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Quarterly report

State of Crypto Licensing Q3 2026: Gateways Open, Deadlines Slip

Q3 2026 Published 2026-10-02 By LicenceMap Research

What Q3 2026 means for a licensing decision

The third quarter of 2026 rewarded firms that had already picked a route and punished those still waiting for the rules to settle. Between 1 July and 30 September 2026, Japan passed its long-trailed overhaul, the UK opened its authorisation gateway on schedule, and Hungary dismantled the domestic regime that had made it an outlier inside MiCA. In the same quarter the United States missed its own stablecoin rulemaking deadline and Romania still had no designated MiCA authority. If you are choosing where to apply in Q4 2026, the practical message is that the jurisdictions with a working front door have pulled further ahead of those still building one.

Our view: treat the UK and Japan as live planning targets now, treat Hungary as newly viable for an EU passport, and treat Romania and the US federal stablecoin route as dependencies you cannot yet schedule against. Our H1 2026 report framed the EU as three tiers of volume hubs, selective gateways and a long tail. Nothing in Q3 2026 broke that framing, but two states moved categories.

What changed in the LicenceMap dataset

Every figure in this section comes from the git history of our crypto and e-money datasets between 3 July 2026 and 1 September 2026, plus the run summaries in our refresh log.

  • Refresh cadence: nine dataset version bumps in each regime during the quarter, from 10 July 2026 to 1 September 2026, plus a US state file release on 17 July 2026 covering 56 states and territories.
  • Coverage: one jurisdiction added. Iceland joined the crypto matrix on 10 July 2026, taking it to 53 regimes. The e-money matrix held at 37. Nothing was removed.
  • Crypto: 119 cell values changed across 50 jurisdictions. The busiest field was authorised-firm counts (38 cells), followed by recent regulatory changes (28) and key restrictions (10). Spain saw the most revisions (6 cells), with Gibraltar, Liechtenstein, Czechia, Sweden and Turkey on 5 each.
  • E-money: 57 cell values changed across 36 jurisdictions, led by recent regulatory changes (35 cells) and authorised-institution counts (6). Gibraltar and Singapore saw the most revisions (4 each).
  • Cost, capital and timeline cells: 35 crypto cells and 15 e-money cells in these gated fields changed value during the quarter. The current figures sit behind the paid tier.
  • Confidence upgrades: 32 crypto cells and 14 e-money cells moved to "verified" against a primary source, mostly in the 10 July, 1 August and 15 August 2026 refreshes.
  • Regime status: no jurisdiction flipped status in either regime this quarter, according to the change log entries dated 10 July, 1 August and 15 August 2026 and the 1 September 2026 run summary.

Revisions clustered in authorised-firm counts and recent-change narrative, as expected once MiCA's transitional periods ended on 1 July 2026. Entry-level detail is on the changes page.

Licence wording that changed

Four free-text licence descriptions were rewritten in Q3 2026 because the underlying legal basis had moved or been clarified:

  • Gibraltar, crypto: now described as a GFSC permission under the DLT Providers and VAA Providers Regulations 2020, reflecting the virtual asset arrangement provider category. The e-money entry now cites the Electronic Money Regulations 2020 rather than the 2011 regulations.
  • Romania: now described as CASP authorisation under directly applicable MiCA, with national implementation unsettled (see below).
  • Thailand: the SEC category list was reworded and now includes the digital asset advisor category, per the SEC licence check register.
  • Indonesia: the regulator entry now records that OJK took over supervision from Bappebti under Government Regulation 49/2024.

The quarter's regulatory moves

Japan passes its FIEA overhaul

On 15 July 2026 the Diet gave final passage to the bill amending the Financial Instruments and Exchange Act and the Payment Services Act, which the Cabinet had approved on 10 April 2026. Our H1 report covered this as a pending bill, so the news in Q3 2026 is enactment. Commentary published on 28 July 2026 states the law takes effect within one year of promulgation. Japan is moving crypto business from a payments framework towards securities-style regulation, so firms planning entry in 2027 should plan for an FIEA-grade compliance build.

The UK gateway opens on time

The FCA opened its cryptoasset authorisation gateway on 30 September 2026, following final rules published in June 2026 under the Financial Services and Markets Act 2000 (Cryptoassets) Regulations 2026. The FCA states the application window closes on 28 February 2027 and the regime commences on 25 October 2027. For any firm serving UK customers, the United Kingdom is now the most time-critical decision on our map, because the window is fixed and closes well before commencement.

Hungary removes its outlier regime

Hungary's Act XXXVIII of 2026 was published in the Magyar Közlöny on 30 July 2026 and took effect on 7 August 2026. It ends the mandatory crypto-exchange validation regime and removes the related Criminal Code offences. Through H1 2026 that regime had made Hungary awkward to operate in even for firms holding a MiCA passport from elsewhere. From 7 August 2026, that national overlay is gone, which in our view puts Hungary back on a passporting shortlist. We recorded the change in our 15 August 2026 refresh.

Romania still has no designated MiCA authority

As of 1 July 2026, the ASF's First Vice-President confirmed in an interview that Romania had no authority designated to apply MiCA. We found no enabling law or ordinance adopted by 30 September 2026. A Ministry of Finance ordinance has been proposed but not adopted. Until a competent authority is designated, Romania cannot sensibly be planned as a home state for authorisation, though inbound passporting from another member state is unaffected.

The US misses its stablecoin rulemaking deadline

The GENIUS Act, signed on 18 July 2025, set 18 July 2026 as the deadline for implementing regulations. That date passed without a final rule from any federal banking agency. The OCC proposed in March 2026 and the FDIC published its proposal on 10 April 2026. The Federal Reserve published its proposal on 29 September 2026, and Treasury published an interim final rule on state certification procedures on 30 September 2026, with comments on both due by 30 November 2026. The Act's backstop effective date is 18 January 2027 or 120 days after final regulations, whichever is earlier. For US stablecoin issuers, the federal licensing path is still a moving target as at 30 September 2026.

Guernsey widens access

Rules made in September 2026 and in force from 1 October 2026 remove Guernsey's blanket restriction on retail activity by virtual asset service providers, and drop the need for already-licensed firms to hold a separate VASP licence, according to local press on 27 September 2026 and the GFSC's December 2025 consultation. The change takes effect in Q4 2026, but firms considering Guernsey should weigh it now.

First CASPs in smaller EU and EEA markets

Portugal saw a bank reported as its first authorised CASP on 30 July 2026. Iceland's first CASP authorisation was reported on 25 June 2026, and we added Iceland to the crypto matrix on 10 July 2026. The long tail is filling slowly, and one authorisation does not make a practical gateway.

What to watch in Q4 2026

  • UK applications: the FCA window runs to 28 February 2027.
  • US: comments close on the Fed proposal and Treasury interim rule on 30 November 2026, ahead of the 18 January 2027 backstop.
  • Romania: whether Parliament, back from recess since 1 September 2026, designates a MiCA authority.
  • Japan: the promulgation date and FSA implementing ordinances.
  • E-money: formal adoption of PSD3 and the PSR, which had not been published in the Official Journal by 30 September 2026.

Sources

This report is for information only and is not legal advice. Check current requirements with the relevant regulator before acting.

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Informational only, not legal advice. Verify with the relevant regulator and qualified counsel before acting.