Global Regulation Intelligence
Nine of the 15 market files have a broadly operating regime. But only UAE (Dubai) marks trading, customer assets, stablecoins, lending and marketing as live together. That is rulebook coverage—not a licence for a company.
FCA crypto permission application window opens
Application windows, transition ends and new operating rules do different things. The line below keeps them on one clock without pretending they are the same event.
FCA crypto permission application window opens
26 days from editionPrudential requirements begin
119 days from editionFCA application window closes
177 days from editionLicence transition period ends
300 days from editionFCA expects the wider crypto regime to begin
416 days from editionThe broad label hides the real work. Trading and customer-asset rules are live in ten of the 15 files. Lending and staking are fully live in one. Select a service to recolour the atlas; the written chart stays complete without JavaScript.
| Market file | Trading | Customer assets | Stablecoins | Lending & staking | Marketing |
|---|---|---|---|---|---|
| AustraliaTransition · checked 4 Sep 2026 | Changing | Split | Changing | Split | Rules live |
| RussiaTransition · checked 4 Sep 2026 | Changing | Changing | Changing | Not verified | Rules live |
| United KingdomTransition · checked 4 Sep 2026 | Changing | Changing | Changing | Changing | Rules live |
| IndiaPartial · checked 4 Sep 2026 | Limited rules | Limited rules | Not verified | Not verified | Split |
| South KoreaPartial · checked 4 Sep 2026 | Rules live | Rules live | Changing | Split | Limited rules |
| United StatesPartial · checked 4 Sep 2026 | Split | Split | Changing | Split | Split |
| BrazilOperating · checked 4 Sep 2026 | Rules live | Rules live | Split | Split | Rules live |
| CanadaOperating · checked 4 Sep 2026 | Rules live | Rules live | Changing | Split | Rules live |
| European UnionOperating · checked 4 Sep 2026 | Rules live | Rules live | Rules live | Split | Rules live |
| Hong KongOperating · checked 4 Sep 2026 | Rules live | Rules live | Rules live | Split | Rules live |
| JapanOperating · checked 4 Sep 2026 | Rules live | Rules live | Rules live | Split | Rules live |
| SingaporeOperating · checked 4 Sep 2026 | Rules live | Rules live | Rules live | Split | Rules live |
| South AfricaOperating · checked 4 Sep 2026 | Rules live | Rules live | Split | Split | Rules live |
| SwitzerlandOperating · checked 4 Sep 2026 | Rules live | Rules live | Rules live | Split | Rules live |
| UAE (Dubai)Operating · checked 4 Sep 2026 | Rules live | Rules live | Rules live | Rules live | Rules live |
Each file separates what is law today, what is proposed or still moving through transition, and the exact permission a company must check. It also names the assumption most likely to cause a bad cross-country comparison.
Coverage: 15 selected market files. The European Union appears as one common rulebook covering 27 member states; Dubai covers the VARA perimeter outside the DIFC, not the whole UAE. This is not a list of every jurisdiction.
MiCA is the common licensing rule. The final transition ended on 1 July 2026, so covered providers need authorisation to keep serving EU clients.
The live question is whether the legal entity and each service appear under the correct authorisation.
A pending application or an old national registration no longer preserves a right to keep serving EU clients.
FCA anti-money-laundering registration and financial-promotion rules apply today.
The FCA expects applications to open on 30 September 2026 and the wider regime to begin on 25 October 2027.
An existing anti-money-laundering registration will not automatically become permission under the new regime.
The GENIUS Act enacted a federal payment-stablecoin framework, but implementation is still under way. Other crypto activity remains split across federal and state rules.
Watch final stablecoin rules and whether wider market-structure legislation closes the federal split.
A federal stablecoin law is not a single operating licence for exchanges, custody, lending or every state.
VARA licenses firms by activity in Dubai outside the DIFC. In-principle approval does not permit operations.
Track licence status and the exact activities each firm is allowed to perform.
An in-principle approval is not permission to operate, and a Dubai permission does not automatically cover the DIFC or the rest of the UAE.
Digital payment token services sit inside the Payment Services Act and appear in the MAS institution directory.
The key signal is the licence type, permitted activity and cross-border limits—not a marketing presence.
A payment licence covers every crypto product, cross-border service or lending activity.
Centralised trading platforms need an SFC licence. Fiat-referenced stablecoin issuers have required a separate HKMA licence since August 2025.
Check the exact SFC or HKMA permission for the service and legal entity.
A platform licence also authorises stablecoin issuance or every lending product.
Crypto-asset exchange providers must register with the FSA and local finance bureaus.
Track the exact registration: intermediary status is narrower than exchange or custody registration.
An intermediary registration permits the firm to hold customer assets or operate an exchange.
VASP registration, anti-money-laundering and customer-asset safeguards apply. Stricter entry rules took effect on 20 August 2026.
Transfer reporting and enhanced customer checks begin six months after promulgation; they were approved but were not all live on 20 August.
Every rule approved in August took effect on the same day.
FIU registration makes VDA service providers reporting entities. It is not a full operating licence or safety approval.
The missing layer is a complete rulebook for licensing, custody, market conduct, stablecoins and consumer redress.
FIU registration settles custody, stablecoin, lending, market-conduct or customer-recovery rules.
A new circulation law took effect on 1 September 2026. Trading moves into regulated intermediaries, with limits for non-qualified investors.
Firms have until 1 July 2027 to obtain licences. Cross-border crypto payments are allowed; domestic crypto payments remain prohibited.
Permitted trading or cross-border settlement makes crypto legal for domestic payments; domestic payment use remains barred.
Crypto businesses enter existing financial-law categories; DLT trading facilities have a specific FINMA licence.
The direction is integration with supervised market infrastructure rather than a single all-purpose crypto licence.
A DLT label removes banking, securities, anti-money-laundering or product-specific duties.
AUSTRAC registration and anti-money-laundering duties apply. ASIC licensing and conduct rules also apply when a digital asset or service is a financial product.
Platform-specific legislation remains proposed, so the answer still depends on the asset and service.
AUSTRAC registration is a complete operating licence, or that all crypto activity sits outside existing financial law.
Crypto platforms can face provincial securities requirements, while virtual-currency dealers also face federal FINTRAC registration and anti-money-laundering duties.
The Stablecoin Act received Royal Assent on 26 March 2026 but awaits regulations.
A provincial platform decision replaces federal money-services registration or future stablecoin requirements.
Central Bank rules for VASP authorisation and operation took effect on 2 February 2026.
Prudential requirements begin on 1 January 2027 while incumbent providers complete the transition.
Today’s operating rules mean the prudential transition is already complete.
Crypto-asset service providers require authorisation under the FAIS framework.
The register proves authorisation status; product-level prudential and market rules still need separate checks.
FAIS authorisation settles every product, prudential or market-infrastructure question.