🇧🇲 Bermuda vs 🇯🇪 Jersey: crypto licensing compared
Decision context and regulator route
Bermuda's public Digital Asset Business (DAB) licence under the Digital Asset Business Act 2018 (DABA), with three tiers: Class T (Test/sandbox licence for early-stage/proof-of-concept businesses, time-limited ~3-12 months), Class M (Modified licence for limited-scope/lower-risk operations, a stepping stone to full authorization), and Class F (Full, unrestricted licence covering the complete range of digital asset business activities, issuance, exchange, custody, payment services, dealing as principal, etc., with no expiry, subject to ongoing supervision). and Jersey's public Virtual Asset Service Provider (VASP) registration, not a bespoke prudential licence. Legal basis: the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008, the Money Laundering (Jersey) Order 2008, and the JFSC's AML/CFT/CPF Handbook, implementing FATF VASP Guidance (effective from early 2023). This is fundamentally an AML/CFT registration, without a conduct-of-business or prudential capital regime. As of mid-2026, Jersey has not introduced a dedicated substantive VASP licensing framework with conduct/prudential requirements. 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.
Bermuda: verified 2026-08-15 · Jersey: verified 2026-07-02
| Dimension |
🇧🇲 Bermuda
partly open
Verified 2026-08-15
|
🇯🇪 Jersey
partly open
Verified 2026-07-02
|
|---|---|---|
| Licence type | Digital Asset Business (DAB) licence under the Digital Asset Business Act 2018 (DABA), with three tiers: Class T (Test/sandbox licence for early-stage/proof-of-concept businesses, time-limited ~3-12 months), Class M (Modified licence for limited-scope/lower-risk operations, a stepping stone to full authorization), and Class F (Full, unrestricted licence covering the complete range of digital asset business activities, issuance, exchange, custody, payment services, dealing as principal, etc., with no expiry, subject to ongoing supervision). | Virtual Asset Service Provider (VASP) registration, not a bespoke prudential licence. Legal basis: the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008, the Money Laundering (Jersey) Order 2008, and the JFSC's AML/CFT/CPF Handbook, implementing FATF VASP Guidance (effective from early 2023). This is fundamentally an AML/CFT registration, without a conduct-of-business or prudential capital regime. As of mid-2026, Jersey has not introduced a dedicated substantive VASP licensing framework with conduct/prudential requirements. |
| Regulator | Bermuda Monetary Authority (BMA) | Jersey Financial Services Commission (JFSC). |
| Capital requirement | Bermuda capital requirement is included in the £349 pass. | Jersey capital requirement is included in the £349 pass. |
| Timeline to authorisation | Bermuda timeline to authorisation is included in the £349 pass. | Jersey timeline to authorisation is included in the £349 pass. |
| Local substance | Bermuda local substance is included in the £349 pass. | Jersey local substance is included in the £349 pass. |
| Application cost | Bermuda application cost is included in the £349 pass. | Jersey application cost is included in the £349 pass. |
| Ongoing cost | Bermuda ongoing cost is included in the £349 pass. | Jersey ongoing cost is included in the £349 pass. |
| Passporting | Bermuda passporting is included in the £349 pass. | Jersey passporting is included in the £349 pass. |
| MiCA CASPs approved | Bermuda mica casps approved is included in the £349 pass. | Jersey mica casps approved is included in the £349 pass. |
| Key restrictions | Bermuda key restrictions is included in the £349 pass. | Jersey key restrictions is included in the £349 pass. |
| Recent changes | 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. Bitcoin Suisse (International) Ltd was granted a Class F digital asset business licence with Class B investment business registration, reported 13 May 2026, pre-operational pending standard conditions. On tokenisation, the BMA issued a stakeholder letter on 30 March 2026 and a consultation paper on 9 April 2026 (feedback to 30 June 2026); on 21 July 2026 it opened a further consultation on letting certain insurers, ILS structures and investment funds use fully fiat-backed stablecoins for subscriptions, treasury and premium or claims payments (comments to 30 September 2026). | 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. |
| Difficulty rating | Bermuda difficulty rating is included in the £349 pass. | Jersey difficulty rating is included in the £349 pass. |
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What changed recently
🇧🇲 Bermuda (verified 2026-08-01): 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. Bitcoin Suisse (International) Ltd was granted a Class F digital asset business licence with Class B investment business registration, reported 13 May 2026, pre-operational pending standard conditions. On tokenisation, the BMA issued a stakeholder letter on 30 March 2026 and a consultation paper on 9 April 2026 (feedback to 30 June 2026); on 21 July 2026 it opened a further consultation on letting certain insurers, ILS structures and investment funds use fully fiat-backed stablecoins for subscriptions, treasury and premium or claims payments (comments to 30 September 2026).
🇯🇪 Jersey (verified 2026-07-02): 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.
Quick answers
Who regulates crypto licensing in Bermuda and Jersey?
Bermuda: Bermuda Monetary Authority (BMA). Jersey: Jersey Financial Services Commission (JFSC)..
What licence do you need in Bermuda compared with Jersey?
In Bermuda the authorisation route is Digital Asset Business (DAB) licence under the Digital Asset Business Act 2018 (DABA), with three tiers: Class T (Test/sandbox licence for early-stage/proof-of-concept businesses, time-limited ~3-12 months), Class M (Modified licence for limited-scope/lower-risk operations, a stepping stone to full authorization), and Class F (Full, unrestricted licence covering the complete range of digital asset business activities, issuance, exchange, custody, payment services, dealing as principal, etc., with no expiry, subject to ongoing supervision).; in Jersey it is Virtual Asset Service Provider (VASP) registration, not a bespoke prudential licence. Legal basis: the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008, the Money Laundering (Jersey) Order 2008, and the JFSC's AML/CFT/CPF Handbook, implementing FATF VASP Guidance (effective from early 2023). This is fundamentally an AML/CFT registration, without a conduct-of-business or prudential capital regime. As of mid-2026, Jersey has not introduced a dedicated substantive VASP licensing framework with conduct/prudential requirements.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Bermuda vs Jersey 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/bermuda-vs-jersey.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.