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| Dimension |
Pinned 🇧🇪 Belgium partly open Verified 2026-10-01
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🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
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|---|---|---|
| Licence type | MiCA CASP authorisation under Article 63 MiCA, given domestic legal effect by the Belgian Act of 11 December 2025 (published in the Belgian Official Gazette 24 December 2025, entered into force 3 January 2026). Before this Act, MiCA was directly applicable EU law but Belgium lacked a domestic supervisory/sanctioning framework, creating a practical gap. | Today, FCA registration under the Money Laundering Regulations 2017 remains the AML and counter-terrorist financing route. Applications for full FSMA authorisation under SI 2026/102 opened on 30 September 2026 and close on 28 February 2027. The mandatory regime commences on 25 October 2027, and existing registrations and permissions do not convert automatically. |
| Regulator | FSMA (Financial Services and Markets Authority) is the competent authority for CASPs that are not credit institutions or stockbroking firms, this covers the great majority of pure-play exchanges and custodians and includes both prudential and conduct-of-business supervision under Article 63. The National Bank of Belgium (NBB) takes the prudential lead where the CASP is (or is part of) a credit institution. | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Belgium capital requirement is included in the £349 pass. | No minimum initial capital under the current MLR registration. The incoming FSMA regime's final prudential rules (PS26/12, 30 Jun 2026) set Permanent Minimum Requirements by activity: GBP 75,000 (arranging/dealing as agent), 150,000 (custody, trading platform, staking), 350,000 (stablecoin issuance), 750,000 (dealing as principal). |
| Timeline to authorisation | Belgium timeline to authorisation is included in the £349 pass. | MLR registration: 3-month statutory clock from a COMPLETE application, but realistically ~9-12 months including pre-application; historically low approval rate. |
| Local substance | Belgium local substance is included in the £349 pass. | Business must be carried on in the UK (UK entity in practice); an MLRO / nominated officer (Reg 21(3)) who is UK-based, genuinely competent, independent and closely involved. |
| Application cost | Belgium application cost is included in the £349 pass. | FCA application fee GBP 11,260 (Category 6, fee-block G23, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | Belgium ongoing cost is included in the £349 pass. | Annual FCA periodic fee under fee-block G.30 for 2026/27: minimum GBP 2,251 plus GBP 6.01 per GBP 1,000 of cryptoasset income above GBP 100,000. Plus AML operations, annual audit and compliance headcount; costs rise materially under the incoming FSMA regime. |
| Passporting | Belgium passporting is included in the £349 pass. | No - post-Brexit the UK regime is standalone; no EU/EEA passport and no MiCA equivalence in either direction. |
| MiCA CASPs approved | Belgium mica casps approved is included in the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Belgium key restrictions is included in the £349 pass. | Cryptoasset financial promotions regime (since 8 Oct 2023): mandatory risk warnings, 24-hour cooling-off for first-timers, ban on incentives; plus significant bank de-risking / de-banking of crypto firms. |
| Recent changes | The Act of 11 December 2025 (Belgium's MiCA implementing law) was the single biggest development: it was published 24 December 2025 and entered into force 3 January 2026, only then giving FSMA/NBB a full domestic legal basis for authorisation, supervision and sanctions. Before that date Belgium had a live enforcement gap despite MiCA being EU law since December 2024. As of last check, 0 CASPs were authorised in Belgium, consistent with the regime being newly operative. As of 3 Jul 2026 the FSMA's own list of authorised Belgian CASPs still records zero authorisations. On 3 Jul 2026 the FSMA also adopted ESMA's guidelines (FSMA_2026_16) on when a non-EU firm is treated as soliciting EU clients, relevant to enforcement against unauthorised third-country platforms. The FSMA's list now separately signposts ESMA's register for CASPs supervised by the National Bank of Belgium; that register records KBC Bank NV as Belgium's first such entry (updated 13 May 2026). | The FCA authorisation gateway opened on 30 September 2026. Firms can now apply for authorisation or vary existing permissions through Connect, and firms seeking the transitional arrangements must apply by 28 February 2027. The mandatory FSMA regime begins on 25 October 2027. The FCA also published final cryptoasset perimeter guidance, PS26/18, on 16 September 2026. |
| Difficulty rating | Belgium difficulty rating is included in the £349 pass. | 4 - rigorous AML bar, historically low approval rate and severe bank-access friction; the incoming FSMA prudential/conduct regime raises the bar further. |
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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