🇧🇭 Bahrain vs 🇬🇧 United Kingdom: crypto licensing compared
Decision context and regulator route
Choosing between Bahrain and United Kingdom for a crypto licence starts with who you will answer to: Central Bank of Bahrain (CBB) on one side, Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. on the other, via the Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. and the Today, FCA registration under the Money Laundering Regulations 2017 remains the AML and counter-terrorist financing route. Applications for full FSMA authorisation under SI 2026/102 opened on 30 September 2026 and close on 28 February 2027. The mandatory regime commences on 25 October 2027, and existing registrations and permissions do not convert automatically. respectively. The public fields are shown below, with the full dated and sourced comparison included with access.
Bahrain: verified 2026-08-15 · United Kingdom: verified 2026-10-16
| Dimension |
🇧🇭 Bahrain
partly open
Verified 2026-08-15
|
🇬🇧 United Kingdom
Free in full
Verified 2026-10-16
|
|---|---|---|
| Licence type | Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. | Today, FCA registration under the Money Laundering Regulations 2017 remains the AML and counter-terrorist financing route. Applications for full FSMA authorisation under SI 2026/102 opened on 30 September 2026 and close on 28 February 2027. The mandatory regime commences on 25 October 2027, and existing registrations and permissions do not convert automatically. |
| Regulator | Central Bank of Bahrain (CBB) | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Bahrain 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 | Bahrain 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 | Bahrain 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 | Bahrain 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 | Bahrain 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 | Bahrain 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 | Bahrain 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 | Bahrain 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 | 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). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). 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). | The FCA authorisation gateway opened on 30 September 2026. Firms can now apply for authorisation or vary existing permissions through Connect, and firms seeking the transitional arrangements must apply by 28 February 2027. The mandatory FSMA regime begins on 25 October 2027. The FCA also published final cryptoasset perimeter guidance, PS26/18, on 16 September 2026. |
| Difficulty rating | Bahrain 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
🇧🇭 Bahrain (verified 2026-07-15): 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). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). 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).
🇬🇧 United Kingdom (verified 2026-10-16): The FCA authorisation gateway opened on 30 September 2026. Firms can now apply for authorisation or vary existing permissions through Connect, and firms seeking the transitional arrangements must apply by 28 February 2027. The mandatory FSMA regime begins on 25 October 2027. The FCA also published final cryptoasset perimeter guidance, PS26/18, on 16 September 2026.
Quick answers
Who regulates crypto licensing in Bahrain and United Kingdom?
Bahrain: Central Bank of Bahrain (CBB). 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 Bahrain compared with United Kingdom?
In Bahrain the authorisation route is Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers.; in United Kingdom it is Today, FCA registration under the Money Laundering Regulations 2017 remains the AML and counter-terrorist financing route. Applications for full FSMA authorisation under SI 2026/102 opened on 30 September 2026 and close on 28 February 2027. The mandatory regime commences on 25 October 2027, and existing registrations and permissions do not convert automatically.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Bahrain 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/bahrain-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.