Pin and benchmark
Pin the jurisdiction you are leaning towards, then line up to 5 rivals against it. Every unlocked figure shows where a peer beats it or loses to it on capital, timeline, cost and difficulty, so one screen tells you whether your first choice actually holds up.
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| Dimension |
Pinned 🇵🇹 Portugal partly open Verified 2026-07-01
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🇬🇧 United Kingdom
Free in full
Verified 2026-07-03
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|---|---|---|
| Licence type | MiCA CASP authorisation implemented by Lei n.o 69/2025 (22 Dec 2025). Replaces the legacy Banco de Portugal VASP (AML) registration. | Today: FCA registration under the Money Laundering Regs 2017 (AML/CTF only). Incoming: full FSMA authorisation for cryptoassets (SI 2026/102, made 4 Feb 2026, laid 5 Feb) - gateway opens 30 Sep 2026, mandatory regime commences 25 Oct 2027; no automatic conversion from MLR registration. |
| Regulator | 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.) | Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers. |
| Capital requirement | Portugal capital requirement is locked. Unlock with 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 | Portugal timeline to authorisation is locked. Unlock with 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 | Portugal local substance is locked. Unlock with 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 | Portugal application cost is locked. Unlock with the £349 pass. | FCA application fee GBP 11,150 (Category 6, non-refundable) plus typically GBP 50k-150k in professional fees; ~GBP 90k all-in representative (~EUR 105k at 1.16). |
| Ongoing cost | Portugal ongoing cost is locked. Unlock with the £349 pass. | Annual FCA periodic fee under fee-block G.30 (renumbered from G.23): minimum GBP 2,229 for 2025/26 plus GBP 15.13 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 | Portugal passporting is locked. Unlock with 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 | Portugal mica casps approved is locked. Unlock with the £349 pass. | Not applicable: non-MiCA jurisdiction, no CASP regime. See this jurisdiction's own licence route. |
| Key restrictions | Portugal key restrictions is locked. Unlock with 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 | Lei 69/2025 (MiCA) + Lei 70/2025 (Travel Rule) published 22 Dec 2025 - ~1 year late. Legacy-VASP transitional window closes 1 Jul 2026 (today). Few Portugal-AUTHORISED CASPs so far. | SI 2026/102 made 4 Feb 2026 (laid 5 Feb); FCA final rules published 30 Jun 2026 (PS26/10 stablecoins, PS26/11 regulated activities, PS26/12 prudential); authorisation gateway 30 Sep 2026-28 Feb 2027; mandatory FSMA regime from 25 Oct 2027. |
| Difficulty rating | Portugal difficulty rating is locked. Unlock with 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.