🇦🇹 Austria vs 🇬🇧 United Kingdom: crypto licensing compared
Decision context and regulator route
Austria's public MiCA CASP Authorisation granted by the Austrian Financial Market Authority (FMA) and United Kingdom's public 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. are set out side by side. Licence type, regulator and public recent-change notes are open; the full dated and sourced comparison is included with access.
Austria: verified 2026-08-01 · United Kingdom: verified 2026-08-15
| Dimension |
🇦🇹 Austria
partly open
Verified 2026-08-01
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🇬🇧 United Kingdom
Free in full
Verified 2026-08-15
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|---|---|---|
| Licence type | MiCA CASP Authorisation granted by the Austrian Financial Market Authority (FMA) | 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. |
| Regulator | Finanzmarktaufsicht (FMA) Österreich | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Austria capital requirement is included in the £349 pass. | 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 | Austria timeline to authorisation is included in the £349 pass. | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. |
| Local substance | Austria local substance is included in the £349 pass. | 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 | Austria application cost is included in the £349 pass. | FCA application fee GBP 11,260 (Category 6, fee-block G23, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | Austria ongoing cost is included in the £349 pass. | Annual FCA periodic fee under fee-block G.30 for 2026/27: minimum GBP 2,251 plus GBP 6.01 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 | Austria passporting is included in the £349 pass. | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. |
| MiCA CASPs approved | Austria mica casps approved is included in the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Austria key restrictions is included in the £349 pass. | 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 | 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 OSL EU GmbH was authorised on 7 July 2026 (per ESMA's interim register), the eleventh Austrian CASP. | 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 to 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 still expected in a September 2026 Handbook Notice, with nothing published early as of 15 Jul 2026. On 8 July 2026 the FCA published detailed information about the authorisation application form for cryptoasset firms, a full walkthrough of every question the online form will ask; the FCA notes the form's wording may still be refined but its structure is not expected to change, and the online system itself opens for firms to start applications on 30 September 2026 when the gateway opens. Firms have also been able to request a pre-application meeting with the FCA through its PASS service since 11 May 2026, with meetings running from July 2026. |
| Difficulty rating | Austria difficulty rating is included in the £349 pass. | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
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What changed recently
🇦🇹 Austria (verified 2026-08-01): 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 OSL EU GmbH was authorised on 7 July 2026 (per ESMA's interim register), the eleventh Austrian CASP.
🇬🇧 United Kingdom (verified 2026-08-01): 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 to 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 still expected in a September 2026 Handbook Notice, with nothing published early as of 15 Jul 2026. On 8 July 2026 the FCA published detailed information about the authorisation application form for cryptoasset firms, a full walkthrough of every question the online form will ask; the FCA notes the form's wording may still be refined but its structure is not expected to change, and the online system itself opens for firms to start applications on 30 September 2026 when the gateway opens. Firms have also been able to request a pre-application meeting with the FCA through its PASS service since 11 May 2026, with meetings running from July 2026.
Quick answers
Who regulates crypto licensing in Austria and United Kingdom?
Austria: Finanzmarktaufsicht (FMA) Österreich. United Kingdom: Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers..
What licence do you need in Austria compared with United Kingdom?
In Austria the authorisation route is MiCA CASP Authorisation granted by the Austrian Financial Market Authority (FMA); in United Kingdom it is 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.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Austria vs United Kingdom comparison?
The interactive benchmark lets you pin either jurisdiction and add up to five peers; a Founder Pass or Pro subscription unlocks every gated figure with its source and verification date. This page stays free at /crypto/compare/austria-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.