🇲🇹 Malta vs 🇵🇹 Portugal: crypto licensing compared
Malta and Portugal take recognisably different routes to crypto authorisation. In Malta the route is the MiCA CASP authorisation under the Markets in Crypto-Assets Act (Cap. 647); replaces the legacy VFA licence (VFA Act 2018) via a fast-track conversion. Malta granted one of the EU's first full CASP licences (Jan 2025). overseen by Malta Financial Services Authority (MFSA) - single competent authority; a long-standing crypto supervisor since the 2018 VFA regime.; 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.
Malta: verified 2026-07-03 · Portugal: verified 2026-07-01
| Dimension |
🇲🇹 Malta
partly open
Verified 2026-07-03
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🇵🇹 Portugal
partly open
Verified 2026-07-01
|
|---|---|---|
| Licence type | MiCA CASP authorisation under the Markets in Crypto-Assets Act (Cap. 647); replaces the legacy VFA licence (VFA Act 2018) via a fast-track conversion. Malta granted one of the EU's first full CASP licences (Jan 2025). | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. |
| Regulator | Malta Financial Services Authority (MFSA) - single competent authority; a long-standing crypto supervisor since the 2018 VFA regime. | 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 | Malta capital requirement is locked. Unlock with the £349 pass. | Portugal capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Malta timeline to authorisation is locked. Unlock with the £349 pass. | Portugal timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Malta local substance is locked. Unlock with the £349 pass. | Portugal local substance is locked. Unlock with the £349 pass. |
| Application cost | Malta application cost is locked. Unlock with the £349 pass. | Portugal application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Malta ongoing cost is locked. Unlock with the £349 pass. | Portugal ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Malta passporting is locked. Unlock with the £349 pass. | Portugal passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Malta mica casps approved is locked. Unlock with the £349 pass. | Portugal mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Malta key restrictions is locked. Unlock with the £349 pass. | Portugal key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | First-mover: Crypto.com licensed 27 Jan 2025; ~13 CASPs now authorised (OKX, Gemini, Gate, Blockchain.com). ESMA's 10 Jul 2025 peer review criticised the MFSA's authorisation of one CASP, tightening scrutiny. Transition ends 1 Jul 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 | Malta 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
🇲🇹 Malta (verified 2026-07-01): First-mover: Crypto.com licensed 27 Jan 2025; ~13 CASPs now authorised (OKX, Gemini, Gate, Blockchain.com). ESMA's 10 Jul 2025 peer review criticised the MFSA's authorisation of one CASP, tightening scrutiny. Transition ends 1 Jul 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 Malta and Portugal?
Malta: Malta Financial Services Authority (MFSA) - single competent authority; a long-standing crypto supervisor since the 2018 VFA regime.. 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 Malta compared with Portugal?
In Malta the authorisation route is MiCA CASP authorisation under the Markets in Crypto-Assets Act (Cap. 647); replaces the legacy VFA licence (VFA Act 2018) via a fast-track conversion. Malta granted one of the EU's first full CASP licences (Jan 2025).; 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 Malta 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/malta-vs-portugal.
Informational only, not legal advice. Every open figure carries its own verification date; verify with qualified counsel before acting.