINMA published guidance on the risks of holding crypto-based assets for clients. FINMA says it sets out the rules supervised institutions must follow to keep those assets safe.

Is opening a Swiss bank account hard for a crypto company?

It can be slow. Banks ask detailed questions about owners, funds, clients and supervision. A clear business plan and AML policy make it easier.

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*Sources: FINMA news release of 12 January 2026 on the custody of crypto-based assets; State Secretariat for International Finance press release of 22 October 2025.*

Which Switzerland Crypto License Does a Crypto Exchange Need Today?

There is no single Switzerland crypto license for exchanges. Swiss law looks at what your exchange actually does. Does it hold clients’ money? Does it hold their crypto? Does it trade securities in token form? Each answer points to a different route, from a simple membership to a full banking licence.

The rules are also about to change. On 22 October 2025, the Federal Council opened a consultation on a new licence for "crypto institutions". Law firm Loyens & Loeff, reading the draft, says its scope "also encompasses cryptocurrency exchange services". So an exchange planning for 2027 and beyond needs to understand both the current routes and the new one.

First, describe your exchange in plain words

Before you look at any licence, answer four questions.

1. What do users trade? Payment tokens such as bitcoin, or tokens that act like shares or bonds?
2. Do users trade with you, or with each other through your order book?
3. Do you hold users’ crypto or money between trades?
4. Do you pay interest, lend or invest what users leave with you?

Swiss law does not care what you call your business. It cares what the business does. Your four answers decide your route.

Route 1: SRO membership, for a simple exchange

Under the Swiss Anti-Money Laundering Act, a firm that handles other people’s assets as a business is a "financial intermediary". FINMA explains that such firms "must become members of a self-regulatory organisation (SRO)" to meet their anti-money-laundering duties, unless FINMA supervises them directly.

For many exchanges of payment tokens, this is the starting point. A broker that buys and sells bitcoin for clients, and sends it straight to their own wallets, usually works under an SRO. The SRO checks its client checks, its screening of crypto transfers and its reporting.

SRO membership covers anti-money-laundering duties. It is not a licence to take deposits, lend or run a securities market. The detail of this route is on the Switzerland SRO membership page.

Route 2: the FinTech licence, when you hold client assets

Many exchanges hold users’ money or crypto between trades. That can change the answer.

The key question is whether you are taking "public deposits". That is the business Swiss banking law controls.

Swiss francs that clients leave with you, and that you owe back to them, are the clearest case of a deposit. Crypto can be a deposit too. It depends on how you hold it. Crypto kept apart for each named client, which the client still owns and which stays outside your company if it fails, is usually not a deposit. That kind of custody often stays on the anti-money-laundering route. Crypto mixed in one shared pool that you can use as you like is closer to a deposit.

FINMA’s FinTech licence covers the deposit case up to a limit. FINMA says it "allows institutions to accept public deposits of up to CHF 100 million or cryptobased assets, provided that these are not invested and no interest is paid on them". The CHF 100 million limit applies in total, whether the deposits are francs or crypto. Above that limit, the exchange needs a banking licence.

How you hold each asset decides the route. This is exactly the kind of point to settle with a Swiss lawyer before launch.

Route 3: a banking licence, for interest and investing deposits

If your exchange pays interest on client deposits, or lends or invests those deposits, the FinTech licence no longer fits. The same applies once deposits pass CHF 100 million. These cases need a full banking licence from FINMA. Lending your own money or your own coins is a different question from lending clients’ deposits. It is the heaviest route, with strict rules on capital, staff and risk control. Very few new crypto exchanges start here.

Route 4: a DLT trading facility, for tokenised securities

Some platforms trade tokens that are really securities, such as tokenised shares or bonds. FINMA says a DLT trading facility licence "allows for multilateral trading of DLT securities". DLT means distributed ledger technology, the systems that blockchains run on.

This licence is not for a normal bitcoin exchange. It is for a market in securities issued on a blockchain. It is a full FINMA authorisation under the Financial Market Infrastructure Act.

Each Switzerland crypto license route, side by side

This is a simplified guide. Your own facts, and how your contracts are written, decide the real answer.

What the FinIA reform changes for exchanges

The draft amendment to the Financial Institutions Act (FinIA) adds a licence for crypto institutions. Loyens & Loeff describe its scope as custody of crypto-based assets, "client trading and short-term proprietary trading which also encompasses cryptocurrency exchange services".

In practice, that means many exchanges that run under an SRO today would move to direct FINMA supervision. Firms that already do this work under an SRO would get one year from the start of the law to apply. They could keep working while the application is pending, as long as they stay in an SRO. Our guide on the FinIA reform and Switzerland SRO membership covers that transition.

No start date has been set. The consultation closed on 6 February 2026, and Parliament still has to debate the proposal.

One exchange, three stages

Here is how the route can change as one exchange grows.

At the start, the exchange lets users buy bitcoin with Swiss francs. It sends the bitcoin straight to each user’s own wallet. It holds nothing overnight. It joins an SRO and runs its anti-money-laundering checks.

A year later, users ask to keep a balance on the exchange so they can trade faster. Now the exchange holds their francs and their bitcoin. It does not lend them or pay interest. This is the point to check whether the FinTech licence is needed. The team asks a Swiss lawyer before the feature goes live, not after.

Two years in, the exchange wants to offer interest on balances. Paying interest on client deposits takes it outside the FinTech licence, even if the interest comes from its own money. It now needs a banking licence. The team either drops the idea or plans for that much bigger licence.

The same company, with the same name and the same users, can sit under three different routes. The trigger each time is a new feature. So build a habit: before any new feature, ask whether it changes what you hold or what you do with it.

Mistakes exchanges make in Switzerland

The first is starting under an SRO and then adding client balances without checking the rules again. The route that fitted on day one may not fit after a new feature.

The second is treating a token as a payment token without checking. If it behaves like a share, the securities rules apply.

The third is underestimating banking. Even with the right authorisation, a Swiss bank must agree to hold the exchange’s money. Start that conversation early.

Where to go next

If you are setting up from Asia, how Hong Kong founders get a Switzerland crypto license walks through the company, director and bank steps. If speed matters, look at Swiss companies with SRO membership for sale.

Frequently asked questions

Do I need a licence to run a crypto exchange in Switzerland?

Not always a FINMA licence. Every crypto exchange needs anti-money-laundering supervision, usually through SRO membership. A FINMA licence comes in when you take public deposits or trade tokenised securities.

Is SRO membership enough for a crypto exchange in Switzerland?

It can be for an exchange that takes no public deposits and does not trade securities. If you hold client francs or pooled crypto, you may need a FinTech licence.

What does the Swiss FinTech licence allow?

It lets a firm accept public deposits, in francs or crypto, up to CHF 100 million in total. The deposits must not be invested, and no interest may be paid on them.

What is a DLT trading facility in Switzerland?

It is a FINMA licence for multilateral trading of DLT securities, meaning securities issued on a blockchain. It is not needed for a normal bitcoin exchange.

Will the FinIA reform create a crypto exchange licence?

The draft creates a crypto institution licence whose scope includes cryptocurrency exchange services. It is not in force, and no start date has been set.

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*Sources: FINMA pages on self-regulatory organisations, the FinTech licence and DLT trading facilities; State Secretariat for International Finance press release of 22 October 2025; Loyens & Loeff, "FinIA reform: new licences for payment and crypto-institutions", 27 October 2025.*

Before You Sell a Crypto License Company in the EU, Gather These Records

If you own an EU crypto company with a MiCA licence, this may be a good time to sell. On 1 July 2026, the last grace period under MiCA, the EU’s crypto law, ended. Firms that were relying on national rules, and are not authorised, must now wind down that unlicensed EU business. Some of them would rather buy a licensed company than wait for their own.

But you cannot simply sell a crypto license like a car. The regulator must approve the buyer. And a good buyer will check your company closely before they sign. Sellers who have their records ready get better offers and close faster.

You have a duty too, not only the buyer

Most guides talk about the buyer’s side. MiCA also puts a duty on the seller.

Under Article 83(2) of MiCA, anyone who plans to sell a qualifying holding must tell the regulator first. The seller must "notify in writing the competent authority of its decision and indicate the size of such holding". A qualifying holding means at least 10% of the capital or voting rights, held directly or indirectly, or a holding that gives significant influence over the firm’s management.

You must also tell the regulator if your stake will drop below 10%, 20%, 30% or 50%, or if the company will stop being your subsidiary.

The buyer then files its own notice and waits for approval. The regulator has 60 working days to assess the buyer, counted from when it confirms in writing that it has the buyer’s notice. Its questions can pause that clock, usually for up to 20 working days. Our guide on what the EU checks when you buy a crypto license company covers that side of the deal.

Why buyers are careful

A buyer is not paying for a piece of paper. They are paying for a company that the regulator trusts. If that trust has problems, the buyer inherits them.

So a buyer asks three questions. Is the licence clean? Will the regulator approve me? And will the company keep its licence after I take over? Your records answer all three.

The records a buyer will ask for

Gather these before you list the company. Put them in one folder, in this order.

The licence itself

• The regulator’s decision granting the MiCA authorisation.
• The list of services the licence covers, such as custody or exchange.
• The company’s entry on ESMA’s register of crypto-asset service providers.
• Any conditions the regulator attached to the licence.

Every letter with the regulator

• All correspondence since the licence was granted.
• Any findings, warnings or requests for changes, and how you answered them.
• Any open questions the regulator is still waiting on.

This is the folder buyers care about most. A finding that was fixed and closed is fine. A finding that is still open can stop a deal.

Your people

• The current directors and key managers, with their CVs.
• Who holds the compliance and anti-money-laundering (AML) roles.
• Which of these people will stay after the sale, and for how long.

The licence depends on real people doing real jobs. If your compliance officer is leaving, say so early and have a plan.

Your AML set-up

• Your AML policy and risk assessment.
• Your last internal and external AML audit reports.
• Your process for reporting suspicious transactions. Do not share the reports themselves, or say whether any were made. EU tipping-off rules forbid telling a third party, and a buyer is a third party.

Money and capital

• Financial statements for the last two or three years.
• Proof that you meet MiCA’s capital rules today.
• A list of any debts, guarantees or open disputes.

Clients and contracts

• How many active clients you have, and in which countries.
• Your main contracts with banks, custodians and technology providers.
• Any outsourcing, and whether the regulator was told about it.

Common reasons a sale falls apart

Sales fail for a few repeated reasons. The licence covers fewer services than the buyer needs. The company has open issues with its regulator. Key staff leave during the sale. Or the buyer cannot pass the regulator’s own checks.

You control the first three. Check the licence scope against what buyers want. Close open findings before you list. And agree with key staff that they will stay through the approval period.

You do not control the fourth, but you can protect yourself. Ask early about the buyer’s owners, source of funds and management team. A buyer who cannot answer those questions for you will not answer them for the regulator either.

What moves the price

No authority publishes prices for licensed crypto companies, so each deal is priced on its own facts. Still, buyers look at the same things.

The first is the licence scope. A company licensed for several services, such as custody and exchange, is worth more to most buyers than one licensed for advice only.

The second is the country. Buyers weigh how the local regulator works, how long its reviews take and how easy banking is there.

The third is how alive the company is. A company with staff, systems, a bank account and some real clients is a working business. A company with a licence and nothing else is an empty company, and a regulator may ask hard questions about whether the licence should stay.

The fourth is how clean the records are. A buyer who finds gaps will either lower the offer or walk away. Clean records do not raise the price much. Missing records can cut it a lot.

When to start preparing

Start before you tell anyone you want to sell. Gathering the records above can take weeks, especially the letters with the regulator and the audit reports.

Starting early also shows you the problems first. If an old finding is still open, you have time to close it before a buyer sees it. Then the buyer sees a problem that is already fixed, not one that is still open.

How a sale usually runs

1. You prepare the records above and set a price.
2. You list the company or approach buyers directly.
3. A buyer checks your records and agrees terms with you.
4. You notify the regulator of your decision to sell. The buyer files its own notice.
5. The regulator assesses the buyer.
6. Once the regulator approves, or does not oppose in time, the sale closes.

No EU authority publishes an average price or an average time for these sales. The time depends mostly on how fast the regulator can assess the buyer.

Where to list the company

Licensed companies can be offered to buyers through the sell your licence page. Buyers browse the current licensed companies for sale by country and licence type. For help preparing the records and the regulator notices, see support to buy or sell a licensed crypto company.

Frequently asked questions

Can I sell a crypto license in the EU?

You can sell a company that holds a MiCA licence. The licence stays with the company, and the regulator must approve the new owner.

Do I need to tell the regulator before I sell?

Yes. Under Article 83(2) of MiCA, you must notify the regulator in writing before you sell a qualifying holding, and state its size.

How long does it take to sell a licensed crypto company in the EU?

The regulator has 60 working days from its written confirmation of the buyer’s notice, and questions can pause that clock for up to 20 working days in most cases. Preparing records and agreeing terms adds more time.

What records do buyers want when I sell a crypto license company?

The licence decision, all letters with the regulator, details of your people, AML audits, financial statements and your key contracts.

Can the regulator block the sale?

Yes. If the regulator opposes the buyer, the buyer cannot take the qualifying holding.

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*Sources: Regulation (EU) 2023/1114 (MiCA), Articles 3, 83 and 84; ESMA public statement of 23 June 2026.*

Is an Offshore Crypto License Enough for a Business With Hong Kong Clients?

Is an offshore crypto license enough if many of your clients live in Hong Kong? It’s a fair question for a small team. A registration in El Salvador or Canada can look faster and cheaper than a Hong Kong licence. But Hong Kong’s rules look at where you run the business and who you market to. Where your company is registered does not settle it.

The Hong Kong licence also changed this year. On 11 February 2026, the Securities and Futures Commission (SFC) set out a framework for licensed trading platforms to offer perpetual contracts. These are leveraged crypto derivatives, and the SFC says they should only be offered to professional investors. It is part of the SFC’s plan to widen the range of products that licensed platforms can offer.

For a team weighing offshore against Hong Kong, this means the product list is no longer a fixed reason to stay out. Check the SFC’s current position on the product you plan to offer before you decide.

Where each licence applies

A licence works in the place that issued it. An offshore licence covers that country, and a Hong Kong licence covers business in Hong Kong.

So before asking which licence is easier to get, look at where your clients are and where you look for new ones. If the answer includes Hong Kong, Hong Kong’s rules apply to that part of your business, whatever else you hold.

Take a small team with a company in El Salvador, a sales office in Hong Kong and a website in Chinese and English. Its El Salvador registration covers clients in El Salvador. Its Hong Kong clients, and the marketing aimed at them, fall under Hong Kong’s rules.

What an offshore crypto license covers

"Offshore" here means a licence or registration from a place outside your main market. Two are common for small crypto teams.

The first is El Salvador. Its Digital Assets Issuance Law took effect in 2023 and set up the National Commission of Digital Assets (CNAD). Crypto firms register with CNAD as digital asset service providers. A review of the law by Global Financial Integrity, a research group, said this registration lets a firm "offer services only within El Salvador’s jurisdiction". That limit is covered in more detail in whether an El Salvador licence can cover clients abroad.

The second is Canada. There, firms that deal in virtual currencies register with FINTRAC as a money services business (MSB). A firm with no office in Canada that serves Canadian clients registers as a foreign MSB. FINTRAC checks that these firms keep records, know their clients and report certain transactions. It also says it does not regulate them beyond that law, and "cannot offer any assessment of their business practices".

Both are real registrations with anti-money laundering duties, but neither one says anything about clients in Hong Kong.

What Hong Kong asks of a platform with Hong Kong clients

The SFC publishes lists of trading platforms "operating in Hong Kong or actively marketing their services to Hong Kong investors". That wording is the test. You don’t need an office in Hong Kong to fall inside it. Marketing to Hong Kong investors can be enough.

The SFC urges investors to trade "ONLY on SFC-licensed virtual asset trading platforms", and it warns about unregulated overseas platforms. A Hong Kong client who reads those warnings will look for your name on the SFC’s list, not on a register in another country.

Hong Kong does not have one licence for all crypto work. The main tracks are:

• A trading platform licence from the SFC.
• A money service operator (MSO) licence from the Customs and Excise Department, for money changing and remittance.
• A stablecoin issuer licence from the Hong Kong Monetary Authority (HKMA).
• New licences for crypto dealers and custodians, which the government is still turning into law.

The SFC licensing framework for trading platforms explains how the platform licence works. If your plan includes remittance or money changing, the Hong Kong MSO licence is the separate track for that.

Offshore and Hong Kong side by side

Three mistakes to avoid

First, marketing to Hong Kong clients on an offshore licence. Some sellers call an offshore licence "global", but the SFC’s test looks at who you market to, not at where the licence came from.

Second, using an MSO licence for crypto trading. An MSO licence covers money changing and remittance. It does not cover running a crypto trading platform.

Third, waiting for the dealer and custodian licences before you prepare. In its consultation conclusions of December 2025, the government said it does not plan a deeming arrangement for existing dealers. So existing dealers should not expect to keep working as if licensed while they apply. The same conclusions set a target of putting the bill to the Legislative Council in 2026.

If you already hold an offshore licence

You don’t have to give up an offshore licence. It still works for its own market. But you should sort your business by market, and do it early.

1. List where your current clients live and where new clients come from.
2. Check your website, social media and sales materials. Do any of them speak to Hong Kong investors?
3. For each activity that touches Hong Kong, name the Hong Kong licence that covers it. If there is none, that is the gap to fix.
4. Get your papers ready: a group chart up to the final owners, proof of where the money comes from, CVs of directors and key staff, and an anti-money laundering manual written for your business.

A simple way to choose

Ask four questions.

1. Where are most of your clients? If the answer is Hong Kong, start with the Hong Kong licence.
2. What does your business do? A trading platform, dealing, remittance and stablecoin issuing each have their own track.
3. Do you plan to offer derivatives such as perpetual contracts? In Hong Kong, that now runs through a licensed platform, and the SFC asks interested platforms to submit their product structure for review.
4. Do you also serve clients in other countries? Then an offshore licence can sit beside the Hong Kong one, for that other market.

The answer may be a mix: one licence for each market you really serve. The El Salvador crypto license application and Canada MSB registration pages explain the offshore steps, if that is part of your plan. If you’re not sure which mix fits, map it out with a team that handles crypto license applications in several countries before you file anything, so each market has its licence from the start.

Frequently asked questions

Can an offshore crypto license be used in Hong Kong?

It does not replace a Hong Kong licence. An offshore licence covers the country that issued it. A platform that operates in Hong Kong or markets to Hong Kong investors falls under Hong Kong’s rules.

Do I need an office in Hong Kong to need a Hong Kong licence?

Not always. The SFC’s lists cover platforms operating in Hong Kong or actively marketing to Hong Kong investors. Marketing alone can bring a platform inside the rules.

What changed for Hong Kong licensed platforms in 2026?

On 11 February 2026, the SFC set out a framework for licensed trading platforms to offer perpetual contracts. They are for professional investors only, and the SFC asks interested platforms to submit their proposed product structure for review.

Is a Canada MSB registration a licence to run a crypto exchange?

It is a registration with FINTRAC, Canada’s financial intelligence agency. FINTRAC checks duties such as record keeping, client checks and reporting. It says it does not regulate these businesses beyond that law.

Can an El Salvador licence serve Hong Kong clients?

Not on its own. A review of El Salvador’s law found the registration covers services within El Salvador. Clients in Hong Kong fall under Hong Kong’s rules.

Does an MSO licence cover crypto trading?

No. An MSO licence from Customs covers money changing and remittance. A crypto trading platform needs a licence from the SFC.

What Hong Kong’s Planned Crypto License for OTC Dealers Means for You

If your company buys and sells crypto for clients over the counter in Hong Kong, a new crypto license is coming for you. On 24 December 2025, the Financial Services and the Treasury Bureau (FSTB) and the Securities and Futures Commission (SFC) said how they will license virtual asset dealers. They aim to send the bill to the Legislative Council (LegCo) in 2026.

One point in the paper matters most. Existing dealers will not get a "deeming arrangement". That means no temporary licence while your application is checked.

What an OTC desk is, and why it was outside the rules

An OTC desk, or over-the-counter desk, trades crypto directly with a client. There is no public order book. A client wants to sell bitcoin for Hong Kong dollars, and the desk quotes a price and settles the trade.

Since 2023, the SFC has licensed virtual asset trading platforms. Those are exchanges that match many buyers and sellers. A desk that trades ordinary crypto directly with each client was generally not covered by that licence. Crypto that counts as a security is a different case, already covered by securities rules. Many desks worked under a Money Service Operator (MSO) licence from the Customs and Excise Department instead. That licence covers money changing and remittance. It was never built for crypto dealing.

The new regime closes that gap.

What the new crypto license will cover

The government’s conclusions describe two new licences.

The first is for virtual asset dealing. The FSTB paper says the scope will be revised "to align with the scope of Type 1 regulated activity". Type 1 is the licence for dealing in securities. So a crypto dealer will be treated much like a securities dealer.

The second is for virtual asset custody. The SFC said this regime will focus on the risk of keeping clients’ private keys safe. A private key is the secret code that controls a crypto wallet. If you hold keys for clients, you will need this licence.

Some firms will need both. A desk that trades for clients and also keeps their coins overnight is doing both jobs.

Three desks, three different answers

It helps to test the rules against real business models. Here are three common ones.

A desk that quotes a price, takes the client’s Hong Kong dollars and sends the coins to the client’s own wallet the same day is dealing. It does not hold keys for the client. It will most likely need the dealing licence and nothing more.

A desk that trades for clients and then keeps their coins in wallets it controls is dealing and holding keys. It will most likely need both licences. It could also move custody to a firm that holds the custody licence, and keep only the dealing one.

A firm that only changes Hong Kong dollars into US dollars, and never touches crypto, is not a crypto dealer at all. The MSO licence is still the one that applies to it.

These are general cases. Your own activity map, the first step below, decides which one you are.

No deeming arrangement: the part that changes your plans

When the SFC licensed trading platforms in 2023, existing platforms had time to apply while they kept running. This time the FSTB says it does "not plan to grant a deeming arrangement to existing VA dealing service providers". The custodian paper says the same for custodians.

The same paper says "the licensing regime will take full effect on the commencement date". It calls this a "hard" commencement date. In plain terms, existing desks will not be treated as licensed while their applications are checked. A desk that is not licensed when the regime starts would have to stop that dealing.

The government also says it will choose a start date that gives the market time to adjust. So there should be a gap between the law passing and the regime starting. Use that gap. The date is not known yet. The government has said only that the bill should go to LegCo in 2026, and no bill had been introduced by late September 2026.

What we do not know yet

Several details are not published in final form. Be careful with any guide that states them as fact.

• The start date. It will be set by the bill or by a later notice.
• The exact capital figures. The consultation papers discuss them. The final numbers will be in the law and the SFC’s rules.
• The fee and the processing time. The SFC has not published a service time for these new licences.

If an adviser gives you a firm number for any of these today, ask them where it comes from.

Five things to prepare now

You cannot apply until the SFC opens applications under the new law. You can build most of the file now, because the dealing rules are set to follow the Type 1 model.

1. Map your activities. Write down every service you offer. Do you only quote and trade? Do you hold client coins or keys? Do you offer credit? Each answer points to a different licence.
2. Pick your responsible officers. A Type 1 firm needs licensed people who run the business. Check who in your team has the experience and clean record the SFC will look for.
3. Write your anti-money-laundering (AML) manual for crypto. An MSO manual built for cash remittance will not be enough. It needs wallet screening and a process for the "travel rule", which means passing sender and receiver details with each transfer.
4. Sort out custody. If you keep client coins, decide now whether you will hold the keys yourself or use a custodian that will be licensed.
5. Check your bank. Your bank will want to know your licence plan. Talk to them before the bill is published, not after.

If your business is mainly exchange of fiat money, compare this with a Hong Kong MSO licence. Some firms will keep the MSO for fiat and add the new licence for crypto.

How this fits with the rest of Hong Kong’s crypto rules

Hong Kong now licenses crypto through several different doors. The SFC licenses trading platforms, and our overview of how the SFC licenses crypto trading platforms explains that route. The Hong Kong Monetary Authority (HKMA) licenses stablecoin issuers. Customs licenses MSOs. The new dealer and custodian licences will add two more.

Choosing the wrong door wastes months. Our guide on whether your Hong Kong company needs a crypto license or an MSO licence compares the two most common choices side by side.

If you would rather not build the file alone, crypto licensing support can take a desk through the activity map and the officer checks while the bill is still in draft.

Frequently asked questions

Do I need a crypto license in Hong Kong for OTC trading?

Not yet under a dedicated regime. The government plans a new licence for virtual asset dealers, and it aims to put the bill to LegCo in 2026. Once the law starts, OTC dealing with Hong Kong clients will need it.

Will existing OTC desks get time to apply after the law starts?

Not while applications are checked. The FSTB said it does not plan to grant a deeming arrangement to existing dealers, and the regime takes full effect on its start date. The government says it will set that date with time for firms to prepare.

Is an MSO licence enough for a crypto OTC desk?

An MSO licence covers money changing and remittance. It is not a licence for dealing in virtual assets. Under the new regime, crypto dealing will need its own licence.

What is a virtual asset custodian licence?

It is a planned licence for firms that keep clients’ private keys in Hong Kong. The SFC said the regime will focus on the risks of safekeeping those keys.

When will the new Hong Kong dealer licence start?

No start date has been published. The government’s target is to introduce the bill in 2026, and the bill will set out when the licence starts.

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*Sources: FSTB and SFC consultation conclusions on virtual asset dealing and custodian services, and the Hong Kong government press release of 24 December 2025.*

Does Your Hong Kong Company Need a Crypto License or an MSO Licence?

A founder in Hong Kong often starts with one question: crypto license or MSO licence? The two sound close. They are not. Each one covers a different kind of business, and each comes from a different regulator.

The choice got one step harder this year. On 10 April 2026, the Hong Kong Monetary Authority (HKMA) granted the city’s first licences to issue stablecoins. So Hong Kong now has three separate licensing tracks that a crypto or payments firm may run into.

The short answer

Look at what moves through your business.

If you run a money changing or remittance service for customers, such as changing their Hong Kong dollars into US dollars or sending their money abroad, you need an MSO licence. Paying your own suppliers abroad is not a money service. Banks are outside this licence.

If you run a platform where people trade virtual assets such as bitcoin, you need a crypto license from the Securities and Futures Commission (SFC). Other crypto activities, such as over-the-counter dealing and holding clients’ keys, are set to get their own licences.

If you issue a stablecoin tied to a currency, you need an HKMA stablecoin issuer licence.

Many firms do more than one of these. They need more than one licence.

What an MSO licence covers

MSO stands for Money Service Operator. The Customs and Excise Department issues the licence. Its own guidance says "a person who or an institution which operates a money changing service or a remittance service is a Money Service Operator".

So an MSO licence covers two things:

• Money changing, which means exchanging one currency for another.
• Remittance, which means sending money to another person or place for a client.

It does not cover crypto trading. Some firms have used an MSO licence while also touching crypto. That leaves a gap, and the government is closing it with new licences for crypto dealers and custodians.

A full walk-through of the application is on the Hong Kong MSO licence page. If time matters more than setting up from scratch, there is also the option of an existing Hong Kong MSO company for sale.

What a crypto license covers in Hong Kong

In Hong Kong, "crypto license" usually means the SFC licence for a virtual asset trading platform. The SFC says centralised virtual asset trading platforms doing business in Hong Kong "are required to be licensed and regulated by the SFC".

A trading platform is a service that matches buyers and sellers of crypto. It is a heavy licence. The SFC checks your systems, your custody of client assets, your managers and your capital.

Two more crypto licences are planned. One is for dealers, such as over-the-counter desks. The other is for custodians who hold clients’ private keys. Our guide to Hong Kong’s planned crypto license for OTC dealers explains who they will catch and why existing firms will not be treated as licensed while they apply.

The two side by side

The table shows the main scope only. The detail, such as who must hold a licence and what each regulator checks, is in the law and in each regulator’s own guidance.

How the stablecoin licence compares

The Stablecoins Ordinance came into force in August 2025. It created a licence for issuers of stablecoins that are tied to a fiat currency, such as the Hong Kong dollar. The HKMA runs it.

The first two licences went to Anchorpoint Financial Limited and The Hongkong and Shanghai Banking Corporation Limited. The HKMA keeps a public register of licensed stablecoin issuers, and it is the place to check the current list.

If your plan uses a stablecoin but does not issue one, you do not need the issuer licence. But the Stablecoins Ordinance also limits who may offer certain stablecoins to the public, so selling or distributing one needs a legal check. You may still need an MSO licence or a crypto license for the rest of what you do.

Four businesses, four answers

A firm that changes cash and sends money to mainland China and the Philippines needs an MSO licence. It does not touch crypto.

A firm that runs an app where users trade bitcoin with each other needs an SFC crypto license. If it also sends users’ fiat abroad, it may need an MSO licence as well.

An OTC desk that sells crypto to clients for Hong Kong dollars is in between today. It will need the new dealer licence once that law starts.

A payment firm that pays suppliers abroad and sometimes settles in stablecoins needs an MSO licence for the remittance. The stablecoin part needs its own legal check.

These are general cases, not legal advice. The exact answer depends on how your money and assets flow.

Three mistakes that cost founders months

The first mistake is applying for the licence you have heard of, not the one you need. An MSO licence is quicker to get than an SFC licence, so some founders start there. If the business is really a crypto platform, the MSO licence will not cover it, and the work has to be redone.

The second mistake is ignoring the bank. A licence does not open a bank account for you. Banks in Hong Kong ask what you do, who your clients are and which licence covers it. A bank that sees crypto activity under an MSO licence may close the account.

The third mistake is planning for today’s rules only. The dealer and custodian licences are still coming. A desk that sets up this year under an MSO licence should plan now for the day the new law starts, because existing desks will not be treated as licensed while they apply.

What each regulator will look at

Each regulator checks different things, but some checks are the same.

All three want to know who owns the company and who runs it. All three want an anti-money-laundering (AML) programme that fits the business. That means checking clients, watching for odd payments and reporting suspicious ones.

The SFC and the HKMA also look closely at how client assets are kept safe. For a crypto platform, that means how private keys are stored. For a stablecoin issuer, it means how the reserve assets are held.

Customs looks closely at the people. It checks that the owners and managers are "fit and proper", which means honest, competent and financially sound.

Questions to answer before you apply

Write down the answers to these before you speak to any adviser.

1. Do clients give you money that you send to someone else?
2. Do you exchange one currency for another?
3. Do you hold or trade crypto for clients?
4. Do you hold clients’ private keys?
5. Do you plan to issue your own coin or token?

A "yes" to 1 or 2 points to an MSO licence. A "yes" to 3 or 4 points to a crypto license. A "yes" to 5 needs a separate check. If you want a second view on your answers, licensing support across these tracks can map them to the right application.

Frequently asked questions

What is the difference between an MSO licence and a crypto license in Hong Kong?

An MSO licence from Customs covers money changing and remittance. A crypto license from the SFC covers running a virtual asset trading platform. They cover different businesses.

Can an MSO licence be used for crypto trading in Hong Kong?

No. An MSO licence covers money changing and remittance only. Crypto trading needs a licence from the SFC, and new licences for crypto dealers are planned.

Who issues the MSO licence in Hong Kong?

The Customs and Excise Department issues it and supervises licensed Money Service Operators.

Do I need a stablecoin licence to use stablecoins in payments?

The HKMA licence is for issuing a stablecoin tied to a fiat currency. Offering someone else’s stablecoin to the public is also restricted, and you may still need an MSO licence for the payment part.

Can one company hold an MSO licence and a crypto license?

Yes. A company that sends money for clients and also runs a crypto platform may need both, each from its own regulator.

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*Sources: HKMA press release of 10 April 2026; Customs and Excise Department MSO guidance; SFC guidance on virtual asset trading platforms.*

Is a Crypto License Required to Run a Crypto Card Programme in Hong Kong?

A crypto card lets a user hold crypto and spend it at a shop like any other card. For a founder in Hong Kong, the hard part is the licences. The honest answer to "do I need a crypto license?" is: sometimes, and usually not only that one.

The picture changed this year. Hong Kong’s Stablecoins Ordinance came into force in August 2025. On 10 April 2026, the Hong Kong Monetary Authority (HKMA) granted the first licences to issue stablecoins. A card funded with stablecoins now has to think about a licence that did not exist a year ago.

Start with how money moves through your card

Every card programme has the same few moving parts. Draw them out before you ask about licences.

1. The user tops up the card, with Hong Kong dollars, crypto or stablecoins.
2. Someone holds that value until the user spends it.
3. When the user pays at a shop, someone turns crypto into the shop’s currency.
4. A card network carries the payment, and a licensed issuer settles it.

Each step can be done by you or by a partner. Each step you do yourself may need its own licence. Each step a partner does needs that partner to be licensed.

The licences a card can touch

This is the main scope only. The real answer depends on your contracts and who legally holds what.

When you need an SVF licence

The HKMA says it is "responsible for the licensing and supervision of Stored Value Facilities (SVFs), including e-wallets and prepaid cards". If your company takes users’ money and holds it on a prepaid card that can be used at many shops, that is a stored value facility.

Most small teams do not issue the card themselves. They work with an issuer that already holds the licence or is a bank. The issuer holds the value. You run the programme, the app and the customers. This is often called being a programme manager.

If you are a programme manager, your issuer will check you closely. It will want your anti-money-laundering (AML) controls, your client checks and your plan for the crypto side.

When you need a crypto license

The crypto part is where many founders get stuck. At some point, crypto has to become money that a shop accepts. Somebody sells the user’s crypto for Hong Kong dollars or US dollars.

If your company runs a platform where users trade crypto, the SFC requires a licence. Its guidance says centralised virtual asset trading platforms in Hong Kong "are required to be licensed and regulated by the SFC".

If your company simply sells crypto to or buys it from users, that is dealing. Hong Kong plans a new licence for virtual asset dealers, and the bill is due in 2026. Our guide to Hong Kong’s planned crypto license for OTC dealers explains who it will cover.

The common way round this is to use a licensed partner for the conversion. The partner sells the crypto. Your card then handles fiat. Check that the partner is licensed for Hong Kong users, and ask a lawyer whether your own role in the conversion needs a licence too.

When you need an MSO licence

If your programme changes currency or sends money abroad for users, that is a money service. Customs defines a Money Service Operator as a person or firm that "operates a money changing service or a remittance service". A card that lets users send funds to other people or overseas may fall here.

Our comparison of a crypto license and an MSO licence in Hong Kong explains where one ends and the other begins.

Where stablecoins come in

The new HKMA licence is for issuing a stablecoin tied to a fiat currency. If your card lets users top up with a stablecoin that someone else issues, you are not issuing it. But the Stablecoins Ordinance also limits who may offer certain stablecoins to the public in Hong Kong. Only "permitted offerors", such as SFC-licensed platforms, SVF licensees and banks, may offer them. A card that lets users buy or hold one may count as an offer, so check this before launch. You still have to look at how you hold and convert the stablecoin. Use the table above for that.

If you want to issue your own Hong Kong dollar stablecoin for the card, you need the licence. The first two licences went to large banking groups. That shows how high the bar is.

What your issuer will ask you for

If a licensed issuer holds the value, that issuer is the firm the HKMA supervises for the card. So the issuer does its own checks on you before it puts your brand on its card. Expect questions in four areas.

First, your company. Who owns it, who runs it and where it is based. Second, your users. Which countries they live in, how you check who they are, and how you stop people who should not have a card. Third, the crypto side. Which partner turns crypto into fiat, which licence that partner holds, and what happens if the partner stops working. Fourth, your money flows. The issuer will want a diagram showing where funds sit at each step.

A founder who arrives with clear answers moves faster. A founder who says "we will sort the crypto side later" usually waits.

If your users are outside Hong Kong

Many crypto cards are sold to users in several countries. The Hong Kong licences above cover activity in Hong Kong. A user in another country is also covered by that country’s rules.

So check two things. Can your issuer issue cards to users in each country you plan to serve? And is your crypto partner licensed to deal with users there? A card that works in Hong Kong may still need a different issuer or partner for the next market.

A simple way to decide

Answer these three questions for your programme.

• Who legally holds the user’s money? If it is you, look at the SVF licence. If it is an issuer, check the issuer’s licence.
• Who turns crypto into fiat? If it is you, get legal advice on which SFC licence applies, now or under the planned dealer licence. If it is a partner, check the partner’s licence.
• Does money leave Hong Kong or change currency through you? If yes, look at the MSO licence.

Many successful programmes answer "a licensed partner" to the first two. That keeps the founder’s own licence list short and puts the heavy licences with firms that already hold them.

For help putting the pieces together, see card issuing programme set-up and licensing support for the crypto side.

Frequently asked questions

Do I need a crypto license to offer a crypto card in Hong Kong?

It depends on your role. If your company runs a crypto trading platform, it needs an SFC licence, and a planned licence will cover crypto dealers. Many programmes use a licensed partner for the conversion instead.

Who licenses prepaid cards in Hong Kong?

The HKMA licenses stored value facilities, which include e-wallets and prepaid cards, under the Payment Systems and Stored Value Facilities Ordinance.

Can I run a card programme without my own SVF licence?

Yes, if a licensed issuer or a bank holds the stored value. You then act as the programme manager, and the issuer checks your controls.

Does a stablecoin card need a stablecoin licence?

An issuer licence is needed only if you issue the stablecoin. But the Stablecoins Ordinance also restricts offering certain stablecoins to the public, so a card that lets users buy or hold one needs a legal check.

Is an MSO licence needed for a crypto card?

It can be, if your programme changes currency or sends money for users. Customs licenses money changing and remittance services.

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*Sources: HKMA press release of 10 April 2026; Hong Kong government LegCo reply of 10 June 2026; HKMA guidance on stored value facilities; Customs and Excise Department MSO guidance; SFC guidance on virtual asset trading platforms.*

Can an El Salvador Crypto License Cover Clients Outside El Salvador?

Many founders pick an El Salvador crypto license because it looks fast and simple. The country has a dedicated regulator and a clear law for digital assets. But one question often comes too late: where can you actually use it?

The short answer is El Salvador. A registration there lets you offer services in El Salvador. For clients in other countries, their own rules apply. This matters more since 1 July 2026, when the last grace period under the EU’s crypto law ended for firms working under national licences.

What an El Salvador crypto license is

El Salvador’s Digital Assets Issuance Law, known as LEAD, took effect in January 2023. It set up the National Commission of Digital Assets, or CNAD. Firms that provide digital asset services register with CNAD as a Digital Asset Service Provider, or DASP.

When people say "El Salvador crypto license", they usually mean this DASP registration. It covers services such as exchange and custody of digital assets. The steps and documents are on the El Salvador crypto license page.

Where the licence stops

A review of the law by Global Financial Integrity, a research group, put it plainly. The DASP registration lets a firm "offer services only within El Salvador’s jurisdiction". It added that any expansion into other countries "will depend on those jurisdictions’ regulations".

In other words, the licence does not travel. It is not a passport. A client in Germany, Hong Kong or Singapore is covered by the rules of their own country, not by El Salvador’s.

That does not make the licence useless. It makes it one piece of a plan, not the whole plan.

Think of it the way you would think of a shop licence. A licence to trade in one city does not let you open the same shop in another country. You would expect to apply again there, under that country’s rules. Crypto licences work the same way, even though the business runs online.

The most common mistake: serving the EU on a non-EU licence

This is where the risk has grown. The EU’s crypto law is called MiCA, the Markets in Crypto-Assets Regulation. Its licensing rules for crypto service providers have applied since 30 December 2024. Firms that were already working legally under an EU country’s own rules got a transition period. Article 143(3) let them continue "until 1 July 2026", or until their MiCA application was approved or refused. Some EU countries ended it sooner.

That transition never covered a firm whose only permission came from El Salvador. An El Salvador registration is not a MiCA authorisation, and it was not a national EU licence either.

What changed on 1 July 2026 is the market around you. Every provider that was still relying on national rules had to be authorised or wind down. The European Securities and Markets Authority (ESMA) told unauthorised firms in June 2026 to wind down their EU business in an orderly way. So EU regulators and banks now expect every crypto firm serving EU clients to hold MiCA authorisation. MiCA does allow a very narrow case where a client approaches a non-EU firm entirely on their own initiative. It is not a way to run an EU business. A firm that markets to EU clients using only its El Salvador licence is taking a real risk. The EU regulator can act, and so can the firm’s bank.

Other markets work the same way

The EU is not special here. Most markets ask the same question: are you licensed here?

In Hong Kong, the SFC licenses crypto trading platforms, and a separate licence for dealers is planned. Our guide to whether a Hong Kong company needs a crypto license or an MSO licence explains the local options.

Other countries have their own registrations and licences. Each one decides whether a foreign firm can serve its residents, and on what terms.

Why founders still choose El Salvador

There are good reasons to hold an El Salvador crypto license, as long as you know what it does.

• You want to serve clients in El Salvador itself.
• You want a regulated base while you build a product, before you enter bigger markets.
• Your business works with firms or clients in El Salvador’s local market.

It is a weaker choice if your plan is to serve EU or Hong Kong retail clients from day one. For that, you need a licence in the market where your clients live.

Warning signs in an offer

Some sellers and advisers present an El Salvador licence as a global licence. Be careful if you hear any of these:

• "It lets you serve clients anywhere." It does not.
• "It is recognised in the EU." MiCA does not recognise it.
• "No one checks where your clients are." Banks and payment partners do check, and they can close accounts.

Ask any adviser to show you, in writing, which countries’ clients you will be allowed to serve.

How to build a plan that covers your real clients

1. List where your clients live today, and where you want them in two years.
2. For each country, write down which licence or registration it requires.
3. Decide which licence to get first. Often it is the market with the most clients, not the easiest licence.
4. Decide whether to apply or to buy a licensed company. For the EU, see what the regulator checks when you buy a crypto license company.
5. Keep your El Salvador licence where it adds value, and do not market outside its reach.

The comparison of popular crypto licences sets out the main jurisdictions side by side.

If you already hold an El Salvador licence and have EU clients

Act now. There was never a grace period for a non-EU licence, and the last one for EU firms is over. Start with the facts. Pull a list of your active clients by country of residence, and look at where your new sign-ups come from.

If any are in the EU, stop marketing to EU residents first. Then look at your sign-up page. Does it let EU residents open an account? If it does, block new EU sign-ups until you have a plan.

Next, talk to your bank and your payment partners. They will ask how you serve EU clients, and a clear answer protects the accounts. Finally, decide on your EU route. You can apply for a MiCA licence, buy a company that holds one, or work with a licensed EU partner that serves those clients instead.

Questions to ask before you pay for an El Salvador licence

Ask these before you sign anything.

• Which countries’ clients will I be allowed to serve, and why?
• What does CNAD expect from me after the licence, such as reports, audits and local staff?
• Which banks work with El Salvador DASPs, and will they bank my business?
• What happens to my licence if I change owners or add services?
• What will it cost each year to keep, not only to obtain?

A seller who cannot answer these clearly is selling a document, not a working licence.

What we do not know

CNAD has not published a list of countries that accept its registration. No such list exists, because recognition is a decision for each other country. If an adviser gives you one, ask where it comes from.

Frequently asked questions

Is an El Salvador crypto license valid worldwide?

No. The DASP registration lets a firm offer services in El Salvador. Serving clients in other countries depends on those countries’ rules.

Can I serve EU clients with an El Salvador crypto license?

Not on its own. Serving EU clients needs MiCA authorisation, and since 1 July 2026 the last transition for firms under national EU licences has ended. An El Salvador registration was never covered.

What is a DASP in El Salvador?

It is a Digital Asset Service Provider registered with the National Commission of Digital Assets (CNAD) under the Digital Assets Issuance Law.

Why would I get an El Salvador crypto license if it only covers El Salvador?

To serve El Salvador’s market, or to have a regulated base while you build. It works best as part of a plan with other licences.

Can I hold an El Salvador licence and a MiCA licence together?

Yes. Many groups hold licences in several countries. Each licence covers the market that granted it.

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*Sources: Regulation (EU) 2023/1114 (MiCA), Article 143; ESMA public statement of 23 June 2026; Global Financial Integrity, "Changes to the Digital Assets Issuance Law in El Salvador", 11 September 2024.*

The EU Now Vets the New Owner When You Buy a Crypto License Company

On 1 July 2026, the last grace period under the EU’s crypto law ended. The law is the Markets in Crypto-Assets Regulation, called MiCA. A crypto firm serving EU clients now needs a MiCA licence, unless it is a bank or another financial firm allowed to offer crypto services by notifying its regulator. A firm with neither must wind down its unlicensed EU business.

That leaves two ways in. You can apply for a new licence, or you can buy a crypto license company that already holds one. Many founders think buying is the quick route. It can be quicker. But the regulator checks the buyer before the deal can close, and a buyer who skips that step can lose the deal.

What changed on 1 July 2026

Before MiCA, each EU country had its own crypto rules. When MiCA started, firms already working legally under those national rules got a transition period. Article 143(3) of MiCA let them continue "until 1 July 2026", or until their application was approved or refused.

That date has passed. On 23 June 2026, the European Securities and Markets Authority (ESMA) told firms without a licence to wind down their EU business in an orderly way, while protecting their clients. That includes business with existing clients, not only new ones. Some EU countries ended the transition earlier than 1 July 2026.

For a buyer, this matters in two ways. More firms now want a licensed company, so the good ones are harder to find. And a company that looked licensed under old national rules may have lost its right to serve EU clients.

Buying the company means asking for approval

A MiCA licence is granted to a company, based on who owns and runs it. When the owners change, the regulator wants to check the new ones. That is why MiCA has a special process for buying a "qualifying holding".

A qualifying holding means at least 10% of the capital or voting rights, held directly or indirectly, or a holding that lets you have a significant influence on how the firm is run. That is the MiCA definition in Article 3. Holdings owned through other companies count, and so do people acting together. Splitting a stake does not avoid the check.

Under Article 83, you must tell the firm’s regulator in writing before you buy a qualifying holding. You must tell it again before your holding reaches or goes past 20%, 30% or 50%, or before the firm becomes your subsidiary.

The regulator then has 60 working days to assess you. The clock starts on the date it confirms in writing that it has your notice. It can ask for more information up to the 50th working day. That pauses the clock, usually for up to 20 working days. Send a complete file, because every gap invites questions. If it opposes you, the deal cannot go ahead.

What the regulator checks about you

Article 84 lists what the regulator looks at. In plain words, it asks five questions.

1. Is the buyer honest and of good standing?
2. Are the people who will run the firm fit for the job? It checks their reputation, knowledge, skills and experience.
3. Is the buyer financially sound?
4. Will the firm still meet all MiCA rules after the sale?
5. Is there any sign that the deal is linked to money laundering or terrorist financing?

The detailed list of documents is in a separate EU law, Commission Delegated Regulation (EU) 2025/414. Expect to show where your money comes from, who your own owners are, and your plan for the business.

Your own history counts too. If you or your managers were refused a licence elsewhere, or faced action from a regulator, say so early. A regulator that finds it later will trust the rest of your file less.

Before you buy a crypto license company, check these five things

Most failed deals fail on the target, not the buyer. Check the company before you sign.

1. Is it really authorised under MiCA? Look for it on ESMA’s register of crypto-asset service providers. An old national registration is not the same thing after 1 July 2026.
2. Which services does the licence cover? A MiCA licence lists specific services, such as custody or exchange. Buy one that covers what you plan to do.
3. Which country granted it? That country’s regulator will run your approval, and it will supervise you after the sale.
4. Are the staff and systems still in place? The licence depends on real people and working controls. A company with no staff left may not keep its licence.
5. Has it had any problems with its regulator? Ask for all letters from the regulator since it was licensed.

If you are still choosing a market, the comparison of popular crypto licences sets out how the main options differ.

What to put in your file

Build the file in the order the regulator will read it. That saves a round of questions, and each round of questions adds time.

Start with a chart of who owns you, all the way up to the real people at the top. Add where the money for the purchase comes from, with bank records to show it. Then add a short plan for the business after the sale. Say which services you will offer, in which countries, and who will run them.

Next come the people. For each new director or manager, give a CV, proof of any past licences and a clean police record where the country asks for one. If anyone has faced action from a regulator before, explain what happened and what changed.

Last, explain how the firm will keep meeting MiCA rules. The regulator wants to see that the staff, systems and controls will still be there after the sale. A buyer who plans to replace the whole team on day one should say who replaces them and when.

Common reasons a deal stalls

An unclear money trail, a new manager with no record in regulated finance, a thin business plan, or open problems between the target and its regulator. Each can be fixed before you file, and none quickly after.

How long a purchase really takes

The law gives the regulator 60 working days, plus any pause while it waits for your answers. That is about three months of working days before any pause.

Add the time to find the company, check it, agree the price and prepare your file. Then add the time to move bank accounts and sign new contracts. A purchase is often quicker than a new application. It is not quick.

No EU authority publishes an average time or an average price for these deals. If someone quotes you one, ask where it comes from.

Where to find a licensed company

Ready-made companies are listed for sale from time to time. You can see the current ones on the licensed companies for sale page. Each listing shows the country and the type of licence.

If you are on the other side of the deal, the guide on what to prepare before you sell a crypto license company in the EU covers the seller’s steps.

For help with the whole file, from checking the target to writing the notice to the regulator, see crypto licence buying and application support.

Frequently asked questions

Can I buy a crypto license in the EU?

You can buy a company that holds a MiCA licence. You cannot buy the licence on its own. The regulator must approve you as the new owner before you take a qualifying holding.

What is a qualifying holding under MiCA?

It is at least 10% of a firm’s capital or voting rights, held directly or indirectly, or a holding that gives significant influence over its management. Buying one needs the regulator’s approval first.

How long does the regulator take to approve a buyer?

MiCA gives it 60 working days from when it confirms your notice. Questions from the regulator can pause that clock for a while.

What happens if I buy without telling the regulator?

You break Article 83 of MiCA. The regulator can oppose the deal, and EU countries must be able to fine firms for this breach.

Is a company registered before MiCA still licensed?

Not by default. The last transition period ended on 1 July 2026. Check that the company appears on ESMA’s register as a MiCA crypto-asset service provider.

Does the regulator also check new directors?

Yes. It checks the reputation, knowledge, skills and experience of anyone who will run the firm after the sale.

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*Sources: Regulation (EU) 2023/1114 (MiCA), Articles 3, 83, 84 and 143; ESMA public statement of 23 June 2026; Commission Delegated Regulation (EU) 2025/414.*