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| Dimension |
Pinned 🇦🇪 ADGM (Abu Dhabi) partly open Verified 2026-08-15
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🇧🇭 Bahrain
partly open
Verified 2026-08-15
|
|---|---|---|
| Licence type | Financial Services Permission (FSP) from the FSRA to carry on one or more 'Regulated Activities' in relation to Virtual Assets under the ADGM Financial Services and Markets Regulations (FSMR), e.g. Operating a Multilateral Trading Facility (exchange), Providing Custody, Dealing in Investments as Principal/Agent (broker-dealer), Managing Assets, or Advising on Investments, each 'in relation to Virtual Assets.' The framework was originally branded 'Operating a Crypto Asset Business' (2018 Guidance) and has since been folded into the broader Virtual Asset regulated-activities regime under the 'Guidance - Regulation of Virtual Asset Activities in ADGM' (most recent version 10 June 2025). A related but separate activity/licence covers issuing Fiat-Referenced Tokens (FRTs, i.e. stablecoins). | Crypto-Asset Service Licence under CBB Rulebook Volume 6 (Capital Markets), Crypto-Asset Module (CRA), issued under Decree Law No. 64 of 2006 (CBB Law). Four categories: Category 1 (reception/transmission of orders, investment advice), Category 2 (Cat-1 activities plus trading as agent, portfolio management, custody), Category 3 (Cat-2 activities plus trading as principal/dealing on own account), Category 4 (operating a licensed crypto-asset exchange plus custody). A separate Stablecoin Issuance and Offering (SIO) Module (also Volume 6) now licenses stablecoin issuers. |
| Regulator | Financial Services Regulatory Authority (FSRA) of Abu Dhabi Global Market (ADGM) | Central Bank of Bahrain (CBB) |
| Capital requirement | ADGM (Abu Dhabi) capital requirement is included in the £349 pass. | Bahrain capital requirement is included in the £349 pass. |
| Timeline to authorisation | ADGM (Abu Dhabi) timeline to authorisation is included in the £349 pass. | Bahrain timeline to authorisation is included in the £349 pass. |
| Local substance | ADGM (Abu Dhabi) local substance is included in the £349 pass. | Bahrain local substance is included in the £349 pass. |
| Application cost | ADGM (Abu Dhabi) application cost is included in the £349 pass. | Bahrain application cost is included in the £349 pass. |
| Ongoing cost | ADGM (Abu Dhabi) ongoing cost is included in the £349 pass. | Bahrain ongoing cost is included in the £349 pass. |
| Passporting | ADGM (Abu Dhabi) passporting is included in the £349 pass. | Bahrain passporting is included in the £349 pass. |
| MiCA CASPs approved | ADGM (Abu Dhabi) mica casps approved is included in the £349 pass. | Bahrain mica casps approved is included in the £349 pass. |
| Key restrictions | ADGM (Abu Dhabi) key restrictions is included in the £349 pass. | Bahrain key restrictions is included in the £349 pass. |
| Recent changes | June 10, 2025: FSRA implemented major amendments, shifted from FSRA pre-approval for Virtual Assets to a notification-based process built on applicant self-assessment; introduced express prohibition on privacy tokens and algorithmic stablecoins; revised capital requirements and fees for VA firms; added product-intervention power for virtual assets. September 2025 (Abu Dhabi Finance Week): FSRA published Consultation Paper No. 10 of 2025 proposing a staking framework. Finalised Fiat-Referenced Token (FRT) framework followed, with FEES Rulebook amendments effective 1 January 2026 (published 31 October 2025). April 29, 2026: FSRA finalised the Virtual Asset staking regulatory framework after consultation. December 2025/January 2026: Binance received FSRA approval (announced 7 December 2025) to operate its global Binance.com platform in ADGM via three regulated entities, described as the first global platform-level licence of this kind under the ADGM framework, operations beginning 5 January 2026. On 7 Jul 2026 the FSRA granted a Financial Services Permission to BTCS (Middle East), the Abu Dhabi subsidiary of Bitcoin Suisse, covering spot trading in accepted virtual assets, institutional custody and derivatives for institutional and professional clients. On 23 July 2026 the FSRA recognised Tether Gold (XAUT) as an Accepted Spot Commodity in ADGM, a spot-commodities recognition distinct from the virtual-asset regulated activities, allowing appropriately permissioned firms to offer the token. | In July 2025 the CBB issued a new Stablecoin Issuance and Offering (SIO) Module, added to Rulebook Volume 6, creating Bahrain's first dedicated stablecoin licensing framework. It covers issuance, minting, burning, and reserve management of single-currency stablecoins backed by BHD, USD, or other CBB-accepted fiat currencies; requires issuers to incorporate as a Bahraini B.S.C.; mandates perpetual redemption rights for holders; and explicitly permits yield-bearing stablecoins (subject to CBB-set limits). On 3 June 2026 AX Coin Bahrain B.S.C. (c), a subsidiary of Nasdaq-listed Solowin Holdings, announced it had been granted the first licence under this framework, for stablecoin issuer activities (per the issuer's announcement; a CBB press release confirming the grant is pending direct confirmation). Separately, CBB granted a new Category 3 crypto-asset licence to Fasset Financial Services W.L.L. in January 2025. In May 2026 the CBB restructured the approved-persons section (CRA-1.7) of the Crypto-Asset Module, regrouping its fit-and-proper, prior-approval and notification rules under relocated headings (Rulebook revision of 6 May 2026). |
| Difficulty rating | ADGM (Abu Dhabi) difficulty rating is included in the £349 pass. | Bahrain difficulty rating is included in the £349 pass. |
Informational only, not legal advice. A delta compares the sortable figure only (capital, timeline, cost, difficulty, passporting, approvals); it is not a judgement on overall suitability. Verify with qualified counsel before acting.
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