Informational only, not legal advice. Verify with qualified counsel before acting. Full disclaimer

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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
🇨🇭 Switzerland partly open
Verified 2026-07-03
🇬🇧 United Kingdom Free in full
Verified 2026-07-03
Licence type No single crypto licence - regulated by economic function (FINMA token taxonomy; DLT Act 2021). Typical exchange/custodian/broker needs SRO/AMLA affiliation (e.g. VQF) plus, where deposits/custody are involved, a FinTech licence (Banking Act Art. 1b); larger deposit-taking needs a banking licence; a DLT trading facility needs FinMIA authorisation.
Verified 2026-07-03 Source: FINMA - FinTech licence: https://www.finma.ch/en/authorisation/fintech/fintech-bewilligung/
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.
Verified 2026-07-03 Source: FCA - New regime for cryptoasset regulation: https://www.fca.org.uk/firms/new-regime-cryptoasset-regulation
Regulator FINMA (Swiss Financial Market Supervisory Authority) grants all prudential licences; for AML only, firms affiliate with a FINMA-recognised SRO (e.g. VQF). Financial Conduct Authority (FCA); HM Treasury sets the legislative perimeter; Bank of England for systemic stablecoin issuers.
Capital requirement Switzerland 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).
Verified 2026-07-03 Source: FCA PS26/12 - Prudential regime for cryptoasset firms: https://www.fca.org.uk/publication/policy/ps26-12.pdf
Timeline to authorisation Switzerland 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.
Verified 2026-07-03 Source: FCA - How to apply for registration: https://www.fca.org.uk/firms/cryptoassets/how-apply-registration
Local substance Switzerland 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.
Verified 2026-07-01 Source: FCA - How to apply for registration: https://www.fca.org.uk/firms/cryptoassets/how-apply-registration
Application cost Switzerland 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).
Verified 2026-07-03 Source: FCA - Authorisation & registration application fees: https://www.fca.org.uk/firms/authorisation/apply/fees
Ongoing cost Switzerland 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.
Verified 2026-07-03 Source: FCA Handbook FEES App 4 Annex 2 (2025/26 tariff rates): https://www.handbook.fca.org.uk/handbook/FEES/App/4/Annex2.html
Passporting Switzerland 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 Switzerland 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.
Verified 2026-07-01 Source: MiCA scope (EU/EEA only): https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A32023R1114
Key restrictions Switzerland 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.
Verified 2026-07-01 Source: FCA PS23/6 - Financial promotion rules for cryptoassets: https://www.fca.org.uk/publications/policy-statements/ps23-6-financial-promotion-rules-cryptoassets
Recent changes FINMA licensed the first DLT trading facility (BX Digital, 18 Mar 2025); Federal Council consultation (22 Oct 2025 - 6 Feb 2026) proposes to ABOLISH the FinTech licence and replace it with two new categories, Payment Instrument Institutions and Crypto-Institutions, under an amended Financial Institutions Act (FinIA). Confirmed timeline as of this check: new provisions are not expected to enter into force before 2027; existing FinTech-licensed firms will be automatically transitioned to the new Payment Instrument Institution licence without a fresh application, provided they meet the new rules within one year of entry into force. The reform also removes the current CHF 100m deposit cap and adds client-fund segregation on insolvency. FINMA Guidance 01/2026 on crypto custody (12 Jan 2026).
Verified 2026-07-03 Source: Federal Council, admin.ch, https://www.admin.ch/en/newnsb/x4TMWQ1SWofNoFx7XyHhY
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 Switzerland 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.
Verified 2026-07-01 Source: FCA - How to apply: https://www.fca.org.uk/firms/cryptoassets/how-apply-registration

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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.