Pin and benchmark
Pin the jurisdiction you are leaning towards, then line up to 5 rivals against it. Every unlocked figure shows where a peer beats it or loses to it on capital, timeline, cost and difficulty, so one screen tells you whether your first choice actually holds up.
| Dimension |
Pinned 🇬🇧 United Kingdom Verified 2026-07-03
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🇱🇹 Lithuania
partly open
Verified 2026-07-01
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|---|---|---|
| Licence type | Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. | MiCA Crypto-Asset Service Provider (CASP) authorisation under Title V of Reg (EU) 2023/1114; replaced the national VASP registration. Single passportable licence covering the services applied for. |
| Regulator | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. | Bank of Lithuania (Lietuvos bankas) - single competent authority. Publicly selective stance: wants few, solid firms rather than the ~370-strong legacy VASP pool. |
| Capital requirement | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). | |
| Timeline to authorisation | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. | |
| Local substance | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. | |
| Application cost | FCA application fee GBP 11,150 (Category 6, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). | |
| Ongoing cost | Annual FCA periodic fee under fee-block G.30 (renumbered from G.23): minimum GBP 2,229 for 2025/26 plus GBP 15.13 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. | |
| Passporting | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. | |
| MiCA CASPs approved | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. | |
| Key restrictions | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. | |
| Recent changes | 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. | 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. |
| Difficulty rating | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.