Pin and benchmark
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| Dimension |
Pinned 🇧🇲 Bermuda partly open Verified 2026-07-02
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🇰🇾 Cayman Islands
partly open
Verified 2026-07-03
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|---|---|---|
| Licence type | Digital Asset Business (DAB) licence under the Digital Asset Business Act 2018 (DABA), with three tiers: Class T (Test/sandbox licence for early-stage/proof-of-concept businesses, time-limited ~3-12 months), Class M (Modified licence for limited-scope/lower-risk operations, a stepping stone to full authorization), and Class F (Full, unrestricted licence covering the complete range of digital asset business activities, issuance, exchange, custody, payment services, dealing as principal, etc., with no expiry, subject to ongoing supervision). | Two-tier regime under the Virtual Asset (Service Providers) Act (VASP Act, as amended). Phase 1 (in force since 2020): VASP Registration, required for virtual asset services generally that are not custody or trading-platform operation; AML/CFT-focused, lighter touch. Phase 2 (in force since 1 April 2025): VASP Licence, mandatory for entities operating a virtual asset custody service or a virtual asset trading platform; registration is no longer available for these two activity categories. A narrow waiver from registration/licensing is available for entities already licensed under another Cayman regulatory law. |
| Regulator | Bermuda Monetary Authority (BMA) | Cayman Islands Monetary Authority (CIMA) |
| Capital requirement | Bermuda capital requirement is locked. Unlock with the £349 pass. | Cayman Islands capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Bermuda timeline to authorisation is locked. Unlock with the £349 pass. | Cayman Islands timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Bermuda local substance is locked. Unlock with the £349 pass. | Cayman Islands local substance is locked. Unlock with the £349 pass. |
| Application cost | Bermuda application cost is locked. Unlock with the £349 pass. | Cayman Islands application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Bermuda ongoing cost is locked. Unlock with the £349 pass. | Cayman Islands ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Bermuda passporting is locked. Unlock with the £349 pass. | Cayman Islands passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Bermuda mica casps approved is locked. Unlock with the £349 pass. | Cayman Islands mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Bermuda key restrictions is locked. Unlock with the £349 pass. | Cayman Islands key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | In January 2026, at the WEF Annual Meeting in Davos, the Government of Bermuda announced a partnership with Circle and Coinbase (and Stellar) to build what it describes as the world's first 'fully onchain' national economy, including plans for a sovereign Bermuda digital dollar. The BMA has begun real-world pilots, airdropping USDC to residents, enabling payments at a pop-up marketplace, and preparing to accept digital assets for government fees. Bermuda also hosts regulated derivatives operations tied to major exchanges including Coinbase and Kraken. The BMA's 2025 annual report shows licensed digital asset businesses rose to 49 by end of 2025 (up from 36 a year earlier). The DABA Code of Practice was also updated in 2024 with more detailed marketing/promotion and governance requirements. | Phase 2 licensing (custody and trading platforms) came into force 1 April 2025, with a 90-day transition deadline of 30 June 2025 for existing registrants to convert to a licence. CIMA updated the VASP application forms, Rule, and Statement of Guidance in December 2024 ahead of Phase 2. From 1 December 2025, CIMA introduced a new quarterly financial reporting requirement via the REEFS portal, layered on top of the existing annual audited accounts requirement. CIMA conducted a Thematic Desk-Based Review of 11 regulated VASPs (September 2024-February 2025), with findings published November 2025 and a further legal briefing in February 2026, identifying gaps in board composition, cybersecurity governance, staff training, and sanctions-screening practices. A Phase 3 is expected but not yet commenced as of mid-2026. |
| Difficulty rating | Bermuda difficulty rating is locked. Unlock with the £349 pass. | Cayman Islands difficulty rating is locked. Unlock with 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.