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| Dimension |
Pinned 🇮🇲 Isle of Man partly open Verified 2026-07-02
|
🇯🇪 Jersey
partly open
Verified 2026-07-02
|
|---|---|---|
| Licence type | No dedicated/bespoke crypto licence exists. Virtual asset/virtual-currency businesses not otherwise regulated must register as a 'Designated Business' with the Isle of Man Financial Services Authority (IOMFSA) under the Designated Businesses (Registration and Oversight) Act 2015 (DBRO Act). This is an AML/CTF registration regime only, it confers no market authorisation, conduct-of-business, or prudential status akin to a licence. | Virtual Asset Service Provider (VASP) registration, not a bespoke prudential licence. Legal basis: the Proceeds of Crime (Supervisory Bodies) (Jersey) Law 2008, the Money Laundering (Jersey) Order 2008, and the JFSC's AML/CFT/CPF Handbook, implementing FATF VASP Guidance (effective from early 2023). This is fundamentally an AML/CFT registration, without a conduct-of-business or prudential capital regime. As of mid-2026, Jersey has not introduced a dedicated substantive VASP licensing framework with conduct/prudential requirements. |
| Regulator | Isle of Man Financial Services Authority (IOMFSA), administering DBRO Act registration (oversight of some professions may be delegated to a recognised delegated oversight body, e.g. legal/accountancy bodies). | Jersey Financial Services Commission (JFSC). |
| Capital requirement | Isle of Man capital requirement is locked. Unlock with the £349 pass. | Jersey capital requirement is locked. Unlock with the £349 pass. |
| Timeline to authorisation | Isle of Man timeline to authorisation is locked. Unlock with the £349 pass. | Jersey timeline to authorisation is locked. Unlock with the £349 pass. |
| Local substance | Isle of Man local substance is locked. Unlock with the £349 pass. | Jersey local substance is locked. Unlock with the £349 pass. |
| Application cost | Isle of Man application cost is locked. Unlock with the £349 pass. | Jersey application cost is locked. Unlock with the £349 pass. |
| Ongoing cost | Isle of Man ongoing cost is locked. Unlock with the £349 pass. | Jersey ongoing cost is locked. Unlock with the £349 pass. |
| Passporting | Isle of Man passporting is locked. Unlock with the £349 pass. | Jersey passporting is locked. Unlock with the £349 pass. |
| MiCA CASPs approved | Isle of Man mica casps approved is locked. Unlock with the £349 pass. | Jersey mica casps approved is locked. Unlock with the £349 pass. |
| Key restrictions | Isle of Man key restrictions is locked. Unlock with the £349 pass. | Jersey key restrictions is locked. Unlock with the £349 pass. |
| Recent changes | After a 2024 consultation on introducing a more substantive crypto licensing regime, the IOMFSA confirmed (2025) it would retain the current DBRO-Act registration approach 'for the time being', while keeping the matter under review. Separately, an industry-funded fee model phased in from 2023 is being revisited via consultation CP25-04 (issued 6 November 2025) on the proposed IOMFSA Fees Order 2026. | JFSC proposed enhancements to the AML/CFT/CPF Handbook (consultation published June 2025), taking effect 1 January 2026, including new sector-specific guidance for VASPs/DNFBPs partly in response to MONEYVAL's 2024 evaluation of Jersey. Jersey is implementing the OECD Crypto-Asset Reporting Framework (CARF): consultation began November 2024, legislation expected 2025, first CARF reporting due 2027. A government consultation (July-Sept 2025) on repealing the Control of Borrowing (COBO) framework proposes replacement legislation for digital-asset-related structures with a 12-24 month transition. In 2024 Jersey launched its first real-world-asset tokenisation platform under JFSC guidance. |
| Difficulty rating | Isle of Man difficulty rating is locked. Unlock with the £349 pass. | Jersey 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.