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| Dimension |
Pinned 🇲🇹 Malta partly open Verified 2026-08-15
|
🇵🇹 Portugal
partly open
Verified 2026-08-15
|
|---|---|---|
| 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 included in the £349 pass. | Portugal capital requirement is included in the £349 pass. |
| Timeline to authorisation | Malta timeline to authorisation is included in the £349 pass. | Portugal timeline to authorisation is included in the £349 pass. |
| Local substance | Malta local substance is included in the £349 pass. | Portugal local substance is included in the £349 pass. |
| Application cost | Malta application cost is included in the £349 pass. | Portugal application cost is included in the £349 pass. |
| Ongoing cost | Malta ongoing cost is included in the £349 pass. | Portugal ongoing cost is included in the £349 pass. |
| Passporting | Malta passporting is included in the £349 pass. | Portugal passporting is included in the £349 pass. |
| MiCA CASPs approved | Malta mica casps approved is included in the £349 pass. | Portugal mica casps approved is included in the £349 pass. |
| Key restrictions | Malta key restrictions is included in the £349 pass. | Portugal key restrictions is included in 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) and Lei 70/2025 (Travel Rule) published 22 Dec 2025, about a year late. The legacy-VASP transitional window closed 1 Jul 2026. Bison Bank became Portugal's first MiCA-authorised CASP in late Jun 2026, following approval from Banco de Portugal and the CMVM. |
| Difficulty rating | Malta difficulty rating is included in the £349 pass. | Portugal 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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