🇱🇺 Luxembourg vs 🇵🇹 Portugal: crypto licensing compared
Luxembourg and Portugal take recognisably different routes to crypto authorisation. In Luxembourg the route is the MiCA CASP Authorisation granted by the Commission de Surveillance du Secteur Financier (CSSF) overseen by Commission de Surveillance du Secteur Financier (CSSF); in Portugal it is the MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. under Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.). The two regimes differ on 6 of 9 tracked decision dimensions, including local substance and application cost. The free columns below are open to everyone; the decision figures unlock with a pass, each one dated and sourced.
Luxembourg: verified 2026-07-02 · Portugal: verified 2026-07-01
| Dimension |
🇱🇺 Luxembourg
partly open
Verified 2026-07-02
|
🇵🇹 Portugal
partly open
Verified 2026-07-01
|
|---|---|---|
| Licence type | MiCA CASP Authorisation granted by the Commission de Surveillance du Secteur Financier (CSSF) | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. |
| Regulator | Commission de Surveillance du Secteur Financier (CSSF) | Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.) |
| Capital requirement | Luxembourg capital requirement is locked. Unlock with the £349 pass. | Portugal capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Luxembourg timeline to authorisation is locked. Unlock with the £349 pass. | Portugal timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Luxembourg local substance is locked. Unlock with the £349 pass. | Portugal local substance is locked. Unlock with the £349 pass. |
| Application cost | Luxembourg application cost is locked. Unlock with the £349 pass. | Portugal application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Luxembourg ongoing cost is locked. Unlock with the £349 pass. | Portugal ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Luxembourg passporting is locked. Unlock with the £349 pass. | Portugal passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Luxembourg mica casps approved is locked. Unlock with the £349 pass. | Portugal mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Luxembourg key restrictions is locked. Unlock with the £349 pass. | Portugal key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | Rapid growth in H1 2026: as of 30 June 2026, 11 active CASPs including B2C2 Europe, Banking Circle, Bitstamp Europe, Bridge Building, Clearstream Banking, Coinbase Luxembourg, Stokr, Standard Chartered Luxembourg, Swissquote Bank Europe, Zodia Custody Europe and BitFlyer; BitFlyer authorised 26 June 2026, Stokr 22 June 2026, Bridge Building 29 June 2026, all just before the transitional deadline expired on 1 July 2026 | Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far. |
| Difficulty rating | Luxembourg difficulty rating is locked. Unlock with the £349 pass. | Portugal difficulty rating is locked. Unlock with the £349 pass. |
The two regimes differ on 6 of 9 tracked decision dimensions, including local substance and application cost. Unlock the pass to see each figure with its source and verification date.
What changed recently
🇱🇺 Luxembourg (verified 2026-07-02): Rapid growth in H1 2026: as of 30 June 2026, 11 active CASPs including B2C2 Europe, Banking Circle, Bitstamp Europe, Bridge Building, Clearstream Banking, Coinbase Luxembourg, Stokr, Standard Chartered Luxembourg, Swissquote Bank Europe, Zodia Custody Europe and BitFlyer; BitFlyer authorised 26 June 2026, Stokr 22 June 2026, Bridge Building 29 June 2026, all just before the transitional deadline expired on 1 July 2026
🇵🇹 Portugal (verified 2026-07-01): Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far.
Quick answers
Who regulates crypto licensing in Luxembourg and Portugal?
Luxembourg: Commission de Surveillance du Secteur Financier (CSSF). Portugal: Twin-peaks: BANCO DE PORTUGAL is the CASP authorisation authority + prudential/AML supervisor (single application front door); CMVM is the conduct-of-business and market-abuse supervisor. (Corrects the seed - not CMVM-led.).
What licence do you need in Luxembourg compared with Portugal?
In Luxembourg the authorisation route is MiCA CASP Authorisation granted by the Commission de Surveillance du Secteur Financier (CSSF); in Portugal it is MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration.. The comparison table on this page lines the two up dimension by dimension.
Where can I see the full Luxembourg vs Portugal 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/luxembourg-vs-portugal.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.