Regulatory changes
What has moved recently in each covered crypto regime, free to read; Pro subscribers get it pushed to their inbox the moment an entry is updated.
Change log
🇨🇭 Switzerland
FinTech licence abolition confirmed progressing: the consultation closed 6 February 2026, entry into force is 2027 at the earliest, and existing licensees are grandfathered automatically.
🇰🇷 South Korea
The 20 August 2026 tightening of the virtual-asset regime is now traced to its enabling statute, Act No. 21358.
🇹🇷 Turkey
New mandatory TCMA membership requirement for crypto service providers, in force since February 2026.
🇰🇾 Cayman Islands
VASP registrations revised from 19 to 18 per CIMA's latest published statistics.
🇺🇸 United States
GENIUS Act implementing rules are due by 18 July 2026; the CLARITY Act remains pending after the 15 to 9 Senate Banking Committee vote.
Current position by jurisdiction
🇬🇧 United Kingdom
SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026-28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. The FCA published its 2026/27 fees policy statement PS26/14 on 2 Jul 2026; cryptoasset periodic fee-block detail is expected in a September 2026 Handbook Notice.
🇵🇹 Portugal
Lei 69/2025 (MiCA) and Lei 70/2025 (Travel Rule) published 22 Dec 2025, about a year late. The legacy-VASP transitional window closed 1 Jul 2026. Bison Bank became Portugal's first MiCA-authorised CASP in late Jun 2026, following approval from Banco de Portugal and the CMVM.
🇨🇭 Switzerland
FINMA licensed the first DLT trading facility (BX Digital, 18 Mar 2025); Federal Council consultation (22 Oct 2025 - 6 Feb 2026) proposes to ABOLISH the FinTech licence and replace it with two new categories, Payment Instrument Institutions and Crypto-Institutions, under an amended Financial Institutions Act (FinIA). Confirmed timeline as of this check: new provisions are not expected to enter into force before 2027; existing FinTech-licensed firms will be automatically transitioned to the new Payment Instrument Institution licence without a fresh application, provided they meet the new rules within one year of entry into force. The reform also removes the current CHF 100m deposit cap and adds client-fund segregation on insolvency. FINMA Guidance 01/2026 on crypto custody (12 Jan 2026).
🇭🇰 Hong Kong
SFC ASPIRe roadmap (19 Feb 2025); VATP staking guidance (7 Apr 2025); HKMA Stablecoins Ordinance in force 1 Aug 2025, with the first two issuer licences (HSBC, Anchorpoint) granted 10 Apr 2026 and the HKMA register still showing only these two as of 10 Jul 2026. FSTB and SFC published consultation conclusions on virtual asset dealing and custody licensing on 24 Dec 2025 and consulted on advisory and management regimes to 23 Jan 2026; a single bill covering all four new regimes is planned within 2026 and had not been introduced as of 10 Jul 2026. 13 VATPs licensed by the SFC as of 10 Jul 2026 (most recently NewBX, 18 May 2026).
🇬🇮 Gibraltar
Fee increases in force 1 Apr 2025 (application GBP 45k; annual trade-fee cap GBP 90k); world-first Digital Clearing and Settlement Framework announced 13 May 2025; Restricted Promotions rules (May 2025); CARF adoption from 2026. The Financial Services Act 2019 was amended in late 2025 to extend the DLT framework's regulated activities to providing virtual asset arrangements (exchange of virtual assets for money or other virtual assets), and the GFSC register now lists such providers (for example Xapo VASP Limited). The DLT Regulations overhaul with progressive MiCA alignment signalled in Feb 2026 had no published draft as of 10 Jul 2026. UK transitional passporting extended to 31 Dec 2026.
🇱🇮 Liechtenstein
Bank Frick received MiCAR authorisation from FMA Liechtenstein on 20 January 2026, one of the first in the country under the new regime; FMA also authorised Bitcoin Suisse (Europe), the European arm of the Swiss group, covering trading, custody and staking for institutional/HNW clients. Smart Valor was authorised as a CASP under MiCAR Article 63 with effect from 1 Jul 2026, and Kaiser Partner Privatbank was authorised for certain crypto-asset services via the Article 60 notification route from 29 Jun 2026; the FMA confirmed the MiCAR transitional period ended on schedule on 1 Jul 2026.
🇱🇺 Luxembourg
Rapid growth in H1 2026: as of 30 June 2026, 11 active CASPs including B2C2 Europe, Banking Circle, Bitstamp Europe, Bridge Building, Clearstream Banking, Coinbase Luxembourg, Stokr, Standard Chartered Luxembourg, Swissquote Bank Europe, Zodia Custody Europe and BitFlyer; BitFlyer authorised 26 June 2026, Stokr 22 June 2026, Bridge Building 29 June 2026, all just before the transitional deadline expired on 1 July 2026
🇪🇸 Spain
The CNMV's own register shows a bank-led adoption pattern: home-authorised providers include BBVA, CaixaBank, Cecabank, Kutxabank, Open Bank and Renta 4 alongside fintechs such as Bit2Me, Criptan Trade and Crossmint Europe, 10 in total by late Jun 2026. CNMV published updated MiCA Q&A guidance in Dec 2025 ahead of full application from 1 Jul 2026.
🇮🇹 Italy
Consob Resolution 23700/2025 (introducing the EUR 20,000 fee) took effect 1 December 2025; the transitional regime for pre-MiCA VASPs was extended to 1 July 2026 (later than the original MiCA default cut-off), giving Italian firms extra runway. As of 1 July 2026, 8 firms hold full CASP authorisation, a sharp jump from near-zero conversions reported earlier in 2026, though still a small fraction of the pre-MiCA registered population.
🇧🇪 Belgium
The Act of 11 December 2025 (Belgium's MiCA implementing law) was the single biggest development: it was published 24 December 2025 and entered into force 3 January 2026, only then giving FSMA/NBB a full domestic legal basis for authorisation, supervision and sanctions. Before that date Belgium had a live enforcement gap despite MiCA being EU law since December 2024. As of last check, 0 CASPs were authorised in Belgium, consistent with the regime being newly operative. As of 3 Jul 2026 the FSMA's own list of authorised Belgian CASPs still records zero authorisations. On 3 Jul 2026 the FSMA also adopted ESMA's guidelines (FSMA_2026_16) on when a non-EU firm is treated as soliciting EU clients, relevant to enforcement against unauthorised third-country platforms.
🇵🇱 Poland
The enabling law (Crypto-Assets Market Act) remains blocked: the Sejm adopted a third draft on 15 May 2026, the Senate passed it unamended on 22 May 2026, and the President vetoed it for a third time on 11 Jun 2026 (earlier vetoes 1 Dec 2025 and 12 Feb 2026; an override attempt failed 17 Apr 2026). With the EU transitional period over on 1 Jul 2026, the KNF confirmed on the record that no Polish authority is designated for MiCA except for e-money token issuers; roughly 2,000 Polish VASPs are affected, with EEA passporting the working route into Poland.
🇭🇺 Hungary
The European Commission opened a MiCA infringement case against Hungary (implications for market participants unclear); the transitional period for ex-VASPs ended 1 July 2025; the SZTFH validation-certificate requirement took effect 27 December 2025, with the first provider registered shortly after. On 30 Jun 2026 the new government tabled Bill T/305 to repeal the SZTFH conversion-validation regime and its criminal penalties, aiming to align Hungary with MiCA; the bill is before Parliament and the validation requirement remains in force until passage.
🇷🇴 Romania
Romania's MiCA implementation is unsettled and sources conflict: 2025 commentary cited GEO 10/2025 (reported in force from 13 Mar 2025) as designating ASF and BNR, but ASF's First Vice-President stated on the record on 1 Jul 2026 that no Romanian authority has yet been designated as competent for MiCA, that the implementing act remains a Ministry of Finance draft presented to Government in first reading in Apr 2026, and that applications cannot currently be received or resolved. The EU-wide transitional period ended 1 Jul 2026.
🇦🇪 ADGM (Abu Dhabi)
June 10, 2025: FSRA implemented major amendments, shifted from FSRA pre-approval for Virtual Assets to a notification-based process built on applicant self-assessment; introduced express prohibition on privacy tokens and algorithmic stablecoins; revised capital requirements and fees for VA firms; added product-intervention power for virtual assets. September 2025 (Abu Dhabi Finance Week): FSRA published Consultation Paper No. 10 of 2025 proposing a staking framework. Finalised Fiat-Referenced Token (FRT) framework followed, with FEES Rulebook amendments effective 1 January 2026 (published 31 October 2025). April 29, 2026: FSRA finalised the Virtual Asset staking regulatory framework after consultation. December 2025/January 2026: Binance received FSRA approval (announced 7 December 2025) to operate its global Binance.com platform in ADGM via three regulated entities, described as the first global platform-level licence of this kind under the ADGM framework, operations beginning 5 January 2026. On 7 Jul 2026 the FSRA granted a Financial Services Permission to BTCS (Middle East), the Abu Dhabi subsidiary of Bitcoin Suisse, covering spot trading in accepted virtual assets, institutional custody and derivatives for institutional and professional clients.
🇧🇭 Bahrain
CONFIRMED: In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits), a more permissive stance than many other jurisdictions. This confirms the '2025 stablecoin module' claim. Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. In May 2026 the CBB restructured the approved-persons section (CRA-1.7) of the Crypto-Asset Module, regrouping its fit-and-proper, prior-approval and notification rules under relocated headings (Rulebook revision of 6 May 2026).
🇮🇲 Isle of Man
After a 2024 consultation on introducing a more substantive crypto licensing regime, the IOMFSA confirmed (2025) it would retain the current DBRO-Act registration approach for the time being, while keeping the matter under review. The consolidated Isle of Man Financial Services Authority (Fees) Order 2026 (consultation closed 18 Dec 2025; feedback statement 17 Feb 2026) took effect on 1 Apr 2026, raising most fees, including designated-business fees, by about 2.9 per cent in line with CPI.
🇺🇸 United States
GENIUS Act (stablecoins, signed 18 Jul 2025): implementing rules are due from federal agencies by 18 Jul 2026. Treasury, FinCEN and OFAC issued a joint proposed rule on illicit-finance requirements on 8 Apr 2026, the OCC issued its proposal on 2 Mar 2026 (comments closed 1 May 2026) and the FDIC has issued application-procedure proposals; the Federal Reserve had not yet issued its own proposal as of 10 Jul 2026, and the Act sets no fallback if the deadline is missed. Enforcement provisions apply no later than 18 Jan 2027. CLARITY Act (market structure): advanced by Senate Banking 15 to 9 on 14 May 2026 and still awaiting a Senate floor vote. The SEC's 2026 regulatory agenda (published 7 Jul 2026) targets three crypto rulemakings for proposal in July 2026: a capital-formation safe harbour for token issuers, broker-dealer capital and customer-protection amendments, and crypto market-structure amendments.
🇮🇸 Iceland
Iceland enacted Act No. 101/2025 on markets for crypto-assets on 24 December 2025, in force 1 January 2026, giving MiCA (Regulation (EU) 2023/1114) legal effect domestically with the adaptations in EEA Joint Committee Decision 41/2025. That JCD was adopted on 20 February 2025 and entered into force in the EEA on 24 June 2025. The transitional period for providers active before 30 December 2024 runs until 1 July 2026 or until a licence is granted or refused.
🇲🇽 Mexico
Major AML Law reform enacted 16 Jul 2025 (VASPs serving Mexican residents in scope; Travel Rule; 10-yr records). Banxico (Dec 2025) reiterated stablecoins pose financial-stability risks. A Fintech Law 2.0 is discussed but NOT enacted.
🇦🇪 United Arab Emirates (Dubai - VARA)
'Rulebook 2.0' reissued all twelve rulebooks effective 19 Jun 2025 (mandatory Travel Rule, wind-down plans, TLPT, a new VA Issuance rulebook). AML circular (Mar 2026) and token-issuance guidance (Apr 2026). VARA penalised ~19 unlicensed firms.
🇭🇷 Croatia
HANFA granted Croatia's first MiCA CASP licence to Zagreb-based Electrocoin in April 2026 - the first authorisation issued in-country.
🇯🇵 Japan
Major overhaul underway: Japan's Cabinet approved an FIEA amendment bill (10 April 2026) to reclassify crypto-assets as 'financial instruments,' moving oversight from the PSA to FIEA, applying insider-trading rules, disclosure obligations, and market-conduct rules akin to securities law, alongside sharply increased criminal penalties (up to 10 years imprisonment / JPY 10 million fines for unregistered solicitation). The Lower House passed the bill 11 June 2026; it awaits Upper House passage, with effect expected as early as 2027. A flat 20% capital-gains tax on crypto (replacing progressive rates up to 55%) has been approved in principle. On 1 May 2025, PSA/LPAI amendments took effect introducing a new intermediary-only registration category and tightening stablecoin/EPI rules; a further overseas trust-type stablecoin equivalence framework takes effect 13 June 2026.
🇰🇷 South Korea
The 20 Aug 2026 tightening is now identifiable as Act No. 21358 (amendment to the FTRA/AML Reporting Act), promulgated 19 Feb 2026 and taking effect 20 Aug 2026. It removes the KRW 1,000,000 Travel Rule de minimis threshold and separately expands VASP entry screening: adds a statutory definition of major shareholders, extends fit-and-proper disqualification checks to major shareholders, adds financial condition, social credibility, organisational, staffing and IT review factors, and authorises KoFIU to attach conditions when accepting a VASP report. Existing registered VASPs must re-report under the amended Article 7 within 3 months of the effective date (by approximately 20 Nov 2026). Separately, a Foreign Exchange Transactions Act amendment creating cross-border VASP registration passed 7 May 2026 (effective date disputed, 2 Aug vs 2 Dec 2026).
🇹🇷 Turkey
Secondary regulations (Communiques III-35/B.1 and III-35/B.2, 13 March 2025) operationalised Law 7518. New development: following a February 2026 amendment to the Turkish Capital Markets Association (TCMA/TSPB) statute (effective 27 Feb 2026), CMB-licensed Crypto Asset Service Providers must apply for TCMA membership within 3 months of obtaining their CMB operating permit, and a dedicated professional committee for CASPs has been created within the TCMA structure. In March 2026 the CMB extended certain deadlines on custody agreements and authorisation certificates. The final compliance deadline of 30 June 2026 for the transitional licensing cohort has passed as of this report; market consolidation continues, with only a small number of exchanges (reported as Paribu, BtcTurk, Koinim) confirmed as fully licensed against a much larger transitional applicant pool.
🇹🇭 Thailand
April 2025: extraterritorial scope amendment plus MDES no-court-order blocking powers, the biggest regulatory shift in this period. 1 November 2024: new capital requirement notification (KorThor. 28/2567) took effect, phased to full compliance by 1 November 2025. May-June 2025: first major enforcement wave blocking 5 offshore exchanges. Early 2026: criminal complaints filed against local/overseas joint-operation arrangements, signaling a shift from blocking to prosecution. ERX rebranded as KuCoin Thailand in 2025 following acquisition by KuCoin, illustrating global exchanges entering via licensed local subsidiaries.
🇮🇩 Indonesia
10 January 2025: regulatory authority formally transferred from Bappebti to OJK; POJK 27/2024 took effect the same date. 10 July 2025: deadline for existing operators to complete governance/data-protection/consumer-protection upgrades. December 2025: OJK issued POJK 23/2025 amending POJK 27/2024, introducing a formal crypto derivatives trading framework. 19 December 2025: OJK published a whitelist of 29 licensed/registered digital financial asset and crypto asset trading operators. A later source (May 2026) cites 26 licensed entities against OJK's own December count of 29; the gap likely reflects licences lapsing or being reclassified between the two counts, not yet confirmed against OJK directly.
🇳🇱 Netherlands
Netherlands became one of the highest-volume MiCA jurisdictions through H1 2026 as the 1 July 2026 EU-wide transitional deadline approached; notable authorisations include Bitvavo, Amdax, MoonPay, Finst, Fiat Republic, and Banxa (Oct 2025); dedicated 'ARI10' authorisation added Feb 2026 per one tracker
🇨🇾 Cyprus
CySEC set a hard 27 February 2026 deadline for existing national-regime CASPs to submit MiCA applications; preliminary assessment phase opened 13 Nov 2024, formal applications from 1 Jan 2025; national transitional regime and full MiCA regime now running in parallel toward the 1 July 2026 EU-wide cutover
🇦🇹 Austria
Austria set 30 June 2026 as the end of its transitional regime (shorter runway than the EU default 1 July 2026 deadline), creating pressure for existing FM-GwG registered VASPs to secure full CASP authorisation; Bybit reported as licensed in Austria per exchange-tracking source
🇨🇿 Czechia
Authorisation count growth confirmed: 0 authorised CASPs as of February 2026, moving to the CNB's first 6 authorisations issued 11 February 2026, then to 7 authorised CASPs by May 2026 (per Helms Advisory tracker). Czechia is described by multiple sources as the fastest-moving MiCA CASP jurisdiction in the EU in 2026, processing English-language applications from a pool of 248 filings.
🇸🇪 Sweden
Sweden's transitional period closed 30 September 2025, after which all CASPs needed full MiCA authorisation to continue operating, a materially earlier cutoff than the EU default. As of 3 March 2026, Sweden had 1 CASP authorisation (source: Bank of Lithuania comparative announcement). No update since; the current figure may be marginally higher.
🇳🇴 Norway
AK Jensen Norway AS became Norway's first MiCA-authorised firm (Article 60 route), effective 2 February 2026. Firi, the largest Nordic crypto exchange (400,000+ users), was authorised by Finanstilsynet in May 2026, becoming one of the first full standalone Nordic crypto exchanges under the new framework. Norway's national VASP registry is being wound down ahead of the 30 June 2026 EEA-wide MiCA transitional deadline.
🇩🇰 Denmark
Grandfathering deadline for legacy VASPs passed 30 December 2025, pushing remaining Danish crypto firms into full MiCA authorisation or market exit.
🇫🇮 Finland
FIN-FSA launched a public register of authorised CASPs and a warning list of unauthorised providers; the 6-month transition period closed 30 June 2025, requiring firms to already hold full MiCA authorisation.
🇧🇬 Bulgaria
BG MiCA Act adopted 20 June 2025, entered force 8 July 2025 - a relatively late national implementer among EEA states; grandfathering deadline (8 Oct 2025) has already passed.
🇪🇪 Estonia
Estonia's VASP population collapsed from 641 valid licences (mid-2021 peak) to 36 remaining by early 2026; as of recent reporting only one entity (Lightspark Payments Europe AS) had received full MiCA CASP authorisation. From 18 March 2026, CASP applications must go through FI's new application portal.
🇬🇷 Greece
Law 5193/2025 passed 11 April 2025; HCMC Decision 8/1059 (CASP licensing procedure) issued 30 July 2025; national compliance deadline of 30 December 2025 has already passed as of this research (July 2026).
🇱🇻 Latvia
Latvijas Banka has issued multiple CASP licences during 2025-2026, including to SIA AlphaRoute and Backpack, and reportedly Paybis (May 2026, per one directory source). Latvia offers free pre-licensing consultations and a formal Innovation Hub.
🇸🇰 Slovakia
Act No. 248/2024 Coll. entered into force to implement MiCA nationally; the transitional/grandfathering deadline for existing VASPs expired 30 December 2025, meaning all Slovak crypto firms must now hold full NBS CASP authorisation.
🇸🇮 Slovenia
ZIUTK in force since November 2024 as the national implementing law; the national transitional/grandfathering period for legacy providers expired 1 July 2025, earlier than Slovakia's, tightening the runway for unlicensed Slovenian crypto firms.
🇰🇾 Cayman Islands
Phase 2 licensing (custody and trading platforms) came into force 1 April 2025, with a 90-day transition deadline of 30 June 2025 for existing registrants to convert to a licence. CIMA updated the VASP application forms, Rule, and Statement of Guidance in December 2024 ahead of Phase 2. From 1 December 2025, CIMA introduced a new quarterly financial reporting requirement via the REEFS portal, layered on top of the existing annual audited accounts requirement. CIMA conducted a Thematic Desk-Based Review of 11 regulated VASPs (September 2024-February 2025), with findings published November 2025 and a further legal briefing in February 2026, identifying gaps in board composition, cybersecurity governance, staff training, and sanctions-screening practices. A Phase 3 is expected but not yet commenced as of mid-2026.
🇧🇲 Bermuda
In January 2026, at the WEF Annual Meeting in Davos, the Government of Bermuda announced a partnership with Circle and Coinbase (and Stellar) to build what it describes as the world's first 'fully onchain' national economy, including plans for a sovereign Bermuda digital dollar. The BMA has begun real-world pilots, airdropping USDC to residents, enabling payments at a pop-up marketplace, and preparing to accept digital assets for government fees. Bermuda also hosts regulated derivatives operations tied to major exchanges including Coinbase and Kraken. The BMA's 2025 annual report shows licensed digital asset businesses rose to 49 by end of 2025 (up from 36 a year earlier). The DABA Code of Practice was also updated in 2024 with more detailed marketing/promotion and governance requirements.
🇻🇬 British Virgin Islands (BVI)
November 2025: FSC issued Industry Circular 43 of 2025, publishing a comprehensive 'Understanding Virtual Assets and VASP Regulation' FAQ document clarifying scope (e.g., confirming pure ICO/ITO token issuance without other regulated activity does not require VASP registration). March 2025: BVI launched the Virtual Asset Service Providers Advisory Committee (VASPAC), a public-private body to enhance regulation/supervision of the sector, first meeting 27 March 2025. The FSC's Compliance Inspection Unit began a major round of onsite VASP/TCSP/Investment Business inspections in 2025 running through Q1 2026, focused on AML/CFT/CPF controls, internal audit, and staff training.
🇸🇻 El Salvador
(1) January-February 2025: Bitcoin Law amended to remove mandatory merchant acceptance and tax-payment use, as an IMF program condition; IMF Extended Fund Facility approved. (2) August 2024-January 2025: CNAD granted Tether a DASP licence and a stablecoin issuer-related authorization; Tether announced relocation of its group headquarters to El Salvador (January 2025). (3) Bitfinex Derivatives received a DASP licence (January 2025) and Bitfinex's core platform/securities arm expanded its CNAD-supervised licence coverage across spot and derivatives (reported May 2026). (4) Continued steady growth in DASP approvals through 2025-2026, including named entities such as B2BINPAY (November 2025), Freedx (April 2025) and Finprime.pro (October 2025), with Binance also reported to hold CNAD DASP authorization. (5) CNAD has begun processing stablecoin issuer registrations under its Public Offering of Stable Coins regulations, requiring three years of externally audited financial statements and publication of a 'Relevant Information Document' (DIR).
🇯🇪 Jersey
JFSC proposed enhancements to the AML/CFT/CPF Handbook (consultation published June 2025), taking effect 1 January 2026, including new sector-specific guidance for VASPs/DNFBPs partly in response to MONEYVAL's 2024 evaluation of Jersey. Jersey is implementing the OECD Crypto-Asset Reporting Framework (CARF): consultation began November 2024, legislation expected 2025, first CARF reporting due 2027. A government consultation (July-Sept 2025) on repealing the Control of Borrowing (COBO) framework proposes replacement legislation for digital-asset-related structures with a 12-24 month transition. In 2024 Jersey launched its first real-world-asset tokenisation platform under JFSC guidance.
🇬🇬 Guernsey
GFSC launched a 'Digital Finance Initiative' (DFI) in September 2025 to reposition Guernsey as a digital finance hub, including a Digital Forum for industry engagement and a consultation on stablecoins/broader digital-asset policy running until 6 March 2026. For 2026, GFSC announced fee reductions specifically for VASP applications to encourage more firms to establish in the Bailiwick, implying low uptake of the regime to date.
🇨🇦 Canada
6 August 2024: CSA closed the restricted-dealer/PRU interim pathway to new CTP applicants, the most material structural change, pushing all new entrants to full CIRO Investment Dealer membership. December 2024: OSC Staff Notice 33-757 published findings from a compliance review of six Ontario-registered restricted-dealer CTPs. February 2026: CIRO published a Notice on its Digital Asset Custody Framework with tiered custodian capital requirements. March 2026: legislative amendments to the PCMLTFA (via the Strengthening Canada's Immigration System and Borders Act and Budget 2025 Implementation Act) established a new 'Stablecoin Act' with dedicated AML/CFT requirements for stablecoin issuers. Ongoing FINTRAC enforcement crackdown in 2026, with reports of roughly 50 MSB registrations revoked in a single quarter.
🇱🇹 Lithuania
Lithuania used a shortened 12-month grandfathering - legacy VASP cover ended 1 Jan 2026 (vs the EU 1 Jul 2026 backstop). First CASP: Robinhood Europe (29 May 2025); only ~4 CASPs authorised by Mar 2026.
🇮🇪 Ireland
Transitional period ended 30 Dec 2025 (12 months; simplified route declined). ~10 CASPs authorised by late 2025 (Kraken Jun 2025, Coinbase, StoneX 10th). Revised Consumer Protection Code from 24 Mar 2026.
🇲🇹 Malta
First-mover: Crypto.com licensed 27 Jan 2025; ~13 CASPs now authorised (OKX, Gemini, Gate, Blockchain.com). ESMA's 10 Jul 2025 peer review criticised the MFSA's authorisation of one CASP, tightening scrutiny. Transition ends 1 Jul 2026.
🇫🇷 France
France used the full 18-month transition, ending 1 Jul 2026 (today). Deblock first CASP (May 2025), SG-Forge (Oct 2025); ~18 CASPs authorised by 28 May 2026. AMF adopted ESMA staff knowledge/competence guidelines (Mar 2026).
🇩🇪 Germany
FinmadiG + KMAG in force 27 Dec 2024; Germany used a 12-month grandfathering (apply before 8 Oct 2025; effective end-2025). By mid-2026 the EU's #1 hub - ~57 CASP authorisations (~23% of the EU's ~244), incl. Trade Republic, N26, Commerzbank, Bitpanda.
🇸🇬 Singapore
DTSP regime (FSMA Part 9) commenced 30 Jun 2025 - Singapore firms serving only overseas customers must be licensed, and MAS 'will generally not issue' such licences (no transition). MPI DPT licensees ~37 by mid-2026. MAS revoked Bsquared Technology's MPI licence (May 2026). Stablecoin legislation still in drafting.
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