🇬🇮 Gibraltar vs 🇬🇧 United Kingdom: crypto licensing compared
Choosing between Gibraltar and United Kingdom for a crypto licence starts with who you will answer to: Gibraltar Financial Services Commission (GFSC), with a dedicated DLT/innovation team running pre-application engagement; also the AML/CFT supervisor under the Proceeds of Crime Act 2015. 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 GFSC DLT Provider licence under the Financial Services (DLT Providers) Regulations 2020 (in force since 1 Jan 2018), required of any firm using DLT to store or transmit value belonging to others in/from Gibraltar. Principles-based (10 core principles), not a MiCA-style category licence. and the 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. respectively. The two regimes differ on 7 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. Every figure behind the comparison carries a last-verified date and a primary source.
Gibraltar: verified 2026-07-03 · United Kingdom: verified 2026-07-03
| Dimension |
🇬🇮 Gibraltar
partly open
Verified 2026-07-03
|
🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
|
|---|---|---|
| Licence type | GFSC DLT Provider licence under the Financial Services (DLT Providers) Regulations 2020 (in force since 1 Jan 2018), required of any firm using DLT to store or transmit value belonging to others in/from Gibraltar. Principles-based (10 core principles), not a MiCA-style category licence. | 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 | Gibraltar Financial Services Commission (GFSC), with a dedicated DLT/innovation team running pre-application engagement; also the AML/CFT supervisor under the Proceeds of Crime Act 2015. | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Gibraltar capital requirement is locked. Unlock with 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 | Gibraltar timeline to authorisation is locked. Unlock with 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 | Gibraltar local substance is locked. Unlock with 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 | Gibraltar application cost is locked. Unlock with the £349 pass. | 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 | Gibraltar ongoing cost is locked. Unlock with the £349 pass. | 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 | Gibraltar passporting is locked. Unlock with 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 | Gibraltar mica casps approved is locked. Unlock with the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Gibraltar key restrictions is locked. Unlock with 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 | Fee increases in force 1 Apr 2025 (application GBP 45k; annual trade-fee cap GBP 90k); world-first Digital Clearing & Settlement Framework announced 13 May 2025; Restricted Promotions rules (May 2025); CARF adoption from 2026; and a DLT Regs overhaul with progressive MiCA-alignment signalled Feb 2026 (draft expected 2026). UK transitional passporting extended to 31 Dec 2026. | 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. |
| Difficulty rating | Gibraltar difficulty rating is locked. Unlock with 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. |
The two regimes differ on 7 of 9 tracked decision dimensions, including capital requirement and timeline to authorisation. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇬🇮 Gibraltar (verified 2026-07-03): Fee increases in force 1 Apr 2025 (application GBP 45k; annual trade-fee cap GBP 90k); world-first Digital Clearing & Settlement Framework announced 13 May 2025; Restricted Promotions rules (May 2025); CARF adoption from 2026; and a DLT Regs overhaul with progressive MiCA-alignment signalled Feb 2026 (draft expected 2026). UK transitional passporting extended to 31 Dec 2026.
🇬🇧 United Kingdom (verified 2026-07-03): 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.
Quick answers
Who regulates crypto licensing in Gibraltar and United Kingdom?
Gibraltar: Gibraltar Financial Services Commission (GFSC), with a dedicated DLT/innovation team running pre-application engagement; also the AML/CFT supervisor under the Proceeds of Crime Act 2015.. 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 Gibraltar compared with United Kingdom?
In Gibraltar the authorisation route is GFSC DLT Provider licence under the Financial Services (DLT Providers) Regulations 2020 (in force since 1 Jan 2018), required of any firm using DLT to store or transmit value belonging to others in/from Gibraltar. Principles-based (10 core principles), not a MiCA-style category licence.; 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 Gibraltar 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/gibraltar-vs-united-kingdom.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.