Pin and benchmark
Pin one jurisdiction. Line up to five rivals against it. Deltas show where each peer is better or worse.
Sign in to watch these jurisdictions for changes.
| Dimension |
Pinned 🇮🇹 Italy partly open Verified 2026-10-01
|
🇬🇧 United Kingdom
Free in full
Verified 2026-10-01
|
|---|---|---|
| Licence type | MiCA CASP authorisation under EU Regulation 2023/1114, transposed via Legislative Decree 129/2025 and implemented through Consob Resolution 23700/2025. Pre-MiCA VASPs (registered under the OAM register per AML Decree 90/2017) had to convert to full CASP authorisation; transitional regime for existing VASPs was extended to 1 July 2026. | 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 | Split regulator model: Consob (Commissione Nazionale per le Società e la Borsa) is the lead competent authority issuing CASP authorisation and supervising conduct-of-business/market integrity; Banca d'Italia is consulted on and supervises prudential aspects (capital, governance, AML) and directly handles credit institutions/e-money institutions offering crypto services (e.g. Banca Sella's notification route). | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Italy 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 | Italy 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 | Italy 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 | Italy 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 | Italy 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 | Italy 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 | Italy 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 | Italy 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 | Consob Resolution 23700/2025 (introducing the EUR 20,000 fee) took effect 1 December 2025; the transitional regime for pre-MiCA VASPs was extended to 1 July 2026 (later than the original MiCA default cut-off), giving Italian firms extra runway. As of 1 July 2026, 8 firms hold full CASP authorisation, a sharp jump from near-zero conversions reported earlier in 2026, though still a small fraction of the pre-MiCA registered population. | 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 | Italy 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.
One-question research
Did this page help you reach the next useful outcome?
No email is collected. An optional short note helps us understand what is missing.