🇬🇮 Gibraltar vs 🇬🇧 United Kingdom: crypto licensing compared
Decision context and regulator route
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 permission under the Financial Services (DLT Providers and VAA Providers) Regulations 2020. The framework covers firms using DLT to store or transmit value belonging to others and, since 27 October 2025, VAA providers exchanging virtual assets for money or other virtual assets. It is a principles-based permission, not a MiCA category licence. 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.
Gibraltar: verified 2026-10-01 · United Kingdom: verified 2026-10-01
| Dimension |
🇬🇮 Gibraltar
partly open
Verified 2026-10-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
|
|---|---|---|
| Licence type | GFSC permission under the Financial Services (DLT Providers and VAA Providers) Regulations 2020. The framework covers firms using DLT to store or transmit value belonging to others and, since 27 October 2025, VAA providers exchanging virtual assets for money or other virtual assets. It is a principles-based permission, not a MiCA category licence. | 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 | 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 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 | Gibraltar 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 | Gibraltar 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 | Gibraltar 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 | Gibraltar 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 | Gibraltar 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 | Gibraltar 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 | Gibraltar 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 | LN 2025/254 expanded the 2020 Regulations to DLT Providers and VAA Providers from 27 October 2025, expressly capturing virtual-asset exchange arrangements. LN 2026/053 took effect on 26 March 2026 and introduced 30-day pre-notification and GFSC no-objection requirements for dividends by DLT and VAA providers. The wider DLT-regime overhaul signalled in February 2026 still had no published draft or Bill in the official legislation register on 1 October 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 | Gibraltar 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
🇬🇮 Gibraltar (verified 2026-10-01): LN 2025/254 expanded the 2020 Regulations to DLT Providers and VAA Providers from 27 October 2025, expressly capturing virtual-asset exchange arrangements. LN 2026/053 took effect on 26 March 2026 and introduced 30-day pre-notification and GFSC no-objection requirements for dividends by DLT and VAA providers. The wider DLT-regime overhaul signalled in February 2026 still had no published draft or Bill in the official legislation register on 1 October 2026.
🇬🇧 United Kingdom (verified 2026-10-01): 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 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 permission under the Financial Services (DLT Providers and VAA Providers) Regulations 2020. The framework covers firms using DLT to store or transmit value belonging to others and, since 27 October 2025, VAA providers exchanging virtual assets for money or other virtual assets. It is a principles-based permission, not a MiCA category licence.; 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 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.