USD 13 k
The Chart Room · Second edition · November 2026
Before the institution, the regulator
Which regulator, which license category, how much capital, and what it costs to hold. Thirty-four regulators, read from their own rulebooks where they are published, and mapped to the forty-seven systems the House designs.
Browse the index, A to Z
34Regulatorson five continents
563License categorieseach with its rule
47Systemsthat the House designs
460Fees & leviesrecorded by moment
The atlas
Thirty-four regulators, at their seats
Choose a region to sail in. Each mark is a regulator; its shape gives the standing that banks and counterparties read into the license. Select any name to open its sheet.
Drag sideways to explore the chart.
Tier 1, the deepest water Tier 2 Offshore Illustrative corridors between centers
The twelve highest on the balanced ranking
Americas · 7 regulators, by rank
Europe · 8 regulators, by rank
Middle East · 9 regulators, by rank
Africa · 5 regulators, by rank
Asia-Pacific · 5 regulators, by rank
The pyramid
Four depths of standing
The thirty-four regulators by the weight their license carries with counterparties. Tiers 1 and 2 are onshore. The offshore centers are divided by IOSCO status and FATF standing, as read in November 2026.
TIER 114
TIER 213
TIER 35
Tier 3 · Offshore, recognized
TIER 42
Tier 4 · Offshore, under review
Tier 1
Generally accepted by banks, liquidity providers and institutional clients.
Tier 2
Respected onshore regulators with a narrower reach, a younger regime or a smaller market.
Tier 3
Offshore centers that are full IOSCO signatories and outside FATF increased monitoring.
Tier 4
Offshore centers on IOSCO Appendix B or under FATF increased monitoring.
TIER 114
TIER 213
TIER 35
TIER 42
Tier 1 · The deepest water14
Generally accepted by banks, liquidity providers and institutional clients.
Tier 2 · Recognized onshore13
Respected onshore regulators with a narrower reach, a younger regime or a smaller market.
Tier 3 · Offshore, recognized5
Offshore centers that are full IOSCO signatories and outside FATF increased monitoring.
Tier 4 · Offshore, under review2
Offshore centers on IOSCO Appendix B or under FATF increased monitoring.
Within each tier, regulators appear in order of the balanced ranking · select one for its sheet
How it works
From the system to the license, in four steps
1
Choose the system
Start from the institution you mean to build: a broker, a fund, a bank, an exchange.
2
See who licenses it
Every regulator with a fitting category, ranked and compared.
3
Read the category
What it permits, the capital it asks, the clients it may serve.
4
Count the cost
Application, grant, deposits and every year after, separated.
The ranking
Ten regulators, on five measures
Credibility, breadth, entry threshold, speed and reach, weighted and added. Each bar shows where the score comes from. Change the weights on the rankings page to see the order move.
CredibilityBreadthEntry thresholdSpeedReach
The cost of a license
Six kinds of money, from filing to every year
A license is paid for when the application is filed, again when it is granted, and every year after. Capital and deposits are different again: they stay on the balance sheet, but cannot be spent freely.
Filing
Grant
Opening
Every year
At filing
Application
Processing or vetting fee paid when the file goes in. Usually not refunded.
At grant
On grant
License issue or registration fee, and any first contribution to a compensation fund.
Held throughout
Minimum capital
Own funds the firm must keep. It stays on the balance sheet but cannot be spent below the floor.
Held throughout
Deposits & guarantees
Security deposits, bonds or bank guarantees lodged beyond the capital.
Every year
Annual fees & levies
License renewal, supervision fees and levies, often scaled to income.
As it arises
Other charges
Approved persons, change of control, new funds or new activities.
The register in figures
Where the thresholds sit, and how each was read
Minimum capital
403 categories with a fixed figure
Middle half, USD 100 k to USD 1.25 mOther bins
Half-decade bins on a logarithmic scale. Beneath, the box spans the middle half and the whiskers the 10th to the 90th percentile. The median is USD 250 k.
Reading
How each figure was read
Read in the rulebook325 · 58%
From a secondary source192 · 34%
To be confirmed46 · 8%
Only figures read in the regulator’s own text are marked as read in the rulebook. Anything marked to be confirmed should be confirmed with counsel before it is relied on.
It is
A register of license categories, read from the regulators’ own rulebooks where they could be read, with its source cited beside every figure. It answers the first structural question of any mandate: for this system, which regulator, and which category of its license.
It is not
Legal advice, or a substitute for counsel admitted in the jurisdiction. Capital figures are statutory minima and fees are as published; what a working institution needs is usually higher. Rules change; every figure carries its source and a mark showing how it was read.
From the House of X‑CHASE
The Chart Room · a register of regulators and license categories; not legal advice
The systems
Choose the institution
Forty-seven systems in four domains. Each opens on the regulators that license it, the category to apply for, the capital and the cost. The figure beside each is the number of regulators, of thirty-four, with a category that fits; the rule beneath shows the same share.
Capital Markets
10 systems · Where price is discovered, and risk is carried.
Asset & Wealth
15 systems · Where capital is gathered, mandated and stewarded.
Banking & Payments
11 systems · Where money is held, moved and settled.
Alternative Systems
11 systems · Where new instruments and new rails are built.
Retail Brokerage
A broker serving retail clients in FX, CFDs and listed products. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators25 of 34
Lowest capitalUSD 13 kFSC Mauritius
Median capitalUSD 289 k
Retail clients allowed25 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (client money / MTF)
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (holds client money/assets or operates MTF)
- Capital
- USD 174 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Leveraged FX dealer
- Capital
- USD 3.85 m
- Fees at start
- USD 17 k
- Every year
- USD 17 k
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 289 k
FSC Mauritius
USD 13 k
FSA SeychellesUSD 100 k
CIMAUSD 122 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
CySECUSD 174 k
FCAUSD 200 k
DFSAUSD 200 k
CMA KenyaUSD 233 k
BMAUSD 250 k
FSA JapanUSD 335 k
MASUSD 390 k
FSRAUSD 500 k
ASICUSD 700 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
FINMAUSD 1.88 m
CBBUSD 2.66 m
SFCUSD 3.85 m
CMA UAEUSD 8.17 m
CFTC · NFAUSD 20 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Forex brokerage
Seven ways to run a forex broker
Each model asks for a different permission. Choose a model to see, at every regulator, the category to apply for and what it requires. A model is counted wherever any category permits it, so a count can exceed the regulators mapped to the system above.
B-book · dealing desk
Market maker
The broker takes the other side of each client trade and carries the market risk on its own book.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Proprietary trading for others (Eigenhandel) / dealing on own account; EUR 750,000 initial capital (Section 17(1) no. 1 WpIG) plus IFR own funds; BaFin's CFD general administrative act applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 leveraged foreign exchange trading (general case): HK$30 million paid-up capital and HK$15 million liquid capital, two responsible officers; CFDs on securities need Type 1 instead. Very few new Type 3 licenses are granted.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I Financial Instruments Business registration covers OTC derivatives including retail FX and CFDs; stock company with board, JPY 50 million stated capital and net assets, capital adequacy ratio of at least 120%, FFAJ membership effectively required.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Part 4A permission for dealing in investments as principal; GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4) plus fixed overheads and K-factor tests; this is the standard license for market-making FX/CFD brokers; COBS 22.5 applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | AFSL authorizations to deal in and make a market in derivatives and FX contracts for retail clients (issuer of retail OTC derivatives); NTA of the greater of AUD 1 million or 10% of average revenue, half in cash (Instrument 2022/705, RG 166).Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | CMS license for dealing in capital markets products: spot FX for leveraged FX trading and, for CFDs on other underlyings, OTC derivatives; base capital S$5 million each where any retail customer is served, plus risk-based capital (Notice SFA 04-N13).Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (not as Matched Principal) in Category 2, USD 2 million base capital plus risk capital; FSRA lists market-maker CFD/FX brokers here.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | In practice Swiss retail FX/CFD market makers hold a bank license (CHF 10 million minimum capital), because FINMA has treated client margin balances held by non-banks as public deposits since about 2009; a securities firm license (CHF 1.5 million, own-account dealing and market making) may suffice only if client balances qualify as settlement accounts. Unconfirmed: confirm with FINMA.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing on own account in the EUR 750,000 band (Law on Markets in Financial Instruments Art. 14); market-maker and CFD principal models require this band; ESMA-derived retail CFD caps apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (Category 2), USD 2 million base capital plus risk capital; a Retail Endorsement is needed to deal with retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing on own account under an Investment Services Licence in the IFD Art. 9(1) band; EUR 750,000 initial capital plus recovery and resolution rules; CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Acting as counterparty to retail off-exchange forex requires RFED registration (or FCM status with retail forex) and NFA Forex Dealer Member status, with adjusted net capital of at least USD 20 million plus 5% of retail forex obligations above USD 10 million.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Issuing CFDs/rolling spot FX as principal requires ODP authorization under the Financial Markets Act 2012 (no fixed rand capital; about 6 months of liquid net assets per practitioner summaries, with bank-like capital rules for non-bank ODPs signalled in 2025), and retail distribution also needs a FAIS Category I license with subcategories 1.13/1.15 (own or a partner FSP).Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Dealing as principal for resale to clients falls under the Investment Dealer (Full Service Dealer, excluding Underwriting) license, MUR 1,000,000 stated unimpaired capital, PI cover, compliance officer and MLRO, and GBC substance if held through a GBC.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm (dealing in financial instruments as principal), BD 1 million minimum capital or the higher risk-based requirement; this is the CBB route for market-making brokers.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Dealing in FX and other CFDs as principal requires CFD registration under the Securities Industry (Contracts for Differences) Rules, 2020, either as a CFD-only firm or alongside dealing registration; capital is a Commission formula (r.13), with a USD 1,000,000 bank-deposit floor proposed in the 2026 draft amendment (not final as of October 2026), and a resident CFD Supervisory Officer.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; market-maker CFD brokers (e.g. Plus500, XTB, Deriv) hold this license, but the rulebook text read did not state expressly whether dealing as principal is permitted, so confirm with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Investment Business Act standard license as a principal investment provider, minimum net assets USD 250,000 (or 8% of risk-weighted assets) plus liquid assets of three months' expenditure.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal, prudentially regulated under BANK (base capital not confirmed); retail FX/CFD brokerage is not an established QFC model, so this is realistic only for business and professional clients.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | SIBA license for dealing in securities and market making; base financial resource requirement CI$100,000 (higher of that and a quarter of annual expenditure plus risk requirements), professional indemnity cover of CI$1 million per claim, monthly financial statements; retail FX/CFD brokers use this license.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | A Dealing Online Foreign Exchange Broker trades as principal and market maker (Reg. 2, Online FX Trading Regulations 2017); KES 50 million paid-up capital, liquid capital of the higher of KES 30 million or 8% of liabilities, Kenyan-incorporated company.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The Securities Dealer license covers dealing in securities including CFDs and FX as principal (B-book); USD 100,000 paid-up capital since the Securities (Amendment) Act 2024, physical office, two natural-person directors, licensed representative and compliance officer.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | SIBA Category 1(b), dealing as principal including taking the other side of client trades; no fixed minimum capital, as the FSC sets financial resources case by case under Regulatory Code s. 181 (advisers budget about USD 1 million) and expects more for principal dealing.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: a retail FX counterparty must be an RFED or an FCM. SEC broker-dealer dealer status covers securities only, and CFDs on US securities (security-based swaps) cannot be offered off-exchange to non-ECP retail clients.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No SEC category for retail FX/CFD market making is currently in force; SEC proposed rules of 1 September 2026 would create a B-book/market-making forex broker registration at NGN 3 billion paid-up capital, and FX itself is under CBN control.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM). No NYDFS category covers acting as counterparty to FX or CFD trades.
- Labuan FSA Not permitted: Labuan money brokers may not act as principal (Money Broking Guidelines, 9 September 2024), and retail FX/CFD brokerage is not available in Labuan. A Labuan investment bank (RM10 million) may deal FX as principal but only with institutional clients, not as a retail B-book.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A principal desk dealing only in virtual assets would need Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book · no dealing desk
STP / agency
Orders pass straight through to liquidity providers; the broker acts as agent or matched principal and keeps no market risk.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 covers both dealing-desk and STP brokers (the SFC's review found most Type 3 firms hedge back-to-back with liquidity providers); same HK$30 million paid-up capital; disclose any affiliate liquidity provider in the execution policy.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Brokerage or intermediation of OTC FX derivatives is also Type I business, so an STP broker needs the same registration and JPY 50 million capital.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 200 k | Agency execution / arranging with permission to hold client money (CASS) is the GBP 150,000 tier; a matched-principal STP model is dealing as principal and generally needs the GBP 750,000 permission (we did not confirm whether MIFIDPRU 4.4 gives matched-principal firms a lower PMR).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | An Australian STP broker is still the issuer of the OTC derivative to its retail client, so it needs the same issuer and market-making authorizations and AUD 1 million NTA as a market maker.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | The CMS dealing license covers dealing as principal or agent, so an STP broker needs the same license and S$5 million base capital for retail clients; no lighter agency-only FX category exists.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency brokerCategory 3A | USD 500 k | Dealing in Investments as Agent or as Matched Principal (Category 3A), USD 500,000 base capital, rising to USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | An agency broker that keeps client accounts needs a bank or securities firm license (securities firm keeping client accounts, CHF 1.5 million); which one applies to OTC FX/CFD balances was not confirmed. A firm that only forwards orders to a licensed bank without holding money needs no FINMA license (see introducing broker).Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 174 k | Agency execution holding client money is in the EUR 150,000 band; a matched-principal STP model is dealing on own account and needs the EUR 750,000 band.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A Principal dealer / credit providerCategory 2 | USD 200 k | Pure agency (Dealing in Investments as Agent) is Category 3A at USD 200,000 base capital after the CP161 reforms (secondary); since the 2025 PIB amendments, matched-principal A-book dealing sits in Category 2 (USD 2 million; a lower matched-principal figure is reported but unconfirmed).Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 87 k | Agency execution / RTO holding client money is the IFD Art. 9(3) band (EUR 150,000); a matched-principal STP model counts as dealing on own account and needs the Art. 9(1) band (EUR 750,000).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Only an RFED or FCM may accept retail forex orders and funds, so an STP broker that hedges back-to-back with liquidity providers still registers as an RFED/FCM and holds the USD 20 million minimum; there is no lighter agency-only category for retail forex.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | A pure agent passing orders to a third-party issuer needs FAIS Category I (1.13 derivatives, 1.15 forex investment business); a matched-principal STP that is itself the client's counterparty on the CFD still needs ODP authorization, since FAIS does not permit issuing OTC derivatives.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) BrokerInvestment Dealer (Broker) | USD 13 k | Agency-only order routing to a third-party LP fits the Discount Broker (execution-only, MUR 600,000) or Broker (with advice/portfolio management, MUR 700,000) categories; a matched-principal STP that is counterparty to the client should take the Full Service Dealer license instead.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | Category 2 investment firm (all services except dealing as principal, including agency dealing and holding client money), BD 250,000 minimum capital. Whether CBB treats riskless matched-principal as principal dealing (Category 1) was not confirmed.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | The CFD Rules cover dealing in, providing or marketing CFDs in or from The Bahamas regardless of hedging model, so an STP broker also registers as a CFD dealer; same capital and resident-officer conditions as a market maker.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Labuan money broking license (arranging FX and money market deals only), RM1 million paid-up capital; clients limited to institutional investors and high-net-worth individuals, non-residents of Malaysia only, operational office in Labuan.Retail leverage No retail FX/CFD offering permitted. For eligible institutional and high-net-worth clients of money brokers, maximum leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards (Money Broking Guidelines, 9 September 2024). |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; covers brokerage of OTC derivatives and spot FX for onshore clients, including retail.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | Standard license acting as agent, minimum net assets USD 100,000 plus three months' liquid assets; a matched-principal model may fall in the principal bucket, so confirm with the BMA.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Agency dealing is listed within this category's permits; whether a pure agency broker is placed under BANK or INMA was not confirmed, and retail FX/CFD is not an established QFC model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Dealing as agent is also covered by the broker-dealer SIBA license, with the same CI$100,000 base financial resources.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | A Non-Dealing Online Foreign Exchange Broker links clients to the FX market for commission or mark-up and does not make markets (Reg. 2); KES 30 million paid-up capital, same liquid-capital test.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The same Securities Dealer license covers dealing as agent; there is no lower agency-only category, so the USD 100,000 capital applies.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Category 1(a) for agency execution; a matched-principal STP model is principal dealing and falls under 1(b). Category 2 (arranging) is commonly added.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 7 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: retail forex orders can be accepted only by an FCM or RFED, whatever the execution model.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria Not yet licensable; the proposed rules (1 September 2026) would create an STP/ECN/A-book broker registration at NGN 2 billion paid-up capital, and the existing Broker category covers securities only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Agency or matched-principal brokerage of virtual assets is Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book and B-book
Hybrid
Part of the flow is internalized and part passed on; the license must allow dealing as principal.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 general case, as for a market maker; the client agreement must state whether the firm takes the opposite side of client trades.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I registration as for a market maker; mandatory loss-cut rules and trust segregation of client margin apply.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Internalizing any client flow requires the dealing-as-principal permission and the GBP 750,000 PMR; CASS client-money permission is also needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | Same retail OTC derivatives issuer AFSL as a market maker; AUD 1 million NTA.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Same CMS dealing license as a market maker, with S$5 million base capital for retail; conflict management and execution policy apply.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Keeping any B-book risk is dealing as principal, so Category 2 (USD 2 million plus risk capital).Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | Same as the market maker: internalizing flow is own-account dealing; established Swiss practice is a bank license.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Internalizing any client flow is dealing on own account, so the EUR 750,000 band is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Internalizing any flow is dealing as principal, so Category 2 (USD 2 million plus risk capital), with a Retail Endorsement for retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Internalizing any client flow is dealing on own account, so the Art. 9(1) band (EUR 750,000) is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Internalizing any retail flow is acting as counterparty, so RFED or FCM registration with USD 20 million minimum adjusted net capital is required.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Internalising any flow means acting as principal on OTC derivatives, so ODP authorization is needed, plus FAIS Category I for retail distribution.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Any internalization is principal dealing, so the Full Service Dealer (excluding Underwriting) license is needed (MUR 1,000,000).Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Internalizing any flow is dealing as principal, so Category 1 (BD 1 million or risk-based capital).Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Same CFD dealer registration as a market maker; disclose the internalization policy and conflicts in the order execution policy.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | Same First Category OTC license (AED 30 million) as the market-maker model; principal-dealing scope to be confirmed with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Any internalized flow means dealing as principal: principal standard license, USD 250,000 minimum net assets.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Principal dealing under BANK, with the same retail limitation as the market-maker model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Broker-dealer / market maker SIBA license covers both principal and agency flow.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | Any internalization is market making, so the Dealing Online Foreign Exchange Broker license (KES 50 million) is needed.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Covered by the Securities Dealer license, which permits both agency and principal dealing (USD 100,000).Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent | — | Principal dealing (1(b)) for internalized flow plus agency dealing (1(a)) for passed-through flow.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC (RFED or FCM counterparty status).
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No category in force; under the proposed rules a hybrid would need the market-making (B-book) broker registration at NGN 3 billion.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- Labuan FSA Not permitted: internalizing flow requires principal dealing, which money brokers are prohibited from doing.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Multilateral matching
ECN / MTF venue
A venue where many participants’ orders meet; licensed as an exchange, MTF or OTF, not as a broker.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| SFC#3 Hong Kong | Automated trading venueType 7 – Providing automated trading services | USD 642 k | Uncertain: Type 7 automated trading services (HK$5 million paid-up capital) covers electronic venues for securities and futures contracts; whether a multilateral leveraged-FX venue falls under Type 7 or Type 3 was not confirmed. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | Operating an MTF without own-account dealing is in the GBP 150,000 tier (an OTF with own-account dealing needs GBP 750,000); a recognized investment exchange is a heavier, separate route, and most new venues start as MTFs. |
| ASIC#6 Australia | Licensed market operatorAustralian market license (Corporations Act Part 7.2) | — | A multilateral venue is a financial market requiring an Australian market license (Part 7.2), unless exempt; no fixed capital, adequate resources required (s 792A). |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| MAS#8 Singapore | Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | A multilateral trading venue is an organized market operated as a Recognised Market Operator (higher of S$250,000 or 25% of annual operating expenses for a Singapore RMO). Uncertain: whether a spot FX matching venue counts as an organized market was not confirmed. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Operating an MTF or OTF is a Category 4 activity (USD 50,000 base capital), but MTF/OTF operators remain subject to the Expenditure-Based Capital Minimum and FSRA market-operator requirements; a virtual-asset MTF is a separate category. |
| FINMA#10 Switzerland | Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | A stock exchange or MTF license (CHF 1 million minimum, FinMIO Art. 13) covers multilateral trading of securities; spot FX is not a security under FinMIA, so an FX-only matching venue may fall outside it. Uncertain. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band | USD 174 k | Operating an MTF falls in the EUR 150,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A | USD 200 k | Operating an Alternative Trading System (DIFC term for MTF/OTF) moved from Category 4 to Category 3A under the 2025 PIB amendments; ATS operators must also meet the AMI/ATS market-integrity rules (effective date of the move reported as July 2025 or July 2026 by different advisers). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Operating a trading facility is listed only under the Art. 9(1) license scope, but since the September 2025 amendment (Part BI R1-5.1.2) an MTF operator that does not deal on own account has EUR 150,000 initial capital; confirm the license scope with the MFSA. |
| CFTC · NFA#15 United States | DCM (futures exchange)Designated contract market (CEA s.5; Part 38) SEFSwap execution facility (CEA s.5h; Part 37) | — | Off-exchange retail forex cannot be run as a multilateral venue for non-ECP retail clients: an FX futures venue is a DCM (retail access via FCMs) and an FX swap/NDF venue is a SEF (ECPs only); institutional spot FX ECNs fall largely outside CFTC registration. Both need financial resources covering one year of operating costs. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| FSCA#17 South Africa | Licensed exchangeExchange license, Financial Markets Act 2012 | — | A multilateral venue for securities including derivative instruments must be a licensed exchange under the FMA 2012 (liquid net assets of at least 6 months' operating expenses, reg. 8 of GN R98); no MTF-style lighter category exists, and whether an OTC FX matching venue falls inside the exchange definition should be confirmed with counsel. |
| SCB Bahamas#21 The Bahamas | MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | A multilateral venue for capital markets instruments is registered as a marketplace under the Securities Industry Act, 2024, with SCB-approved rulebook and systems and capital set case by case; no FX-specific venue category exists. |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite)Non-Composite Securities Exchange | USD 3.33 m | Only an exchange-traded venue (e.g. FX derivatives on a securities exchange such as FMDQ) is licensable today, as a Non-Composite Securities Exchange at NGN 5 billion; an OTC FX/CFD matching venue has no category and would also need CBN involvement. Uncertain. |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB) | — | Uncertain: a multilateral venue would need Labuan exchange approval (LFSSA s.134) with capital set case by case; no FX-specific venue guideline was found. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The 2017 FX regulations have no venue category; the OTC Platform provider category under LN 197 of 2025 is the closest fit for a multilateral OTC venue, but its capital and whether it extends to online FX/CFDs are unconfirmed. |
| FSA Seychelles#32 Seychelles | Securities exchangeSecurities Exchange license (Securities Act 2007) | — | A multilateral venue would need a Securities Exchange license (sole activity, at least three independent dealer members, clearing, surveillance and compensation arrangements); whether the FSA would treat an OTC FX/CFD matching venue this way is uncertain. |
| BVI FSC#34 British Virgin Islands | Investment exchangeSIBA Category 7: Operating an investment exchange | — | Category 7 covers providing a facility for orderly trading of investments; whether an FX/CFD matching venue fits was not confirmed, so check with the FSC. |
Not available at 13 regulators
- FSA Japan Uncertain: the PTS authorization covers securities venues only; no Chart Room category for a multilateral retail FX venue was identified. Electronic trading platforms for certain OTC derivatives exist under the FIEA but were not confirmed for FX.
- SEC No SEC category for an FX venue; spot FX is not a security. The SEC ATS and exchange categories cover securities only; FX futures venues are CFTC DCMs and FX swap/NDF venues are CFTC SEFs.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- FSC Mauritius No venue category is in this register: operating a multilateral market requires a Securities Exchange license from the FSC under the Securities Act 2005, which is not recorded here.
- CBB No investment-firm category covers running a multilateral venue; licensed exchanges are authorized under CBB Volume 6 (market operators), which is not in this register.
- NYDFS Not licensed by NYDFS; FX futures venues are CFTC DCMs and FX swap venues are CFTC SEFs.
- CMA UAE No CMA category for operating an OTC FX/CFD multilateral venue was identified in the data; exchange and platform licensing outside the virtual-asset Seventh Category is not covered, so confirm with the CMA.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A virtual-asset matching venue, including exchange-traded VA derivatives under the March 2026 Part V rules, is Exchange Services; fiat-currency matching is excluded.
- BMA No category for operating a multilateral FX trading venue is in the register; exchange recognition is outside these license types. Uncertain.
- QFCRA No category for operating a multilateral trading venue was identified in the QFCRA data; onshore exchange-traded markets fall under the QFMA.
- CIMA No category in this register for a multilateral FX/CFD venue; the Cayman Islands Stock Exchange is a separate listing exchange. Not confirmed whether operating a matching platform would need a SIBA license.
- CMA Saudi Not available: the Saudi Exchange (Tadawul) is the only licensed exchange and there is no OTC FX venue license.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Referral and arranging
Introducing broker
Brings clients to a licensed broker without executing trades or holding client money.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| CSSF#2 Luxembourg | Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | Type 3 approved introducing agent: HK$5 million paid-up and HK$3 million liquid capital; may not carry client positions or hold client assets. |
| FCA#5 United Kingdom | Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | USD 100 k | Own Part 4A permission for arranging deals / making arrangements without client money (GBP 75,000 PMR), or act as an appointed representative (including an introducer AR) of an authorized broker that accepts responsibility. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Typically a corporate authorized representative of the issuing licensee (no own capital requirement), or the firm's own AFSL with dealing (arranging) authorization; ASIC has scrutinized CAR use in OTC derivatives. |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | Uncertain: the SFA definition of dealing includes inducing a person to enter into a transaction, so an introducer soliciting Singapore clients generally needs its own CMS dealing license or must act through the licensee's notified representatives; MAS has no dedicated IB license. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Arranging Deals in Investments (Category 4), USD 50,000 base capital from 19 August 2025; no EBCM if no Client Assets are held. FSRA proposed barring authorized firms from accepting paid retail referrals from unregulated third parties, so IBs introducing retail clients should be FSRA-authorised. |
| Bank of Lithuania#11 Lithuania | Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band | USD 87 k | RTO / arranging without client money in the EUR 75,000 band. The financial advisor company license does not fit because it covers only transferable securities and fund units, not CFDs or FX derivatives. Tied-agent status under MiFID II Art. 29 is also possible but is not a category in this register. |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arrangerCategory 4 | USD 30 k | Arranging Deals in Investments (Category 4), USD 30,000 base capital after the 2026 amendments (secondary); no execution or client money. A Representative Office is not an option: since April 2015 the DFSA will not accept Representative Office applications from firms marketing FX or other highly leveraged products to retail clients. |
| MFSA#14 Malta | Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | RTO / advice without holding client money in the IFD Art. 9(2) band (EUR 75,000); orders must go to an authorized broker; the professional-only variant (legacy 1B) has the same capital. Tied-agent status is also possible under MiFID II Art. 29 but is not a category in this register. |
| CFTC · NFA#15 United States | Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | USD 45 k | Soliciting retail forex for an RFED/FCM without holding customer funds requires IB registration and NFA membership: independent IB with at least USD 45,000 adjusted net capital, or guaranteed IB with no capital requirement but introducing only to its guarantor. |
| CySEC#16 Cyprus | Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Introducing or arranging for clients is a FAIS intermediary service, so a Category I license (1.13/1.15) or appointment as a representative of a licensed FSP is needed; referral to offshore brokers while collecting local rand deposits has drawn SARB exchange-control action. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | Category 3 (arranging and advising, BD 25,000 plus liquid funds of 25% of prior-year operating expenses) only fits an IB paid by its clients, because Category 3 firms must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent; a rebate-funded IB therefore needs Category 2 (BD 250,000). |
| SCB Bahamas#21 The Bahamas | Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | Introducing clients to a dealer without dealing is arranging deals (USD 25,000 floor under the older formula); the CFD Rules also capture marketing CFDs in or from The Bahamas, so check with the SCB whether an introducer also needs CFD registration. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Uncertain: arranging FX transactions from Labuan falls within money broking (RM1 million); no lighter introducer category exists. An introducer based outside Labuan is governed by its own jurisdiction. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | Fifth Category introducing and promotion, AED 500,000 paid-up capital; may introduce UAE clients to an offshore or free-zone broker but may not hold client assets or execute. Most CFD brokers entering the UAE (XM, Exinity, Pepperstone and others) use this route. |
| BMA#27 Bermuda | Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | Arranging deals without dealing as agent or principal: standard license (neither agent nor principal), minimum net assets USD 12,000 plus one month's liquid assets. |
| QFCRA#28 Qatar · QFC | Investment adviser / arrangerAdvisory and arranging firm (INMA 2014) | USD 250 k | Arranging deals in investments (INMA advisory and arranging firm), base capital about USD 250,000 restated in QAR plus 13/52 of annual operating expenses; no client money. A December 2025 consultation may lower requirements for wholesale advisers. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | SIBA license for arranging deals in securities; CI$15,000 base financial resources plus professional indemnity insurance. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The FX regulations have no introducing-broker category; the Intermediary Service Platform provider category (LN 197 of 2025), granted to Safaricom and Airtel Money in December 2025 for onboarding and market access, is the closest fit, but its use for FX referral is unconfirmed, and offshore brokers may not serve Kenyan clients. |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | SIBA Category 2, arranging deals in investments, including introducing clients to dealers. |
Not available at 11 regulators
- FSA Japan Not a Chart Room category: an introducer registers as a Financial Instruments Intermediary Service Provider (FIEA Art. 66) tied to a Type I firm, or registers as Type I itself. Unregistered solicitation of Japanese residents is prohibited.
- FINMA No FINMA license for pure referral without handling client money or orders. A firm that transmits orders provides a FinSA financial service, so its client advisers must be in the FinSA adviser register unless the firm is supervised; AML SRO membership may apply if it acts as a financial intermediary. Uncertain.
- SEC Licensed by the CFTC/NFA, not the SEC: introducing retail forex accounts requires CFTC introducing broker registration and NFA membership; an SEC introducing broker-dealer status does not cover FX.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime. SAMA's 2017 circular prohibits marketing by foreign forex firms without a contract with a licensed Saudi institution.
- FSC Mauritius No dedicated introducing-broker category was found; whether pure referral is licensable is uncertain, and if the firm advises it needs Investment Adviser (Restricted), or if it receives and transmits orders, Investment Dealer (Broker).
- SEC Nigeria No category in force; the proposed rules would create Corporate Introducing Broker (NGN 150 million) and Individual Introducing Broker (NGN 30 million) registrations and would ban referral incentives. The existing Sub-Broker (Digital) category routes securities orders only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (CFTC introducing broker with NFA membership).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Arranging orders in virtual assets falls under Broker-Dealer Services.
- CMA Saudi No fit: Arranging covers securities only, and a 2017 SAMA circular prohibits foreign forex companies without contracts with licensed Saudi institutions from marketing in the Kingdom.
- FSA Seychelles No introducing-broker category exists in the register, and a secondary source reports no FSA restrictions on IBs; if the firm gives advice it needs an Investment Adviser license (USD 25,000). Treatment of a Seychelles-based referral business is uncertain.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022. Introducing to brokers is the CMA Fifth Category.
A brand on a host license
White label
Operates its own brand on another firm’s license and platform, often as its appointed representative.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | No tied-agent or appointed-representative regime: a Hong Kong-facing brand must be licensed itself, usually as a Type 3 introducing agent referring clients to the executing Type 3 firm. |
| FCA#5 United Kingdom | Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | — | Appointed representative of the principal broker under SUP 12; no separate license or capital, but the principal must notify the FCA 30 days ahead and oversee the AR, and the AR cannot deal as principal or hold client money. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Corporate authorized representative of the AFS licensee; no separate license, but the CAR cannot issue products in its own right and the licensee remains responsible. |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CFTC · NFA#15 United States | Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | No white-label license exists; a US-facing brand on another firm's platform must register itself, usually as a guaranteed IB of the RFED/FCM (closest equivalent to an appointed representative), since anyone soliciting retail forex must be registered. |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Most South African CFD brands hold their own FAIS Category I license and distribute a third-party ODP's products; alternatively the brand can operate as a juristic representative of a licensed FSP under the FAIS Act without its own license, with the FSP remaining responsible. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) | USD 13 k | No tied-agent or appointed-representative regime for corporate white labels was identified, so a white label serving clients from Mauritius generally needs its own Investment Dealer license, commonly the Discount Broker category on a partner's platform and liquidity. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | No tied-agent or appointed-representative regime was identified; a white-label brand marketing onshore needs at least a Fifth Category promotion license, and a First Category OTC license if it contracts with or executes for clients. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | Cayman has no appointed-representative or tied-agent regime, so a white label carrying on securities investment business from the Cayman Islands needs its own SIBA license, at least the arranging license if the partner broker is the counterparty. Not confirmed. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | No tied-agent or appointed-representative regime exists; a white label serving Kenyan clients needs its own CMA online FX license, typically non-dealing, held by a Kenyan-incorporated company, with a service level agreement with the platform provider (Reg. 4(2)(j)). |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | No tied-agent or appointed-representative regime was identified, so a white label dealing with clients from Seychelles needs its own Securities Dealer license (USD 100,000, local office and staff). |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | The BVI has no tied-agent or appointed-representative regime, so a BVI white label needs its own SIBA license: Category 2 if the partner broker deals with the clients, Category 1 if it deals itself. Not confirmed. |
Not available at 19 regulators
- FSA Japan No dedicated pathway: the brand must register itself (Type I) or act as a Financial Instruments Intermediary Service Provider tied to the registered firm; that intermediary status is not a Chart Room category.
- MAS No dedicated pathway: a brand must hold its own CMS license or act through the licensee's notified representatives; MAS has no appointed-representative regime for firms.
- FSRA No appointed-representative or tied-agent regime was identified for ADGM, so a white-label brand needs its own FSRA permission: Category 4 if it only arranges for the licensed broker, Category 2 or 3A if it deals or contracts with clients (confirm with the FSRA).
- FINMA Switzerland has no tied-agent or appointed-representative regime. A pure marketing brand of a licensed Swiss bank needs no license, but a white label that contracts with clients or holds their money needs its own bank or securities firm license.
- Bank of Lithuania No category in this register: a white label can run as a MiFID tied agent of the licensing broker (no separate license), otherwise it needs its own financial brokerage firm license.
- DFSA No appointed-representative or tied-agent route was identified in the DFSA regime, so a DIFC white-label brand needs its own license: Category 4 if it only markets and arranges for the principal broker, Category 2 or 3A if it contracts with clients or executes (confirm with the DFSA).
- SEC Licensed by the CFTC/NFA, not the SEC: the nearest US structure is a guaranteed IB of an RFED or FCM.
- MFSA No category in this register: a white label can run as a MiFID tied agent registered by its principal (no separate license), otherwise it needs its own Investment Services Licence.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- CBB Not confirmed: Category 3 firms are barred from acting as tied agents, implying a tied-agent concept, but the tied-agent regime was not researched; otherwise the brand needs its own Category 2 or Category 1 license depending on whether it deals as principal.
- SCB Bahamas No appointed-representative or tied-agent regime was found; a brand that deals in or markets CFDs in or from The Bahamas registers itself (CFD dealer, or arranging deals for a pure referral model). Uncertain: confirm with the SCB.
- SEC Nigeria No FX/CFD white-label route exists today; the proposed rules require brokers and technology providers to allocate compliance responsibility, and a separate Technology/Platform Provider registration at NGN 5 billion; no tied-agent regime for FX is proposed.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA; the nearest structure is a CFTC guaranteed IB.
- Labuan FSA No appointed-representative or white-label regime: the brand must hold its own money broking license, with substance in Labuan.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- BMA No appointed-representative or tied-agent route was identified; a Bermuda white-label operator needs its own standard license in the bucket matching its role. Class A registration is only for Bermuda-formed firms regulated by a recognized foreign regulator with no place of business in Bermuda.
- QFCRA No appointed-representative or tied-agent regime was identified; a white-label brand would need its own QFC authorization (arranging or dealing). Uncertain.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Prime-of-Prime
Liquidity provider / PoP
Deals as principal with brokers and institutions, redistributing prime liquidity; not retail.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions is Eigenhandel or own-account dealing in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Uncertain: principal dealing in leveraged FX with clients needs Type 3, but some dealings with banks and other professionals may fall under SFO exclusions or the LFET exemption rules; HKMA-authorized banks are exempt. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Uncertain: principal OTC derivatives dealing is Type I business, but certain transactions with financial institutions or qualified institutional investors may be excluded under the FIEA Enforcement Order; confirm before relying on an exclusion. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Dealing in investments as principal with brokers and institutions; GBP 750,000 PMR; this is the tier used for principal-model prime-of-prime and non-bank prime services. |
| ASIC#6 Australia | Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | AFSL limited to wholesale clients (s 761G) for dealing and market making in derivatives and FX; no fixed capital minimum beyond RG 166 base-level requirements; the usual route for prime-of-prime and liquidity providers. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Dealing as principal with brokers and institutions is a CMS dealing activity; base capital S$1 million for leveraged FX or OTC derivatives when serving only accredited, institutional or expert investors. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties (Category 2), USD 2 million base capital plus risk capital. |
| FINMA#10 Switzerland | Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | A securities firm license (own-account dealer or market maker, CHF 1.5 million) covers professional own-account dealing with institutions; banks also act as LPs under their bank license. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing as principal with brokers and institutions requires the EUR 750,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties only (no Retail Endorsement needed), USD 2 million base capital plus market and credit risk capital. |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing as principal with brokers and institutions needs the Art. 9(1) band (EUR 750,000); large firms may fall under CRR as Class 1 or Class 1 Minus. |
| CFTC · NFA#15 United States | Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | Dealing as principal in spot and deliverable FX forwards with eligible contract participants generally needs no CFTC registration; swap dealer registration (USD 20 million minimum capital) applies only if FX swaps such as NDFs or CFDs with ECPs exceed the de minimis threshold. Providing liquidity to an RFED or FCM does not by itself require RFED status. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | Dealing as principal in OTC derivatives with brokers and institutions is ODP activity under the FMA (trade-repository reporting and Joint Standard 2 of 2020 margin rules apply); no separate institutional-only category exists, and bank LPs rely on their Prudential Authority banking license. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Principal dealing with brokers and institutions fits the Full Service Dealer (excluding Underwriting) license (MUR 1,000,000); the Investment Dealer (Derivatives) category covers agency and exchange market making only and was not confirmed for an OTC principal book. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm dealing as principal with institutional counterparties, BD 1 million or risk-based capital; wholesale banks are the alternative. |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | USD 300 k | Dealing as principal in derivatives with brokers and institutions is dealing in capital markets instruments as principal (USD 300,000 floor under the older formula); add CFD registration where the instruments supplied are CFDs. |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | Uncertain: principal dealing in FX and derivatives with institutions fits a Labuan investment bank license (RM10 million paid-up capital, no deposit-taking); money brokers cannot act as principal. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Principal standard license (USD 250,000 minimum net assets); Class B registration excludes market intermediaries, so a liquidity provider cannot rely on it. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal with institutional and professional counterparties under BANK; base capital not confirmed. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4) | USD 122 k | Principal dealing with brokers and institutions needs the broker-dealer license; a firm dealing only with sophisticated or high-net-worth persons (entities with USD 5 million or more in assets) may register as a SIBA registered person instead, with no stated capital. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Principal dealing with brokers and institutions falls under the Securities Dealer license (USD 100,000); there is no separate institutional category. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Dealing in investments as principal with brokers and institutions, Category 1(b); the FSC sets capital case by case. |
Not available at 9 regulators
- SEC Not an SEC matter for FX: spot and deliverable forward FX dealing between eligible contract participants is largely outside registration, and NDFs and other FX swaps fall under the CFTC (swap dealer above the de minimis threshold).
- SAMA Interbank FX is dealt by SAMA-licensed banks; no separate non-bank FX liquidity license exists. A money changer license covers spot cash currency exchange only.
- SEC Nigeria No SEC category for FX/CFD liquidity provision; FX dealing as principal is the domain of CBN-licensed banks and authorized dealers, and the proposed rules do not mention liquidity providers.
- NYDFS Not licensed by NYDFS; FX dealing with institutions is largely outside registration or falls under CFTC swap dealer rules. A New York state-chartered bank conducts FX dealing under its banking charter, which is not a practical brokerage route.
- CMA UAE No wholesale-only principal dealing category for OTC FX was identified; the 'financial products dealer' activity under First Category may be relevant but its scope for OTC FX was not confirmed. Onshore interbank FX liquidity comes from CBUAE-licensed banks.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A VA OTC liquidity desk would need Broker-Dealer Services.
- CMA Kenya No CMA category covers institutional-only FX/CFD principal dealing; Kenyan dealing brokers hedge with offshore LPs or banks, and interbank FX dealing is done by CBK-licensed banks. Uncertain.
- CMA Saudi Not a CMA activity; interbank FX dealing is done by SAMA-licensed banks.
- CBUAE No non-bank FX dealing license exists at the CBUAE; interbank FX liquidity is provided by licensed banks (Licensed Bank at AED 2 billion or Restricted Licence Bank at AED 1 billion), which is not a practical route for a liquidity-provider start-up.
Every fitting category
38 categories at 25 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary |
| Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary |
| Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Matched-principal / agency broker Category 3A | USD 500 k | USD 40 k | USD 50 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary | |
| CBB#20 Bahrain | Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Retail FX / CFD broker First Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | — | — | Retail | Rulebook |
| Americas | ||||||
| CFTC · NFA#15 United States | FCM offering retail forex FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | USD 26 k | USD 125 k | Retail | Rulebook |
| RFED Retail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) | USD 20 m | USD 26 k | USD 125 k | Retail | Rulebook | |
| SCB Bahamas#21 The Bahamas | CFD dealer Registered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | USD 25 k | USD 45 k | Retail | Rulebook |
| BMA#27 Bermuda | Investment dealer (principal) Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Agency broker SIBA Category 1, sub-category (a): Dealing in investments as agent | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary |
| Principal dealer / market maker SIBA Category 1, sub-category (b): Dealing in investments as principal | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Leveraged FX dealer Type 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | USD 17 k | USD 17 k | Retail | Rulebook |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Retail CFD/FX market maker AFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | USD 2 k | USD 83 k | Retail | Rulebook |
| MAS#8 Singapore | OTC derivatives / CFD dealer CMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| Leveraged FX dealer CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Advice and intermediary FSP FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | USD 154 (nominal) | — | Retail | Rulebook |
| OTC derivative provider Authorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | USD 3 k | — | Retail | Secondary | |
| FSC Mauritius#19 Mauritius | Full-service dealer Investment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | USD 1 k | USD 3 k | Retail | Rulebook |
| Execution-only broker Investment Dealer (Discount Broker) | USD 13 k | USD 300 (nominal) | USD 2 k | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Non-dealing online FX broker Non-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | USD 78 (nominal) | — | Retail | Rulebook |
| Dealing online FX broker Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | USD 78 (nominal) | — | Retail | Rulebook | |
| FSA Seychelles#32 Seychelles | Securities dealer Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | USD 3 k | USD 6 k | Retail | Rulebook |
Not licensed by: VARA, CBUAE, CMA Saudi, SAMA, QFCRA, SEC, NYDFS, Labuan FSA, SEC Nigeria.
Private Brokerage
A broker serving a closed circle of private and professional clients. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators26 of 34
Lowest capitalUSD 5 kSEC
Median capitalUSD 200 k
Retail clients allowed25 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (client money / MTF)
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (holds client money/assets or operates MTF)
- Capital
- USD 174 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities dealer
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 200 k
SEC
USD 5 k
FSC MauritiusUSD 15 k
MASUSD 39 k
CFTC · NFAUSD 45 k
BMAUSD 100 k
FSA SeychellesUSD 100 k
SCB BahamasUSD 120 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
CySECUSD 174 k
FCAUSD 200 k
DFSAUSD 200 k
Labuan FSAUSD 236 k
FSA JapanUSD 335 k
CMA KenyaUSD 388 k
SEC NigeriaUSD 400 k
FSRAUSD 500 k
SFCUSD 642 k
CBBUSD 665 k
ASICUSD 700 k
CMA UAEUSD 8.17 m
CMA SaudiUSD 13.33 m
1k10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Forex brokerage
Seven ways to run a forex broker
Each model asks for a different permission. Choose a model to see, at every regulator, the category to apply for and what it requires. A model is counted wherever any category permits it, so a count can exceed the regulators mapped to the system above.
B-book · dealing desk
Market maker
The broker takes the other side of each client trade and carries the market risk on its own book.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Proprietary trading for others (Eigenhandel) / dealing on own account; EUR 750,000 initial capital (Section 17(1) no. 1 WpIG) plus IFR own funds; BaFin's CFD general administrative act applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 leveraged foreign exchange trading (general case): HK$30 million paid-up capital and HK$15 million liquid capital, two responsible officers; CFDs on securities need Type 1 instead. Very few new Type 3 licenses are granted.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I Financial Instruments Business registration covers OTC derivatives including retail FX and CFDs; stock company with board, JPY 50 million stated capital and net assets, capital adequacy ratio of at least 120%, FFAJ membership effectively required.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Part 4A permission for dealing in investments as principal; GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4) plus fixed overheads and K-factor tests; this is the standard license for market-making FX/CFD brokers; COBS 22.5 applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | AFSL authorizations to deal in and make a market in derivatives and FX contracts for retail clients (issuer of retail OTC derivatives); NTA of the greater of AUD 1 million or 10% of average revenue, half in cash (Instrument 2022/705, RG 166).Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | CMS license for dealing in capital markets products: spot FX for leveraged FX trading and, for CFDs on other underlyings, OTC derivatives; base capital S$5 million each where any retail customer is served, plus risk-based capital (Notice SFA 04-N13).Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (not as Matched Principal) in Category 2, USD 2 million base capital plus risk capital; FSRA lists market-maker CFD/FX brokers here.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | In practice Swiss retail FX/CFD market makers hold a bank license (CHF 10 million minimum capital), because FINMA has treated client margin balances held by non-banks as public deposits since about 2009; a securities firm license (CHF 1.5 million, own-account dealing and market making) may suffice only if client balances qualify as settlement accounts. Unconfirmed: confirm with FINMA.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing on own account in the EUR 750,000 band (Law on Markets in Financial Instruments Art. 14); market-maker and CFD principal models require this band; ESMA-derived retail CFD caps apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (Category 2), USD 2 million base capital plus risk capital; a Retail Endorsement is needed to deal with retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing on own account under an Investment Services Licence in the IFD Art. 9(1) band; EUR 750,000 initial capital plus recovery and resolution rules; CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Acting as counterparty to retail off-exchange forex requires RFED registration (or FCM status with retail forex) and NFA Forex Dealer Member status, with adjusted net capital of at least USD 20 million plus 5% of retail forex obligations above USD 10 million.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Issuing CFDs/rolling spot FX as principal requires ODP authorization under the Financial Markets Act 2012 (no fixed rand capital; about 6 months of liquid net assets per practitioner summaries, with bank-like capital rules for non-bank ODPs signalled in 2025), and retail distribution also needs a FAIS Category I license with subcategories 1.13/1.15 (own or a partner FSP).Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Dealing as principal for resale to clients falls under the Investment Dealer (Full Service Dealer, excluding Underwriting) license, MUR 1,000,000 stated unimpaired capital, PI cover, compliance officer and MLRO, and GBC substance if held through a GBC.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm (dealing in financial instruments as principal), BD 1 million minimum capital or the higher risk-based requirement; this is the CBB route for market-making brokers.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Dealing in FX and other CFDs as principal requires CFD registration under the Securities Industry (Contracts for Differences) Rules, 2020, either as a CFD-only firm or alongside dealing registration; capital is a Commission formula (r.13), with a USD 1,000,000 bank-deposit floor proposed in the 2026 draft amendment (not final as of October 2026), and a resident CFD Supervisory Officer.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; market-maker CFD brokers (e.g. Plus500, XTB, Deriv) hold this license, but the rulebook text read did not state expressly whether dealing as principal is permitted, so confirm with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Investment Business Act standard license as a principal investment provider, minimum net assets USD 250,000 (or 8% of risk-weighted assets) plus liquid assets of three months' expenditure.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal, prudentially regulated under BANK (base capital not confirmed); retail FX/CFD brokerage is not an established QFC model, so this is realistic only for business and professional clients.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | SIBA license for dealing in securities and market making; base financial resource requirement CI$100,000 (higher of that and a quarter of annual expenditure plus risk requirements), professional indemnity cover of CI$1 million per claim, monthly financial statements; retail FX/CFD brokers use this license.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | A Dealing Online Foreign Exchange Broker trades as principal and market maker (Reg. 2, Online FX Trading Regulations 2017); KES 50 million paid-up capital, liquid capital of the higher of KES 30 million or 8% of liabilities, Kenyan-incorporated company.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The Securities Dealer license covers dealing in securities including CFDs and FX as principal (B-book); USD 100,000 paid-up capital since the Securities (Amendment) Act 2024, physical office, two natural-person directors, licensed representative and compliance officer.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | SIBA Category 1(b), dealing as principal including taking the other side of client trades; no fixed minimum capital, as the FSC sets financial resources case by case under Regulatory Code s. 181 (advisers budget about USD 1 million) and expects more for principal dealing.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: a retail FX counterparty must be an RFED or an FCM. SEC broker-dealer dealer status covers securities only, and CFDs on US securities (security-based swaps) cannot be offered off-exchange to non-ECP retail clients.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No SEC category for retail FX/CFD market making is currently in force; SEC proposed rules of 1 September 2026 would create a B-book/market-making forex broker registration at NGN 3 billion paid-up capital, and FX itself is under CBN control.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM). No NYDFS category covers acting as counterparty to FX or CFD trades.
- Labuan FSA Not permitted: Labuan money brokers may not act as principal (Money Broking Guidelines, 9 September 2024), and retail FX/CFD brokerage is not available in Labuan. A Labuan investment bank (RM10 million) may deal FX as principal but only with institutional clients, not as a retail B-book.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A principal desk dealing only in virtual assets would need Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book · no dealing desk
STP / agency
Orders pass straight through to liquidity providers; the broker acts as agent or matched principal and keeps no market risk.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 covers both dealing-desk and STP brokers (the SFC's review found most Type 3 firms hedge back-to-back with liquidity providers); same HK$30 million paid-up capital; disclose any affiliate liquidity provider in the execution policy.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Brokerage or intermediation of OTC FX derivatives is also Type I business, so an STP broker needs the same registration and JPY 50 million capital.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 200 k | Agency execution / arranging with permission to hold client money (CASS) is the GBP 150,000 tier; a matched-principal STP model is dealing as principal and generally needs the GBP 750,000 permission (we did not confirm whether MIFIDPRU 4.4 gives matched-principal firms a lower PMR).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | An Australian STP broker is still the issuer of the OTC derivative to its retail client, so it needs the same issuer and market-making authorizations and AUD 1 million NTA as a market maker.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | The CMS dealing license covers dealing as principal or agent, so an STP broker needs the same license and S$5 million base capital for retail clients; no lighter agency-only FX category exists.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency brokerCategory 3A | USD 500 k | Dealing in Investments as Agent or as Matched Principal (Category 3A), USD 500,000 base capital, rising to USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | An agency broker that keeps client accounts needs a bank or securities firm license (securities firm keeping client accounts, CHF 1.5 million); which one applies to OTC FX/CFD balances was not confirmed. A firm that only forwards orders to a licensed bank without holding money needs no FINMA license (see introducing broker).Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 174 k | Agency execution holding client money is in the EUR 150,000 band; a matched-principal STP model is dealing on own account and needs the EUR 750,000 band.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A Principal dealer / credit providerCategory 2 | USD 200 k | Pure agency (Dealing in Investments as Agent) is Category 3A at USD 200,000 base capital after the CP161 reforms (secondary); since the 2025 PIB amendments, matched-principal A-book dealing sits in Category 2 (USD 2 million; a lower matched-principal figure is reported but unconfirmed).Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 87 k | Agency execution / RTO holding client money is the IFD Art. 9(3) band (EUR 150,000); a matched-principal STP model counts as dealing on own account and needs the Art. 9(1) band (EUR 750,000).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Only an RFED or FCM may accept retail forex orders and funds, so an STP broker that hedges back-to-back with liquidity providers still registers as an RFED/FCM and holds the USD 20 million minimum; there is no lighter agency-only category for retail forex.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | A pure agent passing orders to a third-party issuer needs FAIS Category I (1.13 derivatives, 1.15 forex investment business); a matched-principal STP that is itself the client's counterparty on the CFD still needs ODP authorization, since FAIS does not permit issuing OTC derivatives.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) BrokerInvestment Dealer (Broker) | USD 13 k | Agency-only order routing to a third-party LP fits the Discount Broker (execution-only, MUR 600,000) or Broker (with advice/portfolio management, MUR 700,000) categories; a matched-principal STP that is counterparty to the client should take the Full Service Dealer license instead.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | Category 2 investment firm (all services except dealing as principal, including agency dealing and holding client money), BD 250,000 minimum capital. Whether CBB treats riskless matched-principal as principal dealing (Category 1) was not confirmed.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | The CFD Rules cover dealing in, providing or marketing CFDs in or from The Bahamas regardless of hedging model, so an STP broker also registers as a CFD dealer; same capital and resident-officer conditions as a market maker.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Labuan money broking license (arranging FX and money market deals only), RM1 million paid-up capital; clients limited to institutional investors and high-net-worth individuals, non-residents of Malaysia only, operational office in Labuan.Retail leverage No retail FX/CFD offering permitted. For eligible institutional and high-net-worth clients of money brokers, maximum leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards (Money Broking Guidelines, 9 September 2024). |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; covers brokerage of OTC derivatives and spot FX for onshore clients, including retail.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | Standard license acting as agent, minimum net assets USD 100,000 plus three months' liquid assets; a matched-principal model may fall in the principal bucket, so confirm with the BMA.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Agency dealing is listed within this category's permits; whether a pure agency broker is placed under BANK or INMA was not confirmed, and retail FX/CFD is not an established QFC model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Dealing as agent is also covered by the broker-dealer SIBA license, with the same CI$100,000 base financial resources.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | A Non-Dealing Online Foreign Exchange Broker links clients to the FX market for commission or mark-up and does not make markets (Reg. 2); KES 30 million paid-up capital, same liquid-capital test.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The same Securities Dealer license covers dealing as agent; there is no lower agency-only category, so the USD 100,000 capital applies.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Category 1(a) for agency execution; a matched-principal STP model is principal dealing and falls under 1(b). Category 2 (arranging) is commonly added.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 7 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: retail forex orders can be accepted only by an FCM or RFED, whatever the execution model.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria Not yet licensable; the proposed rules (1 September 2026) would create an STP/ECN/A-book broker registration at NGN 2 billion paid-up capital, and the existing Broker category covers securities only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Agency or matched-principal brokerage of virtual assets is Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book and B-book
Hybrid
Part of the flow is internalized and part passed on; the license must allow dealing as principal.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 general case, as for a market maker; the client agreement must state whether the firm takes the opposite side of client trades.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I registration as for a market maker; mandatory loss-cut rules and trust segregation of client margin apply.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Internalizing any client flow requires the dealing-as-principal permission and the GBP 750,000 PMR; CASS client-money permission is also needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | Same retail OTC derivatives issuer AFSL as a market maker; AUD 1 million NTA.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Same CMS dealing license as a market maker, with S$5 million base capital for retail; conflict management and execution policy apply.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Keeping any B-book risk is dealing as principal, so Category 2 (USD 2 million plus risk capital).Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | Same as the market maker: internalizing flow is own-account dealing; established Swiss practice is a bank license.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Internalizing any client flow is dealing on own account, so the EUR 750,000 band is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Internalizing any flow is dealing as principal, so Category 2 (USD 2 million plus risk capital), with a Retail Endorsement for retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Internalizing any client flow is dealing on own account, so the Art. 9(1) band (EUR 750,000) is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Internalizing any retail flow is acting as counterparty, so RFED or FCM registration with USD 20 million minimum adjusted net capital is required.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Internalising any flow means acting as principal on OTC derivatives, so ODP authorization is needed, plus FAIS Category I for retail distribution.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Any internalization is principal dealing, so the Full Service Dealer (excluding Underwriting) license is needed (MUR 1,000,000).Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Internalizing any flow is dealing as principal, so Category 1 (BD 1 million or risk-based capital).Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Same CFD dealer registration as a market maker; disclose the internalization policy and conflicts in the order execution policy.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | Same First Category OTC license (AED 30 million) as the market-maker model; principal-dealing scope to be confirmed with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Any internalized flow means dealing as principal: principal standard license, USD 250,000 minimum net assets.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Principal dealing under BANK, with the same retail limitation as the market-maker model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Broker-dealer / market maker SIBA license covers both principal and agency flow.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | Any internalization is market making, so the Dealing Online Foreign Exchange Broker license (KES 50 million) is needed.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Covered by the Securities Dealer license, which permits both agency and principal dealing (USD 100,000).Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent | — | Principal dealing (1(b)) for internalized flow plus agency dealing (1(a)) for passed-through flow.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC (RFED or FCM counterparty status).
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No category in force; under the proposed rules a hybrid would need the market-making (B-book) broker registration at NGN 3 billion.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- Labuan FSA Not permitted: internalizing flow requires principal dealing, which money brokers are prohibited from doing.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Multilateral matching
ECN / MTF venue
A venue where many participants’ orders meet; licensed as an exchange, MTF or OTF, not as a broker.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| SFC#3 Hong Kong | Automated trading venueType 7 – Providing automated trading services | USD 642 k | Uncertain: Type 7 automated trading services (HK$5 million paid-up capital) covers electronic venues for securities and futures contracts; whether a multilateral leveraged-FX venue falls under Type 7 or Type 3 was not confirmed. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | Operating an MTF without own-account dealing is in the GBP 150,000 tier (an OTF with own-account dealing needs GBP 750,000); a recognized investment exchange is a heavier, separate route, and most new venues start as MTFs. |
| ASIC#6 Australia | Licensed market operatorAustralian market license (Corporations Act Part 7.2) | — | A multilateral venue is a financial market requiring an Australian market license (Part 7.2), unless exempt; no fixed capital, adequate resources required (s 792A). |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| MAS#8 Singapore | Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | A multilateral trading venue is an organized market operated as a Recognised Market Operator (higher of S$250,000 or 25% of annual operating expenses for a Singapore RMO). Uncertain: whether a spot FX matching venue counts as an organized market was not confirmed. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Operating an MTF or OTF is a Category 4 activity (USD 50,000 base capital), but MTF/OTF operators remain subject to the Expenditure-Based Capital Minimum and FSRA market-operator requirements; a virtual-asset MTF is a separate category. |
| FINMA#10 Switzerland | Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | A stock exchange or MTF license (CHF 1 million minimum, FinMIO Art. 13) covers multilateral trading of securities; spot FX is not a security under FinMIA, so an FX-only matching venue may fall outside it. Uncertain. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band | USD 174 k | Operating an MTF falls in the EUR 150,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A | USD 200 k | Operating an Alternative Trading System (DIFC term for MTF/OTF) moved from Category 4 to Category 3A under the 2025 PIB amendments; ATS operators must also meet the AMI/ATS market-integrity rules (effective date of the move reported as July 2025 or July 2026 by different advisers). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Operating a trading facility is listed only under the Art. 9(1) license scope, but since the September 2025 amendment (Part BI R1-5.1.2) an MTF operator that does not deal on own account has EUR 150,000 initial capital; confirm the license scope with the MFSA. |
| CFTC · NFA#15 United States | DCM (futures exchange)Designated contract market (CEA s.5; Part 38) SEFSwap execution facility (CEA s.5h; Part 37) | — | Off-exchange retail forex cannot be run as a multilateral venue for non-ECP retail clients: an FX futures venue is a DCM (retail access via FCMs) and an FX swap/NDF venue is a SEF (ECPs only); institutional spot FX ECNs fall largely outside CFTC registration. Both need financial resources covering one year of operating costs. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| FSCA#17 South Africa | Licensed exchangeExchange license, Financial Markets Act 2012 | — | A multilateral venue for securities including derivative instruments must be a licensed exchange under the FMA 2012 (liquid net assets of at least 6 months' operating expenses, reg. 8 of GN R98); no MTF-style lighter category exists, and whether an OTC FX matching venue falls inside the exchange definition should be confirmed with counsel. |
| SCB Bahamas#21 The Bahamas | MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | A multilateral venue for capital markets instruments is registered as a marketplace under the Securities Industry Act, 2024, with SCB-approved rulebook and systems and capital set case by case; no FX-specific venue category exists. |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite)Non-Composite Securities Exchange | USD 3.33 m | Only an exchange-traded venue (e.g. FX derivatives on a securities exchange such as FMDQ) is licensable today, as a Non-Composite Securities Exchange at NGN 5 billion; an OTC FX/CFD matching venue has no category and would also need CBN involvement. Uncertain. |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB) | — | Uncertain: a multilateral venue would need Labuan exchange approval (LFSSA s.134) with capital set case by case; no FX-specific venue guideline was found. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The 2017 FX regulations have no venue category; the OTC Platform provider category under LN 197 of 2025 is the closest fit for a multilateral OTC venue, but its capital and whether it extends to online FX/CFDs are unconfirmed. |
| FSA Seychelles#32 Seychelles | Securities exchangeSecurities Exchange license (Securities Act 2007) | — | A multilateral venue would need a Securities Exchange license (sole activity, at least three independent dealer members, clearing, surveillance and compensation arrangements); whether the FSA would treat an OTC FX/CFD matching venue this way is uncertain. |
| BVI FSC#34 British Virgin Islands | Investment exchangeSIBA Category 7: Operating an investment exchange | — | Category 7 covers providing a facility for orderly trading of investments; whether an FX/CFD matching venue fits was not confirmed, so check with the FSC. |
Not available at 13 regulators
- FSA Japan Uncertain: the PTS authorization covers securities venues only; no Chart Room category for a multilateral retail FX venue was identified. Electronic trading platforms for certain OTC derivatives exist under the FIEA but were not confirmed for FX.
- SEC No SEC category for an FX venue; spot FX is not a security. The SEC ATS and exchange categories cover securities only; FX futures venues are CFTC DCMs and FX swap/NDF venues are CFTC SEFs.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- FSC Mauritius No venue category is in this register: operating a multilateral market requires a Securities Exchange license from the FSC under the Securities Act 2005, which is not recorded here.
- CBB No investment-firm category covers running a multilateral venue; licensed exchanges are authorized under CBB Volume 6 (market operators), which is not in this register.
- NYDFS Not licensed by NYDFS; FX futures venues are CFTC DCMs and FX swap venues are CFTC SEFs.
- CMA UAE No CMA category for operating an OTC FX/CFD multilateral venue was identified in the data; exchange and platform licensing outside the virtual-asset Seventh Category is not covered, so confirm with the CMA.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A virtual-asset matching venue, including exchange-traded VA derivatives under the March 2026 Part V rules, is Exchange Services; fiat-currency matching is excluded.
- BMA No category for operating a multilateral FX trading venue is in the register; exchange recognition is outside these license types. Uncertain.
- QFCRA No category for operating a multilateral trading venue was identified in the QFCRA data; onshore exchange-traded markets fall under the QFMA.
- CIMA No category in this register for a multilateral FX/CFD venue; the Cayman Islands Stock Exchange is a separate listing exchange. Not confirmed whether operating a matching platform would need a SIBA license.
- CMA Saudi Not available: the Saudi Exchange (Tadawul) is the only licensed exchange and there is no OTC FX venue license.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Referral and arranging
Introducing broker
Brings clients to a licensed broker without executing trades or holding client money.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| CSSF#2 Luxembourg | Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | Type 3 approved introducing agent: HK$5 million paid-up and HK$3 million liquid capital; may not carry client positions or hold client assets. |
| FCA#5 United Kingdom | Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | USD 100 k | Own Part 4A permission for arranging deals / making arrangements without client money (GBP 75,000 PMR), or act as an appointed representative (including an introducer AR) of an authorized broker that accepts responsibility. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Typically a corporate authorized representative of the issuing licensee (no own capital requirement), or the firm's own AFSL with dealing (arranging) authorization; ASIC has scrutinized CAR use in OTC derivatives. |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | Uncertain: the SFA definition of dealing includes inducing a person to enter into a transaction, so an introducer soliciting Singapore clients generally needs its own CMS dealing license or must act through the licensee's notified representatives; MAS has no dedicated IB license. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Arranging Deals in Investments (Category 4), USD 50,000 base capital from 19 August 2025; no EBCM if no Client Assets are held. FSRA proposed barring authorized firms from accepting paid retail referrals from unregulated third parties, so IBs introducing retail clients should be FSRA-authorised. |
| Bank of Lithuania#11 Lithuania | Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band | USD 87 k | RTO / arranging without client money in the EUR 75,000 band. The financial advisor company license does not fit because it covers only transferable securities and fund units, not CFDs or FX derivatives. Tied-agent status under MiFID II Art. 29 is also possible but is not a category in this register. |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arrangerCategory 4 | USD 30 k | Arranging Deals in Investments (Category 4), USD 30,000 base capital after the 2026 amendments (secondary); no execution or client money. A Representative Office is not an option: since April 2015 the DFSA will not accept Representative Office applications from firms marketing FX or other highly leveraged products to retail clients. |
| MFSA#14 Malta | Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | RTO / advice without holding client money in the IFD Art. 9(2) band (EUR 75,000); orders must go to an authorized broker; the professional-only variant (legacy 1B) has the same capital. Tied-agent status is also possible under MiFID II Art. 29 but is not a category in this register. |
| CFTC · NFA#15 United States | Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | USD 45 k | Soliciting retail forex for an RFED/FCM without holding customer funds requires IB registration and NFA membership: independent IB with at least USD 45,000 adjusted net capital, or guaranteed IB with no capital requirement but introducing only to its guarantor. |
| CySEC#16 Cyprus | Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Introducing or arranging for clients is a FAIS intermediary service, so a Category I license (1.13/1.15) or appointment as a representative of a licensed FSP is needed; referral to offshore brokers while collecting local rand deposits has drawn SARB exchange-control action. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | Category 3 (arranging and advising, BD 25,000 plus liquid funds of 25% of prior-year operating expenses) only fits an IB paid by its clients, because Category 3 firms must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent; a rebate-funded IB therefore needs Category 2 (BD 250,000). |
| SCB Bahamas#21 The Bahamas | Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | Introducing clients to a dealer without dealing is arranging deals (USD 25,000 floor under the older formula); the CFD Rules also capture marketing CFDs in or from The Bahamas, so check with the SCB whether an introducer also needs CFD registration. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Uncertain: arranging FX transactions from Labuan falls within money broking (RM1 million); no lighter introducer category exists. An introducer based outside Labuan is governed by its own jurisdiction. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | Fifth Category introducing and promotion, AED 500,000 paid-up capital; may introduce UAE clients to an offshore or free-zone broker but may not hold client assets or execute. Most CFD brokers entering the UAE (XM, Exinity, Pepperstone and others) use this route. |
| BMA#27 Bermuda | Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | Arranging deals without dealing as agent or principal: standard license (neither agent nor principal), minimum net assets USD 12,000 plus one month's liquid assets. |
| QFCRA#28 Qatar · QFC | Investment adviser / arrangerAdvisory and arranging firm (INMA 2014) | USD 250 k | Arranging deals in investments (INMA advisory and arranging firm), base capital about USD 250,000 restated in QAR plus 13/52 of annual operating expenses; no client money. A December 2025 consultation may lower requirements for wholesale advisers. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | SIBA license for arranging deals in securities; CI$15,000 base financial resources plus professional indemnity insurance. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The FX regulations have no introducing-broker category; the Intermediary Service Platform provider category (LN 197 of 2025), granted to Safaricom and Airtel Money in December 2025 for onboarding and market access, is the closest fit, but its use for FX referral is unconfirmed, and offshore brokers may not serve Kenyan clients. |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | SIBA Category 2, arranging deals in investments, including introducing clients to dealers. |
Not available at 11 regulators
- FSA Japan Not a Chart Room category: an introducer registers as a Financial Instruments Intermediary Service Provider (FIEA Art. 66) tied to a Type I firm, or registers as Type I itself. Unregistered solicitation of Japanese residents is prohibited.
- FINMA No FINMA license for pure referral without handling client money or orders. A firm that transmits orders provides a FinSA financial service, so its client advisers must be in the FinSA adviser register unless the firm is supervised; AML SRO membership may apply if it acts as a financial intermediary. Uncertain.
- SEC Licensed by the CFTC/NFA, not the SEC: introducing retail forex accounts requires CFTC introducing broker registration and NFA membership; an SEC introducing broker-dealer status does not cover FX.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime. SAMA's 2017 circular prohibits marketing by foreign forex firms without a contract with a licensed Saudi institution.
- FSC Mauritius No dedicated introducing-broker category was found; whether pure referral is licensable is uncertain, and if the firm advises it needs Investment Adviser (Restricted), or if it receives and transmits orders, Investment Dealer (Broker).
- SEC Nigeria No category in force; the proposed rules would create Corporate Introducing Broker (NGN 150 million) and Individual Introducing Broker (NGN 30 million) registrations and would ban referral incentives. The existing Sub-Broker (Digital) category routes securities orders only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (CFTC introducing broker with NFA membership).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Arranging orders in virtual assets falls under Broker-Dealer Services.
- CMA Saudi No fit: Arranging covers securities only, and a 2017 SAMA circular prohibits foreign forex companies without contracts with licensed Saudi institutions from marketing in the Kingdom.
- FSA Seychelles No introducing-broker category exists in the register, and a secondary source reports no FSA restrictions on IBs; if the firm gives advice it needs an Investment Adviser license (USD 25,000). Treatment of a Seychelles-based referral business is uncertain.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022. Introducing to brokers is the CMA Fifth Category.
A brand on a host license
White label
Operates its own brand on another firm’s license and platform, often as its appointed representative.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | No tied-agent or appointed-representative regime: a Hong Kong-facing brand must be licensed itself, usually as a Type 3 introducing agent referring clients to the executing Type 3 firm. |
| FCA#5 United Kingdom | Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | — | Appointed representative of the principal broker under SUP 12; no separate license or capital, but the principal must notify the FCA 30 days ahead and oversee the AR, and the AR cannot deal as principal or hold client money. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Corporate authorized representative of the AFS licensee; no separate license, but the CAR cannot issue products in its own right and the licensee remains responsible. |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CFTC · NFA#15 United States | Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | No white-label license exists; a US-facing brand on another firm's platform must register itself, usually as a guaranteed IB of the RFED/FCM (closest equivalent to an appointed representative), since anyone soliciting retail forex must be registered. |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Most South African CFD brands hold their own FAIS Category I license and distribute a third-party ODP's products; alternatively the brand can operate as a juristic representative of a licensed FSP under the FAIS Act without its own license, with the FSP remaining responsible. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) | USD 13 k | No tied-agent or appointed-representative regime for corporate white labels was identified, so a white label serving clients from Mauritius generally needs its own Investment Dealer license, commonly the Discount Broker category on a partner's platform and liquidity. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | No tied-agent or appointed-representative regime was identified; a white-label brand marketing onshore needs at least a Fifth Category promotion license, and a First Category OTC license if it contracts with or executes for clients. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | Cayman has no appointed-representative or tied-agent regime, so a white label carrying on securities investment business from the Cayman Islands needs its own SIBA license, at least the arranging license if the partner broker is the counterparty. Not confirmed. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | No tied-agent or appointed-representative regime exists; a white label serving Kenyan clients needs its own CMA online FX license, typically non-dealing, held by a Kenyan-incorporated company, with a service level agreement with the platform provider (Reg. 4(2)(j)). |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | No tied-agent or appointed-representative regime was identified, so a white label dealing with clients from Seychelles needs its own Securities Dealer license (USD 100,000, local office and staff). |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | The BVI has no tied-agent or appointed-representative regime, so a BVI white label needs its own SIBA license: Category 2 if the partner broker deals with the clients, Category 1 if it deals itself. Not confirmed. |
Not available at 19 regulators
- FSA Japan No dedicated pathway: the brand must register itself (Type I) or act as a Financial Instruments Intermediary Service Provider tied to the registered firm; that intermediary status is not a Chart Room category.
- MAS No dedicated pathway: a brand must hold its own CMS license or act through the licensee's notified representatives; MAS has no appointed-representative regime for firms.
- FSRA No appointed-representative or tied-agent regime was identified for ADGM, so a white-label brand needs its own FSRA permission: Category 4 if it only arranges for the licensed broker, Category 2 or 3A if it deals or contracts with clients (confirm with the FSRA).
- FINMA Switzerland has no tied-agent or appointed-representative regime. A pure marketing brand of a licensed Swiss bank needs no license, but a white label that contracts with clients or holds their money needs its own bank or securities firm license.
- Bank of Lithuania No category in this register: a white label can run as a MiFID tied agent of the licensing broker (no separate license), otherwise it needs its own financial brokerage firm license.
- DFSA No appointed-representative or tied-agent route was identified in the DFSA regime, so a DIFC white-label brand needs its own license: Category 4 if it only markets and arranges for the principal broker, Category 2 or 3A if it contracts with clients or executes (confirm with the DFSA).
- SEC Licensed by the CFTC/NFA, not the SEC: the nearest US structure is a guaranteed IB of an RFED or FCM.
- MFSA No category in this register: a white label can run as a MiFID tied agent registered by its principal (no separate license), otherwise it needs its own Investment Services Licence.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- CBB Not confirmed: Category 3 firms are barred from acting as tied agents, implying a tied-agent concept, but the tied-agent regime was not researched; otherwise the brand needs its own Category 2 or Category 1 license depending on whether it deals as principal.
- SCB Bahamas No appointed-representative or tied-agent regime was found; a brand that deals in or markets CFDs in or from The Bahamas registers itself (CFD dealer, or arranging deals for a pure referral model). Uncertain: confirm with the SCB.
- SEC Nigeria No FX/CFD white-label route exists today; the proposed rules require brokers and technology providers to allocate compliance responsibility, and a separate Technology/Platform Provider registration at NGN 5 billion; no tied-agent regime for FX is proposed.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA; the nearest structure is a CFTC guaranteed IB.
- Labuan FSA No appointed-representative or white-label regime: the brand must hold its own money broking license, with substance in Labuan.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- BMA No appointed-representative or tied-agent route was identified; a Bermuda white-label operator needs its own standard license in the bucket matching its role. Class A registration is only for Bermuda-formed firms regulated by a recognized foreign regulator with no place of business in Bermuda.
- QFCRA No appointed-representative or tied-agent regime was identified; a white-label brand would need its own QFC authorization (arranging or dealing). Uncertain.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Prime-of-Prime
Liquidity provider / PoP
Deals as principal with brokers and institutions, redistributing prime liquidity; not retail.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions is Eigenhandel or own-account dealing in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Uncertain: principal dealing in leveraged FX with clients needs Type 3, but some dealings with banks and other professionals may fall under SFO exclusions or the LFET exemption rules; HKMA-authorized banks are exempt. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Uncertain: principal OTC derivatives dealing is Type I business, but certain transactions with financial institutions or qualified institutional investors may be excluded under the FIEA Enforcement Order; confirm before relying on an exclusion. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Dealing in investments as principal with brokers and institutions; GBP 750,000 PMR; this is the tier used for principal-model prime-of-prime and non-bank prime services. |
| ASIC#6 Australia | Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | AFSL limited to wholesale clients (s 761G) for dealing and market making in derivatives and FX; no fixed capital minimum beyond RG 166 base-level requirements; the usual route for prime-of-prime and liquidity providers. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Dealing as principal with brokers and institutions is a CMS dealing activity; base capital S$1 million for leveraged FX or OTC derivatives when serving only accredited, institutional or expert investors. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties (Category 2), USD 2 million base capital plus risk capital. |
| FINMA#10 Switzerland | Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | A securities firm license (own-account dealer or market maker, CHF 1.5 million) covers professional own-account dealing with institutions; banks also act as LPs under their bank license. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing as principal with brokers and institutions requires the EUR 750,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties only (no Retail Endorsement needed), USD 2 million base capital plus market and credit risk capital. |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing as principal with brokers and institutions needs the Art. 9(1) band (EUR 750,000); large firms may fall under CRR as Class 1 or Class 1 Minus. |
| CFTC · NFA#15 United States | Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | Dealing as principal in spot and deliverable FX forwards with eligible contract participants generally needs no CFTC registration; swap dealer registration (USD 20 million minimum capital) applies only if FX swaps such as NDFs or CFDs with ECPs exceed the de minimis threshold. Providing liquidity to an RFED or FCM does not by itself require RFED status. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | Dealing as principal in OTC derivatives with brokers and institutions is ODP activity under the FMA (trade-repository reporting and Joint Standard 2 of 2020 margin rules apply); no separate institutional-only category exists, and bank LPs rely on their Prudential Authority banking license. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Principal dealing with brokers and institutions fits the Full Service Dealer (excluding Underwriting) license (MUR 1,000,000); the Investment Dealer (Derivatives) category covers agency and exchange market making only and was not confirmed for an OTC principal book. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm dealing as principal with institutional counterparties, BD 1 million or risk-based capital; wholesale banks are the alternative. |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | USD 300 k | Dealing as principal in derivatives with brokers and institutions is dealing in capital markets instruments as principal (USD 300,000 floor under the older formula); add CFD registration where the instruments supplied are CFDs. |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | Uncertain: principal dealing in FX and derivatives with institutions fits a Labuan investment bank license (RM10 million paid-up capital, no deposit-taking); money brokers cannot act as principal. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Principal standard license (USD 250,000 minimum net assets); Class B registration excludes market intermediaries, so a liquidity provider cannot rely on it. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal with institutional and professional counterparties under BANK; base capital not confirmed. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4) | USD 122 k | Principal dealing with brokers and institutions needs the broker-dealer license; a firm dealing only with sophisticated or high-net-worth persons (entities with USD 5 million or more in assets) may register as a SIBA registered person instead, with no stated capital. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Principal dealing with brokers and institutions falls under the Securities Dealer license (USD 100,000); there is no separate institutional category. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Dealing in investments as principal with brokers and institutions, Category 1(b); the FSC sets capital case by case. |
Not available at 9 regulators
- SEC Not an SEC matter for FX: spot and deliverable forward FX dealing between eligible contract participants is largely outside registration, and NDFs and other FX swaps fall under the CFTC (swap dealer above the de minimis threshold).
- SAMA Interbank FX is dealt by SAMA-licensed banks; no separate non-bank FX liquidity license exists. A money changer license covers spot cash currency exchange only.
- SEC Nigeria No SEC category for FX/CFD liquidity provision; FX dealing as principal is the domain of CBN-licensed banks and authorized dealers, and the proposed rules do not mention liquidity providers.
- NYDFS Not licensed by NYDFS; FX dealing with institutions is largely outside registration or falls under CFTC swap dealer rules. A New York state-chartered bank conducts FX dealing under its banking charter, which is not a practical brokerage route.
- CMA UAE No wholesale-only principal dealing category for OTC FX was identified; the 'financial products dealer' activity under First Category may be relevant but its scope for OTC FX was not confirmed. Onshore interbank FX liquidity comes from CBUAE-licensed banks.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A VA OTC liquidity desk would need Broker-Dealer Services.
- CMA Kenya No CMA category covers institutional-only FX/CFD principal dealing; Kenyan dealing brokers hedge with offshore LPs or banks, and interbank FX dealing is done by CBK-licensed banks. Uncertain.
- CMA Saudi Not a CMA activity; interbank FX dealing is done by SAMA-licensed banks.
- CBUAE No non-bank FX dealing license exists at the CBUAE; interbank FX liquidity is provided by licensed banks (Licensed Bank at AED 2 billion or Restricted Licence Bank at AED 1 billion), which is not a practical route for a liquidity-provider start-up.
Every fitting category
42 categories at 26 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary |
| Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary |
| Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency broker Category 3A | USD 500 k | USD 40 k | USD 50 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook |
| Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook | |
| CMA UAE#25 UAE · Federal | Securities broker / dealer First Category – Dealing in Securities (trading broker, trading and clearing broker, international markets broker, financial products dealer) | USD 8.17 m | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Principal dealer / broker Investment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Dealing / brokerage Dealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1)) | USD 13.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | Introducing broker-dealer (receiving) Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)) | USD 50 k | USD 8 k | USD 1 k | Retail | Rulebook |
| Non-receiving broker-dealer Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) | USD 5 k | USD 8 k | USD 1 k | Retail | Rulebook | |
| CFTC · NFA#15 United States | Independent IB Introducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) | USD 45 k | USD 950 (nominal) | USD 750 (nominal) | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent) Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) | USD 300 k | USD 16 k | USD 8 k | Retail | To confirm |
| Securities dealer (agent only) Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024) | USD 120 k | USD 16 k | USD 8 k | Retail | To confirm | |
| BMA#27 Bermuda | Investment dealer (principal) Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Investment broker (agent) Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook | |
| BVI FSC#34 British Virgin Islands | Agency broker SIBA Category 1, sub-category (a): Dealing in investments as agent | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Leveraged FX dealer Type 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | USD 17 k | USD 17 k | Retail | Rulebook | |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Retail CFD/FX market maker AFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | USD 2 k | USD 83 k | Retail | Rulebook |
| Wholesale-only AFSL AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | USD 1 k | — | Professional only | Rulebook | |
| MAS#8 Singapore | Securities and exchange-traded derivatives dealer CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives) | USD 39 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| OTC derivatives / CFD dealer CMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Leveraged FX dealer CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX) Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | USD 500 (nominal) | USD 6 k | Professional only | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Advice and intermediary FSP FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | USD 154 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | Full-service dealer Investment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | USD 1 k | USD 3 k | Retail | Rulebook |
| Broker Investment Dealer (Broker) | USD 15 k | USD 700 (nominal) | USD 3 k | Retail | Rulebook | |
| SEC Nigeria#22 Nigeria | Broker Broker (client execution only) | USD 400 k | — | — | Retail | Rulebook |
| Broker-dealer Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services) | USD 1.33 m | USD 4 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Stockbroker Stockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025) | USD 388 k | USD 853 (nominal) | USD 775 (nominal) | Retail | Secondary |
| Broker-dealer Broker-Dealer (new hybrid category, LN 197 of 2025) | USD 543 k | USD 2 k | USD 2 k | Retail | Secondary | |
| FSA Seychelles#32 Seychelles | Securities dealer Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | USD 3 k | USD 6 k | Retail | Rulebook |
Not licensed by: MFSA, FINMA, Bank of Lithuania, VARA, CBUAE, SAMA, NYDFS, CIMA.
Institutional Brokerage
Execution for professional and institutional clients only. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators30 of 34
Lowest capitalUSD 15 kFSC Mauritius
Median capitalUSD 174 k
Retail clients allowed29 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (client money / MTF)
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (holds client money/assets or operates MTF)
- Capital
- USD 174 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities introducing agent / trader
- Capital
- USD 64 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 174 k
FSC Mauritius
USD 15 k
Labuan FSAUSD 35 k
MASUSD 39 k
SECUSD 50 k
SFCUSD 64 k
MFSAUSD 87 k
BMAUSD 100 k
FSA SeychellesUSD 100 k
SCB BahamasUSD 120 k
CIMAUSD 122 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
Bank of LithuaniaUSD 174 k
CySECUSD 174 k
FCAUSD 200 k
DFSAUSD 200 k
FSA JapanUSD 335 k
CMA KenyaUSD 388 k
SEC NigeriaUSD 400 k
FSRAUSD 500 k
CBBUSD 665 k
CFTC · NFAUSD 1 m
FINMAUSD 1.88 m
CMA UAEUSD 8.17 m
CMA SaudiUSD 13.33 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Forex brokerage
Seven ways to run a forex broker
Each model asks for a different permission. Choose a model to see, at every regulator, the category to apply for and what it requires. A model is counted wherever any category permits it, so a count can exceed the regulators mapped to the system above.
B-book · dealing desk
Market maker
The broker takes the other side of each client trade and carries the market risk on its own book.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Proprietary trading for others (Eigenhandel) / dealing on own account; EUR 750,000 initial capital (Section 17(1) no. 1 WpIG) plus IFR own funds; BaFin's CFD general administrative act applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 leveraged foreign exchange trading (general case): HK$30 million paid-up capital and HK$15 million liquid capital, two responsible officers; CFDs on securities need Type 1 instead. Very few new Type 3 licenses are granted.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I Financial Instruments Business registration covers OTC derivatives including retail FX and CFDs; stock company with board, JPY 50 million stated capital and net assets, capital adequacy ratio of at least 120%, FFAJ membership effectively required.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Part 4A permission for dealing in investments as principal; GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4) plus fixed overheads and K-factor tests; this is the standard license for market-making FX/CFD brokers; COBS 22.5 applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | AFSL authorizations to deal in and make a market in derivatives and FX contracts for retail clients (issuer of retail OTC derivatives); NTA of the greater of AUD 1 million or 10% of average revenue, half in cash (Instrument 2022/705, RG 166).Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | CMS license for dealing in capital markets products: spot FX for leveraged FX trading and, for CFDs on other underlyings, OTC derivatives; base capital S$5 million each where any retail customer is served, plus risk-based capital (Notice SFA 04-N13).Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (not as Matched Principal) in Category 2, USD 2 million base capital plus risk capital; FSRA lists market-maker CFD/FX brokers here.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | In practice Swiss retail FX/CFD market makers hold a bank license (CHF 10 million minimum capital), because FINMA has treated client margin balances held by non-banks as public deposits since about 2009; a securities firm license (CHF 1.5 million, own-account dealing and market making) may suffice only if client balances qualify as settlement accounts. Unconfirmed: confirm with FINMA.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing on own account in the EUR 750,000 band (Law on Markets in Financial Instruments Art. 14); market-maker and CFD principal models require this band; ESMA-derived retail CFD caps apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (Category 2), USD 2 million base capital plus risk capital; a Retail Endorsement is needed to deal with retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing on own account under an Investment Services Licence in the IFD Art. 9(1) band; EUR 750,000 initial capital plus recovery and resolution rules; CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Acting as counterparty to retail off-exchange forex requires RFED registration (or FCM status with retail forex) and NFA Forex Dealer Member status, with adjusted net capital of at least USD 20 million plus 5% of retail forex obligations above USD 10 million.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Issuing CFDs/rolling spot FX as principal requires ODP authorization under the Financial Markets Act 2012 (no fixed rand capital; about 6 months of liquid net assets per practitioner summaries, with bank-like capital rules for non-bank ODPs signalled in 2025), and retail distribution also needs a FAIS Category I license with subcategories 1.13/1.15 (own or a partner FSP).Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Dealing as principal for resale to clients falls under the Investment Dealer (Full Service Dealer, excluding Underwriting) license, MUR 1,000,000 stated unimpaired capital, PI cover, compliance officer and MLRO, and GBC substance if held through a GBC.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm (dealing in financial instruments as principal), BD 1 million minimum capital or the higher risk-based requirement; this is the CBB route for market-making brokers.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Dealing in FX and other CFDs as principal requires CFD registration under the Securities Industry (Contracts for Differences) Rules, 2020, either as a CFD-only firm or alongside dealing registration; capital is a Commission formula (r.13), with a USD 1,000,000 bank-deposit floor proposed in the 2026 draft amendment (not final as of October 2026), and a resident CFD Supervisory Officer.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; market-maker CFD brokers (e.g. Plus500, XTB, Deriv) hold this license, but the rulebook text read did not state expressly whether dealing as principal is permitted, so confirm with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Investment Business Act standard license as a principal investment provider, minimum net assets USD 250,000 (or 8% of risk-weighted assets) plus liquid assets of three months' expenditure.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal, prudentially regulated under BANK (base capital not confirmed); retail FX/CFD brokerage is not an established QFC model, so this is realistic only for business and professional clients.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | SIBA license for dealing in securities and market making; base financial resource requirement CI$100,000 (higher of that and a quarter of annual expenditure plus risk requirements), professional indemnity cover of CI$1 million per claim, monthly financial statements; retail FX/CFD brokers use this license.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | A Dealing Online Foreign Exchange Broker trades as principal and market maker (Reg. 2, Online FX Trading Regulations 2017); KES 50 million paid-up capital, liquid capital of the higher of KES 30 million or 8% of liabilities, Kenyan-incorporated company.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The Securities Dealer license covers dealing in securities including CFDs and FX as principal (B-book); USD 100,000 paid-up capital since the Securities (Amendment) Act 2024, physical office, two natural-person directors, licensed representative and compliance officer.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | SIBA Category 1(b), dealing as principal including taking the other side of client trades; no fixed minimum capital, as the FSC sets financial resources case by case under Regulatory Code s. 181 (advisers budget about USD 1 million) and expects more for principal dealing.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: a retail FX counterparty must be an RFED or an FCM. SEC broker-dealer dealer status covers securities only, and CFDs on US securities (security-based swaps) cannot be offered off-exchange to non-ECP retail clients.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No SEC category for retail FX/CFD market making is currently in force; SEC proposed rules of 1 September 2026 would create a B-book/market-making forex broker registration at NGN 3 billion paid-up capital, and FX itself is under CBN control.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM). No NYDFS category covers acting as counterparty to FX or CFD trades.
- Labuan FSA Not permitted: Labuan money brokers may not act as principal (Money Broking Guidelines, 9 September 2024), and retail FX/CFD brokerage is not available in Labuan. A Labuan investment bank (RM10 million) may deal FX as principal but only with institutional clients, not as a retail B-book.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A principal desk dealing only in virtual assets would need Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book · no dealing desk
STP / agency
Orders pass straight through to liquidity providers; the broker acts as agent or matched principal and keeps no market risk.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 covers both dealing-desk and STP brokers (the SFC's review found most Type 3 firms hedge back-to-back with liquidity providers); same HK$30 million paid-up capital; disclose any affiliate liquidity provider in the execution policy.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Brokerage or intermediation of OTC FX derivatives is also Type I business, so an STP broker needs the same registration and JPY 50 million capital.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 200 k | Agency execution / arranging with permission to hold client money (CASS) is the GBP 150,000 tier; a matched-principal STP model is dealing as principal and generally needs the GBP 750,000 permission (we did not confirm whether MIFIDPRU 4.4 gives matched-principal firms a lower PMR).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | An Australian STP broker is still the issuer of the OTC derivative to its retail client, so it needs the same issuer and market-making authorizations and AUD 1 million NTA as a market maker.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | The CMS dealing license covers dealing as principal or agent, so an STP broker needs the same license and S$5 million base capital for retail clients; no lighter agency-only FX category exists.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency brokerCategory 3A | USD 500 k | Dealing in Investments as Agent or as Matched Principal (Category 3A), USD 500,000 base capital, rising to USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | An agency broker that keeps client accounts needs a bank or securities firm license (securities firm keeping client accounts, CHF 1.5 million); which one applies to OTC FX/CFD balances was not confirmed. A firm that only forwards orders to a licensed bank without holding money needs no FINMA license (see introducing broker).Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 174 k | Agency execution holding client money is in the EUR 150,000 band; a matched-principal STP model is dealing on own account and needs the EUR 750,000 band.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A Principal dealer / credit providerCategory 2 | USD 200 k | Pure agency (Dealing in Investments as Agent) is Category 3A at USD 200,000 base capital after the CP161 reforms (secondary); since the 2025 PIB amendments, matched-principal A-book dealing sits in Category 2 (USD 2 million; a lower matched-principal figure is reported but unconfirmed).Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 87 k | Agency execution / RTO holding client money is the IFD Art. 9(3) band (EUR 150,000); a matched-principal STP model counts as dealing on own account and needs the Art. 9(1) band (EUR 750,000).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Only an RFED or FCM may accept retail forex orders and funds, so an STP broker that hedges back-to-back with liquidity providers still registers as an RFED/FCM and holds the USD 20 million minimum; there is no lighter agency-only category for retail forex.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | A pure agent passing orders to a third-party issuer needs FAIS Category I (1.13 derivatives, 1.15 forex investment business); a matched-principal STP that is itself the client's counterparty on the CFD still needs ODP authorization, since FAIS does not permit issuing OTC derivatives.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) BrokerInvestment Dealer (Broker) | USD 13 k | Agency-only order routing to a third-party LP fits the Discount Broker (execution-only, MUR 600,000) or Broker (with advice/portfolio management, MUR 700,000) categories; a matched-principal STP that is counterparty to the client should take the Full Service Dealer license instead.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | Category 2 investment firm (all services except dealing as principal, including agency dealing and holding client money), BD 250,000 minimum capital. Whether CBB treats riskless matched-principal as principal dealing (Category 1) was not confirmed.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | The CFD Rules cover dealing in, providing or marketing CFDs in or from The Bahamas regardless of hedging model, so an STP broker also registers as a CFD dealer; same capital and resident-officer conditions as a market maker.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Labuan money broking license (arranging FX and money market deals only), RM1 million paid-up capital; clients limited to institutional investors and high-net-worth individuals, non-residents of Malaysia only, operational office in Labuan.Retail leverage No retail FX/CFD offering permitted. For eligible institutional and high-net-worth clients of money brokers, maximum leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards (Money Broking Guidelines, 9 September 2024). |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; covers brokerage of OTC derivatives and spot FX for onshore clients, including retail.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | Standard license acting as agent, minimum net assets USD 100,000 plus three months' liquid assets; a matched-principal model may fall in the principal bucket, so confirm with the BMA.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Agency dealing is listed within this category's permits; whether a pure agency broker is placed under BANK or INMA was not confirmed, and retail FX/CFD is not an established QFC model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Dealing as agent is also covered by the broker-dealer SIBA license, with the same CI$100,000 base financial resources.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | A Non-Dealing Online Foreign Exchange Broker links clients to the FX market for commission or mark-up and does not make markets (Reg. 2); KES 30 million paid-up capital, same liquid-capital test.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The same Securities Dealer license covers dealing as agent; there is no lower agency-only category, so the USD 100,000 capital applies.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Category 1(a) for agency execution; a matched-principal STP model is principal dealing and falls under 1(b). Category 2 (arranging) is commonly added.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 7 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: retail forex orders can be accepted only by an FCM or RFED, whatever the execution model.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria Not yet licensable; the proposed rules (1 September 2026) would create an STP/ECN/A-book broker registration at NGN 2 billion paid-up capital, and the existing Broker category covers securities only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Agency or matched-principal brokerage of virtual assets is Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book and B-book
Hybrid
Part of the flow is internalized and part passed on; the license must allow dealing as principal.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 general case, as for a market maker; the client agreement must state whether the firm takes the opposite side of client trades.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I registration as for a market maker; mandatory loss-cut rules and trust segregation of client margin apply.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Internalizing any client flow requires the dealing-as-principal permission and the GBP 750,000 PMR; CASS client-money permission is also needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | Same retail OTC derivatives issuer AFSL as a market maker; AUD 1 million NTA.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Same CMS dealing license as a market maker, with S$5 million base capital for retail; conflict management and execution policy apply.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Keeping any B-book risk is dealing as principal, so Category 2 (USD 2 million plus risk capital).Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | Same as the market maker: internalizing flow is own-account dealing; established Swiss practice is a bank license.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Internalizing any client flow is dealing on own account, so the EUR 750,000 band is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Internalizing any flow is dealing as principal, so Category 2 (USD 2 million plus risk capital), with a Retail Endorsement for retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Internalizing any client flow is dealing on own account, so the Art. 9(1) band (EUR 750,000) is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Internalizing any retail flow is acting as counterparty, so RFED or FCM registration with USD 20 million minimum adjusted net capital is required.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Internalising any flow means acting as principal on OTC derivatives, so ODP authorization is needed, plus FAIS Category I for retail distribution.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Any internalization is principal dealing, so the Full Service Dealer (excluding Underwriting) license is needed (MUR 1,000,000).Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Internalizing any flow is dealing as principal, so Category 1 (BD 1 million or risk-based capital).Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Same CFD dealer registration as a market maker; disclose the internalization policy and conflicts in the order execution policy.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | Same First Category OTC license (AED 30 million) as the market-maker model; principal-dealing scope to be confirmed with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Any internalized flow means dealing as principal: principal standard license, USD 250,000 minimum net assets.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Principal dealing under BANK, with the same retail limitation as the market-maker model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Broker-dealer / market maker SIBA license covers both principal and agency flow.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | Any internalization is market making, so the Dealing Online Foreign Exchange Broker license (KES 50 million) is needed.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Covered by the Securities Dealer license, which permits both agency and principal dealing (USD 100,000).Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent | — | Principal dealing (1(b)) for internalized flow plus agency dealing (1(a)) for passed-through flow.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC (RFED or FCM counterparty status).
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No category in force; under the proposed rules a hybrid would need the market-making (B-book) broker registration at NGN 3 billion.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- Labuan FSA Not permitted: internalizing flow requires principal dealing, which money brokers are prohibited from doing.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Multilateral matching
ECN / MTF venue
A venue where many participants’ orders meet; licensed as an exchange, MTF or OTF, not as a broker.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| SFC#3 Hong Kong | Automated trading venueType 7 – Providing automated trading services | USD 642 k | Uncertain: Type 7 automated trading services (HK$5 million paid-up capital) covers electronic venues for securities and futures contracts; whether a multilateral leveraged-FX venue falls under Type 7 or Type 3 was not confirmed. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | Operating an MTF without own-account dealing is in the GBP 150,000 tier (an OTF with own-account dealing needs GBP 750,000); a recognized investment exchange is a heavier, separate route, and most new venues start as MTFs. |
| ASIC#6 Australia | Licensed market operatorAustralian market license (Corporations Act Part 7.2) | — | A multilateral venue is a financial market requiring an Australian market license (Part 7.2), unless exempt; no fixed capital, adequate resources required (s 792A). |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| MAS#8 Singapore | Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | A multilateral trading venue is an organized market operated as a Recognised Market Operator (higher of S$250,000 or 25% of annual operating expenses for a Singapore RMO). Uncertain: whether a spot FX matching venue counts as an organized market was not confirmed. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Operating an MTF or OTF is a Category 4 activity (USD 50,000 base capital), but MTF/OTF operators remain subject to the Expenditure-Based Capital Minimum and FSRA market-operator requirements; a virtual-asset MTF is a separate category. |
| FINMA#10 Switzerland | Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | A stock exchange or MTF license (CHF 1 million minimum, FinMIO Art. 13) covers multilateral trading of securities; spot FX is not a security under FinMIA, so an FX-only matching venue may fall outside it. Uncertain. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band | USD 174 k | Operating an MTF falls in the EUR 150,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A | USD 200 k | Operating an Alternative Trading System (DIFC term for MTF/OTF) moved from Category 4 to Category 3A under the 2025 PIB amendments; ATS operators must also meet the AMI/ATS market-integrity rules (effective date of the move reported as July 2025 or July 2026 by different advisers). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Operating a trading facility is listed only under the Art. 9(1) license scope, but since the September 2025 amendment (Part BI R1-5.1.2) an MTF operator that does not deal on own account has EUR 150,000 initial capital; confirm the license scope with the MFSA. |
| CFTC · NFA#15 United States | DCM (futures exchange)Designated contract market (CEA s.5; Part 38) SEFSwap execution facility (CEA s.5h; Part 37) | — | Off-exchange retail forex cannot be run as a multilateral venue for non-ECP retail clients: an FX futures venue is a DCM (retail access via FCMs) and an FX swap/NDF venue is a SEF (ECPs only); institutional spot FX ECNs fall largely outside CFTC registration. Both need financial resources covering one year of operating costs. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| FSCA#17 South Africa | Licensed exchangeExchange license, Financial Markets Act 2012 | — | A multilateral venue for securities including derivative instruments must be a licensed exchange under the FMA 2012 (liquid net assets of at least 6 months' operating expenses, reg. 8 of GN R98); no MTF-style lighter category exists, and whether an OTC FX matching venue falls inside the exchange definition should be confirmed with counsel. |
| SCB Bahamas#21 The Bahamas | MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | A multilateral venue for capital markets instruments is registered as a marketplace under the Securities Industry Act, 2024, with SCB-approved rulebook and systems and capital set case by case; no FX-specific venue category exists. |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite)Non-Composite Securities Exchange | USD 3.33 m | Only an exchange-traded venue (e.g. FX derivatives on a securities exchange such as FMDQ) is licensable today, as a Non-Composite Securities Exchange at NGN 5 billion; an OTC FX/CFD matching venue has no category and would also need CBN involvement. Uncertain. |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB) | — | Uncertain: a multilateral venue would need Labuan exchange approval (LFSSA s.134) with capital set case by case; no FX-specific venue guideline was found. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The 2017 FX regulations have no venue category; the OTC Platform provider category under LN 197 of 2025 is the closest fit for a multilateral OTC venue, but its capital and whether it extends to online FX/CFDs are unconfirmed. |
| FSA Seychelles#32 Seychelles | Securities exchangeSecurities Exchange license (Securities Act 2007) | — | A multilateral venue would need a Securities Exchange license (sole activity, at least three independent dealer members, clearing, surveillance and compensation arrangements); whether the FSA would treat an OTC FX/CFD matching venue this way is uncertain. |
| BVI FSC#34 British Virgin Islands | Investment exchangeSIBA Category 7: Operating an investment exchange | — | Category 7 covers providing a facility for orderly trading of investments; whether an FX/CFD matching venue fits was not confirmed, so check with the FSC. |
Not available at 13 regulators
- FSA Japan Uncertain: the PTS authorization covers securities venues only; no Chart Room category for a multilateral retail FX venue was identified. Electronic trading platforms for certain OTC derivatives exist under the FIEA but were not confirmed for FX.
- SEC No SEC category for an FX venue; spot FX is not a security. The SEC ATS and exchange categories cover securities only; FX futures venues are CFTC DCMs and FX swap/NDF venues are CFTC SEFs.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- FSC Mauritius No venue category is in this register: operating a multilateral market requires a Securities Exchange license from the FSC under the Securities Act 2005, which is not recorded here.
- CBB No investment-firm category covers running a multilateral venue; licensed exchanges are authorized under CBB Volume 6 (market operators), which is not in this register.
- NYDFS Not licensed by NYDFS; FX futures venues are CFTC DCMs and FX swap venues are CFTC SEFs.
- CMA UAE No CMA category for operating an OTC FX/CFD multilateral venue was identified in the data; exchange and platform licensing outside the virtual-asset Seventh Category is not covered, so confirm with the CMA.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A virtual-asset matching venue, including exchange-traded VA derivatives under the March 2026 Part V rules, is Exchange Services; fiat-currency matching is excluded.
- BMA No category for operating a multilateral FX trading venue is in the register; exchange recognition is outside these license types. Uncertain.
- QFCRA No category for operating a multilateral trading venue was identified in the QFCRA data; onshore exchange-traded markets fall under the QFMA.
- CIMA No category in this register for a multilateral FX/CFD venue; the Cayman Islands Stock Exchange is a separate listing exchange. Not confirmed whether operating a matching platform would need a SIBA license.
- CMA Saudi Not available: the Saudi Exchange (Tadawul) is the only licensed exchange and there is no OTC FX venue license.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Referral and arranging
Introducing broker
Brings clients to a licensed broker without executing trades or holding client money.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| CSSF#2 Luxembourg | Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | Type 3 approved introducing agent: HK$5 million paid-up and HK$3 million liquid capital; may not carry client positions or hold client assets. |
| FCA#5 United Kingdom | Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | USD 100 k | Own Part 4A permission for arranging deals / making arrangements without client money (GBP 75,000 PMR), or act as an appointed representative (including an introducer AR) of an authorized broker that accepts responsibility. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Typically a corporate authorized representative of the issuing licensee (no own capital requirement), or the firm's own AFSL with dealing (arranging) authorization; ASIC has scrutinized CAR use in OTC derivatives. |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | Uncertain: the SFA definition of dealing includes inducing a person to enter into a transaction, so an introducer soliciting Singapore clients generally needs its own CMS dealing license or must act through the licensee's notified representatives; MAS has no dedicated IB license. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Arranging Deals in Investments (Category 4), USD 50,000 base capital from 19 August 2025; no EBCM if no Client Assets are held. FSRA proposed barring authorized firms from accepting paid retail referrals from unregulated third parties, so IBs introducing retail clients should be FSRA-authorised. |
| Bank of Lithuania#11 Lithuania | Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band | USD 87 k | RTO / arranging without client money in the EUR 75,000 band. The financial advisor company license does not fit because it covers only transferable securities and fund units, not CFDs or FX derivatives. Tied-agent status under MiFID II Art. 29 is also possible but is not a category in this register. |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arrangerCategory 4 | USD 30 k | Arranging Deals in Investments (Category 4), USD 30,000 base capital after the 2026 amendments (secondary); no execution or client money. A Representative Office is not an option: since April 2015 the DFSA will not accept Representative Office applications from firms marketing FX or other highly leveraged products to retail clients. |
| MFSA#14 Malta | Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | RTO / advice without holding client money in the IFD Art. 9(2) band (EUR 75,000); orders must go to an authorized broker; the professional-only variant (legacy 1B) has the same capital. Tied-agent status is also possible under MiFID II Art. 29 but is not a category in this register. |
| CFTC · NFA#15 United States | Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | USD 45 k | Soliciting retail forex for an RFED/FCM without holding customer funds requires IB registration and NFA membership: independent IB with at least USD 45,000 adjusted net capital, or guaranteed IB with no capital requirement but introducing only to its guarantor. |
| CySEC#16 Cyprus | Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Introducing or arranging for clients is a FAIS intermediary service, so a Category I license (1.13/1.15) or appointment as a representative of a licensed FSP is needed; referral to offshore brokers while collecting local rand deposits has drawn SARB exchange-control action. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | Category 3 (arranging and advising, BD 25,000 plus liquid funds of 25% of prior-year operating expenses) only fits an IB paid by its clients, because Category 3 firms must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent; a rebate-funded IB therefore needs Category 2 (BD 250,000). |
| SCB Bahamas#21 The Bahamas | Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | Introducing clients to a dealer without dealing is arranging deals (USD 25,000 floor under the older formula); the CFD Rules also capture marketing CFDs in or from The Bahamas, so check with the SCB whether an introducer also needs CFD registration. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Uncertain: arranging FX transactions from Labuan falls within money broking (RM1 million); no lighter introducer category exists. An introducer based outside Labuan is governed by its own jurisdiction. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | Fifth Category introducing and promotion, AED 500,000 paid-up capital; may introduce UAE clients to an offshore or free-zone broker but may not hold client assets or execute. Most CFD brokers entering the UAE (XM, Exinity, Pepperstone and others) use this route. |
| BMA#27 Bermuda | Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | Arranging deals without dealing as agent or principal: standard license (neither agent nor principal), minimum net assets USD 12,000 plus one month's liquid assets. |
| QFCRA#28 Qatar · QFC | Investment adviser / arrangerAdvisory and arranging firm (INMA 2014) | USD 250 k | Arranging deals in investments (INMA advisory and arranging firm), base capital about USD 250,000 restated in QAR plus 13/52 of annual operating expenses; no client money. A December 2025 consultation may lower requirements for wholesale advisers. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | SIBA license for arranging deals in securities; CI$15,000 base financial resources plus professional indemnity insurance. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The FX regulations have no introducing-broker category; the Intermediary Service Platform provider category (LN 197 of 2025), granted to Safaricom and Airtel Money in December 2025 for onboarding and market access, is the closest fit, but its use for FX referral is unconfirmed, and offshore brokers may not serve Kenyan clients. |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | SIBA Category 2, arranging deals in investments, including introducing clients to dealers. |
Not available at 11 regulators
- FSA Japan Not a Chart Room category: an introducer registers as a Financial Instruments Intermediary Service Provider (FIEA Art. 66) tied to a Type I firm, or registers as Type I itself. Unregistered solicitation of Japanese residents is prohibited.
- FINMA No FINMA license for pure referral without handling client money or orders. A firm that transmits orders provides a FinSA financial service, so its client advisers must be in the FinSA adviser register unless the firm is supervised; AML SRO membership may apply if it acts as a financial intermediary. Uncertain.
- SEC Licensed by the CFTC/NFA, not the SEC: introducing retail forex accounts requires CFTC introducing broker registration and NFA membership; an SEC introducing broker-dealer status does not cover FX.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime. SAMA's 2017 circular prohibits marketing by foreign forex firms without a contract with a licensed Saudi institution.
- FSC Mauritius No dedicated introducing-broker category was found; whether pure referral is licensable is uncertain, and if the firm advises it needs Investment Adviser (Restricted), or if it receives and transmits orders, Investment Dealer (Broker).
- SEC Nigeria No category in force; the proposed rules would create Corporate Introducing Broker (NGN 150 million) and Individual Introducing Broker (NGN 30 million) registrations and would ban referral incentives. The existing Sub-Broker (Digital) category routes securities orders only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (CFTC introducing broker with NFA membership).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Arranging orders in virtual assets falls under Broker-Dealer Services.
- CMA Saudi No fit: Arranging covers securities only, and a 2017 SAMA circular prohibits foreign forex companies without contracts with licensed Saudi institutions from marketing in the Kingdom.
- FSA Seychelles No introducing-broker category exists in the register, and a secondary source reports no FSA restrictions on IBs; if the firm gives advice it needs an Investment Adviser license (USD 25,000). Treatment of a Seychelles-based referral business is uncertain.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022. Introducing to brokers is the CMA Fifth Category.
A brand on a host license
White label
Operates its own brand on another firm’s license and platform, often as its appointed representative.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | No tied-agent or appointed-representative regime: a Hong Kong-facing brand must be licensed itself, usually as a Type 3 introducing agent referring clients to the executing Type 3 firm. |
| FCA#5 United Kingdom | Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | — | Appointed representative of the principal broker under SUP 12; no separate license or capital, but the principal must notify the FCA 30 days ahead and oversee the AR, and the AR cannot deal as principal or hold client money. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Corporate authorized representative of the AFS licensee; no separate license, but the CAR cannot issue products in its own right and the licensee remains responsible. |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CFTC · NFA#15 United States | Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | No white-label license exists; a US-facing brand on another firm's platform must register itself, usually as a guaranteed IB of the RFED/FCM (closest equivalent to an appointed representative), since anyone soliciting retail forex must be registered. |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Most South African CFD brands hold their own FAIS Category I license and distribute a third-party ODP's products; alternatively the brand can operate as a juristic representative of a licensed FSP under the FAIS Act without its own license, with the FSP remaining responsible. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) | USD 13 k | No tied-agent or appointed-representative regime for corporate white labels was identified, so a white label serving clients from Mauritius generally needs its own Investment Dealer license, commonly the Discount Broker category on a partner's platform and liquidity. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | No tied-agent or appointed-representative regime was identified; a white-label brand marketing onshore needs at least a Fifth Category promotion license, and a First Category OTC license if it contracts with or executes for clients. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | Cayman has no appointed-representative or tied-agent regime, so a white label carrying on securities investment business from the Cayman Islands needs its own SIBA license, at least the arranging license if the partner broker is the counterparty. Not confirmed. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | No tied-agent or appointed-representative regime exists; a white label serving Kenyan clients needs its own CMA online FX license, typically non-dealing, held by a Kenyan-incorporated company, with a service level agreement with the platform provider (Reg. 4(2)(j)). |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | No tied-agent or appointed-representative regime was identified, so a white label dealing with clients from Seychelles needs its own Securities Dealer license (USD 100,000, local office and staff). |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | The BVI has no tied-agent or appointed-representative regime, so a BVI white label needs its own SIBA license: Category 2 if the partner broker deals with the clients, Category 1 if it deals itself. Not confirmed. |
Not available at 19 regulators
- FSA Japan No dedicated pathway: the brand must register itself (Type I) or act as a Financial Instruments Intermediary Service Provider tied to the registered firm; that intermediary status is not a Chart Room category.
- MAS No dedicated pathway: a brand must hold its own CMS license or act through the licensee's notified representatives; MAS has no appointed-representative regime for firms.
- FSRA No appointed-representative or tied-agent regime was identified for ADGM, so a white-label brand needs its own FSRA permission: Category 4 if it only arranges for the licensed broker, Category 2 or 3A if it deals or contracts with clients (confirm with the FSRA).
- FINMA Switzerland has no tied-agent or appointed-representative regime. A pure marketing brand of a licensed Swiss bank needs no license, but a white label that contracts with clients or holds their money needs its own bank or securities firm license.
- Bank of Lithuania No category in this register: a white label can run as a MiFID tied agent of the licensing broker (no separate license), otherwise it needs its own financial brokerage firm license.
- DFSA No appointed-representative or tied-agent route was identified in the DFSA regime, so a DIFC white-label brand needs its own license: Category 4 if it only markets and arranges for the principal broker, Category 2 or 3A if it contracts with clients or executes (confirm with the DFSA).
- SEC Licensed by the CFTC/NFA, not the SEC: the nearest US structure is a guaranteed IB of an RFED or FCM.
- MFSA No category in this register: a white label can run as a MiFID tied agent registered by its principal (no separate license), otherwise it needs its own Investment Services Licence.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- CBB Not confirmed: Category 3 firms are barred from acting as tied agents, implying a tied-agent concept, but the tied-agent regime was not researched; otherwise the brand needs its own Category 2 or Category 1 license depending on whether it deals as principal.
- SCB Bahamas No appointed-representative or tied-agent regime was found; a brand that deals in or markets CFDs in or from The Bahamas registers itself (CFD dealer, or arranging deals for a pure referral model). Uncertain: confirm with the SCB.
- SEC Nigeria No FX/CFD white-label route exists today; the proposed rules require brokers and technology providers to allocate compliance responsibility, and a separate Technology/Platform Provider registration at NGN 5 billion; no tied-agent regime for FX is proposed.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA; the nearest structure is a CFTC guaranteed IB.
- Labuan FSA No appointed-representative or white-label regime: the brand must hold its own money broking license, with substance in Labuan.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- BMA No appointed-representative or tied-agent route was identified; a Bermuda white-label operator needs its own standard license in the bucket matching its role. Class A registration is only for Bermuda-formed firms regulated by a recognized foreign regulator with no place of business in Bermuda.
- QFCRA No appointed-representative or tied-agent regime was identified; a white-label brand would need its own QFC authorization (arranging or dealing). Uncertain.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Prime-of-Prime
Liquidity provider / PoP
Deals as principal with brokers and institutions, redistributing prime liquidity; not retail.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions is Eigenhandel or own-account dealing in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Uncertain: principal dealing in leveraged FX with clients needs Type 3, but some dealings with banks and other professionals may fall under SFO exclusions or the LFET exemption rules; HKMA-authorized banks are exempt. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Uncertain: principal OTC derivatives dealing is Type I business, but certain transactions with financial institutions or qualified institutional investors may be excluded under the FIEA Enforcement Order; confirm before relying on an exclusion. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Dealing in investments as principal with brokers and institutions; GBP 750,000 PMR; this is the tier used for principal-model prime-of-prime and non-bank prime services. |
| ASIC#6 Australia | Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | AFSL limited to wholesale clients (s 761G) for dealing and market making in derivatives and FX; no fixed capital minimum beyond RG 166 base-level requirements; the usual route for prime-of-prime and liquidity providers. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Dealing as principal with brokers and institutions is a CMS dealing activity; base capital S$1 million for leveraged FX or OTC derivatives when serving only accredited, institutional or expert investors. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties (Category 2), USD 2 million base capital plus risk capital. |
| FINMA#10 Switzerland | Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | A securities firm license (own-account dealer or market maker, CHF 1.5 million) covers professional own-account dealing with institutions; banks also act as LPs under their bank license. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing as principal with brokers and institutions requires the EUR 750,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties only (no Retail Endorsement needed), USD 2 million base capital plus market and credit risk capital. |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing as principal with brokers and institutions needs the Art. 9(1) band (EUR 750,000); large firms may fall under CRR as Class 1 or Class 1 Minus. |
| CFTC · NFA#15 United States | Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | Dealing as principal in spot and deliverable FX forwards with eligible contract participants generally needs no CFTC registration; swap dealer registration (USD 20 million minimum capital) applies only if FX swaps such as NDFs or CFDs with ECPs exceed the de minimis threshold. Providing liquidity to an RFED or FCM does not by itself require RFED status. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | Dealing as principal in OTC derivatives with brokers and institutions is ODP activity under the FMA (trade-repository reporting and Joint Standard 2 of 2020 margin rules apply); no separate institutional-only category exists, and bank LPs rely on their Prudential Authority banking license. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Principal dealing with brokers and institutions fits the Full Service Dealer (excluding Underwriting) license (MUR 1,000,000); the Investment Dealer (Derivatives) category covers agency and exchange market making only and was not confirmed for an OTC principal book. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm dealing as principal with institutional counterparties, BD 1 million or risk-based capital; wholesale banks are the alternative. |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | USD 300 k | Dealing as principal in derivatives with brokers and institutions is dealing in capital markets instruments as principal (USD 300,000 floor under the older formula); add CFD registration where the instruments supplied are CFDs. |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | Uncertain: principal dealing in FX and derivatives with institutions fits a Labuan investment bank license (RM10 million paid-up capital, no deposit-taking); money brokers cannot act as principal. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Principal standard license (USD 250,000 minimum net assets); Class B registration excludes market intermediaries, so a liquidity provider cannot rely on it. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal with institutional and professional counterparties under BANK; base capital not confirmed. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4) | USD 122 k | Principal dealing with brokers and institutions needs the broker-dealer license; a firm dealing only with sophisticated or high-net-worth persons (entities with USD 5 million or more in assets) may register as a SIBA registered person instead, with no stated capital. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Principal dealing with brokers and institutions falls under the Securities Dealer license (USD 100,000); there is no separate institutional category. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Dealing in investments as principal with brokers and institutions, Category 1(b); the FSC sets capital case by case. |
Not available at 9 regulators
- SEC Not an SEC matter for FX: spot and deliverable forward FX dealing between eligible contract participants is largely outside registration, and NDFs and other FX swaps fall under the CFTC (swap dealer above the de minimis threshold).
- SAMA Interbank FX is dealt by SAMA-licensed banks; no separate non-bank FX liquidity license exists. A money changer license covers spot cash currency exchange only.
- SEC Nigeria No SEC category for FX/CFD liquidity provision; FX dealing as principal is the domain of CBN-licensed banks and authorized dealers, and the proposed rules do not mention liquidity providers.
- NYDFS Not licensed by NYDFS; FX dealing with institutions is largely outside registration or falls under CFTC swap dealer rules. A New York state-chartered bank conducts FX dealing under its banking charter, which is not a practical brokerage route.
- CMA UAE No wholesale-only principal dealing category for OTC FX was identified; the 'financial products dealer' activity under First Category may be relevant but its scope for OTC FX was not confirmed. Onshore interbank FX liquidity comes from CBUAE-licensed banks.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A VA OTC liquidity desk would need Broker-Dealer Services.
- CMA Kenya No CMA category covers institutional-only FX/CFD principal dealing; Kenyan dealing brokers hedge with offshore LPs or banks, and interbank FX dealing is done by CBK-licensed banks. Uncertain.
- CMA Saudi Not a CMA activity; interbank FX dealing is done by SAMA-licensed banks.
- CBUAE No non-bank FX dealing license exists at the CBUAE; interbank FX liquidity is provided by licensed banks (Licensed Bank at AED 2 billion or Restricted Licence Bank at AED 1 billion), which is not a practical route for a liquidity-provider start-up.
Every fitting category
54 categories at 30 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary |
| Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assets Financial brokerage firm - EUR 150,000 band | USD 174 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Portfolio manager / agency broker Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | USD 87 k | USD 5 k | USD 5 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary |
| Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Matched-principal / agency broker Category 3A | USD 500 k | USD 40 k | USD 50 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary | |
| CBB#20 Bahrain | Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook |
| Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook | |
| CMA UAE#25 UAE · Federal | Securities broker / dealer First Category – Dealing in Securities (trading broker, trading and clearing broker, international markets broker, financial products dealer) | USD 8.17 m | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Principal dealer / broker Investment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Dealing / brokerage Dealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1)) | USD 13.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | Carrying / clearing broker-dealer Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)) | USD 250 k | USD 8 k | USD 1 k | Retail | Rulebook |
| Introducing broker-dealer (receiving) Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)) | USD 50 k | USD 8 k | USD 1 k | Retail | Rulebook | |
| CFTC · NFA#15 United States | FCM Futures commission merchant (CEA s.4d; Regulation 1.17) | USD 1 m | USD 2 k | USD 2 k | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent) Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) | USD 300 k | USD 16 k | USD 8 k | Retail | To confirm |
| Securities dealer (agent only) Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024) | USD 120 k | USD 16 k | USD 8 k | Retail | To confirm | |
| BMA#27 Bermuda | Investment dealer (principal) Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Investment broker (agent) Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Agency broker SIBA Category 1, sub-category (a): Dealing in investments as agent | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Securities introducing agent / trader Type 1 – Dealing in securities (approved introducing agent or trader) | USD 64 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| Futures dealer Type 2 – Dealing in futures contracts (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| Futures introducing agent / non-clearing dealer Type 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer) | USD 64 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Wholesale-only AFSL AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | USD 1 k | — | Professional only | Rulebook |
| MAS#8 Singapore | Securities and exchange-traded derivatives dealer CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives) | USD 39 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| OTC derivatives / CFD dealer CMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Leveraged FX dealer CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Commodity futures broker CMS license: Dealing in capital markets products (specified commodity futures) | USD 195 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX) Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | USD 500 (nominal) | USD 6 k | Professional only | Rulebook |
| Securities licensee Labuan securities licensee (LFSSA s. 55; Islamic under LIFSSA) | USD 35 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | OTC derivative provider Authorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | USD 3 k | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | Full-service dealer with underwriting Investment Dealer (Full Service Dealer, including Underwriting) | USD 217 k | USD 3 k | USD 10 k | Retail | Rulebook |
| Full-service dealer Investment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | USD 1 k | USD 3 k | Retail | Rulebook | |
| Broker Investment Dealer (Broker) | USD 15 k | USD 700 (nominal) | USD 3 k | Retail | Rulebook | |
| Derivatives dealer Investment Dealer (Derivatives) | USD 22 k | USD 1 k | USD 3 k | Retail, with conditions | Rulebook | |
| SEC Nigeria#22 Nigeria | Broker Broker (client execution only) | USD 400 k | — | — | Retail | Rulebook |
| Broker-dealer Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services) | USD 1.33 m | USD 4 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Stockbroker Stockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025) | USD 388 k | USD 853 (nominal) | USD 775 (nominal) | Retail | Secondary |
| Broker-dealer Broker-Dealer (new hybrid category, LN 197 of 2025) | USD 543 k | USD 2 k | USD 2 k | Retail | Secondary | |
| FSA Seychelles#32 Seychelles | Securities dealer Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | USD 3 k | USD 6 k | Retail | Rulebook |
Prime Brokerage
Credit, clearing and custody for institutional trading clients. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators17 of 34
Lowest capitalUSD 39 kMAS
Median capitalUSD 998 k
Retail clients allowed17 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities dealer
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 998 k
MAS
USD 39 k
SECUSD 250 k
FSA JapanUSD 335 k
SFCUSD 642 k
BaFinUSD 870 k
CSSFUSD 870 k
CBI IrelandUSD 870 k
CySECUSD 870 k
FCAUSD 998 k
CFTC · NFAUSD 1 m
FSRAUSD 2 m
DFSAUSD 2 m
Bank of LithuaniaUSD 5.8 m
MFSAUSD 5.8 m
ASICUSD 7 m
FINMAUSD 12.5 m
CMA UAEUSD 13.61 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
27 categories at 17 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| Bank Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 5.8 m | USD 37 k | USD 3 k | Retail | Rulebook | |
| CBI Ireland#7 Ireland | Bank Credit institution (bank license under Section 9 of the Central Bank Act 1971) | USD 5.8 m | — | USD 339 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| CMA UAE#25 UAE · Federal | Custodian / clearing member Third Category – Custody, Clearing and Registration | USD 13.61 m | — | — | Retail, with conditions | Rulebook |
| Americas | ||||||
| SEC#13 United States | Carrying / clearing broker-dealer Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)) | USD 250 k | USD 8 k | USD 1 k | Retail | Rulebook |
| CFTC · NFA#15 United States | FCM Futures commission merchant (CEA s.4d; Regulation 1.17) | USD 1 m | USD 2 k | USD 2 k | Retail | Rulebook |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Futures dealer Type 2 – Dealing in futures contracts (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| Securities margin financier Type 8 – Securities margin financing | USD 1.28 m | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| OTC derivatives client clearer Type 12 – Providing client clearing services for OTC derivative transactions | — | USD 609 (nominal) | USD 609 (nominal) | Professional only | To confirm | |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Custodian AFSL – provide custodial or depository services (non-incidental) | USD 7 m | USD 2 k | USD 836 (nominal) | Retail | Rulebook |
| MAS#8 Singapore | Securities and exchange-traded derivatives dealer CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives) | USD 39 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| Custodian CMS license: Providing custodial services | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Margin / product financier CMS license: Product financing | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
Not licensed by: VARA, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, NYDFS, CIMA, BVI FSC, BMA, SCB Bahamas, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Prime-of-Prime
Prime liquidity and credit redistributed to brokers and institutions. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators23 of 34
Lowest capitalUSD 22 kFSC Mauritius
Median capitalUSD 870 k
Retail clients allowed22 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Leveraged FX dealer
- Capital
- USD 3.85 m
- Fees at start
- USD 17 k
- Every year
- USD 17 k
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 870 k
FSC Mauritius
USD 22 k
FSA SeychellesUSD 100 k
CIMAUSD 122 k
BMAUSD 250 k
SCB BahamasUSD 300 k
FSA JapanUSD 335 k
MASUSD 390 k
BaFinUSD 870 k
CSSFUSD 870 k
CBI IrelandUSD 870 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
CySECUSD 870 k
FCAUSD 998 k
FINMAUSD 1.88 m
FSRAUSD 2 m
DFSAUSD 2 m
CBBUSD 2.66 m
SFCUSD 3.85 m
CMA UAEUSD 8.17 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Forex brokerage
Seven ways to run a forex broker
Each model asks for a different permission. Choose a model to see, at every regulator, the category to apply for and what it requires. A model is counted wherever any category permits it, so a count can exceed the regulators mapped to the system above.
B-book · dealing desk
Market maker
The broker takes the other side of each client trade and carries the market risk on its own book.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Proprietary trading for others (Eigenhandel) / dealing on own account; EUR 750,000 initial capital (Section 17(1) no. 1 WpIG) plus IFR own funds; BaFin's CFD general administrative act applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 leveraged foreign exchange trading (general case): HK$30 million paid-up capital and HK$15 million liquid capital, two responsible officers; CFDs on securities need Type 1 instead. Very few new Type 3 licenses are granted.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I Financial Instruments Business registration covers OTC derivatives including retail FX and CFDs; stock company with board, JPY 50 million stated capital and net assets, capital adequacy ratio of at least 120%, FFAJ membership effectively required.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Part 4A permission for dealing in investments as principal; GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4) plus fixed overheads and K-factor tests; this is the standard license for market-making FX/CFD brokers; COBS 22.5 applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | AFSL authorizations to deal in and make a market in derivatives and FX contracts for retail clients (issuer of retail OTC derivatives); NTA of the greater of AUD 1 million or 10% of average revenue, half in cash (Instrument 2022/705, RG 166).Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | CMS license for dealing in capital markets products: spot FX for leveraged FX trading and, for CFDs on other underlyings, OTC derivatives; base capital S$5 million each where any retail customer is served, plus risk-based capital (Notice SFA 04-N13).Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (not as Matched Principal) in Category 2, USD 2 million base capital plus risk capital; FSRA lists market-maker CFD/FX brokers here.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | In practice Swiss retail FX/CFD market makers hold a bank license (CHF 10 million minimum capital), because FINMA has treated client margin balances held by non-banks as public deposits since about 2009; a securities firm license (CHF 1.5 million, own-account dealing and market making) may suffice only if client balances qualify as settlement accounts. Unconfirmed: confirm with FINMA.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing on own account in the EUR 750,000 band (Law on Markets in Financial Instruments Art. 14); market-maker and CFD principal models require this band; ESMA-derived retail CFD caps apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (Category 2), USD 2 million base capital plus risk capital; a Retail Endorsement is needed to deal with retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing on own account under an Investment Services Licence in the IFD Art. 9(1) band; EUR 750,000 initial capital plus recovery and resolution rules; CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Acting as counterparty to retail off-exchange forex requires RFED registration (or FCM status with retail forex) and NFA Forex Dealer Member status, with adjusted net capital of at least USD 20 million plus 5% of retail forex obligations above USD 10 million.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Issuing CFDs/rolling spot FX as principal requires ODP authorization under the Financial Markets Act 2012 (no fixed rand capital; about 6 months of liquid net assets per practitioner summaries, with bank-like capital rules for non-bank ODPs signalled in 2025), and retail distribution also needs a FAIS Category I license with subcategories 1.13/1.15 (own or a partner FSP).Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Dealing as principal for resale to clients falls under the Investment Dealer (Full Service Dealer, excluding Underwriting) license, MUR 1,000,000 stated unimpaired capital, PI cover, compliance officer and MLRO, and GBC substance if held through a GBC.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm (dealing in financial instruments as principal), BD 1 million minimum capital or the higher risk-based requirement; this is the CBB route for market-making brokers.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Dealing in FX and other CFDs as principal requires CFD registration under the Securities Industry (Contracts for Differences) Rules, 2020, either as a CFD-only firm or alongside dealing registration; capital is a Commission formula (r.13), with a USD 1,000,000 bank-deposit floor proposed in the 2026 draft amendment (not final as of October 2026), and a resident CFD Supervisory Officer.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; market-maker CFD brokers (e.g. Plus500, XTB, Deriv) hold this license, but the rulebook text read did not state expressly whether dealing as principal is permitted, so confirm with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Investment Business Act standard license as a principal investment provider, minimum net assets USD 250,000 (or 8% of risk-weighted assets) plus liquid assets of three months' expenditure.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal, prudentially regulated under BANK (base capital not confirmed); retail FX/CFD brokerage is not an established QFC model, so this is realistic only for business and professional clients.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | SIBA license for dealing in securities and market making; base financial resource requirement CI$100,000 (higher of that and a quarter of annual expenditure plus risk requirements), professional indemnity cover of CI$1 million per claim, monthly financial statements; retail FX/CFD brokers use this license.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | A Dealing Online Foreign Exchange Broker trades as principal and market maker (Reg. 2, Online FX Trading Regulations 2017); KES 50 million paid-up capital, liquid capital of the higher of KES 30 million or 8% of liabilities, Kenyan-incorporated company.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The Securities Dealer license covers dealing in securities including CFDs and FX as principal (B-book); USD 100,000 paid-up capital since the Securities (Amendment) Act 2024, physical office, two natural-person directors, licensed representative and compliance officer.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | SIBA Category 1(b), dealing as principal including taking the other side of client trades; no fixed minimum capital, as the FSC sets financial resources case by case under Regulatory Code s. 181 (advisers budget about USD 1 million) and expects more for principal dealing.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: a retail FX counterparty must be an RFED or an FCM. SEC broker-dealer dealer status covers securities only, and CFDs on US securities (security-based swaps) cannot be offered off-exchange to non-ECP retail clients.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No SEC category for retail FX/CFD market making is currently in force; SEC proposed rules of 1 September 2026 would create a B-book/market-making forex broker registration at NGN 3 billion paid-up capital, and FX itself is under CBN control.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM). No NYDFS category covers acting as counterparty to FX or CFD trades.
- Labuan FSA Not permitted: Labuan money brokers may not act as principal (Money Broking Guidelines, 9 September 2024), and retail FX/CFD brokerage is not available in Labuan. A Labuan investment bank (RM10 million) may deal FX as principal but only with institutional clients, not as a retail B-book.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A principal desk dealing only in virtual assets would need Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book · no dealing desk
STP / agency
Orders pass straight through to liquidity providers; the broker acts as agent or matched principal and keeps no market risk.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 covers both dealing-desk and STP brokers (the SFC's review found most Type 3 firms hedge back-to-back with liquidity providers); same HK$30 million paid-up capital; disclose any affiliate liquidity provider in the execution policy.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Brokerage or intermediation of OTC FX derivatives is also Type I business, so an STP broker needs the same registration and JPY 50 million capital.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 200 k | Agency execution / arranging with permission to hold client money (CASS) is the GBP 150,000 tier; a matched-principal STP model is dealing as principal and generally needs the GBP 750,000 permission (we did not confirm whether MIFIDPRU 4.4 gives matched-principal firms a lower PMR).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | An Australian STP broker is still the issuer of the OTC derivative to its retail client, so it needs the same issuer and market-making authorizations and AUD 1 million NTA as a market maker.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | The CMS dealing license covers dealing as principal or agent, so an STP broker needs the same license and S$5 million base capital for retail clients; no lighter agency-only FX category exists.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency brokerCategory 3A | USD 500 k | Dealing in Investments as Agent or as Matched Principal (Category 3A), USD 500,000 base capital, rising to USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | An agency broker that keeps client accounts needs a bank or securities firm license (securities firm keeping client accounts, CHF 1.5 million); which one applies to OTC FX/CFD balances was not confirmed. A firm that only forwards orders to a licensed bank without holding money needs no FINMA license (see introducing broker).Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 174 k | Agency execution holding client money is in the EUR 150,000 band; a matched-principal STP model is dealing on own account and needs the EUR 750,000 band.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A Principal dealer / credit providerCategory 2 | USD 200 k | Pure agency (Dealing in Investments as Agent) is Category 3A at USD 200,000 base capital after the CP161 reforms (secondary); since the 2025 PIB amendments, matched-principal A-book dealing sits in Category 2 (USD 2 million; a lower matched-principal figure is reported but unconfirmed).Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 87 k | Agency execution / RTO holding client money is the IFD Art. 9(3) band (EUR 150,000); a matched-principal STP model counts as dealing on own account and needs the Art. 9(1) band (EUR 750,000).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Only an RFED or FCM may accept retail forex orders and funds, so an STP broker that hedges back-to-back with liquidity providers still registers as an RFED/FCM and holds the USD 20 million minimum; there is no lighter agency-only category for retail forex.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | A pure agent passing orders to a third-party issuer needs FAIS Category I (1.13 derivatives, 1.15 forex investment business); a matched-principal STP that is itself the client's counterparty on the CFD still needs ODP authorization, since FAIS does not permit issuing OTC derivatives.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) BrokerInvestment Dealer (Broker) | USD 13 k | Agency-only order routing to a third-party LP fits the Discount Broker (execution-only, MUR 600,000) or Broker (with advice/portfolio management, MUR 700,000) categories; a matched-principal STP that is counterparty to the client should take the Full Service Dealer license instead.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | Category 2 investment firm (all services except dealing as principal, including agency dealing and holding client money), BD 250,000 minimum capital. Whether CBB treats riskless matched-principal as principal dealing (Category 1) was not confirmed.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | The CFD Rules cover dealing in, providing or marketing CFDs in or from The Bahamas regardless of hedging model, so an STP broker also registers as a CFD dealer; same capital and resident-officer conditions as a market maker.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Labuan money broking license (arranging FX and money market deals only), RM1 million paid-up capital; clients limited to institutional investors and high-net-worth individuals, non-residents of Malaysia only, operational office in Labuan.Retail leverage No retail FX/CFD offering permitted. For eligible institutional and high-net-worth clients of money brokers, maximum leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards (Money Broking Guidelines, 9 September 2024). |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; covers brokerage of OTC derivatives and spot FX for onshore clients, including retail.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | Standard license acting as agent, minimum net assets USD 100,000 plus three months' liquid assets; a matched-principal model may fall in the principal bucket, so confirm with the BMA.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Agency dealing is listed within this category's permits; whether a pure agency broker is placed under BANK or INMA was not confirmed, and retail FX/CFD is not an established QFC model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Dealing as agent is also covered by the broker-dealer SIBA license, with the same CI$100,000 base financial resources.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | A Non-Dealing Online Foreign Exchange Broker links clients to the FX market for commission or mark-up and does not make markets (Reg. 2); KES 30 million paid-up capital, same liquid-capital test.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The same Securities Dealer license covers dealing as agent; there is no lower agency-only category, so the USD 100,000 capital applies.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Category 1(a) for agency execution; a matched-principal STP model is principal dealing and falls under 1(b). Category 2 (arranging) is commonly added.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 7 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: retail forex orders can be accepted only by an FCM or RFED, whatever the execution model.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria Not yet licensable; the proposed rules (1 September 2026) would create an STP/ECN/A-book broker registration at NGN 2 billion paid-up capital, and the existing Broker category covers securities only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Agency or matched-principal brokerage of virtual assets is Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book and B-book
Hybrid
Part of the flow is internalized and part passed on; the license must allow dealing as principal.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 general case, as for a market maker; the client agreement must state whether the firm takes the opposite side of client trades.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I registration as for a market maker; mandatory loss-cut rules and trust segregation of client margin apply.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Internalizing any client flow requires the dealing-as-principal permission and the GBP 750,000 PMR; CASS client-money permission is also needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | Same retail OTC derivatives issuer AFSL as a market maker; AUD 1 million NTA.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Same CMS dealing license as a market maker, with S$5 million base capital for retail; conflict management and execution policy apply.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Keeping any B-book risk is dealing as principal, so Category 2 (USD 2 million plus risk capital).Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | Same as the market maker: internalizing flow is own-account dealing; established Swiss practice is a bank license.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Internalizing any client flow is dealing on own account, so the EUR 750,000 band is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Internalizing any flow is dealing as principal, so Category 2 (USD 2 million plus risk capital), with a Retail Endorsement for retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Internalizing any client flow is dealing on own account, so the Art. 9(1) band (EUR 750,000) is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Internalizing any retail flow is acting as counterparty, so RFED or FCM registration with USD 20 million minimum adjusted net capital is required.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Internalising any flow means acting as principal on OTC derivatives, so ODP authorization is needed, plus FAIS Category I for retail distribution.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Any internalization is principal dealing, so the Full Service Dealer (excluding Underwriting) license is needed (MUR 1,000,000).Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Internalizing any flow is dealing as principal, so Category 1 (BD 1 million or risk-based capital).Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Same CFD dealer registration as a market maker; disclose the internalization policy and conflicts in the order execution policy.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | Same First Category OTC license (AED 30 million) as the market-maker model; principal-dealing scope to be confirmed with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Any internalized flow means dealing as principal: principal standard license, USD 250,000 minimum net assets.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Principal dealing under BANK, with the same retail limitation as the market-maker model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Broker-dealer / market maker SIBA license covers both principal and agency flow.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | Any internalization is market making, so the Dealing Online Foreign Exchange Broker license (KES 50 million) is needed.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Covered by the Securities Dealer license, which permits both agency and principal dealing (USD 100,000).Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent | — | Principal dealing (1(b)) for internalized flow plus agency dealing (1(a)) for passed-through flow.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC (RFED or FCM counterparty status).
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No category in force; under the proposed rules a hybrid would need the market-making (B-book) broker registration at NGN 3 billion.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- Labuan FSA Not permitted: internalizing flow requires principal dealing, which money brokers are prohibited from doing.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Multilateral matching
ECN / MTF venue
A venue where many participants’ orders meet; licensed as an exchange, MTF or OTF, not as a broker.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| SFC#3 Hong Kong | Automated trading venueType 7 – Providing automated trading services | USD 642 k | Uncertain: Type 7 automated trading services (HK$5 million paid-up capital) covers electronic venues for securities and futures contracts; whether a multilateral leveraged-FX venue falls under Type 7 or Type 3 was not confirmed. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | Operating an MTF without own-account dealing is in the GBP 150,000 tier (an OTF with own-account dealing needs GBP 750,000); a recognized investment exchange is a heavier, separate route, and most new venues start as MTFs. |
| ASIC#6 Australia | Licensed market operatorAustralian market license (Corporations Act Part 7.2) | — | A multilateral venue is a financial market requiring an Australian market license (Part 7.2), unless exempt; no fixed capital, adequate resources required (s 792A). |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| MAS#8 Singapore | Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | A multilateral trading venue is an organized market operated as a Recognised Market Operator (higher of S$250,000 or 25% of annual operating expenses for a Singapore RMO). Uncertain: whether a spot FX matching venue counts as an organized market was not confirmed. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Operating an MTF or OTF is a Category 4 activity (USD 50,000 base capital), but MTF/OTF operators remain subject to the Expenditure-Based Capital Minimum and FSRA market-operator requirements; a virtual-asset MTF is a separate category. |
| FINMA#10 Switzerland | Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | A stock exchange or MTF license (CHF 1 million minimum, FinMIO Art. 13) covers multilateral trading of securities; spot FX is not a security under FinMIA, so an FX-only matching venue may fall outside it. Uncertain. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band | USD 174 k | Operating an MTF falls in the EUR 150,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A | USD 200 k | Operating an Alternative Trading System (DIFC term for MTF/OTF) moved from Category 4 to Category 3A under the 2025 PIB amendments; ATS operators must also meet the AMI/ATS market-integrity rules (effective date of the move reported as July 2025 or July 2026 by different advisers). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Operating a trading facility is listed only under the Art. 9(1) license scope, but since the September 2025 amendment (Part BI R1-5.1.2) an MTF operator that does not deal on own account has EUR 150,000 initial capital; confirm the license scope with the MFSA. |
| CFTC · NFA#15 United States | DCM (futures exchange)Designated contract market (CEA s.5; Part 38) SEFSwap execution facility (CEA s.5h; Part 37) | — | Off-exchange retail forex cannot be run as a multilateral venue for non-ECP retail clients: an FX futures venue is a DCM (retail access via FCMs) and an FX swap/NDF venue is a SEF (ECPs only); institutional spot FX ECNs fall largely outside CFTC registration. Both need financial resources covering one year of operating costs. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| FSCA#17 South Africa | Licensed exchangeExchange license, Financial Markets Act 2012 | — | A multilateral venue for securities including derivative instruments must be a licensed exchange under the FMA 2012 (liquid net assets of at least 6 months' operating expenses, reg. 8 of GN R98); no MTF-style lighter category exists, and whether an OTC FX matching venue falls inside the exchange definition should be confirmed with counsel. |
| SCB Bahamas#21 The Bahamas | MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | A multilateral venue for capital markets instruments is registered as a marketplace under the Securities Industry Act, 2024, with SCB-approved rulebook and systems and capital set case by case; no FX-specific venue category exists. |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite)Non-Composite Securities Exchange | USD 3.33 m | Only an exchange-traded venue (e.g. FX derivatives on a securities exchange such as FMDQ) is licensable today, as a Non-Composite Securities Exchange at NGN 5 billion; an OTC FX/CFD matching venue has no category and would also need CBN involvement. Uncertain. |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB) | — | Uncertain: a multilateral venue would need Labuan exchange approval (LFSSA s.134) with capital set case by case; no FX-specific venue guideline was found. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The 2017 FX regulations have no venue category; the OTC Platform provider category under LN 197 of 2025 is the closest fit for a multilateral OTC venue, but its capital and whether it extends to online FX/CFDs are unconfirmed. |
| FSA Seychelles#32 Seychelles | Securities exchangeSecurities Exchange license (Securities Act 2007) | — | A multilateral venue would need a Securities Exchange license (sole activity, at least three independent dealer members, clearing, surveillance and compensation arrangements); whether the FSA would treat an OTC FX/CFD matching venue this way is uncertain. |
| BVI FSC#34 British Virgin Islands | Investment exchangeSIBA Category 7: Operating an investment exchange | — | Category 7 covers providing a facility for orderly trading of investments; whether an FX/CFD matching venue fits was not confirmed, so check with the FSC. |
Not available at 13 regulators
- FSA Japan Uncertain: the PTS authorization covers securities venues only; no Chart Room category for a multilateral retail FX venue was identified. Electronic trading platforms for certain OTC derivatives exist under the FIEA but were not confirmed for FX.
- SEC No SEC category for an FX venue; spot FX is not a security. The SEC ATS and exchange categories cover securities only; FX futures venues are CFTC DCMs and FX swap/NDF venues are CFTC SEFs.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- FSC Mauritius No venue category is in this register: operating a multilateral market requires a Securities Exchange license from the FSC under the Securities Act 2005, which is not recorded here.
- CBB No investment-firm category covers running a multilateral venue; licensed exchanges are authorized under CBB Volume 6 (market operators), which is not in this register.
- NYDFS Not licensed by NYDFS; FX futures venues are CFTC DCMs and FX swap venues are CFTC SEFs.
- CMA UAE No CMA category for operating an OTC FX/CFD multilateral venue was identified in the data; exchange and platform licensing outside the virtual-asset Seventh Category is not covered, so confirm with the CMA.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A virtual-asset matching venue, including exchange-traded VA derivatives under the March 2026 Part V rules, is Exchange Services; fiat-currency matching is excluded.
- BMA No category for operating a multilateral FX trading venue is in the register; exchange recognition is outside these license types. Uncertain.
- QFCRA No category for operating a multilateral trading venue was identified in the QFCRA data; onshore exchange-traded markets fall under the QFMA.
- CIMA No category in this register for a multilateral FX/CFD venue; the Cayman Islands Stock Exchange is a separate listing exchange. Not confirmed whether operating a matching platform would need a SIBA license.
- CMA Saudi Not available: the Saudi Exchange (Tadawul) is the only licensed exchange and there is no OTC FX venue license.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Referral and arranging
Introducing broker
Brings clients to a licensed broker without executing trades or holding client money.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| CSSF#2 Luxembourg | Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | Type 3 approved introducing agent: HK$5 million paid-up and HK$3 million liquid capital; may not carry client positions or hold client assets. |
| FCA#5 United Kingdom | Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | USD 100 k | Own Part 4A permission for arranging deals / making arrangements without client money (GBP 75,000 PMR), or act as an appointed representative (including an introducer AR) of an authorized broker that accepts responsibility. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Typically a corporate authorized representative of the issuing licensee (no own capital requirement), or the firm's own AFSL with dealing (arranging) authorization; ASIC has scrutinized CAR use in OTC derivatives. |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | Uncertain: the SFA definition of dealing includes inducing a person to enter into a transaction, so an introducer soliciting Singapore clients generally needs its own CMS dealing license or must act through the licensee's notified representatives; MAS has no dedicated IB license. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Arranging Deals in Investments (Category 4), USD 50,000 base capital from 19 August 2025; no EBCM if no Client Assets are held. FSRA proposed barring authorized firms from accepting paid retail referrals from unregulated third parties, so IBs introducing retail clients should be FSRA-authorised. |
| Bank of Lithuania#11 Lithuania | Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band | USD 87 k | RTO / arranging without client money in the EUR 75,000 band. The financial advisor company license does not fit because it covers only transferable securities and fund units, not CFDs or FX derivatives. Tied-agent status under MiFID II Art. 29 is also possible but is not a category in this register. |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arrangerCategory 4 | USD 30 k | Arranging Deals in Investments (Category 4), USD 30,000 base capital after the 2026 amendments (secondary); no execution or client money. A Representative Office is not an option: since April 2015 the DFSA will not accept Representative Office applications from firms marketing FX or other highly leveraged products to retail clients. |
| MFSA#14 Malta | Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | RTO / advice without holding client money in the IFD Art. 9(2) band (EUR 75,000); orders must go to an authorized broker; the professional-only variant (legacy 1B) has the same capital. Tied-agent status is also possible under MiFID II Art. 29 but is not a category in this register. |
| CFTC · NFA#15 United States | Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | USD 45 k | Soliciting retail forex for an RFED/FCM without holding customer funds requires IB registration and NFA membership: independent IB with at least USD 45,000 adjusted net capital, or guaranteed IB with no capital requirement but introducing only to its guarantor. |
| CySEC#16 Cyprus | Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Introducing or arranging for clients is a FAIS intermediary service, so a Category I license (1.13/1.15) or appointment as a representative of a licensed FSP is needed; referral to offshore brokers while collecting local rand deposits has drawn SARB exchange-control action. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | Category 3 (arranging and advising, BD 25,000 plus liquid funds of 25% of prior-year operating expenses) only fits an IB paid by its clients, because Category 3 firms must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent; a rebate-funded IB therefore needs Category 2 (BD 250,000). |
| SCB Bahamas#21 The Bahamas | Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | Introducing clients to a dealer without dealing is arranging deals (USD 25,000 floor under the older formula); the CFD Rules also capture marketing CFDs in or from The Bahamas, so check with the SCB whether an introducer also needs CFD registration. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Uncertain: arranging FX transactions from Labuan falls within money broking (RM1 million); no lighter introducer category exists. An introducer based outside Labuan is governed by its own jurisdiction. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | Fifth Category introducing and promotion, AED 500,000 paid-up capital; may introduce UAE clients to an offshore or free-zone broker but may not hold client assets or execute. Most CFD brokers entering the UAE (XM, Exinity, Pepperstone and others) use this route. |
| BMA#27 Bermuda | Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | Arranging deals without dealing as agent or principal: standard license (neither agent nor principal), minimum net assets USD 12,000 plus one month's liquid assets. |
| QFCRA#28 Qatar · QFC | Investment adviser / arrangerAdvisory and arranging firm (INMA 2014) | USD 250 k | Arranging deals in investments (INMA advisory and arranging firm), base capital about USD 250,000 restated in QAR plus 13/52 of annual operating expenses; no client money. A December 2025 consultation may lower requirements for wholesale advisers. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | SIBA license for arranging deals in securities; CI$15,000 base financial resources plus professional indemnity insurance. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The FX regulations have no introducing-broker category; the Intermediary Service Platform provider category (LN 197 of 2025), granted to Safaricom and Airtel Money in December 2025 for onboarding and market access, is the closest fit, but its use for FX referral is unconfirmed, and offshore brokers may not serve Kenyan clients. |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | SIBA Category 2, arranging deals in investments, including introducing clients to dealers. |
Not available at 11 regulators
- FSA Japan Not a Chart Room category: an introducer registers as a Financial Instruments Intermediary Service Provider (FIEA Art. 66) tied to a Type I firm, or registers as Type I itself. Unregistered solicitation of Japanese residents is prohibited.
- FINMA No FINMA license for pure referral without handling client money or orders. A firm that transmits orders provides a FinSA financial service, so its client advisers must be in the FinSA adviser register unless the firm is supervised; AML SRO membership may apply if it acts as a financial intermediary. Uncertain.
- SEC Licensed by the CFTC/NFA, not the SEC: introducing retail forex accounts requires CFTC introducing broker registration and NFA membership; an SEC introducing broker-dealer status does not cover FX.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime. SAMA's 2017 circular prohibits marketing by foreign forex firms without a contract with a licensed Saudi institution.
- FSC Mauritius No dedicated introducing-broker category was found; whether pure referral is licensable is uncertain, and if the firm advises it needs Investment Adviser (Restricted), or if it receives and transmits orders, Investment Dealer (Broker).
- SEC Nigeria No category in force; the proposed rules would create Corporate Introducing Broker (NGN 150 million) and Individual Introducing Broker (NGN 30 million) registrations and would ban referral incentives. The existing Sub-Broker (Digital) category routes securities orders only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (CFTC introducing broker with NFA membership).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Arranging orders in virtual assets falls under Broker-Dealer Services.
- CMA Saudi No fit: Arranging covers securities only, and a 2017 SAMA circular prohibits foreign forex companies without contracts with licensed Saudi institutions from marketing in the Kingdom.
- FSA Seychelles No introducing-broker category exists in the register, and a secondary source reports no FSA restrictions on IBs; if the firm gives advice it needs an Investment Adviser license (USD 25,000). Treatment of a Seychelles-based referral business is uncertain.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022. Introducing to brokers is the CMA Fifth Category.
A brand on a host license
White label
Operates its own brand on another firm’s license and platform, often as its appointed representative.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | No tied-agent or appointed-representative regime: a Hong Kong-facing brand must be licensed itself, usually as a Type 3 introducing agent referring clients to the executing Type 3 firm. |
| FCA#5 United Kingdom | Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | — | Appointed representative of the principal broker under SUP 12; no separate license or capital, but the principal must notify the FCA 30 days ahead and oversee the AR, and the AR cannot deal as principal or hold client money. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Corporate authorized representative of the AFS licensee; no separate license, but the CAR cannot issue products in its own right and the licensee remains responsible. |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CFTC · NFA#15 United States | Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | No white-label license exists; a US-facing brand on another firm's platform must register itself, usually as a guaranteed IB of the RFED/FCM (closest equivalent to an appointed representative), since anyone soliciting retail forex must be registered. |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Most South African CFD brands hold their own FAIS Category I license and distribute a third-party ODP's products; alternatively the brand can operate as a juristic representative of a licensed FSP under the FAIS Act without its own license, with the FSP remaining responsible. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) | USD 13 k | No tied-agent or appointed-representative regime for corporate white labels was identified, so a white label serving clients from Mauritius generally needs its own Investment Dealer license, commonly the Discount Broker category on a partner's platform and liquidity. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | No tied-agent or appointed-representative regime was identified; a white-label brand marketing onshore needs at least a Fifth Category promotion license, and a First Category OTC license if it contracts with or executes for clients. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | Cayman has no appointed-representative or tied-agent regime, so a white label carrying on securities investment business from the Cayman Islands needs its own SIBA license, at least the arranging license if the partner broker is the counterparty. Not confirmed. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | No tied-agent or appointed-representative regime exists; a white label serving Kenyan clients needs its own CMA online FX license, typically non-dealing, held by a Kenyan-incorporated company, with a service level agreement with the platform provider (Reg. 4(2)(j)). |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | No tied-agent or appointed-representative regime was identified, so a white label dealing with clients from Seychelles needs its own Securities Dealer license (USD 100,000, local office and staff). |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | The BVI has no tied-agent or appointed-representative regime, so a BVI white label needs its own SIBA license: Category 2 if the partner broker deals with the clients, Category 1 if it deals itself. Not confirmed. |
Not available at 19 regulators
- FSA Japan No dedicated pathway: the brand must register itself (Type I) or act as a Financial Instruments Intermediary Service Provider tied to the registered firm; that intermediary status is not a Chart Room category.
- MAS No dedicated pathway: a brand must hold its own CMS license or act through the licensee's notified representatives; MAS has no appointed-representative regime for firms.
- FSRA No appointed-representative or tied-agent regime was identified for ADGM, so a white-label brand needs its own FSRA permission: Category 4 if it only arranges for the licensed broker, Category 2 or 3A if it deals or contracts with clients (confirm with the FSRA).
- FINMA Switzerland has no tied-agent or appointed-representative regime. A pure marketing brand of a licensed Swiss bank needs no license, but a white label that contracts with clients or holds their money needs its own bank or securities firm license.
- Bank of Lithuania No category in this register: a white label can run as a MiFID tied agent of the licensing broker (no separate license), otherwise it needs its own financial brokerage firm license.
- DFSA No appointed-representative or tied-agent route was identified in the DFSA regime, so a DIFC white-label brand needs its own license: Category 4 if it only markets and arranges for the principal broker, Category 2 or 3A if it contracts with clients or executes (confirm with the DFSA).
- SEC Licensed by the CFTC/NFA, not the SEC: the nearest US structure is a guaranteed IB of an RFED or FCM.
- MFSA No category in this register: a white label can run as a MiFID tied agent registered by its principal (no separate license), otherwise it needs its own Investment Services Licence.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- CBB Not confirmed: Category 3 firms are barred from acting as tied agents, implying a tied-agent concept, but the tied-agent regime was not researched; otherwise the brand needs its own Category 2 or Category 1 license depending on whether it deals as principal.
- SCB Bahamas No appointed-representative or tied-agent regime was found; a brand that deals in or markets CFDs in or from The Bahamas registers itself (CFD dealer, or arranging deals for a pure referral model). Uncertain: confirm with the SCB.
- SEC Nigeria No FX/CFD white-label route exists today; the proposed rules require brokers and technology providers to allocate compliance responsibility, and a separate Technology/Platform Provider registration at NGN 5 billion; no tied-agent regime for FX is proposed.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA; the nearest structure is a CFTC guaranteed IB.
- Labuan FSA No appointed-representative or white-label regime: the brand must hold its own money broking license, with substance in Labuan.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- BMA No appointed-representative or tied-agent route was identified; a Bermuda white-label operator needs its own standard license in the bucket matching its role. Class A registration is only for Bermuda-formed firms regulated by a recognized foreign regulator with no place of business in Bermuda.
- QFCRA No appointed-representative or tied-agent regime was identified; a white-label brand would need its own QFC authorization (arranging or dealing). Uncertain.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Prime-of-Prime
Liquidity provider / PoP
Deals as principal with brokers and institutions, redistributing prime liquidity; not retail.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions is Eigenhandel or own-account dealing in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Uncertain: principal dealing in leveraged FX with clients needs Type 3, but some dealings with banks and other professionals may fall under SFO exclusions or the LFET exemption rules; HKMA-authorized banks are exempt. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Uncertain: principal OTC derivatives dealing is Type I business, but certain transactions with financial institutions or qualified institutional investors may be excluded under the FIEA Enforcement Order; confirm before relying on an exclusion. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Dealing in investments as principal with brokers and institutions; GBP 750,000 PMR; this is the tier used for principal-model prime-of-prime and non-bank prime services. |
| ASIC#6 Australia | Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | AFSL limited to wholesale clients (s 761G) for dealing and market making in derivatives and FX; no fixed capital minimum beyond RG 166 base-level requirements; the usual route for prime-of-prime and liquidity providers. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Dealing as principal with brokers and institutions is a CMS dealing activity; base capital S$1 million for leveraged FX or OTC derivatives when serving only accredited, institutional or expert investors. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties (Category 2), USD 2 million base capital plus risk capital. |
| FINMA#10 Switzerland | Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | A securities firm license (own-account dealer or market maker, CHF 1.5 million) covers professional own-account dealing with institutions; banks also act as LPs under their bank license. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing as principal with brokers and institutions requires the EUR 750,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties only (no Retail Endorsement needed), USD 2 million base capital plus market and credit risk capital. |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing as principal with brokers and institutions needs the Art. 9(1) band (EUR 750,000); large firms may fall under CRR as Class 1 or Class 1 Minus. |
| CFTC · NFA#15 United States | Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | Dealing as principal in spot and deliverable FX forwards with eligible contract participants generally needs no CFTC registration; swap dealer registration (USD 20 million minimum capital) applies only if FX swaps such as NDFs or CFDs with ECPs exceed the de minimis threshold. Providing liquidity to an RFED or FCM does not by itself require RFED status. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | Dealing as principal in OTC derivatives with brokers and institutions is ODP activity under the FMA (trade-repository reporting and Joint Standard 2 of 2020 margin rules apply); no separate institutional-only category exists, and bank LPs rely on their Prudential Authority banking license. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Principal dealing with brokers and institutions fits the Full Service Dealer (excluding Underwriting) license (MUR 1,000,000); the Investment Dealer (Derivatives) category covers agency and exchange market making only and was not confirmed for an OTC principal book. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm dealing as principal with institutional counterparties, BD 1 million or risk-based capital; wholesale banks are the alternative. |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | USD 300 k | Dealing as principal in derivatives with brokers and institutions is dealing in capital markets instruments as principal (USD 300,000 floor under the older formula); add CFD registration where the instruments supplied are CFDs. |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | Uncertain: principal dealing in FX and derivatives with institutions fits a Labuan investment bank license (RM10 million paid-up capital, no deposit-taking); money brokers cannot act as principal. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Principal standard license (USD 250,000 minimum net assets); Class B registration excludes market intermediaries, so a liquidity provider cannot rely on it. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal with institutional and professional counterparties under BANK; base capital not confirmed. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4) | USD 122 k | Principal dealing with brokers and institutions needs the broker-dealer license; a firm dealing only with sophisticated or high-net-worth persons (entities with USD 5 million or more in assets) may register as a SIBA registered person instead, with no stated capital. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Principal dealing with brokers and institutions falls under the Securities Dealer license (USD 100,000); there is no separate institutional category. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Dealing in investments as principal with brokers and institutions, Category 1(b); the FSC sets capital case by case. |
Not available at 9 regulators
- SEC Not an SEC matter for FX: spot and deliverable forward FX dealing between eligible contract participants is largely outside registration, and NDFs and other FX swaps fall under the CFTC (swap dealer above the de minimis threshold).
- SAMA Interbank FX is dealt by SAMA-licensed banks; no separate non-bank FX liquidity license exists. A money changer license covers spot cash currency exchange only.
- SEC Nigeria No SEC category for FX/CFD liquidity provision; FX dealing as principal is the domain of CBN-licensed banks and authorized dealers, and the proposed rules do not mention liquidity providers.
- NYDFS Not licensed by NYDFS; FX dealing with institutions is largely outside registration or falls under CFTC swap dealer rules. A New York state-chartered bank conducts FX dealing under its banking charter, which is not a practical brokerage route.
- CMA UAE No wholesale-only principal dealing category for OTC FX was identified; the 'financial products dealer' activity under First Category may be relevant but its scope for OTC FX was not confirmed. Onshore interbank FX liquidity comes from CBUAE-licensed banks.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A VA OTC liquidity desk would need Broker-Dealer Services.
- CMA Kenya No CMA category covers institutional-only FX/CFD principal dealing; Kenyan dealing brokers hedge with offshore LPs or banks, and interbank FX dealing is done by CBK-licensed banks. Uncertain.
- CMA Saudi Not a CMA activity; interbank FX dealing is done by SAMA-licensed banks.
- CBUAE No non-bank FX dealing license exists at the CBUAE; interbank FX liquidity is provided by licensed banks (Licensed Bank at AED 2 billion or Restricted Licence Bank at AED 1 billion), which is not a practical route for a liquidity-provider start-up.
Every fitting category
25 categories at 23 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| CSSF#2 Luxembourg | Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Retail FX / CFD broker First Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent) Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) | USD 300 k | USD 16 k | USD 8 k | Retail | To confirm |
| CFD dealer Registered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | USD 25 k | USD 45 k | Retail | Rulebook | |
| BMA#27 Bermuda | Investment dealer (principal) Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Principal dealer / market maker SIBA Category 1, sub-category (b): Dealing in investments as principal | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Leveraged FX dealer Type 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | USD 17 k | USD 17 k | Retail | Rulebook |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Wholesale-only AFSL AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | USD 1 k | — | Professional only | Rulebook |
| MAS#8 Singapore | OTC derivatives / CFD dealer CMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| Leveraged FX dealer CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | OTC derivative provider Authorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | USD 3 k | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | Full-service dealer Investment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | USD 1 k | USD 3 k | Retail | Rulebook |
| FSA Seychelles#32 Seychelles | Securities dealer Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | USD 3 k | USD 6 k | Retail | Rulebook |
Not licensed by: VARA, CBUAE, CMA Saudi, SAMA, QFCRA, SEC, CFTC · NFA, NYDFS, Labuan FSA, CMA Kenya, SEC Nigeria.
ECN & DMA Venue
A multilateral or organized venue that matches orders. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators23 of 34
Lowest capitalUSD 5 kSEC
Median capitalUSD 197 k
Retail clients allowed23 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (client money / MTF)
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (holds client money/assets or operates MTF)
- Capital
- USD 174 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Automated trading venue
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 197 k
SEC
USD 5 k
FSRAUSD 50 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
Bank of LithuaniaUSD 174 k
CySECUSD 174 k
MASUSD 195 k
FCAUSD 200 k
DFSAUSD 200 k
SFCUSD 642 k
MFSAUSD 870 k
FINMAUSD 1.25 m
FSA JapanUSD 2.01 m
SEC NigeriaUSD 3.33 m
CMA KenyaUSD 7.75 m
1k10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
29 categories at 23 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook |
| FCA#5 United Kingdom | Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary |
| Recognised investment exchange Recognised investment exchange (RIE) - recognition order under FSMA Part XVIII | — | USD 299 k | — | Retail | To confirm | |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | Exchange / MTF Trading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | — | USD 19 k | Retail, with conditions | Rulebook |
| DLT trading facility DLT trading facility (FinMIA Art. 73a) | USD 1.25 m | — | USD 9 k | Retail | Rulebook | |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assets Financial brokerage firm - EUR 150,000 band | USD 174 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operator Category 4 | USD 50 k | USD 20 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary |
| Americas | ||||||
| SEC#13 United States | Alternative trading system Alternative trading system (Regulation ATS, Rules 300-304; Form ATS or Form ATS-N) | USD 5 k | USD 8 k | USD 1 k | Retail, with conditions | Secondary |
| Registered securities exchange National securities exchange (Exchange Act s.6; Form 1) | — | — | — | Retail, with conditions | Secondary | |
| CFTC · NFA#15 United States | DCM (futures exchange) Designated contract market (CEA s.5; Part 38) | — | — | — | Retail | Rulebook |
| SEF Swap execution facility (CEA s.5h; Part 37) | — | — | — | Professional only | Secondary | |
| SCB Bahamas#21 The Bahamas | Marketplace Marketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | — | — | Retail, with conditions | Secondary |
| BVI FSC#34 British Virgin Islands | Investment exchange SIBA Category 7: Operating an investment exchange | — | USD 5 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Automated trading venue Type 7 – Providing automated trading services | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Proprietary trading system (PTS) PTS operation authorization (FIEA Art. 30) for a Type I firm | USD 2.01 m | — | — | Retail, with conditions | Rulebook |
| ASIC#6 Australia | Licensed market operator Australian market license (Corporations Act Part 7.2) | — | — | USD 4 k | Retail, with conditions | Secondary |
| MAS#8 Singapore | Approved exchange Approved Exchange (AE) under Part 2 of the SFA | USD 7.8 m | USD 3 k | — | Retail | Rulebook |
| Recognised market operator Recognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | USD 3 k | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchange Labuan exchange approval (LFSSA s. 134; Form LEB) | — | USD 500 (nominal) | USD 14 k | Retail, with conditions | To confirm |
| Africa | ||||||
| FSCA#17 South Africa | Licensed exchange Exchange license, Financial Markets Act 2012 | — | USD 27 k | — | Retail, with conditions | Rulebook |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite) Non-Composite Securities Exchange | USD 3.33 m | — | — | Retail | Rulebook |
| CMA Kenya#30 Kenya | Securities exchange Securities Exchange (LN 197 of 2025) | USD 7.75 m | USD 2 k | — | Retail | Secondary |
| OTC platform / ISP OTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | USD 466 (nominal) | USD 388 (nominal) | Retail, with conditions | To confirm | |
| FSA Seychelles#32 Seychelles | Securities exchange Securities Exchange license (Securities Act 2007) | — | USD 5 k | USD 10 k | Retail | Rulebook |
Not licensed by: VARA, CMA UAE, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, NYDFS, CIMA, BMA, FSC Mauritius.
Proprietary Trading Firm
A firm trading its own capital, including funded-trader models. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators12 of 34
Lowest capitalUSD 100 kSEC
Median capitalUSD 870 k
Retail clients allowed10 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#5 overall Tier 1
FCA
United Kingdom
Apply for: Investment firm (dealing on own account)
- Capital
- USD 998 k
- Fees at start
- USD 15 k
- Every year
- USD 3 k
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 870 k
SEC
USD 100 k
CIMAUSD 122 k
CMA KenyaUSD 155 k
SEC NigeriaUSD 667 k
BaFinUSD 870 k
CSSFUSD 870 k
CBI IrelandUSD 870 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
CySECUSD 870 k
FCAUSD 998 k
FINMAUSD 1.88 m
100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
12 categories at 12 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| CSSF#2 Luxembourg | Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Americas | ||||||
| SEC#13 United States | Dealer / non-carrying principal broker-dealer Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)) | USD 100 k | USD 8 k | USD 1 k | Retail | Rulebook |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| Africa | ||||||
| SEC Nigeria#22 Nigeria | Dealer Dealer (proprietary trading only) | USD 667 k | — | — | Professional only | Rulebook |
| CMA Kenya#30 Kenya | Dealer Dealer (LN 197 of 2025) | USD 155 k | USD 853 (nominal) | USD 775 (nominal) | Professional only | Secondary |
Not licensed by: DFSA, FSRA, VARA, CMA UAE, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, CFTC · NFA, NYDFS, BVI FSC, BMA, SCB Bahamas, MAS, SFC, ASIC, FSA Japan, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles.
Quantitative Trading Desk
Systematic and algorithmic trading on own or managed capital. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators21 of 34
Lowest capitalUSD 13 kSFC
Median capitalUSD 171 k
Retail clients allowed18 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 171 k
SFC
USD 13 k
CMA KenyaUSD 78 k
SECUSD 100 k
DFSAUSD 140 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
CySECUSD 145 k
FSCAUSD 171 k
MASUSD 195 k
FSRAUSD 250 k
FSA JapanUSD 335 k
CBBUSD 665 k
SEC NigeriaUSD 667 k
CMA UAEUSD 817 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
FINMAUSD 1.88 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
29 categories at 21 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary | |
| CSSF#2 Luxembourg | Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary |
| Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary | |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary |
| Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary | |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Asset / wealth manager; custodian Category 3C (Managing Assets / Custody / PSIAr / express trustee) | USD 250 k | USD 25 k | USD 25 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Asset / wealth manager Category 3C (Managing Assets, PSIAr, express trustee) | USD 140 k | USD 40 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Investment manager Second Category – Dealing in Investment (Portfolio management) | USD 817 k | — | — | Retail | Secondary |
| Americas | ||||||
| SEC#13 United States | Dealer / non-carrying principal broker-dealer Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)) | USD 100 k | USD 8 k | USD 1 k | Retail | Rulebook |
| CFTC · NFA#15 United States | CPO Commodity pool operator (CEA s.1a(11); Part 4) | — | USD 950 (nominal) | USD 750 (nominal) | Retail, with conditions | Rulebook |
| CTA Commodity trading advisor (CEA s.1a(12); Part 4) | — | USD 950 (nominal) | USD 750 (nominal) | Retail | Rulebook | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Wholesale-only AFSL AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | USD 1 k | — | Professional only | Rulebook |
| MAS#8 Singapore | A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| Hedge fund manager FAIS Category IIA FSP (hedge fund FSP) | USD 171 k | USD 932 (nominal) | — | Retail, with conditions | Rulebook | |
| SEC Nigeria#22 Nigeria | Dealer Dealer (proprietary trading only) | USD 667 k | — | — | Professional only | Rulebook |
| CMA Kenya#30 Kenya | Online FX money manager Money Manager (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 78 k | — | — | Retail | Rulebook |
| Dealer Dealer (LN 197 of 2025) | USD 155 k | USD 853 (nominal) | USD 775 (nominal) | Professional only | Secondary | |
Not licensed by: VARA, CBUAE, CMA Saudi, SAMA, QFCRA, NYDFS, CIMA, BVI FSC, BMA, SCB Bahamas, Labuan FSA, FSC Mauritius, FSA Seychelles.
Multi-Asset Brokerage
Securities, futures, FX and CFDs under one house. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators30 of 34
Lowest capitalUSD 22 kFSC Mauritius
Median capitalUSD 335 k
Retail clients allowed30 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (client money / MTF)
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (holds client money/assets or operates MTF)
- Capital
- USD 174 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities dealer
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 335 k
FSC Mauritius
USD 22 k
MASUSD 39 k
FSA SeychellesUSD 100 k
CIMAUSD 122 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
CySECUSD 174 k
FCAUSD 200 k
DFSAUSD 200 k
SECUSD 250 k
BMAUSD 250 k
SCB BahamasUSD 300 k
FSA JapanUSD 335 k
CMA KenyaUSD 388 k
FSRAUSD 500 k
SFCUSD 642 k
ASICUSD 700 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
CFTC · NFAUSD 1 m
SEC NigeriaUSD 1.33 m
FINMAUSD 1.88 m
Labuan FSAUSD 2.36 m
CBBUSD 2.66 m
CMA UAEUSD 8.17 m
CMA SaudiUSD 13.33 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Forex brokerage
Seven ways to run a forex broker
Each model asks for a different permission. Choose a model to see, at every regulator, the category to apply for and what it requires. A model is counted wherever any category permits it, so a count can exceed the regulators mapped to the system above.
B-book · dealing desk
Market maker
The broker takes the other side of each client trade and carries the market risk on its own book.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Proprietary trading for others (Eigenhandel) / dealing on own account; EUR 750,000 initial capital (Section 17(1) no. 1 WpIG) plus IFR own funds; BaFin's CFD general administrative act applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 leveraged foreign exchange trading (general case): HK$30 million paid-up capital and HK$15 million liquid capital, two responsible officers; CFDs on securities need Type 1 instead. Very few new Type 3 licenses are granted.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I Financial Instruments Business registration covers OTC derivatives including retail FX and CFDs; stock company with board, JPY 50 million stated capital and net assets, capital adequacy ratio of at least 120%, FFAJ membership effectively required.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Part 4A permission for dealing in investments as principal; GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4) plus fixed overheads and K-factor tests; this is the standard license for market-making FX/CFD brokers; COBS 22.5 applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | AFSL authorizations to deal in and make a market in derivatives and FX contracts for retail clients (issuer of retail OTC derivatives); NTA of the greater of AUD 1 million or 10% of average revenue, half in cash (Instrument 2022/705, RG 166).Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | CMS license for dealing in capital markets products: spot FX for leveraged FX trading and, for CFDs on other underlyings, OTC derivatives; base capital S$5 million each where any retail customer is served, plus risk-based capital (Notice SFA 04-N13).Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (not as Matched Principal) in Category 2, USD 2 million base capital plus risk capital; FSRA lists market-maker CFD/FX brokers here.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | In practice Swiss retail FX/CFD market makers hold a bank license (CHF 10 million minimum capital), because FINMA has treated client margin balances held by non-banks as public deposits since about 2009; a securities firm license (CHF 1.5 million, own-account dealing and market making) may suffice only if client balances qualify as settlement accounts. Unconfirmed: confirm with FINMA.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing on own account in the EUR 750,000 band (Law on Markets in Financial Instruments Art. 14); market-maker and CFD principal models require this band; ESMA-derived retail CFD caps apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (Category 2), USD 2 million base capital plus risk capital; a Retail Endorsement is needed to deal with retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing on own account under an Investment Services Licence in the IFD Art. 9(1) band; EUR 750,000 initial capital plus recovery and resolution rules; CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Acting as counterparty to retail off-exchange forex requires RFED registration (or FCM status with retail forex) and NFA Forex Dealer Member status, with adjusted net capital of at least USD 20 million plus 5% of retail forex obligations above USD 10 million.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Issuing CFDs/rolling spot FX as principal requires ODP authorization under the Financial Markets Act 2012 (no fixed rand capital; about 6 months of liquid net assets per practitioner summaries, with bank-like capital rules for non-bank ODPs signalled in 2025), and retail distribution also needs a FAIS Category I license with subcategories 1.13/1.15 (own or a partner FSP).Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Dealing as principal for resale to clients falls under the Investment Dealer (Full Service Dealer, excluding Underwriting) license, MUR 1,000,000 stated unimpaired capital, PI cover, compliance officer and MLRO, and GBC substance if held through a GBC.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm (dealing in financial instruments as principal), BD 1 million minimum capital or the higher risk-based requirement; this is the CBB route for market-making brokers.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Dealing in FX and other CFDs as principal requires CFD registration under the Securities Industry (Contracts for Differences) Rules, 2020, either as a CFD-only firm or alongside dealing registration; capital is a Commission formula (r.13), with a USD 1,000,000 bank-deposit floor proposed in the 2026 draft amendment (not final as of October 2026), and a resident CFD Supervisory Officer.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; market-maker CFD brokers (e.g. Plus500, XTB, Deriv) hold this license, but the rulebook text read did not state expressly whether dealing as principal is permitted, so confirm with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Investment Business Act standard license as a principal investment provider, minimum net assets USD 250,000 (or 8% of risk-weighted assets) plus liquid assets of three months' expenditure.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal, prudentially regulated under BANK (base capital not confirmed); retail FX/CFD brokerage is not an established QFC model, so this is realistic only for business and professional clients.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | SIBA license for dealing in securities and market making; base financial resource requirement CI$100,000 (higher of that and a quarter of annual expenditure plus risk requirements), professional indemnity cover of CI$1 million per claim, monthly financial statements; retail FX/CFD brokers use this license.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | A Dealing Online Foreign Exchange Broker trades as principal and market maker (Reg. 2, Online FX Trading Regulations 2017); KES 50 million paid-up capital, liquid capital of the higher of KES 30 million or 8% of liabilities, Kenyan-incorporated company.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The Securities Dealer license covers dealing in securities including CFDs and FX as principal (B-book); USD 100,000 paid-up capital since the Securities (Amendment) Act 2024, physical office, two natural-person directors, licensed representative and compliance officer.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | SIBA Category 1(b), dealing as principal including taking the other side of client trades; no fixed minimum capital, as the FSC sets financial resources case by case under Regulatory Code s. 181 (advisers budget about USD 1 million) and expects more for principal dealing.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: a retail FX counterparty must be an RFED or an FCM. SEC broker-dealer dealer status covers securities only, and CFDs on US securities (security-based swaps) cannot be offered off-exchange to non-ECP retail clients.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No SEC category for retail FX/CFD market making is currently in force; SEC proposed rules of 1 September 2026 would create a B-book/market-making forex broker registration at NGN 3 billion paid-up capital, and FX itself is under CBN control.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM). No NYDFS category covers acting as counterparty to FX or CFD trades.
- Labuan FSA Not permitted: Labuan money brokers may not act as principal (Money Broking Guidelines, 9 September 2024), and retail FX/CFD brokerage is not available in Labuan. A Labuan investment bank (RM10 million) may deal FX as principal but only with institutional clients, not as a retail B-book.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A principal desk dealing only in virtual assets would need Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book · no dealing desk
STP / agency
Orders pass straight through to liquidity providers; the broker acts as agent or matched principal and keeps no market risk.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 covers both dealing-desk and STP brokers (the SFC's review found most Type 3 firms hedge back-to-back with liquidity providers); same HK$30 million paid-up capital; disclose any affiliate liquidity provider in the execution policy.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Brokerage or intermediation of OTC FX derivatives is also Type I business, so an STP broker needs the same registration and JPY 50 million capital.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 200 k | Agency execution / arranging with permission to hold client money (CASS) is the GBP 150,000 tier; a matched-principal STP model is dealing as principal and generally needs the GBP 750,000 permission (we did not confirm whether MIFIDPRU 4.4 gives matched-principal firms a lower PMR).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | An Australian STP broker is still the issuer of the OTC derivative to its retail client, so it needs the same issuer and market-making authorizations and AUD 1 million NTA as a market maker.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | The CMS dealing license covers dealing as principal or agent, so an STP broker needs the same license and S$5 million base capital for retail clients; no lighter agency-only FX category exists.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency brokerCategory 3A | USD 500 k | Dealing in Investments as Agent or as Matched Principal (Category 3A), USD 500,000 base capital, rising to USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | An agency broker that keeps client accounts needs a bank or securities firm license (securities firm keeping client accounts, CHF 1.5 million); which one applies to OTC FX/CFD balances was not confirmed. A firm that only forwards orders to a licensed bank without holding money needs no FINMA license (see introducing broker).Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 174 k | Agency execution holding client money is in the EUR 150,000 band; a matched-principal STP model is dealing on own account and needs the EUR 750,000 band.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A Principal dealer / credit providerCategory 2 | USD 200 k | Pure agency (Dealing in Investments as Agent) is Category 3A at USD 200,000 base capital after the CP161 reforms (secondary); since the 2025 PIB amendments, matched-principal A-book dealing sits in Category 2 (USD 2 million; a lower matched-principal figure is reported but unconfirmed).Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 87 k | Agency execution / RTO holding client money is the IFD Art. 9(3) band (EUR 150,000); a matched-principal STP model counts as dealing on own account and needs the Art. 9(1) band (EUR 750,000).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Only an RFED or FCM may accept retail forex orders and funds, so an STP broker that hedges back-to-back with liquidity providers still registers as an RFED/FCM and holds the USD 20 million minimum; there is no lighter agency-only category for retail forex.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | A pure agent passing orders to a third-party issuer needs FAIS Category I (1.13 derivatives, 1.15 forex investment business); a matched-principal STP that is itself the client's counterparty on the CFD still needs ODP authorization, since FAIS does not permit issuing OTC derivatives.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) BrokerInvestment Dealer (Broker) | USD 13 k | Agency-only order routing to a third-party LP fits the Discount Broker (execution-only, MUR 600,000) or Broker (with advice/portfolio management, MUR 700,000) categories; a matched-principal STP that is counterparty to the client should take the Full Service Dealer license instead.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | Category 2 investment firm (all services except dealing as principal, including agency dealing and holding client money), BD 250,000 minimum capital. Whether CBB treats riskless matched-principal as principal dealing (Category 1) was not confirmed.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | The CFD Rules cover dealing in, providing or marketing CFDs in or from The Bahamas regardless of hedging model, so an STP broker also registers as a CFD dealer; same capital and resident-officer conditions as a market maker.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Labuan money broking license (arranging FX and money market deals only), RM1 million paid-up capital; clients limited to institutional investors and high-net-worth individuals, non-residents of Malaysia only, operational office in Labuan.Retail leverage No retail FX/CFD offering permitted. For eligible institutional and high-net-worth clients of money brokers, maximum leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards (Money Broking Guidelines, 9 September 2024). |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; covers brokerage of OTC derivatives and spot FX for onshore clients, including retail.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | Standard license acting as agent, minimum net assets USD 100,000 plus three months' liquid assets; a matched-principal model may fall in the principal bucket, so confirm with the BMA.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Agency dealing is listed within this category's permits; whether a pure agency broker is placed under BANK or INMA was not confirmed, and retail FX/CFD is not an established QFC model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Dealing as agent is also covered by the broker-dealer SIBA license, with the same CI$100,000 base financial resources.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | A Non-Dealing Online Foreign Exchange Broker links clients to the FX market for commission or mark-up and does not make markets (Reg. 2); KES 30 million paid-up capital, same liquid-capital test.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The same Securities Dealer license covers dealing as agent; there is no lower agency-only category, so the USD 100,000 capital applies.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Category 1(a) for agency execution; a matched-principal STP model is principal dealing and falls under 1(b). Category 2 (arranging) is commonly added.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 7 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: retail forex orders can be accepted only by an FCM or RFED, whatever the execution model.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria Not yet licensable; the proposed rules (1 September 2026) would create an STP/ECN/A-book broker registration at NGN 2 billion paid-up capital, and the existing Broker category covers securities only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Agency or matched-principal brokerage of virtual assets is Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book and B-book
Hybrid
Part of the flow is internalized and part passed on; the license must allow dealing as principal.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 general case, as for a market maker; the client agreement must state whether the firm takes the opposite side of client trades.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I registration as for a market maker; mandatory loss-cut rules and trust segregation of client margin apply.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Internalizing any client flow requires the dealing-as-principal permission and the GBP 750,000 PMR; CASS client-money permission is also needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | Same retail OTC derivatives issuer AFSL as a market maker; AUD 1 million NTA.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Same CMS dealing license as a market maker, with S$5 million base capital for retail; conflict management and execution policy apply.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Keeping any B-book risk is dealing as principal, so Category 2 (USD 2 million plus risk capital).Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | Same as the market maker: internalizing flow is own-account dealing; established Swiss practice is a bank license.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Internalizing any client flow is dealing on own account, so the EUR 750,000 band is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Internalizing any flow is dealing as principal, so Category 2 (USD 2 million plus risk capital), with a Retail Endorsement for retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Internalizing any client flow is dealing on own account, so the Art. 9(1) band (EUR 750,000) is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Internalizing any retail flow is acting as counterparty, so RFED or FCM registration with USD 20 million minimum adjusted net capital is required.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Internalising any flow means acting as principal on OTC derivatives, so ODP authorization is needed, plus FAIS Category I for retail distribution.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Any internalization is principal dealing, so the Full Service Dealer (excluding Underwriting) license is needed (MUR 1,000,000).Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Internalizing any flow is dealing as principal, so Category 1 (BD 1 million or risk-based capital).Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Same CFD dealer registration as a market maker; disclose the internalization policy and conflicts in the order execution policy.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | Same First Category OTC license (AED 30 million) as the market-maker model; principal-dealing scope to be confirmed with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Any internalized flow means dealing as principal: principal standard license, USD 250,000 minimum net assets.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Principal dealing under BANK, with the same retail limitation as the market-maker model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Broker-dealer / market maker SIBA license covers both principal and agency flow.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | Any internalization is market making, so the Dealing Online Foreign Exchange Broker license (KES 50 million) is needed.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Covered by the Securities Dealer license, which permits both agency and principal dealing (USD 100,000).Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent | — | Principal dealing (1(b)) for internalized flow plus agency dealing (1(a)) for passed-through flow.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC (RFED or FCM counterparty status).
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No category in force; under the proposed rules a hybrid would need the market-making (B-book) broker registration at NGN 3 billion.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- Labuan FSA Not permitted: internalizing flow requires principal dealing, which money brokers are prohibited from doing.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Multilateral matching
ECN / MTF venue
A venue where many participants’ orders meet; licensed as an exchange, MTF or OTF, not as a broker.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| SFC#3 Hong Kong | Automated trading venueType 7 – Providing automated trading services | USD 642 k | Uncertain: Type 7 automated trading services (HK$5 million paid-up capital) covers electronic venues for securities and futures contracts; whether a multilateral leveraged-FX venue falls under Type 7 or Type 3 was not confirmed. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | Operating an MTF without own-account dealing is in the GBP 150,000 tier (an OTF with own-account dealing needs GBP 750,000); a recognized investment exchange is a heavier, separate route, and most new venues start as MTFs. |
| ASIC#6 Australia | Licensed market operatorAustralian market license (Corporations Act Part 7.2) | — | A multilateral venue is a financial market requiring an Australian market license (Part 7.2), unless exempt; no fixed capital, adequate resources required (s 792A). |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| MAS#8 Singapore | Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | A multilateral trading venue is an organized market operated as a Recognised Market Operator (higher of S$250,000 or 25% of annual operating expenses for a Singapore RMO). Uncertain: whether a spot FX matching venue counts as an organized market was not confirmed. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Operating an MTF or OTF is a Category 4 activity (USD 50,000 base capital), but MTF/OTF operators remain subject to the Expenditure-Based Capital Minimum and FSRA market-operator requirements; a virtual-asset MTF is a separate category. |
| FINMA#10 Switzerland | Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | A stock exchange or MTF license (CHF 1 million minimum, FinMIO Art. 13) covers multilateral trading of securities; spot FX is not a security under FinMIA, so an FX-only matching venue may fall outside it. Uncertain. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band | USD 174 k | Operating an MTF falls in the EUR 150,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A | USD 200 k | Operating an Alternative Trading System (DIFC term for MTF/OTF) moved from Category 4 to Category 3A under the 2025 PIB amendments; ATS operators must also meet the AMI/ATS market-integrity rules (effective date of the move reported as July 2025 or July 2026 by different advisers). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Operating a trading facility is listed only under the Art. 9(1) license scope, but since the September 2025 amendment (Part BI R1-5.1.2) an MTF operator that does not deal on own account has EUR 150,000 initial capital; confirm the license scope with the MFSA. |
| CFTC · NFA#15 United States | DCM (futures exchange)Designated contract market (CEA s.5; Part 38) SEFSwap execution facility (CEA s.5h; Part 37) | — | Off-exchange retail forex cannot be run as a multilateral venue for non-ECP retail clients: an FX futures venue is a DCM (retail access via FCMs) and an FX swap/NDF venue is a SEF (ECPs only); institutional spot FX ECNs fall largely outside CFTC registration. Both need financial resources covering one year of operating costs. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| FSCA#17 South Africa | Licensed exchangeExchange license, Financial Markets Act 2012 | — | A multilateral venue for securities including derivative instruments must be a licensed exchange under the FMA 2012 (liquid net assets of at least 6 months' operating expenses, reg. 8 of GN R98); no MTF-style lighter category exists, and whether an OTC FX matching venue falls inside the exchange definition should be confirmed with counsel. |
| SCB Bahamas#21 The Bahamas | MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | A multilateral venue for capital markets instruments is registered as a marketplace under the Securities Industry Act, 2024, with SCB-approved rulebook and systems and capital set case by case; no FX-specific venue category exists. |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite)Non-Composite Securities Exchange | USD 3.33 m | Only an exchange-traded venue (e.g. FX derivatives on a securities exchange such as FMDQ) is licensable today, as a Non-Composite Securities Exchange at NGN 5 billion; an OTC FX/CFD matching venue has no category and would also need CBN involvement. Uncertain. |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB) | — | Uncertain: a multilateral venue would need Labuan exchange approval (LFSSA s.134) with capital set case by case; no FX-specific venue guideline was found. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The 2017 FX regulations have no venue category; the OTC Platform provider category under LN 197 of 2025 is the closest fit for a multilateral OTC venue, but its capital and whether it extends to online FX/CFDs are unconfirmed. |
| FSA Seychelles#32 Seychelles | Securities exchangeSecurities Exchange license (Securities Act 2007) | — | A multilateral venue would need a Securities Exchange license (sole activity, at least three independent dealer members, clearing, surveillance and compensation arrangements); whether the FSA would treat an OTC FX/CFD matching venue this way is uncertain. |
| BVI FSC#34 British Virgin Islands | Investment exchangeSIBA Category 7: Operating an investment exchange | — | Category 7 covers providing a facility for orderly trading of investments; whether an FX/CFD matching venue fits was not confirmed, so check with the FSC. |
Not available at 13 regulators
- FSA Japan Uncertain: the PTS authorization covers securities venues only; no Chart Room category for a multilateral retail FX venue was identified. Electronic trading platforms for certain OTC derivatives exist under the FIEA but were not confirmed for FX.
- SEC No SEC category for an FX venue; spot FX is not a security. The SEC ATS and exchange categories cover securities only; FX futures venues are CFTC DCMs and FX swap/NDF venues are CFTC SEFs.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- FSC Mauritius No venue category is in this register: operating a multilateral market requires a Securities Exchange license from the FSC under the Securities Act 2005, which is not recorded here.
- CBB No investment-firm category covers running a multilateral venue; licensed exchanges are authorized under CBB Volume 6 (market operators), which is not in this register.
- NYDFS Not licensed by NYDFS; FX futures venues are CFTC DCMs and FX swap venues are CFTC SEFs.
- CMA UAE No CMA category for operating an OTC FX/CFD multilateral venue was identified in the data; exchange and platform licensing outside the virtual-asset Seventh Category is not covered, so confirm with the CMA.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A virtual-asset matching venue, including exchange-traded VA derivatives under the March 2026 Part V rules, is Exchange Services; fiat-currency matching is excluded.
- BMA No category for operating a multilateral FX trading venue is in the register; exchange recognition is outside these license types. Uncertain.
- QFCRA No category for operating a multilateral trading venue was identified in the QFCRA data; onshore exchange-traded markets fall under the QFMA.
- CIMA No category in this register for a multilateral FX/CFD venue; the Cayman Islands Stock Exchange is a separate listing exchange. Not confirmed whether operating a matching platform would need a SIBA license.
- CMA Saudi Not available: the Saudi Exchange (Tadawul) is the only licensed exchange and there is no OTC FX venue license.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Referral and arranging
Introducing broker
Brings clients to a licensed broker without executing trades or holding client money.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| CSSF#2 Luxembourg | Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | Type 3 approved introducing agent: HK$5 million paid-up and HK$3 million liquid capital; may not carry client positions or hold client assets. |
| FCA#5 United Kingdom | Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | USD 100 k | Own Part 4A permission for arranging deals / making arrangements without client money (GBP 75,000 PMR), or act as an appointed representative (including an introducer AR) of an authorized broker that accepts responsibility. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Typically a corporate authorized representative of the issuing licensee (no own capital requirement), or the firm's own AFSL with dealing (arranging) authorization; ASIC has scrutinized CAR use in OTC derivatives. |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | Uncertain: the SFA definition of dealing includes inducing a person to enter into a transaction, so an introducer soliciting Singapore clients generally needs its own CMS dealing license or must act through the licensee's notified representatives; MAS has no dedicated IB license. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Arranging Deals in Investments (Category 4), USD 50,000 base capital from 19 August 2025; no EBCM if no Client Assets are held. FSRA proposed barring authorized firms from accepting paid retail referrals from unregulated third parties, so IBs introducing retail clients should be FSRA-authorised. |
| Bank of Lithuania#11 Lithuania | Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band | USD 87 k | RTO / arranging without client money in the EUR 75,000 band. The financial advisor company license does not fit because it covers only transferable securities and fund units, not CFDs or FX derivatives. Tied-agent status under MiFID II Art. 29 is also possible but is not a category in this register. |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arrangerCategory 4 | USD 30 k | Arranging Deals in Investments (Category 4), USD 30,000 base capital after the 2026 amendments (secondary); no execution or client money. A Representative Office is not an option: since April 2015 the DFSA will not accept Representative Office applications from firms marketing FX or other highly leveraged products to retail clients. |
| MFSA#14 Malta | Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | RTO / advice without holding client money in the IFD Art. 9(2) band (EUR 75,000); orders must go to an authorized broker; the professional-only variant (legacy 1B) has the same capital. Tied-agent status is also possible under MiFID II Art. 29 but is not a category in this register. |
| CFTC · NFA#15 United States | Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | USD 45 k | Soliciting retail forex for an RFED/FCM without holding customer funds requires IB registration and NFA membership: independent IB with at least USD 45,000 adjusted net capital, or guaranteed IB with no capital requirement but introducing only to its guarantor. |
| CySEC#16 Cyprus | Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Introducing or arranging for clients is a FAIS intermediary service, so a Category I license (1.13/1.15) or appointment as a representative of a licensed FSP is needed; referral to offshore brokers while collecting local rand deposits has drawn SARB exchange-control action. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | Category 3 (arranging and advising, BD 25,000 plus liquid funds of 25% of prior-year operating expenses) only fits an IB paid by its clients, because Category 3 firms must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent; a rebate-funded IB therefore needs Category 2 (BD 250,000). |
| SCB Bahamas#21 The Bahamas | Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | Introducing clients to a dealer without dealing is arranging deals (USD 25,000 floor under the older formula); the CFD Rules also capture marketing CFDs in or from The Bahamas, so check with the SCB whether an introducer also needs CFD registration. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Uncertain: arranging FX transactions from Labuan falls within money broking (RM1 million); no lighter introducer category exists. An introducer based outside Labuan is governed by its own jurisdiction. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | Fifth Category introducing and promotion, AED 500,000 paid-up capital; may introduce UAE clients to an offshore or free-zone broker but may not hold client assets or execute. Most CFD brokers entering the UAE (XM, Exinity, Pepperstone and others) use this route. |
| BMA#27 Bermuda | Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | Arranging deals without dealing as agent or principal: standard license (neither agent nor principal), minimum net assets USD 12,000 plus one month's liquid assets. |
| QFCRA#28 Qatar · QFC | Investment adviser / arrangerAdvisory and arranging firm (INMA 2014) | USD 250 k | Arranging deals in investments (INMA advisory and arranging firm), base capital about USD 250,000 restated in QAR plus 13/52 of annual operating expenses; no client money. A December 2025 consultation may lower requirements for wholesale advisers. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | SIBA license for arranging deals in securities; CI$15,000 base financial resources plus professional indemnity insurance. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The FX regulations have no introducing-broker category; the Intermediary Service Platform provider category (LN 197 of 2025), granted to Safaricom and Airtel Money in December 2025 for onboarding and market access, is the closest fit, but its use for FX referral is unconfirmed, and offshore brokers may not serve Kenyan clients. |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | SIBA Category 2, arranging deals in investments, including introducing clients to dealers. |
Not available at 11 regulators
- FSA Japan Not a Chart Room category: an introducer registers as a Financial Instruments Intermediary Service Provider (FIEA Art. 66) tied to a Type I firm, or registers as Type I itself. Unregistered solicitation of Japanese residents is prohibited.
- FINMA No FINMA license for pure referral without handling client money or orders. A firm that transmits orders provides a FinSA financial service, so its client advisers must be in the FinSA adviser register unless the firm is supervised; AML SRO membership may apply if it acts as a financial intermediary. Uncertain.
- SEC Licensed by the CFTC/NFA, not the SEC: introducing retail forex accounts requires CFTC introducing broker registration and NFA membership; an SEC introducing broker-dealer status does not cover FX.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime. SAMA's 2017 circular prohibits marketing by foreign forex firms without a contract with a licensed Saudi institution.
- FSC Mauritius No dedicated introducing-broker category was found; whether pure referral is licensable is uncertain, and if the firm advises it needs Investment Adviser (Restricted), or if it receives and transmits orders, Investment Dealer (Broker).
- SEC Nigeria No category in force; the proposed rules would create Corporate Introducing Broker (NGN 150 million) and Individual Introducing Broker (NGN 30 million) registrations and would ban referral incentives. The existing Sub-Broker (Digital) category routes securities orders only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (CFTC introducing broker with NFA membership).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Arranging orders in virtual assets falls under Broker-Dealer Services.
- CMA Saudi No fit: Arranging covers securities only, and a 2017 SAMA circular prohibits foreign forex companies without contracts with licensed Saudi institutions from marketing in the Kingdom.
- FSA Seychelles No introducing-broker category exists in the register, and a secondary source reports no FSA restrictions on IBs; if the firm gives advice it needs an Investment Adviser license (USD 25,000). Treatment of a Seychelles-based referral business is uncertain.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022. Introducing to brokers is the CMA Fifth Category.
A brand on a host license
White label
Operates its own brand on another firm’s license and platform, often as its appointed representative.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | No tied-agent or appointed-representative regime: a Hong Kong-facing brand must be licensed itself, usually as a Type 3 introducing agent referring clients to the executing Type 3 firm. |
| FCA#5 United Kingdom | Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | — | Appointed representative of the principal broker under SUP 12; no separate license or capital, but the principal must notify the FCA 30 days ahead and oversee the AR, and the AR cannot deal as principal or hold client money. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Corporate authorized representative of the AFS licensee; no separate license, but the CAR cannot issue products in its own right and the licensee remains responsible. |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CFTC · NFA#15 United States | Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | No white-label license exists; a US-facing brand on another firm's platform must register itself, usually as a guaranteed IB of the RFED/FCM (closest equivalent to an appointed representative), since anyone soliciting retail forex must be registered. |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Most South African CFD brands hold their own FAIS Category I license and distribute a third-party ODP's products; alternatively the brand can operate as a juristic representative of a licensed FSP under the FAIS Act without its own license, with the FSP remaining responsible. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) | USD 13 k | No tied-agent or appointed-representative regime for corporate white labels was identified, so a white label serving clients from Mauritius generally needs its own Investment Dealer license, commonly the Discount Broker category on a partner's platform and liquidity. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | No tied-agent or appointed-representative regime was identified; a white-label brand marketing onshore needs at least a Fifth Category promotion license, and a First Category OTC license if it contracts with or executes for clients. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | Cayman has no appointed-representative or tied-agent regime, so a white label carrying on securities investment business from the Cayman Islands needs its own SIBA license, at least the arranging license if the partner broker is the counterparty. Not confirmed. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | No tied-agent or appointed-representative regime exists; a white label serving Kenyan clients needs its own CMA online FX license, typically non-dealing, held by a Kenyan-incorporated company, with a service level agreement with the platform provider (Reg. 4(2)(j)). |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | No tied-agent or appointed-representative regime was identified, so a white label dealing with clients from Seychelles needs its own Securities Dealer license (USD 100,000, local office and staff). |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | The BVI has no tied-agent or appointed-representative regime, so a BVI white label needs its own SIBA license: Category 2 if the partner broker deals with the clients, Category 1 if it deals itself. Not confirmed. |
Not available at 19 regulators
- FSA Japan No dedicated pathway: the brand must register itself (Type I) or act as a Financial Instruments Intermediary Service Provider tied to the registered firm; that intermediary status is not a Chart Room category.
- MAS No dedicated pathway: a brand must hold its own CMS license or act through the licensee's notified representatives; MAS has no appointed-representative regime for firms.
- FSRA No appointed-representative or tied-agent regime was identified for ADGM, so a white-label brand needs its own FSRA permission: Category 4 if it only arranges for the licensed broker, Category 2 or 3A if it deals or contracts with clients (confirm with the FSRA).
- FINMA Switzerland has no tied-agent or appointed-representative regime. A pure marketing brand of a licensed Swiss bank needs no license, but a white label that contracts with clients or holds their money needs its own bank or securities firm license.
- Bank of Lithuania No category in this register: a white label can run as a MiFID tied agent of the licensing broker (no separate license), otherwise it needs its own financial brokerage firm license.
- DFSA No appointed-representative or tied-agent route was identified in the DFSA regime, so a DIFC white-label brand needs its own license: Category 4 if it only markets and arranges for the principal broker, Category 2 or 3A if it contracts with clients or executes (confirm with the DFSA).
- SEC Licensed by the CFTC/NFA, not the SEC: the nearest US structure is a guaranteed IB of an RFED or FCM.
- MFSA No category in this register: a white label can run as a MiFID tied agent registered by its principal (no separate license), otherwise it needs its own Investment Services Licence.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- CBB Not confirmed: Category 3 firms are barred from acting as tied agents, implying a tied-agent concept, but the tied-agent regime was not researched; otherwise the brand needs its own Category 2 or Category 1 license depending on whether it deals as principal.
- SCB Bahamas No appointed-representative or tied-agent regime was found; a brand that deals in or markets CFDs in or from The Bahamas registers itself (CFD dealer, or arranging deals for a pure referral model). Uncertain: confirm with the SCB.
- SEC Nigeria No FX/CFD white-label route exists today; the proposed rules require brokers and technology providers to allocate compliance responsibility, and a separate Technology/Platform Provider registration at NGN 5 billion; no tied-agent regime for FX is proposed.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA; the nearest structure is a CFTC guaranteed IB.
- Labuan FSA No appointed-representative or white-label regime: the brand must hold its own money broking license, with substance in Labuan.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- BMA No appointed-representative or tied-agent route was identified; a Bermuda white-label operator needs its own standard license in the bucket matching its role. Class A registration is only for Bermuda-formed firms regulated by a recognized foreign regulator with no place of business in Bermuda.
- QFCRA No appointed-representative or tied-agent regime was identified; a white-label brand would need its own QFC authorization (arranging or dealing). Uncertain.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Prime-of-Prime
Liquidity provider / PoP
Deals as principal with brokers and institutions, redistributing prime liquidity; not retail.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions is Eigenhandel or own-account dealing in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Uncertain: principal dealing in leveraged FX with clients needs Type 3, but some dealings with banks and other professionals may fall under SFO exclusions or the LFET exemption rules; HKMA-authorized banks are exempt. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Uncertain: principal OTC derivatives dealing is Type I business, but certain transactions with financial institutions or qualified institutional investors may be excluded under the FIEA Enforcement Order; confirm before relying on an exclusion. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Dealing in investments as principal with brokers and institutions; GBP 750,000 PMR; this is the tier used for principal-model prime-of-prime and non-bank prime services. |
| ASIC#6 Australia | Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | AFSL limited to wholesale clients (s 761G) for dealing and market making in derivatives and FX; no fixed capital minimum beyond RG 166 base-level requirements; the usual route for prime-of-prime and liquidity providers. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Dealing as principal with brokers and institutions is a CMS dealing activity; base capital S$1 million for leveraged FX or OTC derivatives when serving only accredited, institutional or expert investors. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties (Category 2), USD 2 million base capital plus risk capital. |
| FINMA#10 Switzerland | Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | A securities firm license (own-account dealer or market maker, CHF 1.5 million) covers professional own-account dealing with institutions; banks also act as LPs under their bank license. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing as principal with brokers and institutions requires the EUR 750,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties only (no Retail Endorsement needed), USD 2 million base capital plus market and credit risk capital. |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing as principal with brokers and institutions needs the Art. 9(1) band (EUR 750,000); large firms may fall under CRR as Class 1 or Class 1 Minus. |
| CFTC · NFA#15 United States | Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | Dealing as principal in spot and deliverable FX forwards with eligible contract participants generally needs no CFTC registration; swap dealer registration (USD 20 million minimum capital) applies only if FX swaps such as NDFs or CFDs with ECPs exceed the de minimis threshold. Providing liquidity to an RFED or FCM does not by itself require RFED status. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | Dealing as principal in OTC derivatives with brokers and institutions is ODP activity under the FMA (trade-repository reporting and Joint Standard 2 of 2020 margin rules apply); no separate institutional-only category exists, and bank LPs rely on their Prudential Authority banking license. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Principal dealing with brokers and institutions fits the Full Service Dealer (excluding Underwriting) license (MUR 1,000,000); the Investment Dealer (Derivatives) category covers agency and exchange market making only and was not confirmed for an OTC principal book. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm dealing as principal with institutional counterparties, BD 1 million or risk-based capital; wholesale banks are the alternative. |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | USD 300 k | Dealing as principal in derivatives with brokers and institutions is dealing in capital markets instruments as principal (USD 300,000 floor under the older formula); add CFD registration where the instruments supplied are CFDs. |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | Uncertain: principal dealing in FX and derivatives with institutions fits a Labuan investment bank license (RM10 million paid-up capital, no deposit-taking); money brokers cannot act as principal. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Principal standard license (USD 250,000 minimum net assets); Class B registration excludes market intermediaries, so a liquidity provider cannot rely on it. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal with institutional and professional counterparties under BANK; base capital not confirmed. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4) | USD 122 k | Principal dealing with brokers and institutions needs the broker-dealer license; a firm dealing only with sophisticated or high-net-worth persons (entities with USD 5 million or more in assets) may register as a SIBA registered person instead, with no stated capital. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Principal dealing with brokers and institutions falls under the Securities Dealer license (USD 100,000); there is no separate institutional category. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Dealing in investments as principal with brokers and institutions, Category 1(b); the FSC sets capital case by case. |
Not available at 9 regulators
- SEC Not an SEC matter for FX: spot and deliverable forward FX dealing between eligible contract participants is largely outside registration, and NDFs and other FX swaps fall under the CFTC (swap dealer above the de minimis threshold).
- SAMA Interbank FX is dealt by SAMA-licensed banks; no separate non-bank FX liquidity license exists. A money changer license covers spot cash currency exchange only.
- SEC Nigeria No SEC category for FX/CFD liquidity provision; FX dealing as principal is the domain of CBN-licensed banks and authorized dealers, and the proposed rules do not mention liquidity providers.
- NYDFS Not licensed by NYDFS; FX dealing with institutions is largely outside registration or falls under CFTC swap dealer rules. A New York state-chartered bank conducts FX dealing under its banking charter, which is not a practical brokerage route.
- CMA UAE No wholesale-only principal dealing category for OTC FX was identified; the 'financial products dealer' activity under First Category may be relevant but its scope for OTC FX was not confirmed. Onshore interbank FX liquidity comes from CBUAE-licensed banks.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A VA OTC liquidity desk would need Broker-Dealer Services.
- CMA Kenya No CMA category covers institutional-only FX/CFD principal dealing; Kenyan dealing brokers hedge with offshore LPs or banks, and interbank FX dealing is done by CBK-licensed banks. Uncertain.
- CMA Saudi Not a CMA activity; interbank FX dealing is done by SAMA-licensed banks.
- CBUAE No non-bank FX dealing license exists at the CBUAE; interbank FX liquidity is provided by licensed banks (Licensed Bank at AED 2 billion or Restricted Licence Bank at AED 1 billion), which is not a practical route for a liquidity-provider start-up.
Every fitting category
49 categories at 30 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary |
| Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary |
| Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Matched-principal / agency broker Category 3A | USD 500 k | USD 40 k | USD 50 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary | |
| CBB#20 Bahrain | Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Retail FX / CFD broker First Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | — | — | Retail | Rulebook |
| Securities broker / dealer First Category – Dealing in Securities (trading broker, trading and clearing broker, international markets broker, financial products dealer) | USD 8.17 m | — | — | Retail | Rulebook | |
| QFCRA#28 Qatar · QFC | Principal dealer / broker Investment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Dealing / brokerage Dealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1)) | USD 13.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | Carrying / clearing broker-dealer Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)) | USD 250 k | USD 8 k | USD 1 k | Retail | Rulebook |
| CFTC · NFA#15 United States | FCM Futures commission merchant (CEA s.4d; Regulation 1.17) | USD 1 m | USD 2 k | USD 2 k | Retail | Rulebook |
| FCM offering retail forex FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | USD 26 k | USD 125 k | Retail | Rulebook | |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent) Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) | USD 300 k | USD 16 k | USD 8 k | Retail | To confirm |
| CFD dealer Registered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | USD 25 k | USD 45 k | Retail | Rulebook | |
| BMA#27 Bermuda | Investment dealer (principal) Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Agency broker SIBA Category 1, sub-category (a): Dealing in investments as agent | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary |
| Principal dealer / market maker SIBA Category 1, sub-category (b): Dealing in investments as principal | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Futures dealer Type 2 – Dealing in futures contracts (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| Securities margin financier Type 8 – Securities margin financing | USD 1.28 m | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Retail CFD/FX market maker AFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | USD 2 k | USD 83 k | Retail | Rulebook |
| MAS#8 Singapore | Securities and exchange-traded derivatives dealer CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives) | USD 39 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| OTC derivatives / CFD dealer CMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Commodity futures broker CMS license: Dealing in capital markets products (specified commodity futures) | USD 195 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bank Labuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | USD 500 (nominal) | USD 36 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | OTC derivative provider Authorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | USD 3 k | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | Full-service dealer with underwriting Investment Dealer (Full Service Dealer, including Underwriting) | USD 217 k | USD 3 k | USD 10 k | Retail | Rulebook |
| Full-service dealer Investment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | USD 1 k | USD 3 k | Retail | Rulebook | |
| Derivatives dealer Investment Dealer (Derivatives) | USD 22 k | USD 1 k | USD 3 k | Retail, with conditions | Rulebook | |
| SEC Nigeria#22 Nigeria | Broker-dealer Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services) | USD 1.33 m | USD 4 k | — | Retail | Rulebook |
| CMA Kenya#30 Kenya | Dealing online FX broker Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | USD 78 (nominal) | — | Retail | Rulebook |
| Broker-dealer Broker-Dealer (new hybrid category, LN 197 of 2025) | USD 543 k | USD 2 k | USD 2 k | Retail | Secondary | |
| Investment bank Investment Bank (LN 197 of 2025) | USD 1.16 m | USD 2 k | USD 2 k | Retail | Secondary | |
| FSA Seychelles#32 Seychelles | Securities dealer Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | USD 3 k | USD 6 k | Retail | Rulebook |
White-Label Brokerage
A brand operating under another firm’s license and infrastructure. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators23 of 34
Lowest capitalUSD 5 kSEC
Median capitalUSD 50 k
Retail clients allowed23 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Tied agent (white-label under another firm's license)
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Tied agent (white-label under another firm's license)
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities introducing agent / trader
- Capital
- USD 64 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 50 k
SEC
USD 5 k
FSC MauritiusUSD 13 k
CIMAUSD 18 k
SCB BahamasUSD 25 k
DFSAUSD 30 k
MASUSD 39 k
CFTC · NFAUSD 45 k
FSRAUSD 50 k
SFCUSD 64 k
SEC NigeriaUSD 67 k
Bank of LithuaniaUSD 87 k
MFSAUSD 87 k
BMAUSD 100 k
CMA UAEUSD 136 k
CMA KenyaUSD 233 k
1k10k100k1m
USD, logarithmic scale. Conversions are approximate.
Forex brokerage
Seven ways to run a forex broker
Each model asks for a different permission. Choose a model to see, at every regulator, the category to apply for and what it requires. A model is counted wherever any category permits it, so a count can exceed the regulators mapped to the system above.
B-book · dealing desk
Market maker
The broker takes the other side of each client trade and carries the market risk on its own book.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Proprietary trading for others (Eigenhandel) / dealing on own account; EUR 750,000 initial capital (Section 17(1) no. 1 WpIG) plus IFR own funds; BaFin's CFD general administrative act applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 leveraged foreign exchange trading (general case): HK$30 million paid-up capital and HK$15 million liquid capital, two responsible officers; CFDs on securities need Type 1 instead. Very few new Type 3 licenses are granted.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I Financial Instruments Business registration covers OTC derivatives including retail FX and CFDs; stock company with board, JPY 50 million stated capital and net assets, capital adequacy ratio of at least 120%, FFAJ membership effectively required.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Part 4A permission for dealing in investments as principal; GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4) plus fixed overheads and K-factor tests; this is the standard license for market-making FX/CFD brokers; COBS 22.5 applies to retail.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | AFSL authorizations to deal in and make a market in derivatives and FX contracts for retail clients (issuer of retail OTC derivatives); NTA of the greater of AUD 1 million or 10% of average revenue, half in cash (Instrument 2022/705, RG 166).Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | CMS license for dealing in capital markets products: spot FX for leveraged FX trading and, for CFDs on other underlyings, OTC derivatives; base capital S$5 million each where any retail customer is served, plus risk-based capital (Notice SFA 04-N13).Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (not as Matched Principal) in Category 2, USD 2 million base capital plus risk capital; FSRA lists market-maker CFD/FX brokers here.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | In practice Swiss retail FX/CFD market makers hold a bank license (CHF 10 million minimum capital), because FINMA has treated client margin balances held by non-banks as public deposits since about 2009; a securities firm license (CHF 1.5 million, own-account dealing and market making) may suffice only if client balances qualify as settlement accounts. Unconfirmed: confirm with FINMA.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing on own account in the EUR 750,000 band (Law on Markets in Financial Instruments Art. 14); market-maker and CFD principal models require this band; ESMA-derived retail CFD caps apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal (Category 2), USD 2 million base capital plus risk capital; a Retail Endorsement is needed to deal with retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing on own account under an Investment Services Licence in the IFD Art. 9(1) band; EUR 750,000 initial capital plus recovery and resolution rules; CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Acting as counterparty to retail off-exchange forex requires RFED registration (or FCM status with retail forex) and NFA Forex Dealer Member status, with adjusted net capital of at least USD 20 million plus 5% of retail forex obligations above USD 10 million.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing on own account (MiFID Annex I A(3)); EUR 750,000 initial capital (IFD Art. 9(1)), plus IFR fixed overheads and K-factor own funds; ESMA-derived retail CFD restrictions apply.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Issuing CFDs/rolling spot FX as principal requires ODP authorization under the Financial Markets Act 2012 (no fixed rand capital; about 6 months of liquid net assets per practitioner summaries, with bank-like capital rules for non-bank ODPs signalled in 2025), and retail distribution also needs a FAIS Category I license with subcategories 1.13/1.15 (own or a partner FSP).Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Dealing as principal for resale to clients falls under the Investment Dealer (Full Service Dealer, excluding Underwriting) license, MUR 1,000,000 stated unimpaired capital, PI cover, compliance officer and MLRO, and GBC substance if held through a GBC.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm (dealing in financial instruments as principal), BD 1 million minimum capital or the higher risk-based requirement; this is the CBB route for market-making brokers.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Dealing in FX and other CFDs as principal requires CFD registration under the Securities Industry (Contracts for Differences) Rules, 2020, either as a CFD-only firm or alongside dealing registration; capital is a Commission formula (r.13), with a USD 1,000,000 bank-deposit floor proposed in the 2026 draft amendment (not final as of October 2026), and a resident CFD Supervisory Officer.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; market-maker CFD brokers (e.g. Plus500, XTB, Deriv) hold this license, but the rulebook text read did not state expressly whether dealing as principal is permitted, so confirm with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Investment Business Act standard license as a principal investment provider, minimum net assets USD 250,000 (or 8% of risk-weighted assets) plus liquid assets of three months' expenditure.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal, prudentially regulated under BANK (base capital not confirmed); retail FX/CFD brokerage is not an established QFC model, so this is realistic only for business and professional clients.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | SIBA license for dealing in securities and market making; base financial resource requirement CI$100,000 (higher of that and a quarter of annual expenditure plus risk requirements), professional indemnity cover of CI$1 million per claim, monthly financial statements; retail FX/CFD brokers use this license.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | A Dealing Online Foreign Exchange Broker trades as principal and market maker (Reg. 2, Online FX Trading Regulations 2017); KES 50 million paid-up capital, liquid capital of the higher of KES 30 million or 8% of liabilities, Kenyan-incorporated company.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The Securities Dealer license covers dealing in securities including CFDs and FX as principal (B-book); USD 100,000 paid-up capital since the Securities (Amendment) Act 2024, physical office, two natural-person directors, licensed representative and compliance officer.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | SIBA Category 1(b), dealing as principal including taking the other side of client trades; no fixed minimum capital, as the FSC sets financial resources case by case under Regulatory Code s. 181 (advisers budget about USD 1 million) and expects more for principal dealing.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: a retail FX counterparty must be an RFED or an FCM. SEC broker-dealer dealer status covers securities only, and CFDs on US securities (security-based swaps) cannot be offered off-exchange to non-ECP retail clients.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No SEC category for retail FX/CFD market making is currently in force; SEC proposed rules of 1 September 2026 would create a B-book/market-making forex broker registration at NGN 3 billion paid-up capital, and FX itself is under CBN control.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM). No NYDFS category covers acting as counterparty to FX or CFD trades.
- Labuan FSA Not permitted: Labuan money brokers may not act as principal (Money Broking Guidelines, 9 September 2024), and retail FX/CFD brokerage is not available in Labuan. A Labuan investment bank (RM10 million) may deal FX as principal but only with institutional clients, not as a retail B-book.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A principal desk dealing only in virtual assets would need Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book · no dealing desk
STP / agency
Orders pass straight through to liquidity providers; the broker acts as agent or matched principal and keeps no market risk.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 covers both dealing-desk and STP brokers (the SFC's review found most Type 3 firms hedge back-to-back with liquidity providers); same HK$30 million paid-up capital; disclose any affiliate liquidity provider in the execution policy.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Brokerage or intermediation of OTC FX derivatives is also Type I business, so an STP broker needs the same registration and JPY 50 million capital.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 200 k | Agency execution / arranging with permission to hold client money (CASS) is the GBP 150,000 tier; a matched-principal STP model is dealing as principal and generally needs the GBP 750,000 permission (we did not confirm whether MIFIDPRU 4.4 gives matched-principal firms a lower PMR).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | An Australian STP broker is still the issuer of the OTC derivative to its retail client, so it needs the same issuer and market-making authorizations and AUD 1 million NTA as a market maker.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | The CMS dealing license covers dealing as principal or agent, so an STP broker needs the same license and S$5 million base capital for retail clients; no lighter agency-only FX category exists.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Matched-principal / agency brokerCategory 3A | USD 500 k | Dealing in Investments as Agent or as Matched Principal (Category 3A), USD 500,000 base capital, rising to USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients.Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | An agency broker that keeps client accounts needs a bank or securities firm license (securities firm keeping client accounts, CHF 1.5 million); which one applies to OTC FX/CFD balances was not confirmed. A firm that only forwards orders to a licensed bank without holding money needs no FINMA license (see introducing broker).Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 174 k | Agency execution holding client money is in the EUR 150,000 band; a matched-principal STP model is dealing on own account and needs the EUR 750,000 band.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A Principal dealer / credit providerCategory 2 | USD 200 k | Pure agency (Dealing in Investments as Agent) is Category 3A at USD 200,000 base capital after the CP161 reforms (secondary); since the 2025 PIB amendments, matched-principal A-book dealing sits in Category 2 (USD 2 million; a lower matched-principal figure is reported but unconfirmed).Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 87 k | Agency execution / RTO holding client money is the IFD Art. 9(3) band (EUR 150,000); a matched-principal STP model counts as dealing on own account and needs the Art. 9(1) band (EUR 750,000).Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Only an RFED or FCM may accept retail forex orders and funds, so an STP broker that hedges back-to-back with liquidity providers still registers as an RFED/FCM and holds the USD 20 million minimum; there is no lighter agency-only category for retail forex.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 174 k | Agency execution / reception and transmission of orders with client money needs the EUR 150,000 tier (IFD Art. 9(3)); a matched-principal (riskless principal) STP set-up is dealing on own account and needs the EUR 750,000 tier, as the data notes for matched-principal models.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | A pure agent passing orders to a third-party issuer needs FAIS Category I (1.13 derivatives, 1.15 forex investment business); a matched-principal STP that is itself the client's counterparty on the CFD still needs ODP authorization, since FAIS does not permit issuing OTC derivatives.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) BrokerInvestment Dealer (Broker) | USD 13 k | Agency-only order routing to a third-party LP fits the Discount Broker (execution-only, MUR 600,000) or Broker (with advice/portfolio management, MUR 700,000) categories; a matched-principal STP that is counterparty to the client should take the Full Service Dealer license instead.Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | Category 2 investment firm (all services except dealing as principal, including agency dealing and holding client money), BD 250,000 minimum capital. Whether CBB treats riskless matched-principal as principal dealing (Category 1) was not confirmed.Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | The CFD Rules cover dealing in, providing or marketing CFDs in or from The Bahamas regardless of hedging model, so an STP broker also registers as a CFD dealer; same capital and resident-officer conditions as a market maker.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Labuan money broking license (arranging FX and money market deals only), RM1 million paid-up capital; clients limited to institutional investors and high-net-worth individuals, non-residents of Malaysia only, operational office in Labuan.Retail leverage No retail FX/CFD offering permitted. For eligible institutional and high-net-worth clients of money brokers, maximum leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards (Money Broking Guidelines, 9 September 2024). |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | First Category OTC derivatives and spot FX trading broker, AED 30 million paid-up capital; covers brokerage of OTC derivatives and spot FX for onshore clients, including retail.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | Standard license acting as agent, minimum net assets USD 100,000 plus three months' liquid assets; a matched-principal model may fall in the principal bucket, so confirm with the BMA.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Agency dealing is listed within this category's permits; whether a pure agency broker is placed under BANK or INMA was not confirmed, and retail FX/CFD is not an established QFC model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Dealing as agent is also covered by the broker-dealer SIBA license, with the same CI$100,000 base financial resources.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | A Non-Dealing Online Foreign Exchange Broker links clients to the FX market for commission or mark-up and does not make markets (Reg. 2); KES 30 million paid-up capital, same liquid-capital test.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | The same Securities Dealer license covers dealing as agent; there is no lower agency-only category, so the USD 100,000 capital applies.Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Category 1(a) for agency execution; a matched-principal STP model is principal dealing and falls under 1(b). Category 2 (arranging) is commonly added.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 7 regulators
- SEC Licensed by the CFTC/NFA, not the SEC: retail forex orders can be accepted only by an FCM or RFED, whatever the execution model.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria Not yet licensable; the proposed rules (1 September 2026) would create an STP/ECN/A-book broker registration at NGN 2 billion paid-up capital, and the existing Broker category covers securities only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Agency or matched-principal brokerage of virtual assets is Broker-Dealer Services.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
A-book and B-book
Hybrid
Part of the flow is internalized and part passed on; the license must allow dealing as principal.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by BaFin's 2019 general administrative act on CFDs). |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CSSF national measures). |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Type 3 general case, as for a market maker; the client agreement must state whether the firm takes the opposite side of client trades.Retail leverage About 20:1 for leveraged FX: the SFC sets a 5% minimum margin on leveraged foreign exchange contracts (secondary source; legal basis not read here). CFDs on securities are dealt under Type 1, not Type 3. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Type I registration as for a market maker; mandatory loss-cut rules and trust segregation of client margin apply.Retail leverage 25:1 for individual customers on currency derivatives (4% minimum margin, since 1 August 2011, Cabinet Office Order on Financial Instruments Business); 2:1 for crypto-asset derivatives. Corporate accounts use a risk-based margin computed by the FFAJ (secondary). Caps for non-FX CFDs were not confirmed here. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Internalizing any client flow requires the dealing-as-principal permission and the GBP 750,000 PMR; CASS client-money permission is also needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; crypto-asset CFDs cannot be sold to retail clients at all (ESMA product intervention made permanent by FCA COBS 22.5; crypto derivatives ban in COBS 22.6 since January 2021). |
| ASIC#6 Australia | Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | USD 700 k | Same retail OTC derivatives issuer AFSL as a market maker; AUD 1 million NTA.Retail leverage 30:1 major FX pairs, 20:1 minor FX pairs, gold and major stock indices, 10:1 other commodities and minor indices, 5:1 equities, 2:1 crypto assets (ASIC Corporations (Product Intervention Order - Contracts for Difference) Instrument 2020/986, in force 29 March 2021, extended to 23 May 2027). Consultation CS 64 (closing 9 November 2026) proposes extending it to 2037 and covering crypto-settled CFDs. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Central Bank of Ireland national CFD measures). |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Same CMS dealing license as a market maker, with S$5 million base capital for retail; conflict management and execution policy apply.Retail leverage 20:1 maximum for retail leveraged FX (5% minimum margin), effective 8 October 2019 under the Securities and Futures (Financial and Margin Requirements for Holders of Capital Markets Services Licences) Regulations as amended by S 668/2018; accredited investors were previously able to obtain up to 50:1. Lower caps for non-FX CFDs were not confirmed from MAS text here. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Keeping any B-book risk is dealing as principal, so Category 2 (USD 2 million plus risk capital).Retail leverage 30:1 major FX pairs and relevant sovereign debt, 20:1 non-major FX, gold and major equity indices, 10:1 commodities (excluding gold) and non-major indices, 5:1 individual equities, 2:1 virtual assets (minimum initial margins of 3.33%/5%/10%/20%/50% under FSRA conditions on OTC leveraged product providers, carried into COBS chapter 23 via Consultation Paper No. 5 of 2022). |
| FINMA#10 Switzerland | BankBank license (Banking Act) Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | Same as the market maker: internalizing flow is own-account dealing; established Swiss practice is a bank license.Retail leverage No statutory retail leverage cap; FINMA did not adopt the ESMA measures, and Swiss bank brokers set their own limits (for example up to 100:1 or 200:1 on major FX). Source basis: absence of a FinSA/FINMA leverage rule, per trade press. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Internalizing any client flow is dealing on own account, so the EUR 750,000 band is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by Bank of Lithuania national measures). |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Internalizing any flow is dealing as principal, so Category 2 (USD 2 million plus risk capital), with a Retail Endorsement for retail clients.Retail leverage 30:1 major FX pairs, 20:1 minor FX, gold and major indices, 10:1 other commodities and minor indices, 5:1 shares and other underlyings, 2:1 crypto, as applied by DFSA-licensed brokers to retail clients (broker disclosures state these are fixed by DFSA requirements; the rule reference was not read in the DFSA rulebook). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Internalizing any client flow is dealing on own account, so the Art. 9(1) band (EUR 750,000) is needed.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by MFSA national measures). |
| CFTC · NFA#15 United States | RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | USD 20 m | Internalizing any retail flow is acting as counterparty, so RFED or FCM registration with USD 20 million minimum adjusted net capital is required.Retail leverage 50:1 on major currencies (2% minimum security deposit: GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK, DKK) and 20:1 on all other currency pairs (5%) (CFTC Regulation 5.9; NFA Financial Requirements s.12). NFA can raise margins in volatile markets. CFDs on any other underlying may not be offered to US retail clients. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Internalizing any part of client flow is dealing on own account, so the EUR 750,000 tier is needed, with a conflicts-of-interest and order-execution policy covering the A/B split.Retail leverage 30:1 major FX pairs; 20:1 non-major FX, gold and major indices; 10:1 commodities other than gold and non-major indices; 5:1 individual equities and other underlyings; 2:1 crypto-assets (ESMA product intervention 2018, made permanent by CySEC national product intervention measures). |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Internalising any flow means acting as principal on OTC derivatives, so ODP authorization is needed, plus FAIS Category I for retail distribution.Retail leverage No statutory retail leverage cap for FX/CFDs was identified: neither the FMA Regulations 2018, FSCA Conduct Standard 1 of 2018 nor FAIS sets maximum leverage, and brokers set their own limits. One industry table lists 200:1 majors and 50:1 minors/gold/indices for the FSCA, but with no rule basis, so it is treated as unverified. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Any internalization is principal dealing, so the Full Service Dealer (excluding Underwriting) license is needed (MUR 1,000,000).Retail leverage No statutory retail leverage cap for FX/CFDs was identified in the Securities Act 2005 or the Securities (Licensing) Rules 2007. One industry table lists 100:1 majors and 50:1 minors/gold/indices for the FSC, but with no rule basis, so it is treated as unverified. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Internalizing any flow is dealing as principal, so Category 1 (BD 1 million or risk-based capital).Retail leverage No CBB-specific retail leverage cap for FX/CFDs was identified in the CBB Rulebook (the only margin limits found apply to bank margin lending on listed equities, BC-8). Treat as uncertain and confirm with the CBB. |
| SCB Bahamas#21 The Bahamas | CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | — | Same CFD dealer registration as a market maker; disclose the internalization policy and conflicts in the order execution policy.Retail leverage In force: 200:1 for most CFDs including FX (0.5% minimum retail margin) and 20:1 for digital asset CFDs (5%) (Securities Industry (Contracts for Differences) Rules, 2020, r.23). The 2026 draft amendment would replace fixed margins with an SCB-approved margin policy per firm; not final as of October 2026. |
| CMA UAE#25 UAE · Federal | Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market) | USD 8.17 m | Same First Category OTC license (AED 30 million) as the market-maker model; principal-dealing scope to be confirmed with the CMA.Retail leverage No CMA (formerly SCA) retail leverage cap for OTC FX/CFDs was confirmed; a 2021 press report said the SCA and CBUAE set no leverage limit, and the 2025-26 capital markets overhaul may change this. Treat as uncertain. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Any internalized flow means dealing as principal: principal standard license, USD 250,000 minimum net assets.Retail leverage No retail FX/CFD leverage caps: Bermuda has no dedicated retail FX/CFD conduct regime and none were found. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Principal dealing under BANK, with the same retail limitation as the market-maker model.Retail leverage No retail FX/CFD offering established: the register finds retail FX/CFD brokerage is not available in or from the QFC, and no QFCRA leverage caps were identified. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager | USD 122 k | Broker-dealer / market maker SIBA license covers both principal and agency flow.Retail leverage No statutory retail FX/CFD leverage cap found in CIMA rules or guidance; brokers set leverage under their risk policies. Not confirmed against all CIMA rules. |
| CMA Kenya#30 Kenya | Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 388 k | Any internalization is market making, so the Dealing Online Foreign Exchange Broker license (KES 50 million) is needed.Retail leverage Maximum 400:1 on any currency pair or instrument (Capital Markets (Online Foreign Exchange Trading) Regulations 2017, Reg. 19(1)); the CMA may revise the ratio by circular (Reg. 19(2)). No separate tiers by asset class. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Covered by the Securities Dealer license, which permits both agency and principal dealing (USD 100,000).Retail leverage No statutory retail leverage cap: neither the Securities Act 2007 (as amended 2024) nor FSA guidelines limit FX/CFD leverage, as confirmed by secondary sources. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agent | — | Principal dealing (1(b)) for internalized flow plus agency dealing (1(a)) for passed-through flow.Retail leverage No BVI-specific retail FX/CFD leverage cap found (law-firm guides); leverage is set by the firm's risk policy. |
Not available at 8 regulators
- SEC Licensed by the CFTC/NFA, not the SEC (RFED or FCM counterparty status).
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- SEC Nigeria No category in force; under the proposed rules a hybrid would need the market-making (B-book) broker registration at NGN 3 billion.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (RFED or FCM).
- Labuan FSA Not permitted: internalizing flow requires principal dealing, which money brokers are prohibited from doing.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Multilateral matching
ECN / MTF venue
A venue where many participants’ orders meet; licensed as an exchange, MTF or OTF, not as a broker.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| SFC#3 Hong Kong | Automated trading venueType 7 – Providing automated trading services | USD 642 k | Uncertain: Type 7 automated trading services (HK$5 million paid-up capital) covers electronic venues for securities and futures contracts; whether a multilateral leveraged-FX venue falls under Type 7 or Type 3 was not confirmed. |
| FCA#5 United Kingdom | Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | Operating an MTF without own-account dealing is in the GBP 150,000 tier (an OTF with own-account dealing needs GBP 750,000); a recognized investment exchange is a heavier, separate route, and most new venues start as MTFs. |
| ASIC#6 Australia | Licensed market operatorAustralian market license (Corporations Act Part 7.2) | — | A multilateral venue is a financial market requiring an Australian market license (Part 7.2), unless exempt; no fixed capital, adequate resources required (s 792A). |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| MAS#8 Singapore | Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | A multilateral trading venue is an organized market operated as a Recognised Market Operator (higher of S$250,000 or 25% of annual operating expenses for a Singapore RMO). Uncertain: whether a spot FX matching venue counts as an organized market was not confirmed. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Operating an MTF or OTF is a Category 4 activity (USD 50,000 base capital), but MTF/OTF operators remain subject to the Expenditure-Based Capital Minimum and FSRA market-operator requirements; a virtual-asset MTF is a separate category. |
| FINMA#10 Switzerland | Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA) | USD 1.25 m | A stock exchange or MTF license (CHF 1 million minimum, FinMIO Art. 13) covers multilateral trading of securities; spot FX is not a security under FinMIA, so an FX-only matching venue may fall outside it. Uncertain. |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band | USD 174 k | Operating an MTF falls in the EUR 150,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operatorCategory 3A | USD 200 k | Operating an Alternative Trading System (DIFC term for MTF/OTF) moved from Category 4 to Category 3A under the 2025 PIB amendments; ATS operators must also meet the AMI/ATS market-integrity rules (effective date of the move reported as July 2025 or July 2026 by different advisers). |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Operating a trading facility is listed only under the Art. 9(1) license scope, but since the September 2025 amendment (Part BI R1-5.1.2) an MTF operator that does not deal on own account has EUR 150,000 initial capital; confirm the license scope with the MFSA. |
| CFTC · NFA#15 United States | DCM (futures exchange)Designated contract market (CEA s.5; Part 38) SEFSwap execution facility (CEA s.5h; Part 37) | — | Off-exchange retail forex cannot be run as a multilateral venue for non-ECP retail clients: an FX futures venue is a DCM (retail access via FCMs) and an FX swap/NDF venue is a SEF (ECPs only); institutional spot FX ECNs fall largely outside CFTC registration. Both need financial resources covering one year of operating costs. |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | Operating a multilateral trading facility (MiFID Annex I A(8)) without own-account dealing falls in the EUR 150,000 tier; the operator may not execute client orders against its own capital on the MTF. Few retail FX/CFD venues are true MTFs. |
| FSCA#17 South Africa | Licensed exchangeExchange license, Financial Markets Act 2012 | — | A multilateral venue for securities including derivative instruments must be a licensed exchange under the FMA 2012 (liquid net assets of at least 6 months' operating expenses, reg. 8 of GN R98); no MTF-style lighter category exists, and whether an OTC FX matching venue falls inside the exchange definition should be confirmed with counsel. |
| SCB Bahamas#21 The Bahamas | MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024) | — | A multilateral venue for capital markets instruments is registered as a marketplace under the Securities Industry Act, 2024, with SCB-approved rulebook and systems and capital set case by case; no FX-specific venue category exists. |
| SEC Nigeria#22 Nigeria | Securities exchange (non-composite)Non-Composite Securities Exchange | USD 3.33 m | Only an exchange-traded venue (e.g. FX derivatives on a securities exchange such as FMDQ) is licensable today, as a Non-Composite Securities Exchange at NGN 5 billion; an OTC FX/CFD matching venue has no category and would also need CBN involvement. Uncertain. |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB) | — | Uncertain: a multilateral venue would need Labuan exchange approval (LFSSA s.134) with capital set case by case; no FX-specific venue guideline was found. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The 2017 FX regulations have no venue category; the OTC Platform provider category under LN 197 of 2025 is the closest fit for a multilateral OTC venue, but its capital and whether it extends to online FX/CFDs are unconfirmed. |
| FSA Seychelles#32 Seychelles | Securities exchangeSecurities Exchange license (Securities Act 2007) | — | A multilateral venue would need a Securities Exchange license (sole activity, at least three independent dealer members, clearing, surveillance and compensation arrangements); whether the FSA would treat an OTC FX/CFD matching venue this way is uncertain. |
| BVI FSC#34 British Virgin Islands | Investment exchangeSIBA Category 7: Operating an investment exchange | — | Category 7 covers providing a facility for orderly trading of investments; whether an FX/CFD matching venue fits was not confirmed, so check with the FSC. |
Not available at 13 regulators
- FSA Japan Uncertain: the PTS authorization covers securities venues only; no Chart Room category for a multilateral retail FX venue was identified. Electronic trading platforms for certain OTC derivatives exist under the FIEA but were not confirmed for FX.
- SEC No SEC category for an FX venue; spot FX is not a security. The SEC ATS and exchange categories cover securities only; FX futures venues are CFTC DCMs and FX swap/NDF venues are CFTC SEFs.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- FSC Mauritius No venue category is in this register: operating a multilateral market requires a Securities Exchange license from the FSC under the Securities Act 2005, which is not recorded here.
- CBB No investment-firm category covers running a multilateral venue; licensed exchanges are authorized under CBB Volume 6 (market operators), which is not in this register.
- NYDFS Not licensed by NYDFS; FX futures venues are CFTC DCMs and FX swap venues are CFTC SEFs.
- CMA UAE No CMA category for operating an OTC FX/CFD multilateral venue was identified in the data; exchange and platform licensing outside the virtual-asset Seventh Category is not covered, so confirm with the CMA.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A virtual-asset matching venue, including exchange-traded VA derivatives under the March 2026 Part V rules, is Exchange Services; fiat-currency matching is excluded.
- BMA No category for operating a multilateral FX trading venue is in the register; exchange recognition is outside these license types. Uncertain.
- QFCRA No category for operating a multilateral trading venue was identified in the QFCRA data; onshore exchange-traded markets fall under the QFMA.
- CIMA No category in this register for a multilateral FX/CFD venue; the Cayman Islands Stock Exchange is a separate listing exchange. Not confirmed whether operating a matching platform would need a SIBA license.
- CMA Saudi Not available: the Saudi Exchange (Tadawul) is the only licensed exchange and there is no OTC FX venue license.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Referral and arranging
Introducing broker
Brings clients to a licensed broker without executing trades or holding client money.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| CSSF#2 Luxembourg | Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | Type 3 approved introducing agent: HK$5 million paid-up and HK$3 million liquid capital; may not carry client positions or hold client assets. |
| FCA#5 United Kingdom | Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | USD 100 k | Own Part 4A permission for arranging deals / making arrangements without client money (GBP 75,000 PMR), or act as an appointed representative (including an introducer AR) of an authorized broker that accepts responsibility. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Typically a corporate authorized representative of the issuing licensee (no own capital requirement), or the firm's own AFSL with dealing (arranging) authorization; ASIC has scrutinized CAR use in OTC derivatives. |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) | USD 780 k | Uncertain: the SFA definition of dealing includes inducing a person to enter into a transaction, so an introducer soliciting Singapore clients generally needs its own CMS dealing license or must act through the licensee's notified representatives; MAS has no dedicated IB license. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operatorCategory 4 | USD 50 k | Arranging Deals in Investments (Category 4), USD 50,000 base capital from 19 August 2025; no EBCM if no Client Assets are held. FSRA proposed barring authorized firms from accepting paid retail referrals from unregulated third parties, so IBs introducing retail clients should be FSRA-authorised. |
| Bank of Lithuania#11 Lithuania | Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band | USD 87 k | RTO / arranging without client money in the EUR 75,000 band. The financial advisor company license does not fit because it covers only transferable securities and fund units, not CFDs or FX derivatives. Tied-agent status under MiFID II Art. 29 is also possible but is not a category in this register. |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arrangerCategory 4 | USD 30 k | Arranging Deals in Investments (Category 4), USD 30,000 base capital after the 2026 amendments (secondary); no execution or client money. A Representative Office is not an option: since April 2015 the DFSA will not accept Representative Office applications from firms marketing FX or other highly leveraged products to retail clients. |
| MFSA#14 Malta | Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | RTO / advice without holding client money in the IFD Art. 9(2) band (EUR 75,000); orders must go to an authorized broker; the professional-only variant (legacy 1B) has the same capital. Tied-agent status is also possible under MiFID II Art. 29 but is not a category in this register. |
| CFTC · NFA#15 United States | Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | USD 45 k | Soliciting retail forex for an RFED/FCM without holding customer funds requires IB registration and NFA membership: independent IB with at least USD 45,000 adjusted net capital, or guaranteed IB with no capital requirement but introducing only to its guarantor. |
| CySEC#16 Cyprus | Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | USD 87 k | Own license: reception and transmission of orders / arranging without holding client money in the EUR 75,000 tier (IFD Art. 9(2)); alternatively register as a tied agent of one licensed broker (MiFID II Art. 29), with no capital but only one principal. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Introducing or arranging for clients is a FAIS intermediary service, so a Category I license (1.13/1.15) or appointment as a representative of a licensed FSP is needed; referral to offshore brokers while collecting local rand deposits has drawn SARB exchange-control action. |
| CBB#20 Bahrain | Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b)) Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | Category 3 (arranging and advising, BD 25,000 plus liquid funds of 25% of prior-year operating expenses) only fits an IB paid by its clients, because Category 3 firms must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent; a rebate-funded IB therefore needs Category 2 (BD 250,000). |
| SCB Bahamas#21 The Bahamas | Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | Introducing clients to a dealer without dealing is arranging deals (USD 25,000 floor under the older formula); the CFD Rules also capture marketing CFDs in or from The Bahamas, so check with the SCB whether an introducer also needs CFD registration. |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only | USD 236 k | Uncertain: arranging FX transactions from Labuan falls within money broking (RM1 million); no lighter introducer category exists. An introducer based outside Labuan is governed by its own jurisdiction. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | Fifth Category introducing and promotion, AED 500,000 paid-up capital; may introduce UAE clients to an offshore or free-zone broker but may not hold client assets or execute. Most CFD brokers entering the UAE (XM, Exinity, Pepperstone and others) use this route. |
| BMA#27 Bermuda | Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | Arranging deals without dealing as agent or principal: standard license (neither agent nor principal), minimum net assets USD 12,000 plus one month's liquid assets. |
| QFCRA#28 Qatar · QFC | Investment adviser / arrangerAdvisory and arranging firm (INMA 2014) | USD 250 k | Arranging deals in investments (INMA advisory and arranging firm), base capital about USD 250,000 restated in QAR plus 13/52 of annual operating expenses; no client money. A December 2025 consultation may lower requirements for wholesale advisers. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | SIBA license for arranging deals in securities; CI$15,000 base financial resources plus professional indemnity insurance. |
| CMA Kenya#30 Kenya | OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | — | The FX regulations have no introducing-broker category; the Intermediary Service Platform provider category (LN 197 of 2025), granted to Safaricom and Airtel Money in December 2025 for onboarding and market access, is the closest fit, but its use for FX referral is unconfirmed, and offshore brokers may not serve Kenyan clients. |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | SIBA Category 2, arranging deals in investments, including introducing clients to dealers. |
Not available at 11 regulators
- FSA Japan Not a Chart Room category: an introducer registers as a Financial Instruments Intermediary Service Provider (FIEA Art. 66) tied to a Type I firm, or registers as Type I itself. Unregistered solicitation of Japanese residents is prohibited.
- FINMA No FINMA license for pure referral without handling client money or orders. A firm that transmits orders provides a FinSA financial service, so its client advisers must be in the FinSA adviser register unless the firm is supervised; AML SRO membership may apply if it acts as a financial intermediary. Uncertain.
- SEC Licensed by the CFTC/NFA, not the SEC: introducing retail forex accounts requires CFTC introducing broker registration and NFA membership; an SEC introducing broker-dealer status does not cover FX.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime. SAMA's 2017 circular prohibits marketing by foreign forex firms without a contract with a licensed Saudi institution.
- FSC Mauritius No dedicated introducing-broker category was found; whether pure referral is licensable is uncertain, and if the firm advises it needs Investment Adviser (Restricted), or if it receives and transmits orders, Investment Dealer (Broker).
- SEC Nigeria No category in force; the proposed rules would create Corporate Introducing Broker (NGN 150 million) and Individual Introducing Broker (NGN 30 million) registrations and would ban referral incentives. The existing Sub-Broker (Digital) category routes securities orders only.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA (CFTC introducing broker with NFA membership).
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). Arranging orders in virtual assets falls under Broker-Dealer Services.
- CMA Saudi No fit: Arranging covers securities only, and a 2017 SAMA circular prohibits foreign forex companies without contracts with licensed Saudi institutions from marketing in the Kingdom.
- FSA Seychelles No introducing-broker category exists in the register, and a secondary source reports no FSA restrictions on IBs; if the firm gives advice it needs an Investment Adviser license (USD 25,000). Treatment of a Seychelles-based referral business is uncertain.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022. Introducing to brokers is the CMA Fifth Category.
A brand on a host license
White label
Operates its own brand on another firm’s license and platform, often as its appointed representative.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| SFC#3 Hong Kong | Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | No tied-agent or appointed-representative regime: a Hong Kong-facing brand must be licensed itself, usually as a Type 3 introducing agent referring clients to the executing Type 3 firm. |
| FCA#5 United Kingdom | Appointed representative (white-label)Appointed representative / tied agent (SUP 12) | — | Appointed representative of the principal broker under SUP 12; no separate license or capital, but the principal must notify the FCA 30 days ahead and oversee the AR, and the AR cannot deal as principal or hold client money. |
| ASIC#6 Australia | Authorized representative modelCorporate authorized representative (CAR) of an AFS licensee | — | Corporate authorized representative of the AFS licensee; no separate license, but the CAR cannot issue products in its own right and the licensee remains responsible. |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bank | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| CFTC · NFA#15 United States | Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | No white-label license exists; a US-facing brand on another firm's platform must register itself, usually as a guaranteed IB of the RFED/FCM (closest equivalent to an appointed representative), since anyone soliciting retail forex must be registered. |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register) | — | No separate license if run as a tied agent of the licensing broker, which stays fully responsible; the tied agent may not hold client money and may act for only one principal. A white label that contracts with clients or holds money in its own name needs its own investment firm license. |
| FSCA#17 South Africa | Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | Most South African CFD brands hold their own FAIS Category I license and distribute a third-party ODP's products; alternatively the brand can operate as a juristic representative of a licensed FSP under the FAIS Act without its own license, with the FSP remaining responsible. |
| FSC Mauritius#19 Mauritius | Execution-only brokerInvestment Dealer (Discount Broker) | USD 13 k | No tied-agent or appointed-representative regime for corporate white labels was identified, so a white label serving clients from Mauritius generally needs its own Investment Dealer license, commonly the Discount Broker category on a partner's platform and liquidity. |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducerFifth Category – Arranging and Advice | USD 136 k | No tied-agent or appointed-representative regime was identified; a white-label brand marketing onshore needs at least a Fifth Category promotion license, and a First Category OTC license if it contracts with or executes for clients. |
| CIMA#29 Cayman Islands | Licensed arranger / adviserSIBA license - arranging deals or advising | USD 18 k | Cayman has no appointed-representative or tied-agent regime, so a white label carrying on securities investment business from the Cayman Islands needs its own SIBA license, at least the arranging license if the partner broker is the counterparty. Not confirmed. |
| CMA Kenya#30 Kenya | Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | No tied-agent or appointed-representative regime exists; a white label serving Kenyan clients needs its own CMA online FX license, typically non-dealing, held by a Kenyan-incorporated company, with a service level agreement with the platform provider (Reg. 4(2)(j)). |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | No tied-agent or appointed-representative regime was identified, so a white label dealing with clients from Seychelles needs its own Securities Dealer license (USD 100,000, local office and staff). |
| BVI FSC#34 British Virgin Islands | Arranger / introducing brokerSIBA Category 2: Arranging deals in investments | — | The BVI has no tied-agent or appointed-representative regime, so a BVI white label needs its own SIBA license: Category 2 if the partner broker deals with the clients, Category 1 if it deals itself. Not confirmed. |
Not available at 19 regulators
- FSA Japan No dedicated pathway: the brand must register itself (Type I) or act as a Financial Instruments Intermediary Service Provider tied to the registered firm; that intermediary status is not a Chart Room category.
- MAS No dedicated pathway: a brand must hold its own CMS license or act through the licensee's notified representatives; MAS has no appointed-representative regime for firms.
- FSRA No appointed-representative or tied-agent regime was identified for ADGM, so a white-label brand needs its own FSRA permission: Category 4 if it only arranges for the licensed broker, Category 2 or 3A if it deals or contracts with clients (confirm with the FSRA).
- FINMA Switzerland has no tied-agent or appointed-representative regime. A pure marketing brand of a licensed Swiss bank needs no license, but a white label that contracts with clients or holds their money needs its own bank or securities firm license.
- Bank of Lithuania No category in this register: a white label can run as a MiFID tied agent of the licensing broker (no separate license), otherwise it needs its own financial brokerage firm license.
- DFSA No appointed-representative or tied-agent route was identified in the DFSA regime, so a DIFC white-label brand needs its own license: Category 4 if it only markets and arranges for the principal broker, Category 2 or 3A if it contracts with clients or executes (confirm with the DFSA).
- SEC Licensed by the CFTC/NFA, not the SEC: the nearest US structure is a guaranteed IB of an RFED or FCM.
- MFSA No category in this register: a white label can run as a MiFID tied agent registered by its principal (no separate license), otherwise it needs its own Investment Services Licence.
- SAMA No SAMA license fits: SAMA licenses banks, finance, payment and money-changing firms, not leveraged FX brokerage, and Saudi Arabia has no retail OTC FX/CFD regime.
- CBB Not confirmed: Category 3 firms are barred from acting as tied agents, implying a tied-agent concept, but the tied-agent regime was not researched; otherwise the brand needs its own Category 2 or Category 1 license depending on whether it deals as principal.
- SCB Bahamas No appointed-representative or tied-agent regime was found; a brand that deals in or markets CFDs in or from The Bahamas registers itself (CFD dealer, or arranging deals for a pure referral model). Uncertain: confirm with the SCB.
- SEC Nigeria No FX/CFD white-label route exists today; the proposed rules require brokers and technology providers to allocate compliance responsibility, and a separate Technology/Platform Provider registration at NGN 5 billion; no tied-agent regime for FX is proposed.
- NYDFS Not licensed by NYDFS; retail forex is licensed by the CFTC/NFA; the nearest structure is a CFTC guaranteed IB.
- Labuan FSA No appointed-representative or white-label regime: the brand must hold its own money broking license, with substance in Labuan.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore).
- BMA No appointed-representative or tied-agent route was identified; a Bermuda white-label operator needs its own standard license in the bucket matching its role. Class A registration is only for Bermuda-formed firms regulated by a recognized foreign regulator with no place of business in Bermuda.
- QFCRA No appointed-representative or tied-agent regime was identified; a white-label brand would need its own QFC authorization (arranging or dealing). Uncertain.
- CMA Saudi No CMA license fits: there is no CMA regime for retail OTC FX/CFD trading, and the Dealing license covers securities as defined by the CMA (including securities-based derivatives), not OTC FX.
- CBUAE Not licensed by the CBUAE: onshore OTC FX/CFD brokers are licensed by the CMA (formerly SCA); CBUAE-regulated brokers were moved to SCA from 2022.
Prime-of-Prime
Liquidity provider / PoP
Deals as principal with brokers and institutions, redistributing prime liquidity; not retail.
| Regulator | Apply for | Minimum capital | What to know |
|---|---|---|---|
| BaFin#1 Germany | Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions is Eigenhandel or own-account dealing in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| CSSF#2 Luxembourg | Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| SFC#3 Hong Kong | Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case) | USD 3.85 m | Uncertain: principal dealing in leveraged FX with clients needs Type 3, but some dealings with banks and other professionals may fall under SFO exclusions or the LFET exemption rules; HKMA-authorized banks are exempt. |
| FSA Japan#4 Japan | Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | Uncertain: principal OTC derivatives dealing is Type I business, but certain transactions with financial institutions or qualified institutional investors may be excluded under the FIEA Enforcement Order; confirm before relying on an exclusion. |
| FCA#5 United Kingdom | Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | Dealing in investments as principal with brokers and institutions; GBP 750,000 PMR; this is the tier used for principal-model prime-of-prime and non-bank prime services. |
| ASIC#6 Australia | Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | AFSL limited to wholesale clients (s 761G) for dealing and market making in derivatives and FX; no fixed capital minimum beyond RG 166 base-level requirements; the usual route for prime-of-prime and liquidity providers. |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| MAS#8 Singapore | Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading) OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | Dealing as principal with brokers and institutions is a CMS dealing activity; base capital S$1 million for leveraged FX or OTC derivatives when serving only accredited, institutional or expert investors. |
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties (Category 2), USD 2 million base capital plus risk capital. |
| FINMA#10 Switzerland | Securities firm / broker-dealerSecurities firm (FinIA) | USD 1.88 m | A securities firm license (own-account dealer or market maker, CHF 1.5 million) covers professional own-account dealing with institutions; banks also act as LPs under their bank license. |
| Bank of Lithuania#11 Lithuania | Dealer / underwriterFinancial brokerage firm - EUR 750,000 band | USD 870 k | Dealing as principal with brokers and institutions requires the EUR 750,000 band. |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit providerCategory 2 | USD 2 m | Dealing in Investments as Principal with Professional Clients and Market Counterparties only (no Retail Endorsement needed), USD 2 million base capital plus market and credit risk capital. |
| MFSA#14 Malta | Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | Dealing as principal with brokers and institutions needs the Art. 9(1) band (EUR 750,000); large firms may fall under CRR as Class 1 or Class 1 Minus. |
| CFTC · NFA#15 United States | Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | Dealing as principal in spot and deliverable FX forwards with eligible contract participants generally needs no CFTC registration; swap dealer registration (USD 20 million minimum capital) applies only if FX swaps such as NDFs or CFDs with ECPs exceed the de minimis threshold. Providing liquidity to an RFED or FCM does not by itself require RFED status. |
| CySEC#16 Cyprus | Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | Dealing as principal with brokers and institutions (prime-of-prime, liquidity redistribution) is dealing on own account in the EUR 750,000 tier; retail CFD restrictions do not apply to professional/ECP counterparties. |
| FSCA#17 South Africa | OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | Dealing as principal in OTC derivatives with brokers and institutions is ODP activity under the FMA (trade-repository reporting and Joint Standard 2 of 2020 margin rules apply); no separate institutional-only category exists, and bank LPs rely on their Prudential Authority banking license. |
| FSC Mauritius#19 Mauritius | Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting) | USD 22 k | Principal dealing with brokers and institutions fits the Full Service Dealer (excluding Underwriting) license (MUR 1,000,000); the Investment Dealer (Derivatives) category covers agency and exchange market making only and was not confirmed for an OTC principal book. |
| CBB#20 Bahrain | Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | Category 1 investment firm dealing as principal with institutional counterparties, BD 1 million or risk-based capital; wholesale banks are the alternative. |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | USD 300 k | Dealing as principal in derivatives with brokers and institutions is dealing in capital markets instruments as principal (USD 300,000 floor under the older formula); add CFD registration where the instruments supplied are CFDs. |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | Uncertain: principal dealing in FX and derivatives with institutions fits a Labuan investment bank license (RM10 million paid-up capital, no deposit-taking); money brokers cannot act as principal. |
| BMA#27 Bermuda | Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | Principal standard license (USD 250,000 minimum net assets); Class B registration excludes market intermediaries, so a liquidity provider cannot rely on it. |
| QFCRA#28 Qatar · QFC | Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | Dealing in investments as principal with institutional and professional counterparties under BANK; base capital not confirmed. |
| CIMA#29 Cayman Islands | Licensed securities firmSIBA license - broker-dealer, market maker or securities manager Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4) | USD 122 k | Principal dealing with brokers and institutions needs the broker-dealer license; a firm dealing only with sophisticated or high-net-worth persons (entities with USD 5 million or more in assets) may register as a SIBA registered person instead, with no stated capital. |
| FSA Seychelles#32 Seychelles | Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | USD 100 k | Principal dealing with brokers and institutions falls under the Securities Dealer license (USD 100,000); there is no separate institutional category. |
| BVI FSC#34 British Virgin Islands | Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principal | — | Dealing in investments as principal with brokers and institutions, Category 1(b); the FSC sets capital case by case. |
Not available at 9 regulators
- SEC Not an SEC matter for FX: spot and deliverable forward FX dealing between eligible contract participants is largely outside registration, and NDFs and other FX swaps fall under the CFTC (swap dealer above the de minimis threshold).
- SAMA Interbank FX is dealt by SAMA-licensed banks; no separate non-bank FX liquidity license exists. A money changer license covers spot cash currency exchange only.
- SEC Nigeria No SEC category for FX/CFD liquidity provision; FX dealing as principal is the domain of CBN-licensed banks and authorized dealers, and the proposed rules do not mention liquidity providers.
- NYDFS Not licensed by NYDFS; FX dealing with institutions is largely outside registration or falls under CFTC swap dealer rules. A New York state-chartered bank conducts FX dealing under its banking charter, which is not a practical brokerage route.
- CMA UAE No wholesale-only principal dealing category for OTC FX was identified; the 'financial products dealer' activity under First Category may be relevant but its scope for OTC FX was not confirmed. Onshore interbank FX liquidity comes from CBUAE-licensed banks.
- VARA Not licensed by VARA: VARA covers virtual-asset activity only, and fiat FX/CFD brokers in Dubai are licensed by the DFSA (DIFC) or the CMA (onshore). A VA OTC liquidity desk would need Broker-Dealer Services.
- CMA Kenya No CMA category covers institutional-only FX/CFD principal dealing; Kenyan dealing brokers hedge with offshore LPs or banks, and interbank FX dealing is done by CBK-licensed banks. Uncertain.
- CMA Saudi Not a CMA activity; interbank FX dealing is done by SAMA-licensed banks.
- CBUAE No non-bank FX dealing license exists at the CBUAE; interbank FX liquidity is provided by licensed banks (Licensed Bank at AED 2 billion or Restricted Licence Bank at AED 1 billion), which is not a practical route for a liquidity-provider start-up.
Every fitting category
30 categories at 23 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Tied agent (white-label under another firm's license) Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG) | — | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | Tied agent (white-label under another firm's license) Tied agent of a Luxembourg investment firm or bank (LFS) | — | — | — | Retail | Secondary |
| FCA#5 United Kingdom | Appointed representative (white-label) Appointed representative / tied agent (SUP 12) | — | — | — | Retail, with conditions | Secondary |
| CBI Ireland#7 Ireland | Tied agent (white-label under another firm's license) Tied agent of an Irish MiFID firm or bank | — | — | — | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Investment firm without client assets Financial brokerage firm - EUR 75,000 band | USD 87 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Introducing broker / adviser Investment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) | USD 87 k | USD 4 k | USD 4 k | Retail | Rulebook |
| CySEC#16 Cyprus | Tied agent (white-label under another firm's license) Tied agent of a CIF (CySEC public register) | — | — | — | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operator Category 4 | USD 50 k | USD 20 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arranger Category 4 | USD 30 k | USD 30 k | USD 15 k | Retail, with conditions | Secondary |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducer Fifth Category – Arranging and Advice | USD 136 k | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | Introducing broker-dealer (receiving) Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)) | USD 50 k | USD 8 k | USD 1 k | Retail | Rulebook |
| Non-receiving broker-dealer Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) | USD 5 k | USD 8 k | USD 1 k | Retail | Rulebook | |
| CFTC · NFA#15 United States | Independent IB Introducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) | USD 45 k | USD 950 (nominal) | USD 750 (nominal) | Retail | Rulebook |
| Guaranteed IB Introducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | — | USD 950 (nominal) | USD 750 (nominal) | Retail | Secondary | |
| SCB Bahamas#21 The Bahamas | Securities dealer (agent only) Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024) | USD 120 k | USD 16 k | USD 8 k | Retail | To confirm |
| Arranging deals Registered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 8 k | USD 8 k | Retail | To confirm | |
| BMA#27 Bermuda | Investment broker (agent) Investment business standard license: investment provider acting as agent (Investment Business Act 2003) | USD 100 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed arranger / adviser SIBA license - arranging deals or advising | USD 18 k | USD 7 k | USD 6 k | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Agency broker SIBA Category 1, sub-category (a): Dealing in investments as agent | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary |
| Arranger / introducing broker SIBA Category 2: Arranging deals in investments | — | USD 4 k | USD 2 k | Retail, with conditions | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Securities introducing agent / trader Type 1 – Dealing in securities (approved introducing agent or trader) | USD 64 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| Futures introducing agent / non-clearing dealer Type 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer) | USD 64 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| Leveraged FX introducing agent Type 3 – Leveraged foreign exchange trading (approved introducing agent) | USD 642 k | USD 17 k | USD 17 k | Retail | Rulebook | |
| ASIC#6 Australia | Authorized representative model Corporate authorized representative (CAR) of an AFS licensee | — | — | — | Retail, with conditions | Secondary |
| MAS#8 Singapore | Securities and exchange-traded derivatives dealer CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives) | USD 39 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Advice and intermediary FSP FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | USD 154 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | Execution-only broker Investment Dealer (Discount Broker) | USD 13 k | USD 300 (nominal) | USD 2 k | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Digital sub-broker Sub-Broker (Digital) | USD 67 k | USD 934 (nominal) | — | Retail | Rulebook |
| CMA Kenya#30 Kenya | Non-dealing online FX broker Non-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | USD 233 k | USD 78 (nominal) | — | Retail | Rulebook |
Not licensed by: FINMA, VARA, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, NYDFS, FSA Japan, Labuan FSA, FSA Seychelles.
Asset Management Company
Discretionary management of client portfolios and mandates. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators28 of 34
Lowest capitalUSD 12 kBMA
Median capitalUSD 100 k
Retail clients allowed28 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 100 k
BMA
USD 12 k
SFCUSD 13 k
FSC MauritiusUSD 13 k
SCB BahamasUSD 25 k
FSCAUSD 57 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
BaFinUSD 87 k
CSSFUSD 87 k
CBI IrelandUSD 87 k
MFSAUSD 87 k
CySECUSD 87 k
FCAUSD 100 k
ASICUSD 105 k
CIMAUSD 122 k
FINMAUSD 125 k
DFSAUSD 140 k
Bank of LithuaniaUSD 145 k
CMA KenyaUSD 155 k
MASUSD 195 k
FSRAUSD 250 k
CBBUSD 665 k
CMA UAEUSD 817 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
53 categories at 28 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (agency, no client money) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 | USD 87 k | — | — | Retail | Rulebook |
| UCITS management company UCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB) | USD 145 k | USD 39 k | — | Retail | Secondary | |
| Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary | |
| CSSF#2 Luxembourg | Investment firm (agency, no client money) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 | USD 87 k | USD 58 k | USD 19 k | Retail | Rulebook |
| UCITS management company Management company - Chapter 15 of the Law of 17 December 2010 (UCI Law) | USD 145 k | USD 21 k | USD 49 k | Retail | Rulebook | |
| Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary | |
| FCA#5 United Kingdom | Investment firm (agency, no client money) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 | USD 100 k | USD 4 k | USD 3 k | Retail | Secondary |
| UCITS management company UCITS management company / authorized fund manager (Part 4A permission) | USD 145 k | USD 15 k | USD 3 k | Retail | Secondary | |
| Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 | USD 87 k | — | USD 35 k | Retail | Secondary |
| UCITS management company UCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019) | USD 145 k | — | USD 22 k | Retail | Secondary | |
| Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary | |
| FINMA#10 Switzerland | Fund management company Fund management company (FinIA) | USD 1.25 m | USD 5 k | USD 6 k | Retail | Secondary |
| Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook | |
| Independent wealth manager Portfolio manager (FinIA, supervised by an SO) | USD 125 k | USD 2 k | — | Retail | Secondary | |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assets Financial brokerage firm - EUR 150,000 band | USD 174 k | — | — | Retail | Rulebook |
| Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook | |
| MFSA#14 Malta | Portfolio manager / agency broker Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | USD 87 k | USD 5 k | USD 5 k | Retail | Rulebook |
| UCITS management company Investment Services Licence Category 2 (UCITS management company) | USD 145 k | — | — | Retail | Rulebook | |
| Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook | |
| CySEC#16 Cyprus | Investment firm (agency, no client money) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 | USD 87 k | USD 8 k | USD 8 k | Retail | Secondary |
| UCITS management company UCITS management company (Open-Ended Undertakings for Collective Investment Law 78(I)/2012) | USD 145 k | — | — | Retail | Secondary | |
| Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Asset / wealth manager; custodian Category 3C (Managing Assets / Custody / PSIAr / express trustee) | USD 250 k | USD 25 k | USD 25 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Asset / wealth manager Category 3C (Managing Assets, PSIAr, express trustee) | USD 140 k | USD 40 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Investment manager Second Category – Dealing in Investment (Portfolio management) | USD 817 k | — | — | Retail | Secondary |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Portfolio manager (no fund operation) Managing investments (CMIR Art. 6(g)(2)) | — | — | — | Retail | Rulebook | |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Portfolio management Registered firm: managing capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 14 k | USD 8 k | Retail | To confirm |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary | |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| Asset manager (holding client assets) Type 9 – Asset management (holds client assets) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook |
| Pro investment manager Investment Management Business for Qualified Investors (FIEA Art. 29-5) | USD 67 k | USD 1 k | — | Professional only | Rulebook | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary | |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| CIS manager (ManCo) Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002) | USD 57 k | USD 4 k | — | Retail | Rulebook | |
| FSC Mauritius#19 Mauritius | Investment adviser with discretionary management Investment Adviser (Unrestricted) | USD 13 k | USD 600 (nominal) | USD 2 k | Retail | Rulebook |
| CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook | |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS, FSA Seychelles.
Fund Management Company
A manager of collective investment schemes. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators30 of 34
Lowest capitalUSD 12 kBMA
Median capitalUSD 145 k
Retail clients allowed29 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: UCITS management company
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: UCITS management company
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
BMA
USD 12 k
SFCUSD 13 k
FSC MauritiusUSD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
FSCAUSD 57 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
ASICUSD 105 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
CySECUSD 145 k
CMA KenyaUSD 155 k
MASUSD 195 k
FINMAUSD 250 k
CBBUSD 266 k
CMA UAEUSD 272 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
50 categories at 30 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | UCITS management company UCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB) | USD 145 k | USD 39 k | — | Retail | Secondary |
| Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary | |
| CSSF#2 Luxembourg | UCITS management company Management company - Chapter 15 of the Law of 17 December 2010 (UCI Law) | USD 145 k | USD 21 k | USD 49 k | Retail | Rulebook |
| Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary | |
| FCA#5 United Kingdom | UCITS management company UCITS management company / authorized fund manager (Part 4A permission) | USD 145 k | USD 15 k | USD 3 k | Retail | Secondary |
| Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary | |
| CBI Ireland#7 Ireland | UCITS management company UCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019) | USD 145 k | — | USD 22 k | Retail | Secondary |
| Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary | |
| FINMA#10 Switzerland | Fund management company Fund management company (FinIA) | USD 1.25 m | USD 5 k | USD 6 k | Retail | Secondary |
| Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | UCITS management company Investment Services Licence Category 2 (UCITS management company) | USD 145 k | — | — | Retail | Rulebook |
| Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook | |
| Sub-threshold fund manager Investment Services Licence Category 2 (de minimis AIFM) | USD 145 k | — | — | Professional only | Rulebook | |
| CySEC#16 Cyprus | UCITS management company UCITS management company (Open-Ended Undertakings for Collective Investment Law 78(I)/2012) | USD 145 k | — | — | Retail | Secondary |
| Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Category 2 with custody Category 2 investment firm safeguarding financial instruments (CA-1.2.7(b)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook | |
| Private fund manager Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14) | USD 266 k | USD 2 k | — | Professional only | Rulebook | |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| Exempt reporting adviser (private funds under USD 150m) Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook | |
| CFTC · NFA#15 United States | CPO Commodity pool operator (CEA s.1a(11); Part 4) | — | USD 950 (nominal) | USD 750 (nominal) | Retail, with conditions | Rulebook |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary | |
| CIMA#29 Cayman Islands | Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Approved manager Approved manager (Investment Business (Approved Managers) Regulations 2012) | — | USD 1 k | USD 2 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| Asset manager (holding client assets) Type 9 – Asset management (holds client assets) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Type II FIBO Type II Financial Instruments Business (FIEA Art. 28(2)) | USD 67 k | USD 1 k | — | Retail | Rulebook |
| Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook | |
| Pro investment manager Investment Management Business for Qualified Investors (FIEA Art. 29-5) | USD 67 k | USD 1 k | — | Professional only | Rulebook | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary | |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook | |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | CIS manager (ManCo) Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002) | USD 57 k | USD 4 k | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
| FSA Seychelles#32 Seychelles | Fund administrator Fund Administrator license (Seychelles Fund Administrator or Restricted), Mutual Fund and Hedge Fund Act 2008 | — | USD 1 k | USD 2 k | Retail, with conditions | Rulebook |
Hedge Fund
An alternative fund and its manager. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators30 of 34
Lowest capitalUSD 12 kBMA
Median capitalUSD 145 k
Retail clients allowed28 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
BMA
USD 12 k
SFCUSD 13 k
FSC MauritiusUSD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
FSCAUSD 57 k
CySECUSD 58 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
CMA KenyaUSD 155 k
MASUSD 195 k
FINMAUSD 250 k
CBBUSD 266 k
CMA UAEUSD 272 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
66 categories at 30 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary |
| CSSF#2 Luxembourg | Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | — | USD 8 k | USD 12 k | Professional only | Secondary | |
| SIF (regulated fund) Specialised investment fund (SIF), Law of 13 February 2007 | USD 1.45 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| FCA#5 United Kingdom | Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary |
| Small authorized AIFM Small authorized UK AIFM (Part 4A permission, sub-threshold) | — | — | USD 3 k | Retail, with conditions | To confirm | |
| CBI Ireland#7 Ireland | Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary |
| QIAIF (regulated private fund) Qualifying Investor AIF (QIAIF), authorized under the CBI AIF Rulebook | — | — | USD 10 k | Professional only | Secondary | |
| FINMA#10 Switzerland | Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook |
| Swiss fund (product approval) Swiss collective investment scheme approval (CISA) | — | USD 5 k | USD 750 (nominal) | Retail | To confirm | |
| Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| Sub-threshold fund manager Investment Services Licence Category 2 (de minimis AIFM) | USD 145 k | — | — | Professional only | Rulebook | |
| Licensed alternative fund Licensed AIF (Professional or Qualifying Investors) | — | USD 4 k | USD 5 k | Professional only | Secondary | |
| Notified alternative fund Notified AIF (NAIF) | — | — | — | Professional only | Secondary | |
| Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary | |
| CySEC#16 Cyprus | Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary |
| Sub-threshold fund manager Mini-AIFM / sub-threshold AIFM (Law 81(I)/2020) | USD 58 k | — | — | Professional only | Secondary | |
| Private AIF (up to 50 investors) Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018 | USD 58 k | — | — | Professional only | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Private fund manager Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14) | USD 266 k | USD 2 k | — | Professional only | Rulebook | |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| QFC funds QFC collective investment schemes (Collective Investment Schemes Rules 2010, COLL; Private Placement Schemes Rules, PRIV; Professional Investor Funds Rules 2022, PROF) | — | USD 10 k | USD 5 k | Retail, with conditions | Secondary | |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| Exempt reporting adviser (private funds under USD 150m) Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook | |
| CFTC · NFA#15 United States | CPO Commodity pool operator (CEA s.1a(11); Part 4) | — | USD 950 (nominal) | USD 750 (nominal) | Retail, with conditions | Rulebook |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| Professional fund Professional fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Professional only | Secondary | |
| SMART fund SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | — | USD 2 k | USD 3 k | Retail, with conditions | Secondary | |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary | |
| Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Registered open-ended fund Registered mutual fund (Mutual Funds Act s. 4(3)) | — | — | USD 5 k | Professional only | Rulebook |
| Administered fund Administered mutual fund (Mutual Funds Act s. 4(1)(b)) | — | — | — | Retail, with conditions | Rulebook | |
| Licensed fund Licensed mutual fund (Mutual Funds Act s. 4(1)(a)) | — | — | — | Retail, with conditions | Rulebook | |
| Limited investor fund Limited investor fund (Mutual Funds Act s. 4(4)) | — | — | — | Professional only | Rulebook | |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Approved manager Approved manager (Investment Business (Approved Managers) Regulations 2012) | — | USD 1 k | USD 2 k | Professional only | Secondary | |
| Private fund Private fund (SIBA; Mutual Funds Regulations 2010) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Professional fund Professional fund (SIBA; Mutual Funds Regulations 2010) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Incubator fund Incubator fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Approved fund Approved fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Type II FIBO Type II Financial Instruments Business (FIEA Art. 28(2)) | USD 67 k | USD 1 k | — | Retail | Rulebook |
| Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook | |
| Pro investment manager Investment Management Business for Qualified Investors (FIEA Art. 29-5) | USD 67 k | USD 1 k | — | Professional only | Rulebook | |
| Art. 63 fund GP exemption Specially Permitted Business for Qualified Institutional Investors (FIEA Art. 63) – notification, not registration | — | — | — | Professional only | Secondary | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| MAS#8 Singapore | A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Private fund Labuan private fund (LFSSA s. 28) | — | — | USD 1 k | Professional only | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Hedge fund manager FAIS Category IIA FSP (hedge fund FSP) | USD 171 k | USD 932 (nominal) | — | Retail, with conditions | Rulebook |
| Hedge fund CIS manager Manager of a hedge fund CIS (CISCA declaration of hedge funds, 2015): Retail Hedge Fund (RHF) and Qualified Investor Hedge Fund (QIHF) portfolios | USD 57 k | USD 4 k | — | Retail, with conditions | Rulebook | |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
| FSA Seychelles#32 Seychelles | Private or professional fund Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | — | USD 750 (nominal) | USD 1 k | Professional only | Rulebook |
Private Equity Firm
A closed-ended fund investing in private companies, and its manager. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators28 of 34
Lowest capitalUSD 12 kBMA
Median capitalUSD 145 k
Retail clients allowed24 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
BMA
USD 12 k
SFCUSD 13 k
FSC MauritiusUSD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
CySECUSD 58 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
MASUSD 195 k
FINMAUSD 250 k
CBBUSD 266 k
CMA UAEUSD 272 k
SEC NigeriaUSD 333 k
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
59 categories at 28 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary |
| Registered (sub-threshold) AIFM Registered AIF management company (registrierte KVG, Section 2(4)-(5) and Section 44 KAGB) | — | USD 4 k | — | Professional only | Secondary | |
| CSSF#2 Luxembourg | Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | — | USD 8 k | USD 12 k | Professional only | Secondary | |
| SIF (regulated fund) Specialised investment fund (SIF), Law of 13 February 2007 | USD 1.45 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| SICAR (venture/PE vehicle) Investment company in risk capital (SICAR), Law of 15 June 2004 | USD 1.16 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| FCA#5 United Kingdom | Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary |
| Small authorized AIFM Small authorized UK AIFM (Part 4A permission, sub-threshold) | — | — | USD 3 k | Retail, with conditions | To confirm | |
| Registered AIFM Small registered UK AIFM (registration, not Part 4A) | — | USD 1 k | USD 1 k | Professional only | Secondary | |
| CBI Ireland#7 Ireland | Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Regulation 5 of S.I. 257/2013) | — | — | — | Professional only | Secondary | |
| QIAIF (regulated private fund) Qualifying Investor AIF (QIAIF), authorized under the CBI AIF Rulebook | — | — | USD 10 k | Professional only | Secondary | |
| FINMA#10 Switzerland | Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook |
| Swiss fund (product approval) Swiss collective investment scheme approval (CISA) | — | USD 5 k | USD 750 (nominal) | Retail | To confirm | |
| Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| Sub-threshold fund manager Investment Services Licence Category 2 (de minimis AIFM) | USD 145 k | — | — | Professional only | Rulebook | |
| Licensed alternative fund Licensed AIF (Professional or Qualifying Investors) | — | USD 4 k | USD 5 k | Professional only | Secondary | |
| Notified alternative fund Notified AIF (NAIF) | — | — | — | Professional only | Secondary | |
| Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary | |
| CySEC#16 Cyprus | Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary |
| Sub-threshold fund manager Mini-AIFM / sub-threshold AIFM (Law 81(I)/2020) | USD 58 k | — | — | Professional only | Secondary | |
| Private AIF (up to 50 investors) Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018 | USD 58 k | — | — | Professional only | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Private fund manager Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14) | USD 266 k | USD 2 k | — | Professional only | Rulebook | |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| QFC funds QFC collective investment schemes (Collective Investment Schemes Rules 2010, COLL; Private Placement Schemes Rules, PRIV; Professional Investor Funds Rules 2022, PROF) | — | USD 10 k | USD 5 k | Retail, with conditions | Secondary | |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| Exempt reporting adviser (private funds under USD 150m) Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook | |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| Professional fund Professional fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Professional only | Secondary | |
| SMART fund SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | — | USD 2 k | USD 3 k | Retail, with conditions | Secondary | |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary | |
| Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Closed-ended fund Private fund (Private Funds Act 2020) | — | — | USD 5 k | Professional only | Secondary |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Approved manager Approved manager (Investment Business (Approved Managers) Regulations 2012) | — | USD 1 k | USD 2 k | Professional only | Secondary | |
| Closed-ended private investment fund Private investment fund (closed-ended; SIBA as amended 2019) | — | USD 850 (nominal) | USD 1 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Type II FIBO Type II Financial Instruments Business (FIEA Art. 28(2)) | USD 67 k | USD 1 k | — | Retail | Rulebook |
| Pro investment manager Investment Management Business for Qualified Investors (FIEA Art. 29-5) | USD 67 k | USD 1 k | — | Professional only | Rulebook | |
| Art. 63 fund GP exemption Specially Permitted Business for Qualified Institutional Investors (FIEA Art. 63) – notification, not registration | — | — | — | Professional only | Secondary | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| MAS#8 Singapore | A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Private fund Labuan private fund (LFSSA s. 28) | — | — | USD 1 k | Professional only | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| SEC Nigeria#22 Nigeria | PE fund manager Tier 3 Alternative Investment Fund Manager: Private Equity Fund Manager | USD 333 k | — | — | Professional only | Rulebook |
| FSA Seychelles#32 Seychelles | Private or professional fund Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | — | USD 750 (nominal) | USD 1 k | Professional only | Rulebook |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS, CMA Kenya.
Venture Capital Firm
A fund investing in early-stage companies, and its manager. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators28 of 34
Lowest capitalUSD 13 kSFC
Median capitalUSD 139 k
Retail clients allowed21 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 139 k
SFC
USD 13 k
FSC MauritiusUSD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
CySECUSD 58 k
CBBUSD 66 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
SEC NigeriaUSD 133 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
FINMAUSD 250 k
CMA UAEUSD 272 k
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
53 categories at 28 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary |
| Registered (sub-threshold) AIFM Registered AIF management company (registrierte KVG, Section 2(4)-(5) and Section 44 KAGB) | — | USD 4 k | — | Professional only | Secondary | |
| CSSF#2 Luxembourg | Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | — | USD 8 k | USD 12 k | Professional only | Secondary | |
| SICAR (venture/PE vehicle) Investment company in risk capital (SICAR), Law of 15 June 2004 | USD 1.16 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| FCA#5 United Kingdom | Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary |
| Small authorized AIFM Small authorized UK AIFM (Part 4A permission, sub-threshold) | — | — | USD 3 k | Retail, with conditions | To confirm | |
| Registered AIFM Small registered UK AIFM (registration, not Part 4A) | — | USD 1 k | USD 1 k | Professional only | Secondary | |
| CBI Ireland#7 Ireland | Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Regulation 5 of S.I. 257/2013) | — | — | — | Professional only | Secondary | |
| QIAIF (regulated private fund) Qualifying Investor AIF (QIAIF), authorized under the CBI AIF Rulebook | — | — | USD 10 k | Professional only | Secondary | |
| FINMA#10 Switzerland | Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook |
| Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| Sub-threshold fund manager Investment Services Licence Category 2 (de minimis AIFM) | USD 145 k | — | — | Professional only | Rulebook | |
| Licensed alternative fund Licensed AIF (Professional or Qualifying Investors) | — | USD 4 k | USD 5 k | Professional only | Secondary | |
| Notified alternative fund Notified AIF (NAIF) | — | — | — | Professional only | Secondary | |
| Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary | |
| CySEC#16 Cyprus | Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary |
| Sub-threshold fund manager Mini-AIFM / sub-threshold AIFM (Law 81(I)/2020) | USD 58 k | — | — | Professional only | Secondary | |
| Private AIF (up to 50 investors) Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018 | USD 58 k | — | — | Professional only | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Venture capital fund manager Category 3C (Venture Capital Fund Manager) | USD 50 k | USD 10 k | USD 10 k | Professional only | Secondary |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Private fund manager Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14) | USD 266 k | USD 2 k | — | Professional only | Rulebook |
| Venture capital fund manager Category 4 investment firm - venture capital CIUs only (Volume 4, C4-1.1.14) | USD 66 k | USD 2 k | — | Professional only | Rulebook | |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | Exempt reporting adviser (venture capital) Exempt reporting adviser: venture capital fund adviser exemption (Advisers Act s.203(l); Rule 203(l)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| Professional fund Professional fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Professional only | Secondary | |
| SMART fund SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | — | USD 2 k | USD 3 k | Retail, with conditions | Secondary | |
| BMA#27 Bermuda | Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary |
| Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Closed-ended fund Private fund (Private Funds Act 2020) | — | — | USD 5 k | Professional only | Secondary |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Approved manager Approved manager (Investment Business (Approved Managers) Regulations 2012) | — | USD 1 k | USD 2 k | Professional only | Secondary | |
| Closed-ended private investment fund Private investment fund (closed-ended; SIBA as amended 2019) | — | USD 850 (nominal) | USD 1 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Type II FIBO Type II Financial Instruments Business (FIEA Art. 28(2)) | USD 67 k | USD 1 k | — | Retail | Rulebook |
| Art. 63 fund GP exemption Specially Permitted Business for Qualified Institutional Investors (FIEA Art. 63) – notification, not registration | — | — | — | Professional only | Secondary | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| MAS#8 Singapore | Venture capital fund manager CMS license: Fund management (Venture Capital Fund Manager, VCFM regime) | — | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Private fund Labuan private fund (LFSSA s. 28) | — | — | USD 1 k | Professional only | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| SEC Nigeria#22 Nigeria | VC fund manager Tier 3 Alternative Investment Fund Manager: Venture Capital Fund Manager | USD 133 k | — | — | Professional only | Rulebook |
| FSA Seychelles#32 Seychelles | Private or professional fund Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | — | USD 750 (nominal) | USD 1 k | Professional only | Rulebook |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS, CMA Kenya.
Private Credit Fund
A fund that lends directly to companies. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators28 of 34
Lowest capitalUSD 13 kSFC
Median capitalUSD 145 k
Retail clients allowed25 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
SFC
USD 13 k
FSC MauritiusUSD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
CySECUSD 58 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
SECUSD 100 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
MASUSD 195 k
FINMAUSD 250 k
CBBUSD 266 k
CMA UAEUSD 272 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
60 categories at 28 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Lending institution Credit institution conducting lending business only (Kreditgeschäft, Section 32 KWG, non-CRR) | — | — | — | Retail | To confirm |
| Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary | |
| Registered (sub-threshold) AIFM Registered AIF management company (registrierte KVG, Section 2(4)-(5) and Section 44 KAGB) | — | USD 4 k | — | Professional only | Secondary | |
| CSSF#2 Luxembourg | Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | — | USD 8 k | USD 12 k | Professional only | Secondary | |
| SIF (regulated fund) Specialised investment fund (SIF), Law of 13 February 2007 | USD 1.45 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| FCA#5 United Kingdom | Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary |
| Small authorized AIFM Small authorized UK AIFM (Part 4A permission, sub-threshold) | — | — | USD 3 k | Retail, with conditions | To confirm | |
| Registered AIFM Small registered UK AIFM (registration, not Part 4A) | — | USD 1 k | USD 1 k | Professional only | Secondary | |
| CBI Ireland#7 Ireland | Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Regulation 5 of S.I. 257/2013) | — | — | — | Professional only | Secondary | |
| QIAIF (regulated private fund) Qualifying Investor AIF (QIAIF), authorized under the CBI AIF Rulebook | — | — | USD 10 k | Professional only | Secondary | |
| FINMA#10 Switzerland | Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook |
| Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| Sub-threshold fund manager Investment Services Licence Category 2 (de minimis AIFM) | USD 145 k | — | — | Professional only | Rulebook | |
| Licensed alternative fund Licensed AIF (Professional or Qualifying Investors) | — | USD 4 k | USD 5 k | Professional only | Secondary | |
| Notified alternative fund Notified AIF (NAIF) | — | — | — | Professional only | Secondary | |
| Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary | |
| CySEC#16 Cyprus | Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary |
| Sub-threshold fund manager Mini-AIFM / sub-threshold AIFM (Law 81(I)/2020) | USD 58 k | — | — | Professional only | Secondary | |
| Private AIF (up to 50 investors) Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018 | USD 58 k | — | — | Professional only | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Private fund manager Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14) | USD 266 k | USD 2 k | — | Professional only | Rulebook | |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| Exempt reporting adviser (private funds under USD 150m) Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook | |
| Closed-end fund, interval fund or BDC Registered closed-end fund, interval fund (Rule 23c-3) or business development company (Investment Company Act; Form N-2) | USD 100 k | — | — | Retail | Secondary | |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| Professional fund Professional fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Professional only | Secondary | |
| SMART fund SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | — | USD 2 k | USD 3 k | Retail, with conditions | Secondary | |
| BMA#27 Bermuda | Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary |
| Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Registered open-ended fund Registered mutual fund (Mutual Funds Act s. 4(3)) | — | — | USD 5 k | Professional only | Rulebook |
| Closed-ended fund Private fund (Private Funds Act 2020) | — | — | USD 5 k | Professional only | Secondary | |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Approved manager Approved manager (Investment Business (Approved Managers) Regulations 2012) | — | USD 1 k | USD 2 k | Professional only | Secondary | |
| Professional fund Professional fund (SIBA; Mutual Funds Regulations 2010) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Closed-ended private investment fund Private investment fund (closed-ended; SIBA as amended 2019) | — | USD 850 (nominal) | USD 1 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Type II FIBO Type II Financial Instruments Business (FIEA Art. 28(2)) | USD 67 k | USD 1 k | — | Retail | Rulebook |
| Pro investment manager Investment Management Business for Qualified Investors (FIEA Art. 29-5) | USD 67 k | USD 1 k | — | Professional only | Rulebook | |
| Art. 63 fund GP exemption Specially Permitted Business for Qualified Institutional Investors (FIEA Art. 63) – notification, not registration | — | — | — | Professional only | Secondary | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| MAS#8 Singapore | A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Private fund Labuan private fund (LFSSA s. 28) | — | — | USD 1 k | Professional only | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| FSA Seychelles#32 Seychelles | Private or professional fund Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | — | USD 750 (nominal) | USD 1 k | Professional only | Rulebook |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS, CMA Kenya.
Real Estate Investment Vehicle
A REIT or real estate fund. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators29 of 34
Lowest capitalUSD 13 kSFC
Median capitalUSD 145 k
Retail clients allowed27 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
SFC
USD 13 k
FSC MauritiusUSD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
FSCAUSD 57 k
CySECUSD 58 k
FSA JapanUSD 67 k
CMA KenyaUSD 78 k
SECUSD 100 k
ASICUSD 105 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
MASUSD 195 k
CBBUSD 266 k
CMA UAEUSD 272 k
FINMAUSD 1.25 m
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
61 categories at 29 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary |
| Registered (sub-threshold) AIFM Registered AIF management company (registrierte KVG, Section 2(4)-(5) and Section 44 KAGB) | — | USD 4 k | — | Professional only | Secondary | |
| CSSF#2 Luxembourg | Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | — | USD 8 k | USD 12 k | Professional only | Secondary | |
| SIF (regulated fund) Specialised investment fund (SIF), Law of 13 February 2007 | USD 1.45 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| FCA#5 United Kingdom | Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary |
| Small authorized AIFM Small authorized UK AIFM (Part 4A permission, sub-threshold) | — | — | USD 3 k | Retail, with conditions | To confirm | |
| Registered AIFM Small registered UK AIFM (registration, not Part 4A) | — | USD 1 k | USD 1 k | Professional only | Secondary | |
| CBI Ireland#7 Ireland | Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary |
| Registered AIFM Registered AIFM (sub-threshold, Regulation 5 of S.I. 257/2013) | — | — | — | Professional only | Secondary | |
| QIAIF (regulated private fund) Qualifying Investor AIF (QIAIF), authorized under the CBI AIF Rulebook | — | — | USD 10 k | Professional only | Secondary | |
| FINMA#10 Switzerland | Fund management company Fund management company (FinIA) | USD 1.25 m | USD 5 k | USD 6 k | Retail | Secondary |
| Swiss fund (product approval) Swiss collective investment scheme approval (CISA) | — | USD 5 k | USD 750 (nominal) | Retail | To confirm | |
| Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| Retail alternative fund Retail AIF | — | USD 4 k | USD 5 k | Retail | Secondary | |
| Licensed alternative fund Licensed AIF (Professional or Qualifying Investors) | — | USD 4 k | USD 5 k | Professional only | Secondary | |
| Notified alternative fund Notified AIF (NAIF) | — | — | — | Professional only | Secondary | |
| Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary | |
| CySEC#16 Cyprus | Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary |
| Sub-threshold fund manager Mini-AIFM / sub-threshold AIFM (Law 81(I)/2020) | USD 58 k | — | — | Professional only | Secondary | |
| Private AIF (up to 50 investors) Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018 | USD 58 k | — | — | Professional only | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Private fund manager Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14) | USD 266 k | USD 2 k | — | Professional only | Rulebook | |
| Bahrain-domiciled funds Collective Investment Undertakings (Volume 7) | — | USD 270 (nominal) | USD 5 k | Retail, with conditions | Secondary | |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| QFC funds QFC collective investment schemes (Collective Investment Schemes Rules 2010, COLL; Private Placement Schemes Rules, PRIV; Professional Investor Funds Rules 2022, PROF) | — | USD 10 k | USD 5 k | Retail, with conditions | Secondary | |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Fund and REIT product approval Public investment fund / REIT approval (Investment Funds Regulations; Real Estate Investment Funds Regulations) | — | — | — | Retail | Secondary | |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| Exempt reporting adviser (private funds under USD 150m) Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook | |
| Closed-end fund, interval fund or BDC Registered closed-end fund, interval fund (Rule 23c-3) or business development company (Investment Company Act; Form N-2) | USD 100 k | — | — | Retail | Secondary | |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| Standard fund Standard fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Retail | Secondary | |
| Professional fund Professional fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Professional only | Secondary | |
| BMA#27 Bermuda | Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Closed-ended fund Private fund (Private Funds Act 2020) | — | — | USD 5 k | Professional only | Secondary |
| BVI FSC#34 British Virgin Islands | Public (retail) fund Public fund (SIBA; Public Funds Code 2010) | — | USD 2 k | USD 2 k | Retail | Secondary |
| Closed-ended private investment fund Private investment fund (closed-ended; SIBA as amended 2019) | — | USD 850 (nominal) | USD 1 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Type II FIBO Type II Financial Instruments Business (FIEA Art. 28(2)) | USD 67 k | USD 1 k | — | Retail | Rulebook |
| Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook | |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary | |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook | |
| REIT manager CMS license: Real estate investment trust management | USD 780 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook | |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Private fund Labuan private fund (LFSSA s. 28) | — | — | USD 1 k | Professional only | Rulebook |
| Public fund Labuan public fund (LFSSA s. 33) | — | — | USD 1 k | Retail | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | CIS manager (ManCo) Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002) | USD 57 k | USD 4 k | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | REIT manager REIT Manager (Capital Markets (Real Estate Investment Trusts) (Collective Investment Schemes) Regulations 2013) | USD 78 k | — | — | Retail | Rulebook |
| FSA Seychelles#32 Seychelles | Private or professional fund Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | — | USD 750 (nominal) | USD 1 k | Professional only | Rulebook |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS.
Mutual Fund & UCITS
A collective investment scheme open to retail investors. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators29 of 34
Lowest capitalUSD 22 kFSC Mauritius
Median capitalUSD 145 k
Retail clients allowed29 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: UCITS management company
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: UCITS management company
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (holding client assets)
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
FSC Mauritius
USD 22 k
DFSAUSD 40 k
FSRAUSD 50 k
FSCAUSD 57 k
SECUSD 100 k
ASICUSD 105 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
CySECUSD 145 k
CMA KenyaUSD 155 k
CMA UAEUSD 272 k
FSA JapanUSD 335 k
MASUSD 390 k
SFCUSD 642 k
FINMAUSD 1.25 m
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
36 categories at 29 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | UCITS management company UCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB) | USD 145 k | USD 39 k | — | Retail | Secondary |
| CSSF#2 Luxembourg | UCITS management company Management company - Chapter 15 of the Law of 17 December 2010 (UCI Law) | USD 145 k | USD 21 k | USD 49 k | Retail | Rulebook |
| FCA#5 United Kingdom | UCITS management company UCITS management company / authorized fund manager (Part 4A permission) | USD 145 k | USD 15 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | UCITS management company UCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019) | USD 145 k | — | USD 22 k | Retail | Secondary |
| FINMA#10 Switzerland | Fund management company Fund management company (FinIA) | USD 1.25 m | USD 5 k | USD 6 k | Retail | Secondary |
| Swiss fund (product approval) Swiss collective investment scheme approval (CISA) | — | USD 5 k | USD 750 (nominal) | Retail | To confirm | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | UCITS management company Investment Services Licence Category 2 (UCITS management company) | USD 145 k | — | — | Retail | Rulebook |
| UCITS fund UCITS Scheme | — | USD 4 k | USD 5 k | Retail | Secondary | |
| Retail alternative fund Retail AIF | — | USD 4 k | USD 5 k | Retail | Secondary | |
| CySEC#16 Cyprus | UCITS management company UCITS management company (Open-Ended Undertakings for Collective Investment Law 78(I)/2012) | USD 145 k | — | — | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Bahrain-domiciled funds Collective Investment Undertakings (Volume 7) | — | USD 270 (nominal) | USD 5 k | Retail, with conditions | Secondary |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | QFC funds QFC collective investment schemes (Collective Investment Schemes Rules 2010, COLL; Private Placement Schemes Rules, PRIV; Professional Investor Funds Rules 2022, PROF) | — | USD 10 k | USD 5 k | Retail, with conditions | Secondary |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Fund and REIT product approval Public investment fund / REIT approval (Investment Funds Regulations; Real Estate Investment Funds Regulations) | — | — | — | Retail | Secondary | |
| Americas | ||||||
| SEC#13 United States | Registered mutual fund Registered open-end management investment company (Investment Company Act of 1940; Form N-1A) | USD 100 k | — | — | Retail | Secondary |
| SCB Bahamas#21 The Bahamas | Standard fund Standard fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Retail | Secondary |
| BMA#27 Bermuda | Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed fund Licensed mutual fund (Mutual Funds Act s. 4(1)(a)) | — | — | — | Retail, with conditions | Rulebook |
| BVI FSC#34 British Virgin Islands | Public (retail) fund Public fund (SIBA; Public Funds Code 2010) | — | USD 2 k | USD 2 k | Retail | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (holding client assets) Type 9 – Asset management (holds client assets) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Depositary of SFC-authorized funds Type 13 – Providing depositary services for relevant collective investment schemes | USD 1.28 m | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| Labuan FSA#24 Malaysia · Labuan | Public fund Labuan public fund (LFSSA s. 33) | — | — | USD 1 k | Retail | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | CIS manager (ManCo) Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002) | USD 57 k | USD 4 k | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
| FSA Seychelles#32 Seychelles | Public fund Mutual Fund license: Public Fund (Mutual Fund and Hedge Fund Act 2008) | — | USD 2 k | USD 2 k | Retail | Rulebook |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS.
ETF Platform
An exchange-traded fund range and its issuer. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators20 of 34
Lowest capitalUSD 40 kDFSA
Median capitalUSD 145 k
Retail clients allowed20 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: UCITS management company
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: UCITS management company
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (holding client assets)
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
DFSA
USD 40 k
FSRAUSD 50 k
FSCAUSD 57 k
SECUSD 100 k
ASICUSD 105 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
CySECUSD 145 k
CMA UAEUSD 272 k
FSA JapanUSD 335 k
MASUSD 390 k
SFCUSD 642 k
FINMAUSD 1.25 m
SEC NigeriaUSD 3.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
24 categories at 20 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | UCITS management company UCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB) | USD 145 k | USD 39 k | — | Retail | Secondary |
| CSSF#2 Luxembourg | UCITS management company Management company - Chapter 15 of the Law of 17 December 2010 (UCI Law) | USD 145 k | USD 21 k | USD 49 k | Retail | Rulebook |
| FCA#5 United Kingdom | UCITS management company UCITS management company / authorized fund manager (Part 4A permission) | USD 145 k | USD 15 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | UCITS management company UCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019) | USD 145 k | — | USD 22 k | Retail | Secondary |
| FINMA#10 Switzerland | Fund management company Fund management company (FinIA) | USD 1.25 m | USD 5 k | USD 6 k | Retail | Secondary |
| Swiss fund (product approval) Swiss collective investment scheme approval (CISA) | — | USD 5 k | USD 750 (nominal) | Retail | To confirm | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | UCITS management company Investment Services Licence Category 2 (UCITS management company) | USD 145 k | — | — | Retail | Rulebook |
| UCITS fund UCITS Scheme | — | USD 4 k | USD 5 k | Retail | Secondary | |
| CySEC#16 Cyprus | UCITS management company UCITS management company (Open-Ended Undertakings for Collective Investment Law 78(I)/2012) | USD 145 k | — | — | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| CMA UAE#25 UAE · Federal | Fund manager Second Category – Dealing in Investment (Investment fund management) | USD 272 k | — | — | Retail | Rulebook |
| QFCRA#28 Qatar · QFC | QFC funds QFC collective investment schemes (Collective Investment Schemes Rules 2010, COLL; Private Placement Schemes Rules, PRIV; Professional Investor Funds Rules 2022, PROF) | — | USD 10 k | USD 5 k | Retail, with conditions | Secondary |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Fund and REIT product approval Public investment fund / REIT approval (Investment Funds Regulations; Real Estate Investment Funds Regulations) | — | — | — | Retail | Secondary | |
| Americas | ||||||
| SEC#13 United States | ETF (1940 Act) Exchange-traded fund under Rule 6c-11 (Investment Company Act) | USD 100 k | — | — | Retail | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (holding client assets) Type 9 – Asset management (holds client assets) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Depositary of SFC-authorized funds Type 13 – Providing depositary services for relevant collective investment schemes | USD 1.28 m | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | CIS manager (ManCo) Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002) | USD 57 k | USD 4 k | — | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
Not licensed by: VARA, CBUAE, SAMA, CBB, CFTC · NFA, NYDFS, CIMA, BVI FSC, BMA, SCB Bahamas, Labuan FSA, FSC Mauritius, FSA Seychelles, CMA Kenya.
Wealth Management Firm
Portfolio management and private wealth services. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators28 of 34
Lowest capitalUSD 12 kBMA
Median capitalUSD 102 k
Retail clients allowed28 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities adviser
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 102 k
BMA
USD 12 k
SFCUSD 13 k
FSC MauritiusUSD 13 k
SCB BahamasUSD 25 k
Labuan FSAUSD 71 k
BaFinUSD 87 k
CSSFUSD 87 k
CBI IrelandUSD 87 k
Bank of LithuaniaUSD 87 k
MFSAUSD 87 k
CySECUSD 87 k
FCAUSD 100 k
ASICUSD 105 k
CIMAUSD 122 k
FINMAUSD 125 k
DFSAUSD 140 k
CMA KenyaUSD 155 k
MASUSD 195 k
FSRAUSD 250 k
FSA JapanUSD 335 k
CBBUSD 665 k
CMA UAEUSD 817 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
44 categories at 28 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook |
| Investment firm (agency, no client money) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 | USD 87 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Investment firm (agency, no client money) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 | USD 87 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook | |
| FCA#5 United Kingdom | Investment firm (agency, no client money) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 | USD 100 k | USD 4 k | USD 3 k | Retail | Secondary |
| Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 | USD 87 k | — | USD 35 k | Retail | Secondary |
| Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Independent wealth manager Portfolio manager (FinIA, supervised by an SO) | USD 125 k | USD 2 k | — | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Investment firm without client assets Financial brokerage firm - EUR 75,000 band | USD 87 k | — | — | Retail | Rulebook |
| Investment firm holding client assets Financial brokerage firm - EUR 150,000 band | USD 174 k | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Portfolio manager / agency broker Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | USD 87 k | USD 5 k | USD 5 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (agency, no client money) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 | USD 87 k | USD 8 k | USD 8 k | Retail | Secondary |
| Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Asset / wealth manager; custodian Category 3C (Managing Assets / Custody / PSIAr / express trustee) | USD 250 k | USD 25 k | USD 25 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Asset / wealth manager Category 3C (Managing Assets, PSIAr, express trustee) | USD 140 k | USD 40 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Category 2 with custody Category 2 investment firm safeguarding financial instruments (CA-1.2.7(b)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook | |
| CMA UAE#25 UAE · Federal | Investment manager Second Category – Dealing in Investment (Portfolio management) | USD 817 k | — | — | Retail | Secondary |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Portfolio manager (no fund operation) Managing investments (CMIR Art. 6(g)(2)) | — | — | — | Retail | Rulebook | |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Portfolio management Registered firm: managing capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 14 k | USD 8 k | Retail | To confirm |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed securities firm SIBA license - broker-dealer, market maker or securities manager | USD 122 k | USD 13 k | USD 12 k | Retail | Rulebook |
| Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities adviser Type 4 – Advising on securities (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook | |
| FSA Japan#4 Japan | Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook |
| Investment adviser Investment Advisory and Agency Business (FIEA Art. 28(3)) | — | USD 1 k | — | Retail | Rulebook | |
| ASIC#6 Australia | Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary |
| Adviser / MDA provider AFSL – personal advice and managed discretionary account (MDA) services | — | USD 2 k | — | Retail | Secondary | |
| Authorized representative model Corporate authorized representative (CAR) of an AFS licensee | — | — | — | Retail, with conditions | Secondary | |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook | |
| Licensed financial adviser Financial Advisers Act: Financial adviser's license | USD 195 k | — | — | Retail | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | Investment adviser with discretionary management Investment Adviser (Unrestricted) | USD 13 k | USD 600 (nominal) | USD 2 k | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, NYDFS, FSA Seychelles.
Multi-Family Office
An office serving several families, usually regulated. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators29 of 34
Lowest capitalUSD 12 kBMA
Median capitalUSD 100 k
Retail clients allowed27 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Family office PSF
- Capital
- USD 58 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities adviser
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 100 k
BMA
USD 12 k
SFCUSD 13 k
FSC MauritiusUSD 13 k
SCB BahamasUSD 25 k
CSSFUSD 58 k
CBBUSD 66 k
Labuan FSAUSD 71 k
BaFinUSD 87 k
CBI IrelandUSD 87 k
MFSAUSD 87 k
CySECUSD 87 k
FCAUSD 100 k
FINMAUSD 125 k
DFSAUSD 140 k
CMA KenyaUSD 155 k
Bank of LithuaniaUSD 174 k
MASUSD 195 k
FSRAUSD 250 k
QFCRAUSD 250 k
BVI FSCUSD 250 k
CMA UAEUSD 817 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
47 categories at 29 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook |
| Investment firm (agency, no client money) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 | USD 87 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Investment firm (agency, no client money) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 | USD 87 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook | |
| Family office PSF Family office (specialized PSF, Article 28-6 LFS; Law of 21 December 2012 on family office activity) | USD 58 k | USD 35 k | USD 29 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (agency, no client money) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 | USD 100 k | USD 4 k | USD 3 k | Retail | Secondary |
| Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 | USD 87 k | — | USD 35 k | Retail | Secondary |
| Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Independent wealth manager Portfolio manager (FinIA, supervised by an SO) | USD 125 k | USD 2 k | — | Retail | Secondary |
| Professional trustee Trustee (FinIA, supervised by an SO) | USD 125 k | USD 2 k | — | Retail, with conditions | Secondary | |
| Bank of Lithuania#11 Lithuania | Investment firm holding client assets Financial brokerage firm - EUR 150,000 band | USD 174 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Portfolio manager / agency broker Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | USD 87 k | USD 5 k | USD 5 k | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (agency, no client money) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 | USD 87 k | USD 8 k | USD 8 k | Retail | Secondary |
| Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Asset / wealth manager; custodian Category 3C (Managing Assets / Custody / PSIAr / express trustee) | USD 250 k | USD 25 k | USD 25 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Asset / wealth manager Category 3C (Managing Assets, PSIAr, express trustee) | USD 140 k | USD 40 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| Adviser / arranger Category 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | USD 2 k | — | Retail | Rulebook | |
| CMA UAE#25 UAE · Federal | Investment manager Second Category – Dealing in Investment (Portfolio management) | USD 817 k | — | — | Retail | Secondary |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| Investment adviser / arranger Advisory and arranging firm (INMA 2014) | USD 250 k | USD 10 k | USD 5 k | Retail, with conditions | Secondary | |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Portfolio manager (no fund operation) Managing investments (CMIR Art. 6(g)(2)) | — | — | — | Retail | Rulebook | |
| Investment adviser Advising (CMIR Art. 6(g)(3)) | — | — | — | Retail | Rulebook | |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Portfolio management Registered firm: managing capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 14 k | USD 8 k | Retail | To confirm |
| Investment advice Registered firm: advising on capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 10 k | USD 8 k | Retail | To confirm | |
| NYDFS#23 United States · New York | Limited purpose trust company Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100) | — | USD 12 k | — | Retail | Rulebook |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Registered investment firm Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | — | USD 3 k | USD 850 (nominal) | Professional only | Secondary | |
| CIMA#29 Cayman Islands | Registered investment manager / adviser SIBA registered person (s. 5(4) and Schedule 4) | — | USD 7 k | USD 6 k | Professional only | Rulebook |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Trust company General trust license (Banks and Trust Companies Act 1990) | USD 250 k | — | — | Retail | Rulebook | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities adviser Type 4 – Advising on securities (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook | |
| FSA Japan#4 Japan | Investment adviser Investment Advisory and Agency Business (FIEA Art. 28(3)) | — | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| Adviser / MDA provider AFSL – personal advice and managed discretionary account (MDA) services | — | USD 2 k | — | Retail | Secondary | |
| MAS#8 Singapore | A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | Investment adviser with discretionary management Investment Adviser (Unrestricted) | USD 13 k | USD 600 (nominal) | USD 2 k | Retail | Rulebook |
| Multi-family office Family Office (Multiple) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026) | USD 50 k | USD 5 k | USD 10 k | Professional only | Rulebook | |
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
Not licensed by: VARA, CBUAE, SAMA, CFTC · NFA, FSA Seychelles.
Single-Family Office
An office serving one family, often exempt. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators9 of 34
Lowest capitalUSD 24 kCIMA
Median capitalUSD 24 k
Retail clients allowed1 regulators
A single-family office that manages only its own family’s wealth is exempt from licensing in many jurisdictions, or registers under a light regime. It needs a license as soon as it serves anyone outside the family, at which point it is treated as a multi-family office or an asset manager.
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#4 overall Tier 1
FSA Japan
Japan
Apply for: Art. 63 fund GP exemption
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
#8 overall Tier 1
MAS
Singapore
Apply for: Variable Capital Company
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
#10 overall Tier 1
FINMA
Switzerland
Apply for: Unapproved qualified-investor fund
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
Every fitting category
12 categories at 9 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| FINMA#10 Switzerland | Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook |
| MFSA#14 Malta | Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary |
| Middle East | ||||||
| CMA UAE#25 UAE · Federal | Family office Second Category – Dealing in Investment (Family business investment management – family office) | — | — | — | Professional only | To confirm |
| Americas | ||||||
| SEC#13 United States | Excluded single-family office Family office exclusion (Advisers Act s.202(a)(11)(G); Rule 202(a)(11)(G)-1) | — | — | — | Professional only | Rulebook |
| CIMA#29 Cayman Islands | Limited investor fund Limited investor fund (Mutual Funds Act s. 4(4)) | — | — | — | Professional only | Rulebook |
| In-house / family bank Restricted Class B banking license | USD 24 k | USD 5 k | — | Professional only | Secondary | |
| BVI FSC#34 British Virgin Islands | Restricted trust company Restricted trust license (Banks and Trust Companies Act 1990) | — | — | — | Professional only | Rulebook |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Art. 63 fund GP exemption Specially Permitted Business for Qualified Institutional Investors (FIEA Art. 63) – notification, not registration | — | — | — | Professional only | Secondary |
| MAS#8 Singapore | Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary |
| Single family office Single family office – class exemption from CMS licensing; tax incentives under sections 13O, 13OA and 13U of the Income Tax Act | — | — | — | Professional only | Rulebook | |
| Africa | ||||||
| FSC Mauritius#19 Mauritius | Global business company Global Business Licence (Global Business Company, GBC), Financial Services Act 2007 s.71 | — | — | USD 3 k | Professional only | Secondary |
| Single family office Family Office (Single) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026) | — | USD 2 k | USD 4 k | Professional only | Rulebook | |
Not licensed by: FCA, CySEC, BaFin, CSSF, CBI Ireland, Bank of Lithuania, DFSA, FSRA, VARA, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, CFTC · NFA, NYDFS, BMA, SCB Bahamas, SFC, ASIC, Labuan FSA, FSCA, FSA Seychelles, CMA Kenya, SEC Nigeria.
Investment Advisory Firm
Advice on investments without discretion. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators31 of 34
Lowest capitalUSD 11 kFSC Mauritius
Median capitalUSD 66 k
Retail clients allowed31 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities adviser
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 66 k
FSC Mauritius
USD 11 k
BMAUSD 12 k
SFCUSD 13 k
CIMAUSD 18 k
SCB BahamasUSD 25 k
FSA SeychellesUSD 25 k
VARAUSD 27 k
DFSAUSD 30 k
SEC NigeriaUSD 33 k
Labuan FSAUSD 35 k
FSRAUSD 50 k
CBBUSD 66 k
BaFinUSD 87 k
CSSFUSD 87 k
CBI IrelandUSD 87 k
Bank of LithuaniaUSD 87 k
MFSAUSD 87 k
CySECUSD 87 k
FCAUSD 100 k
FINMAUSD 125 k
CMA UAEUSD 136 k
MASUSD 195 k
QFCRAUSD 250 k
10k100k1m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
39 categories at 31 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (agency, no client money) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 | USD 87 k | — | — | Retail | Rulebook |
| CSSF#2 Luxembourg | Investment firm (agency, no client money) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 | USD 87 k | USD 58 k | USD 19 k | Retail | Rulebook |
| FCA#5 United Kingdom | Investment firm (agency, no client money) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 | USD 100 k | USD 4 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 | USD 87 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | Independent wealth manager Portfolio manager (FinIA, supervised by an SO) | USD 125 k | USD 2 k | — | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Investment firm without client assets Financial brokerage firm - EUR 75,000 band | USD 87 k | — | — | Retail | Rulebook |
| Financial advisor company Financial advisor company license | No minimum set | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Introducing broker / adviser Investment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A) | USD 87 k | USD 4 k | USD 4 k | Retail | Rulebook |
| Adviser / RTO for professional clients only Investment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | USD 87 k | USD 4 k | USD 4 k | Professional only | Rulebook | |
| Portfolio manager / agency broker Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | USD 87 k | USD 5 k | USD 5 k | Retail | Rulebook | |
| CySEC#16 Cyprus | Investment firm (agency, no client money) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 | USD 87 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operator Category 4 | USD 50 k | USD 20 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Adviser / arranger Category 4 | USD 30 k | USD 30 k | USD 15 k | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Adviser / arranger Category 3 investment firm (Volume 4; CA-1.2.7(c)) | USD 66 k | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Adviser / promoter / introducer Fifth Category – Arranging and Advice | USD 136 k | — | — | Retail | Rulebook |
| VARA#26 UAE · Dubai | VA adviser Advisory Services | USD 27 k | USD 11 k | USD 22 k | Retail, with conditions | Rulebook |
| QFCRA#28 Qatar · QFC | Investment adviser / arranger Advisory and arranging firm (INMA 2014) | USD 250 k | USD 10 k | USD 5 k | Retail, with conditions | Secondary |
| CMA Saudi#31 Saudi Arabia | Investment adviser Advising (CMIR Art. 6(g)(3)) | — | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| CFTC · NFA#15 United States | CTA Commodity trading advisor (CEA s.1a(12); Part 4) | — | USD 950 (nominal) | USD 750 (nominal) | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Investment advice Registered firm: advising on capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 10 k | USD 8 k | Retail | To confirm |
| BMA#27 Bermuda | Investment manager / adviser Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | USD 12 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Licensed arranger / adviser SIBA license - arranging deals or advising | USD 18 k | USD 7 k | USD 6 k | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Investment adviser SIBA Category 4: Investment advice | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities adviser Type 4 – Advising on securities (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Futures adviser Type 5 – Advising on futures contracts | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook | |
| FSA Japan#4 Japan | Investment adviser Investment Advisory and Agency Business (FIEA Art. 28(3)) | — | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Adviser / MDA provider AFSL – personal advice and managed discretionary account (MDA) services | — | USD 2 k | — | Retail | Secondary |
| Authorized representative model Corporate authorized representative (CAR) of an AFS licensee | — | — | — | Retail, with conditions | Secondary | |
| MAS#8 Singapore | Licensed financial adviser Financial Advisers Act: Financial adviser's license | USD 195 k | — | — | Retail | Rulebook |
| Labuan FSA#24 Malaysia · Labuan | Securities licensee Labuan securities licensee (LFSSA s. 55; Islamic under LIFSSA) | USD 35 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Advice and intermediary FSP FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund | — | USD 154 (nominal) | — | Retail | Rulebook |
| FSC Mauritius#19 Mauritius | Investment adviser with discretionary management Investment Adviser (Unrestricted) | USD 13 k | USD 600 (nominal) | USD 2 k | Retail | Rulebook |
| Investment adviser (advice only) Investment Adviser (Restricted) | USD 11 k | USD 600 (nominal) | USD 2 k | Retail | Rulebook | |
| VA adviser Virtual Asset Service Provider, Class S (Virtual Asset Advisory Services), VAITOS Act 2021 | — | USD 3 k | USD 5 k | Retail | Rulebook | |
| SEC Nigeria#22 Nigeria | Investment adviser Investment Adviser (Corporate) | USD 33 k | — | — | Retail | Rulebook |
| Robo-adviser Robo Adviser | USD 67 k | — | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Investment adviser Investment Adviser, including automated/robo-advisers (LN 197 of 2025) | — | USD 853 (nominal) | USD 775 (nominal) | Retail | Secondary |
| FSA Seychelles#32 Seychelles | Investment adviser Investment Adviser license (Securities Act 2007) | USD 25 k | USD 2 k | USD 5 k | Retail | Rulebook |
Pension & Endowment Manager
A manager of pension or endowment assets. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators21 of 34
Lowest capitalUSD 13 kSFC
Median capitalUSD 155 k
Retail clients allowed21 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (agency, no client money)
- Capital
- USD 87 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 155 k
SFC
USD 13 k
SCB BahamasUSD 25 k
BaFinUSD 87 k
CSSFUSD 87 k
CBI IrelandUSD 87 k
CySECUSD 87 k
FCAUSD 100 k
DFSAUSD 140 k
CMA KenyaUSD 155 k
Bank of LithuaniaUSD 174 k
FSRAUSD 250 k
FINMAUSD 250 k
FSA JapanUSD 335 k
MASUSD 390 k
CBBUSD 665 k
CMA UAEUSD 817 k
CMA SaudiUSD 5.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
26 categories at 21 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (agency, no client money) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000 | USD 87 k | — | — | Retail | Rulebook |
| Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary | |
| CSSF#2 Luxembourg | Investment firm (agency, no client money) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000 | USD 87 k | USD 58 k | USD 19 k | Retail | Rulebook |
| Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary | |
| FCA#5 United Kingdom | Investment firm (agency, no client money) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 | USD 100 k | USD 4 k | USD 3 k | Retail | Secondary |
| Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary | |
| CBI Ireland#7 Ireland | Investment firm (agency, no client money) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000 | USD 87 k | — | USD 35 k | Retail | Secondary |
| Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary | |
| FINMA#10 Switzerland | Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook |
| Bank of Lithuania#11 Lithuania | Pension fund manager Pension accumulation company | USD 174 k | — | — | Retail | Rulebook |
| CySEC#16 Cyprus | Investment firm (agency, no client money) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000 | USD 87 k | USD 8 k | USD 8 k | Retail | Secondary |
| Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Asset / wealth manager; custodian Category 3C (Managing Assets / Custody / PSIAr / express trustee) | USD 250 k | USD 25 k | USD 25 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Asset / wealth manager Category 3C (Managing Assets, PSIAr, express trustee) | USD 140 k | USD 40 k | — | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Agency broker / asset manager Category 2 investment firm (Volume 4; CA-1.2.7(b)) | USD 665 k | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Investment manager Second Category – Dealing in Investment (Portfolio management) | USD 817 k | — | — | Retail | Secondary |
| QFCRA#28 Qatar · QFC | Investment manager Investment management firm (Investment Management and Advisory Rules 2014, INMA) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Portfolio management Registered firm: managing capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 14 k | USD 8 k | Retail | To confirm |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Investment manager Investment Management Business (FIEA Art. 28(4)) – discretionary investment management | USD 335 k | USD 1 k | — | Retail | Rulebook |
| MAS#8 Singapore | Retail licensed fund manager CMS license: Fund management (Retail LFMC) | USD 390 k | USD 770 (nominal) | USD 3 k | Retail | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Discretionary investment manager FAIS Category II FSP (discretionary) | — | USD 932 (nominal) | — | Retail | Rulebook |
| CMA Kenya#30 Kenya | Fund manager Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | USD 155 k | USD 466 (nominal) | — | Retail | Secondary |
Not licensed by: MFSA, VARA, CBUAE, SAMA, CFTC · NFA, NYDFS, CIMA, BMA, ASIC, Labuan FSA, FSC Mauritius, FSA Seychelles, SEC Nigeria.
Sovereign Investment Vehicle
A state-owned investment entity or its managers. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators0 of 34
Lowest capital—
Median capital—
Retail clients allowed0 regulators
A sovereign investment vehicle is usually created by its own statute or decree and owned by the state, and is not licensed by a market regulator. What is licensed is the work done for it: the asset managers, advisers and custodians it appoints. Those categories appear under Asset Management Company, Fund Management Company and Investment Advisory Firm.
Every fitting category
0 categories at 0 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|
Not licensed by: FCA, CySEC, BaFin, CSSF, CBI Ireland, MFSA, FINMA, Bank of Lithuania, DFSA, FSRA, VARA, CMA UAE, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, SEC, CFTC · NFA, NYDFS, CIMA, BVI FSC, BMA, SCB Bahamas, MAS, SFC, ASIC, FSA Japan, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Private Bank
A deposit-taking bank serving private clients. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators20 of 34
Lowest capitalUSD 488 kCIMA
Median capitalUSD 7.47 m
Retail clients allowed20 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Bank
- Capital
- USD 5.8 m
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Bank
- Capital
- USD 10.09 m
- Fees at start
- USD 87 k
- Every year
- USD 135 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Bank
- Capital
- USD 13.4 m
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 7.47 m
CIMA
USD 488 k
BVI FSCUSD 1 m
Labuan FSAUSD 2.36 m
BMAUSD 5 m
BaFinUSD 5.8 m
FCAUSD 5.8 m
CBI IrelandUSD 5.8 m
Bank of LithuaniaUSD 5.8 m
MFSAUSD 5.8 m
QFCRAUSD 9.62 m
FSRAUSD 10 m
DFSAUSD 10 m
CSSFUSD 10.09 m
FINMAUSD 12.5 m
FSA JapanUSD 13.4 m
CBUAEUSD 27.23 m
MASUSD 78 m
CBBUSD 100 m
100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
33 categories at 20 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| FCA#5 United Kingdom | Bank Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 5.8 m | USD 37 k | USD 3 k | Retail | Rulebook |
| CBI Ireland#7 Ireland | Bank Credit institution (bank license under Section 9 of the Central Bank Act 1971) | USD 5.8 m | — | USD 339 k | Retail | Secondary |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Bank (deposit-taker) Category 1 | USD 10 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Islamic Financial Institution (PSIAu) Category 5 | USD 10 m | USD 30 k | — | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Bank (deposit-taker) Category 1 | USD 10 m | USD 15 k | USD 100 k | Retail, with conditions | Rulebook |
| Islamic Financial Institution (PSIAu) Category 5 | USD 10 m | USD 15 k | — | Retail, with conditions | Rulebook | |
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Wholesale bank Conventional wholesale bank (Volume 1, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| Islamic retail bank Islamic retail bank (Volume 2, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook | |
| QFCRA#28 Qatar · QFC | QFC bank Banking business firm (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| Islamic bank (PSIA) Islamic financial institution operating a profit-sharing investment account (Islamic Banking Business Prudential Rules 2015, IBANK) | USD 9.62 m | USD 10 k | USD 5 k | Retail, with conditions | Secondary | |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Islamic bank Licensed Bank (Islamic, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook | |
| Foreign bank branch Branch of a foreign bank | USD 27.23 m | — | — | Retail | Rulebook | |
| Restricted (wholesale) bank Restricted Licence Bank | USD 272.29 m | — | — | Professional only | Rulebook | |
| Americas | ||||||
| NYDFS#23 United States · New York | State-chartered bank New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | — | USD 12 k | — | Retail | To confirm |
| Foreign bank branch or agency Foreign bank branch, agency or representative office (Banking Law Article V) | — | USD 8 k | — | Retail, with conditions | To confirm | |
| BMA#27 Bermuda | Bermuda bank Bank license (Banks and Deposit Companies Act 1999) | USD 10 m | USD 50 k | USD 25 k | Retail | Rulebook |
| Restricted (fintech) bank Restricted bank license (Banks and Deposit Companies Act 1999) | USD 5 m | USD 50 k | — | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Domestic and offshore bank Class A banking license | USD 488 k | USD 5 k | — | Retail | Secondary |
| Offshore bank Class B banking license (unrestricted) | USD 488 k | USD 5 k | — | Retail, with conditions | Secondary | |
| BVI FSC#34 British Virgin Islands | Bank General banking license (Banks and Trust Companies Act 1990) | USD 2 m | USD 175 k | USD 150 k | Retail | Rulebook |
| Restricted bank Restricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990) | USD 1 m | USD 175 k | USD 150 k | Professional only | Rulebook | |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| MAS#8 Singapore | Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan bank Labuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA) | USD 2.36 m | USD 500 (nominal) | USD 41 k | Retail, with conditions | Rulebook |
Not licensed by: CySEC, VARA, CMA UAE, CMA Saudi, SEC, CFTC · NFA, SCB Bahamas, SFC, ASIC, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Digital Bank
A deposit-taking bank operating without branches. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators19 of 34
Lowest capitalUSD 375 kFINMA
Median capitalUSD 5.8 m
Retail clients allowed19 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Bank
- Capital
- USD 5.8 m
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Bank
- Capital
- USD 10.09 m
- Fees at start
- USD 87 k
- Every year
- USD 135 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Bank
- Capital
- USD 13.4 m
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 5.8 m
FINMA
USD 375 k
CIMAUSD 488 k
Bank of LithuaniaUSD 1.16 m
BVI FSCUSD 2 m
BMAUSD 5 m
BaFinUSD 5.8 m
FCAUSD 5.8 m
CBI IrelandUSD 5.8 m
MFSAUSD 5.8 m
FSRAUSD 10 m
DFSAUSD 10 m
CSSFUSD 10.09 m
MASUSD 11.7 m
Labuan FSAUSD 11.8 m
FSA JapanUSD 13.4 m
CBUAEUSD 81.69 m
CBBUSD 265.96 m
100k1m10m100m1bn
USD, logarithmic scale. Conversions are approximate.
Every fitting category
27 categories at 19 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| FCA#5 United Kingdom | Bank Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 5.8 m | USD 37 k | USD 3 k | Retail | Rulebook |
| CBI Ireland#7 Ireland | Bank Credit institution (bank license under Section 9 of the Central Bank Act 1971) | USD 5.8 m | — | USD 339 k | Retail | Secondary |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Banking license light FinTech license (Art. 1b Banking Act) | USD 375 k | — | USD 4 k | Retail | Secondary | |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| Specialized bank Specialised bank license (Law on Banks) | USD 1.16 m | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Bank (deposit-taker) Category 1 | USD 10 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Bank (deposit-taker) Category 1 | USD 10 m | USD 15 k | USD 100 k | Retail, with conditions | Rulebook |
| SAMA#18 Saudi Arabia | Digital bank Digital-only bank (Additional Licensing Guidelines and Criteria for Digital-Only Banks, Feb 2020) | — | — | — | Retail | Rulebook |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Islamic retail bank Islamic retail bank (Volume 2, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook | |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Islamic bank Licensed Bank (Islamic, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook | |
| Specialized (low-risk) bank Specialized Bank (Specialized Banks with Low Risk Regulation) | USD 81.69 m | — | — | Retail | Rulebook | |
| Americas | ||||||
| NYDFS#23 United States · New York | State-chartered bank New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | — | USD 12 k | — | Retail | To confirm |
| BMA#27 Bermuda | Bermuda bank Bank license (Banks and Deposit Companies Act 1999) | USD 10 m | USD 50 k | USD 25 k | Retail | Rulebook |
| Restricted (fintech) bank Restricted bank license (Banks and Deposit Companies Act 1999) | USD 5 m | USD 50 k | — | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Domestic and offshore bank Class A banking license | USD 488 k | USD 5 k | — | Retail | Secondary |
| BVI FSC#34 British Virgin Islands | Bank General banking license (Banks and Trust Companies Act 1990) | USD 2 m | USD 175 k | USD 150 k | Retail | Rulebook |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| MAS#8 Singapore | Digital full bank Banking Act: Digital full bank (DFB) license | USD 11.7 m | USD 15 k | USD 96 k | Retail | Rulebook |
| Digital wholesale bank Banking Act: Digital wholesale bank (DWB) license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Labuan digital bank Labuan digital banking license (Labuan Digital Banking Framework, Dec 2020) | USD 11.8 m | USD 500 (nominal) | USD 1 k | Retail, with conditions | Rulebook |
| Islamic digital bank (sandbox) Labuan Islamic digital bank under sandbox regulatory requirements (iBOX) | — | — | USD 1 k | Retail, with conditions | To confirm | |
Not licensed by: CySEC, VARA, CMA UAE, CMA Saudi, QFCRA, SEC, CFTC · NFA, SCB Bahamas, SFC, ASIC, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Investment Bank
Underwriting, dealing and advisory on a bank balance sheet. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators24 of 34
Lowest capitalUSD 5 kSEC
Median capitalUSD 932 k
Retail clients allowed22 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Corporate finance adviser / sponsor
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 932 k
SEC
USD 5 k
SFCUSD 13 k
FSC MauritiusUSD 22 k
SCB BahamasUSD 25 k
MASUSD 195 k
BaFinUSD 870 k
CSSFUSD 870 k
CBI IrelandUSD 870 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
CySECUSD 870 k
FCAUSD 998 k
CMA KenyaUSD 1.16 m
SEC NigeriaUSD 1.33 m
FINMAUSD 1.88 m
FSRAUSD 2 m
DFSAUSD 2 m
Labuan FSAUSD 2.36 m
CBBUSD 2.66 m
CMA SaudiUSD 13.33 m
FSA JapanUSD 13.4 m
CBUAEUSD 27.23 m
1k10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
47 categories at 24 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| Bank Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 5.8 m | USD 37 k | USD 3 k | Retail | Rulebook | |
| CBI Ireland#7 Ireland | Bank Credit institution (bank license under Section 9 of the Central Bank Act 1971) | USD 5.8 m | — | USD 339 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary | |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary | |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Bank (deposit-taker) Category 1 | USD 10 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Bank (deposit-taker) Category 1 | USD 10 m | USD 15 k | USD 100 k | Retail, with conditions | Rulebook |
| Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary | |
| CBB#20 Bahrain | Wholesale bank Conventional wholesale bank (Volume 1, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook |
| Islamic wholesale bank Islamic wholesale bank (Volume 2, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook | |
| QFCRA#28 Qatar · QFC | QFC bank Banking business firm (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Dealing / brokerage Dealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1)) | USD 13.33 m | — | — | Retail | Rulebook |
| Arranger / corporate finance Arranging (CMIR Art. 6(g)(3)) | — | — | — | Retail | Rulebook | |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Foreign bank branch Branch of a foreign bank | USD 27.23 m | — | — | Retail | Rulebook | |
| Restricted (wholesale) bank Restricted Licence Bank | USD 272.29 m | — | — | Professional only | Rulebook | |
| Americas | ||||||
| SEC#13 United States | Carrying / clearing broker-dealer Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)) | USD 250 k | USD 8 k | USD 1 k | Retail | Rulebook |
| Dealer / non-carrying principal broker-dealer Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)) | USD 100 k | USD 8 k | USD 1 k | Retail | Rulebook | |
| Non-receiving broker-dealer Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) | USD 5 k | USD 8 k | USD 1 k | Retail | Rulebook | |
| Capital acquisition broker FINRA Capital Acquisition Broker (CAB Rules); statutory M&A broker exemption (Exchange Act s.15(b)(13)) | USD 5 k | — | USD 1 k | Professional only | Secondary | |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent) Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) | USD 300 k | USD 16 k | USD 8 k | Retail | To confirm |
| Arranging deals Registered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | USD 25 k | USD 8 k | USD 8 k | Retail | To confirm | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Corporate finance adviser / sponsor Type 6 – Advising on corporate finance | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| ASIC#6 Australia | Wholesale-only AFSL AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | USD 1 k | — | Professional only | Rulebook |
| MAS#8 Singapore | Corporate finance adviser CMS license: Advising on corporate finance | USD 195 k | USD 770 (nominal) | USD 3 k | Retail, with conditions | Rulebook |
| Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary | |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
| Merchant bank Banking Act: Merchant bank license | USD 11.7 m | USD 15 k | USD 27 k | Professional only | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bank Labuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | USD 500 (nominal) | USD 36 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSC Mauritius#19 Mauritius | Full-service dealer with underwriting Investment Dealer (Full Service Dealer, including Underwriting) | USD 217 k | USD 3 k | USD 10 k | Retail | Rulebook |
| Corporate finance adviser Investment Adviser (Corporate Finance Advisory) | USD 22 k | USD 900 (nominal) | USD 3 k | Professional only | Rulebook | |
| SEC Nigeria#22 Nigeria | Issuing house Issuing House, Tier 1 | USD 1.33 m | — | — | Professional only | Rulebook |
| Issuing house with underwriting Issuing House, Tier 2 (with Underwriting) | USD 4.67 m | — | — | Professional only | Rulebook | |
| CMA Kenya#30 Kenya | Investment bank Investment Bank (LN 197 of 2025) | USD 1.16 m | USD 2 k | USD 2 k | Retail | Secondary |
Not licensed by: VARA, CMA UAE, SAMA, CFTC · NFA, NYDFS, CIMA, BVI FSC, BMA, FSCA, FSA Seychelles.
Electronic Money Institution
Issues electronic money and provides payment services. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators16 of 34
Lowest capitalUSD 43 kFSC Mauritius
Median capitalUSD 406 k
Retail clients allowed16 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: E-money institution
- Capital
- USD 406 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: E-money institution
- Capital
- USD 406 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Funds transfer, Type 1
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 406 k
FSC Mauritius
USD 43 k
MASUSD 78 k
FSRAUSD 250 k
FINMAUSD 375 k
BaFinUSD 406 k
CSSFUSD 406 k
FCAUSD 406 k
CBI IrelandUSD 406 k
Bank of LithuaniaUSD 406 k
MFSAUSD 406 k
DFSAUSD 500 k
SAMAUSD 533 k
CBUAEUSD 4.08 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
21 categories at 16 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | E-money institution Electronic money institution (Section 11 ZAG) | USD 406 k | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | E-money institution Electronic money institution (Law of 10 November 2009 on payment services) | USD 406 k | USD 35 k | USD 29 k | Retail | Secondary |
| FCA#5 United Kingdom | E-money institution Authorized electronic money institution (Electronic Money Regulations 2011) | USD 406 k | USD 8 k | — | Retail | Secondary |
| Small EMI Small electronic money institution (EMRs 2011 reg. 13) | — | USD 2 k | — | Retail | To confirm | |
| CBI Ireland#7 Ireland | E-money institution Electronic money institution (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011) | USD 406 k | — | — | Retail | Secondary |
| FINMA#10 Switzerland | Banking license light FinTech license (Art. 1b Banking Act) | USD 375 k | — | USD 4 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Electronic money institution Electronic money institution license | USD 406 k | — | — | Retail | Rulebook |
| Restricted EMI Electronic money institution license for restricted activity | No minimum set | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Electronic money institution Financial Institution license - electronic money institution | USD 406 k | USD 18 k | USD 41 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Money services firm (remittance, payment services, stored value, currency exchange) Category 3C (Providing Money Services) | USD 250 k | USD 15 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Stored value (e-money) issuer Category 3C (Providing Money Services – issuing Stored Value) | USD 500 k | USD 15 k | — | Retail, with conditions | Secondary |
| SAMA#18 Saudi Arabia | Micro EMI Micro Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(1), 44(1)(c)) | USD 533 k | USD 5 k | — | Retail | Rulebook |
| Major EMI Major Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(2), 44(1)(d)) | USD 2.67 m | USD 13 k | — | Retail | Rulebook | |
| CBUAE#33 UAE · Federal | E-money / wallet issuer Stored Value Facility (SVF) license | USD 4.08 m | — | — | Retail | Rulebook |
| Americas | ||||||
| NYDFS#23 United States · New York | Money transmitter Money transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406) | — | USD 3 k | — | Retail | Secondary |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Funds transfer, Type 1 Funds Transfer Service Provider – Type 1 (registration plus approval of a business implementation plan, Payment Services Act Art. 40-2) | — | — | — | Retail | Secondary |
| Funds transfer, Type 2 Funds Transfer Service Provider – Type 2 (registration, Payment Services Act) | — | — | — | Retail | Secondary | |
| ASIC#6 Australia | Non-cash payment facility provider AFSL – issue and deal in non-cash payment facilities | — | USD 2 k | — | Retail | To confirm |
| MAS#8 Singapore | Standard payment institution Payment Services Act: Standard Payment Institution (SPI) license | USD 78 k | USD 770 (nominal) | USD 4 k | Retail | Rulebook |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| Africa | ||||||
| FSC Mauritius#19 Mauritius | Payment intermediary Payment Intermediary Services (Financial Services Act 2007 s.14) | USD 43 k | USD 1 k | USD 3 k | Retail, with conditions | Secondary |
Not licensed by: CySEC, VARA, CMA UAE, CMA Saudi, CBB, QFCRA, SEC, CFTC · NFA, CIMA, BVI FSC, BMA, SCB Bahamas, SFC, Labuan FSA, FSCA, FSA Seychelles, CMA Kenya, SEC Nigeria.
Payment Service Provider
Executes, transfers and processes payments. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators19 of 34
Lowest capitalUSD 10 kBVI FSC
Median capitalUSD 58 k
Retail clients allowed19 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Payment institution (payment initiation)
- Capital
- USD 58 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Payment institution (payment initiation)
- Capital
- USD 58 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Funds transfer, Type 1
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 58 k
BVI FSC
USD 10 k
Bank of LithuaniaUSD 23 k
MFSAUSD 23 k
CBUAEUSD 27 k
CIMAUSD 37 k
FSC MauritiusUSD 43 k
BaFinUSD 58 k
CSSFUSD 58 k
FCAUSD 58 k
CBI IrelandUSD 58 k
MASUSD 78 k
CBBUSD 80 k
DFSAUSD 200 k
FSRAUSD 250 k
SAMAUSD 267 k
FINMAUSD 375 k
10k100k1m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
39 categories at 19 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Payment institution (payment initiation) Payment institution - payment initiation services only (Section 10 and Section 12 ZAG) | USD 58 k | — | — | Retail | Secondary |
| Payment institution (full) Payment institution - full scope (Section 10 and Section 12 ZAG) | USD 145 k | USD 16 k | — | Retail | Secondary | |
| E-money institution Electronic money institution (Section 11 ZAG) | USD 406 k | — | — | Retail | Secondary | |
| CSSF#2 Luxembourg | Payment institution (payment initiation) Payment institution - payment initiation services only (Law of 10 November 2009 on payment services) | USD 58 k | USD 35 k | USD 29 k | Retail | Secondary |
| Payment institution (full) Payment institution - full scope (Law of 10 November 2009 on payment services) | USD 145 k | USD 35 k | USD 29 k | Retail | Secondary | |
| E-money institution Electronic money institution (Law of 10 November 2009 on payment services) | USD 406 k | USD 35 k | USD 29 k | Retail | Secondary | |
| FCA#5 United Kingdom | E-money institution Authorized electronic money institution (Electronic Money Regulations 2011) | USD 406 k | USD 8 k | — | Retail | Secondary |
| Payment institution (payment initiation) Authorized payment institution - payment initiation services only (PSRs 2017) | USD 58 k | USD 4 k | — | Retail | Secondary | |
| Payment institution (full) Authorized payment institution - other payment services (PSRs 2017) | USD 145 k | USD 8 k | — | Retail | Secondary | |
| Small payment institution Small payment institution (PSRs 2017 reg. 13) | — | USD 2 k | USD 870 (nominal) | Retail | Secondary | |
| CBI Ireland#7 Ireland | Payment institution (payment initiation) Payment institution - payment initiation services only (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | USD 58 k | — | USD 8 k | Retail | Secondary |
| Payment institution (full) Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | USD 145 k | — | USD 8 k | Retail | Secondary | |
| E-money institution Electronic money institution (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011) | USD 406 k | — | — | Retail | Secondary | |
| FINMA#10 Switzerland | Banking license light FinTech license (Art. 1b Banking Act) | USD 375 k | — | USD 4 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Electronic money institution Electronic money institution license | USD 406 k | — | — | Retail | Rulebook |
| Payment institution Payment institution license | USD 23 k | — | — | Retail | Rulebook | |
| Restricted PI Payment institution license for restricted activities | No minimum set | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Electronic money institution Financial Institution license - electronic money institution | USD 406 k | USD 18 k | USD 41 k | Retail | Secondary |
| Payment institution Financial Institution license - payment institution | USD 23 k | USD 12 k | USD 29 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Money services firm (remittance, payment services, stored value, currency exchange) Category 3C (Providing Money Services) | USD 250 k | USD 15 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Payment services (money services other than stored value and money transmission) Category 3D | USD 200 k | USD 15 k | — | Retail, with conditions | Rulebook |
| SAMA#18 Saudi Arabia | Micro payment institution Micro Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(1), 44(1)(a)) | USD 267 k | USD 5 k | — | Retail | Rulebook |
| Major payment institution Major Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b)) | USD 800 k | USD 13 k | — | Retail | Rulebook | |
| Micro EMI Micro Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(1), 44(1)(c)) | USD 533 k | USD 5 k | — | Retail | Rulebook | |
| Major EMI Major Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(2), 44(1)(d)) | USD 2.67 m | USD 13 k | — | Retail | Rulebook | |
| Payment initiation (open banking) Payment Initiation Service provider (Art. 44(1)(e)) | USD 267 k | USD 5 k | — | Retail | Rulebook | |
| CBB#20 Bahrain | Payment service provider Ancillary service provider - card processing and payment service provider (Volume 5, AU-1.2.8; AU-2.5.4) | USD 665 k | USD 270 (nominal) | USD 3 k | Retail | Rulebook |
| Payment initiation (open banking) Payment Initiation Services Provider (Volume 5, AU-2.5.6C) | USD 80 k | USD 270 (nominal) | USD 3 k | Retail | Rulebook | |
| CBUAE#33 UAE · Federal | Payment service provider Retail Payment Services license (Category I to IV, RPSCS Regulation) | USD 27 k | — | — | Retail | Rulebook |
| Americas | ||||||
| NYDFS#23 United States · New York | Money transmitter Money transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406) | — | USD 3 k | — | Retail | Secondary |
| CIMA#29 Cayman Islands | Money services business Money services business license (Money Services Act) | USD 37 k | — | — | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Money services business Money services business license, Class A or Class B (Financing and Money Services Act 2009) | USD 10 k | — | — | Retail | Secondary |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Funds transfer, Type 1 Funds Transfer Service Provider – Type 1 (registration plus approval of a business implementation plan, Payment Services Act Art. 40-2) | — | — | — | Retail | Secondary |
| Funds transfer, Type 2 Funds Transfer Service Provider – Type 2 (registration, Payment Services Act) | — | — | — | Retail | Secondary | |
| Funds transfer, Type 3 Funds Transfer Service Provider – Type 3 (registration, Payment Services Act) | — | — | — | Retail | Secondary | |
| ASIC#6 Australia | Non-cash payment facility provider AFSL – issue and deal in non-cash payment facilities | — | USD 2 k | — | Retail | To confirm |
| MAS#8 Singapore | Standard payment institution Payment Services Act: Standard Payment Institution (SPI) license | USD 78 k | USD 770 (nominal) | USD 4 k | Retail | Rulebook |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| Africa | ||||||
| FSC Mauritius#19 Mauritius | Payment intermediary Payment Intermediary Services (Financial Services Act 2007 s.14) | USD 43 k | USD 1 k | USD 3 k | Retail, with conditions | Secondary |
Not licensed by: CySEC, VARA, CMA UAE, CMA Saudi, QFCRA, SEC, CFTC · NFA, BMA, SCB Bahamas, SFC, Labuan FSA, FSCA, FSA Seychelles, CMA Kenya, SEC Nigeria.
Money Services Business
Remittance, exchange and money transmission. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators16 of 34
Lowest capitalUSD 10 kBVI FSC
Median capitalUSD 25 k
Retail clients allowed16 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Payment institution (money remittance)
- Capital
- USD 23 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Payment institution (money remittance)
- Capital
- USD 23 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Funds transfer, Type 1
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 25 k
BVI FSC
USD 10 k
BaFinUSD 23 k
CSSFUSD 23 k
FCAUSD 23 k
CBI IrelandUSD 23 k
Bank of LithuaniaUSD 23 k
MFSAUSD 23 k
CBUAEUSD 27 k
CIMAUSD 37 k
MASUSD 78 k
DFSAUSD 140 k
FSRAUSD 250 k
SAMAUSD 533 k
CBBUSD 1.33 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
32 categories at 16 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Payment institution (money remittance) Payment institution - money remittance only (Section 10 and Section 12 ZAG) | USD 23 k | — | — | Retail | Secondary |
| Payment institution (full) Payment institution - full scope (Section 10 and Section 12 ZAG) | USD 145 k | USD 16 k | — | Retail | Secondary | |
| CSSF#2 Luxembourg | Payment institution (money remittance) Payment institution - money remittance only (Law of 10 November 2009 on payment services) | USD 23 k | USD 35 k | USD 29 k | Retail | Secondary |
| Payment institution (full) Payment institution - full scope (Law of 10 November 2009 on payment services) | USD 145 k | USD 35 k | USD 29 k | Retail | Secondary | |
| FCA#5 United Kingdom | Payment institution (money remittance) Authorized payment institution - money remittance only (PSRs 2017) | USD 23 k | USD 4 k | — | Retail | Secondary |
| Payment institution (full) Authorized payment institution - other payment services (PSRs 2017) | USD 145 k | USD 8 k | — | Retail | Secondary | |
| Small payment institution Small payment institution (PSRs 2017 reg. 13) | — | USD 2 k | USD 870 (nominal) | Retail | Secondary | |
| CBI Ireland#7 Ireland | Payment institution (money remittance) Payment institution - money remittance only (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | USD 23 k | — | USD 8 k | Retail | Secondary |
| Payment institution (full) Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | USD 145 k | — | USD 8 k | Retail | Secondary | |
| Bank of Lithuania#11 Lithuania | Payment institution Payment institution license | USD 23 k | — | — | Retail | Rulebook |
| Restricted PI Payment institution license for restricted activities | No minimum set | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Payment institution Financial Institution license - payment institution | USD 23 k | USD 12 k | USD 29 k | Retail | Secondary |
| Lending / FX / guarantee company Financial Institution license - traditional activities (First Schedule, other than paras. 4 and 10) | — | USD 12 k | USD 18 k | Retail, with conditions | Rulebook | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Money services firm (remittance, payment services, stored value, currency exchange) Category 3C (Providing Money Services) | USD 250 k | USD 15 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Money transmitter / crowdfunding operator Category 4 (Money Transmission / Crowdfunding Platform holding Client Assets) | USD 140 k | USD 15 k | — | Retail, with conditions | Rulebook |
| SAMA#18 Saudi Arabia | Major payment institution Major Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b)) | USD 800 k | USD 13 k | — | Retail | Rulebook |
| Money changer Money changer - currency exchange (Rules Regulating Money Changing Business) | USD 533 k | — | — | Retail | Rulebook | |
| Money changer with cash import/export Money changer - import and export of cash (Rules Regulating Money Changing Business) | USD 1.87 m | — | — | Retail | Rulebook | |
| Exchange house with remittance Money changer - money transfer inside and outside Saudi Arabia (Rules Regulating Money Changing Business) | USD 2.67 m | — | — | Retail | Rulebook | |
| CBB#20 Bahrain | Money changer / exchange house Money changer licensee (Volume 5 Type 1; CA-1.2.2) | USD 1.33 m | USD 270 (nominal) | — | Retail | Rulebook |
| CBUAE#33 UAE · Federal | Exchange house / remittance Exchange House – Category I, II or III (Exchange Business Regulation 2025) | USD 545 k | — | — | Retail | Secondary |
| Digital-only remittance provider Exchange House – Category IV (digital remittance, Exchange Business Regulation 2025) | USD 6.81 m | — | — | Retail | Secondary | |
| Payment service provider Retail Payment Services license (Category I to IV, RPSCS Regulation) | USD 27 k | — | — | Retail | Rulebook | |
| Americas | ||||||
| NYDFS#23 United States · New York | Money transmitter Money transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406) | — | USD 3 k | — | Retail | Secondary |
| CIMA#29 Cayman Islands | Money services business Money services business license (Money Services Act) | USD 37 k | — | — | Retail | Rulebook |
| BVI FSC#34 British Virgin Islands | Money services business Money services business license, Class A or Class B (Financing and Money Services Act 2009) | USD 10 k | — | — | Retail | Secondary |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Funds transfer, Type 1 Funds Transfer Service Provider – Type 1 (registration plus approval of a business implementation plan, Payment Services Act Art. 40-2) | — | — | — | Retail | Secondary |
| Funds transfer, Type 2 Funds Transfer Service Provider – Type 2 (registration, Payment Services Act) | — | — | — | Retail | Secondary | |
| Funds transfer, Type 3 Funds Transfer Service Provider – Type 3 (registration, Payment Services Act) | — | — | — | Retail | Secondary | |
| MAS#8 Singapore | Money changer Payment Services Act: Money-changing license | — | USD 385 (nominal) | USD 1 k | Retail | Rulebook |
| Standard payment institution Payment Services Act: Standard Payment Institution (SPI) license | USD 78 k | USD 770 (nominal) | USD 4 k | Retail | Rulebook | |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
Not licensed by: CySEC, FINMA, VARA, CMA UAE, CMA Saudi, QFCRA, SEC, CFTC · NFA, BMA, SCB Bahamas, SFC, ASIC, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Card Issuing Program
Issues payment cards to customers. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators15 of 34
Lowest capitalUSD 23 kBank of Lithuania
Median capitalUSD 145 k
Retail clients allowed15 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Payment institution (full)
- Capital
- USD 145 k
- Fees at start
- USD 16 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Payment institution (full)
- Capital
- USD 145 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Bank
- Capital
- USD 13.4 m
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
Bank of Lithuania
USD 23 k
MFSAUSD 23 k
CBUAEUSD 27 k
MASUSD 78 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
DFSAUSD 200 k
FSRAUSD 250 k
SAMAUSD 800 k
FSA JapanUSD 13.4 m
CBBUSD 265.96 m
10k100k1m10m100m1bn
USD, logarithmic scale. Conversions are approximate.
Every fitting category
33 categories at 15 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Payment institution (full) Payment institution - full scope (Section 10 and Section 12 ZAG) | USD 145 k | USD 16 k | — | Retail | Secondary |
| E-money institution Electronic money institution (Section 11 ZAG) | USD 406 k | — | — | Retail | Secondary | |
| CSSF#2 Luxembourg | Payment institution (full) Payment institution - full scope (Law of 10 November 2009 on payment services) | USD 145 k | USD 35 k | USD 29 k | Retail | Secondary |
| E-money institution Electronic money institution (Law of 10 November 2009 on payment services) | USD 406 k | USD 35 k | USD 29 k | Retail | Secondary | |
| FCA#5 United Kingdom | E-money institution Authorized electronic money institution (Electronic Money Regulations 2011) | USD 406 k | USD 8 k | — | Retail | Secondary |
| Payment institution (full) Authorized payment institution - other payment services (PSRs 2017) | USD 145 k | USD 8 k | — | Retail | Secondary | |
| CBI Ireland#7 Ireland | Payment institution (full) Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | USD 145 k | — | USD 8 k | Retail | Secondary |
| E-money institution Electronic money institution (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011) | USD 406 k | — | — | Retail | Secondary | |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| Specialized bank Specialised bank license (Law on Banks) | USD 1.16 m | — | — | Retail | Rulebook | |
| Electronic money institution Electronic money institution license | USD 406 k | — | — | Retail | Rulebook | |
| Payment institution Payment institution license | USD 23 k | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Electronic money institution Financial Institution license - electronic money institution | USD 406 k | USD 18 k | USD 41 k | Retail | Secondary | |
| Payment institution Financial Institution license - payment institution | USD 23 k | USD 12 k | USD 29 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Money services firm (remittance, payment services, stored value, currency exchange) Category 3C (Providing Money Services) | USD 250 k | USD 15 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Payment services (money services other than stored value and money transmission) Category 3D | USD 200 k | USD 15 k | — | Retail, with conditions | Rulebook |
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| Digital bank Digital-only bank (Additional Licensing Guidelines and Criteria for Digital-Only Banks, Feb 2020) | — | — | — | Retail | Rulebook | |
| Finance company Finance company - finance activities other than real estate (Implementing Regulation of the Finance Companies Control Law, Art. 8) | USD 26.67 m | USD 53 k | — | Retail | Rulebook | |
| Major payment institution Major Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b)) | USD 800 k | USD 13 k | — | Retail | Rulebook | |
| Major EMI Major Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(2), 44(1)(d)) | USD 2.67 m | USD 13 k | — | Retail | Rulebook | |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Islamic retail bank Islamic retail bank (Volume 2, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook | |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| E-money / wallet issuer Stored Value Facility (SVF) license | USD 4.08 m | — | — | Retail | Rulebook | |
| Payment service provider Retail Payment Services license (Category I to IV, RPSCS Regulation) | USD 27 k | — | — | Retail | Rulebook | |
| Americas | ||||||
| NYDFS#23 United States · New York | State-chartered bank New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | — | USD 12 k | — | Retail | To confirm |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| ASIC#6 Australia | Non-cash payment facility provider AFSL – issue and deal in non-cash payment facilities | — | USD 2 k | — | Retail | To confirm |
| MAS#8 Singapore | Standard payment institution Payment Services Act: Standard Payment Institution (SPI) license | USD 78 k | USD 770 (nominal) | USD 4 k | Retail | Rulebook |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary | |
Not licensed by: CySEC, FINMA, VARA, CMA UAE, CMA Saudi, QFCRA, SEC, CFTC · NFA, CIMA, BVI FSC, BMA, SCB Bahamas, SFC, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Merchant Acquiring
Accepts and settles card payments for merchants. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators12 of 34
Lowest capitalUSD 23 kBank of Lithuania
Median capitalUSD 145 k
Retail clients allowed12 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Payment institution (full)
- Capital
- USD 145 k
- Fees at start
- USD 16 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Payment institution (full)
- Capital
- USD 145 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#5 overall Tier 1
FCA
United Kingdom
Apply for: Payment institution (full)
- Capital
- USD 145 k
- Fees at start
- USD 8 k
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 145 k
Bank of Lithuania
USD 23 k
MFSAUSD 23 k
CBUAEUSD 27 k
MASUSD 78 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
DFSAUSD 200 k
FSRAUSD 250 k
SAMAUSD 267 k
CBBUSD 665 k
10k100k1m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
23 categories at 12 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Payment institution (full) Payment institution - full scope (Section 10 and Section 12 ZAG) | USD 145 k | USD 16 k | — | Retail | Secondary |
| CSSF#2 Luxembourg | Payment institution (full) Payment institution - full scope (Law of 10 November 2009 on payment services) | USD 145 k | USD 35 k | USD 29 k | Retail | Secondary |
| FCA#5 United Kingdom | Payment institution (full) Authorized payment institution - other payment services (PSRs 2017) | USD 145 k | USD 8 k | — | Retail | Secondary |
| CBI Ireland#7 Ireland | Payment institution (full) Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | USD 145 k | — | USD 8 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| Specialized bank Specialised bank license (Law on Banks) | USD 1.16 m | — | — | Retail | Rulebook | |
| Electronic money institution Electronic money institution license | USD 406 k | — | — | Retail | Rulebook | |
| Payment institution Payment institution license | USD 23 k | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Electronic money institution Financial Institution license - electronic money institution | USD 406 k | USD 18 k | USD 41 k | Retail | Secondary | |
| Payment institution Financial Institution license - payment institution | USD 23 k | USD 12 k | USD 29 k | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Money services firm (remittance, payment services, stored value, currency exchange) Category 3C (Providing Money Services) | USD 250 k | USD 15 k | USD 15 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Payment services (money services other than stored value and money transmission) Category 3D | USD 200 k | USD 15 k | — | Retail, with conditions | Rulebook |
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| Micro payment institution Micro Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(1), 44(1)(a)) | USD 267 k | USD 5 k | — | Retail | Rulebook | |
| Major payment institution Major Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b)) | USD 800 k | USD 13 k | — | Retail | Rulebook | |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Payment service provider Ancillary service provider - card processing and payment service provider (Volume 5, AU-1.2.8; AU-2.5.4) | USD 665 k | USD 270 (nominal) | USD 3 k | Retail | Rulebook | |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Payment service provider Retail Payment Services license (Category I to IV, RPSCS Regulation) | USD 27 k | — | — | Retail | Rulebook | |
| Asia-Pacific | ||||||
| MAS#8 Singapore | Standard payment institution Payment Services Act: Standard Payment Institution (SPI) license | USD 78 k | USD 770 (nominal) | USD 4 k | Retail | Rulebook |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary | |
Not licensed by: CySEC, FINMA, VARA, CMA UAE, CMA Saudi, QFCRA, SEC, CFTC · NFA, NYDFS, CIMA, BVI FSC, BMA, SCB Bahamas, SFC, ASIC, FSA Japan, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Correspondent Banking Structure
Banking services provided to other banks. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators20 of 34
Lowest capitalUSD 488 kCIMA
Median capitalUSD 10 m
Retail clients allowed20 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Bank
- Capital
- USD 5.8 m
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Bank
- Capital
- USD 10.09 m
- Fees at start
- USD 87 k
- Every year
- USD 135 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Bank
- Capital
- USD 13.4 m
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 10 m
CIMA
USD 488 k
BVI FSCUSD 2 m
Labuan FSAUSD 2.36 m
BaFinUSD 5.8 m
FCAUSD 5.8 m
CBI IrelandUSD 5.8 m
Bank of LithuaniaUSD 5.8 m
MFSAUSD 5.8 m
FSRAUSD 10 m
DFSAUSD 10 m
BMAUSD 10 m
CSSFUSD 10.09 m
FINMAUSD 12.5 m
FSA JapanUSD 13.4 m
CBUAEUSD 27.23 m
MASUSD 78 m
CBBUSD 100 m
100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
27 categories at 20 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| FCA#5 United Kingdom | Bank Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 5.8 m | USD 37 k | USD 3 k | Retail | Rulebook |
| CBI Ireland#7 Ireland | Bank Credit institution (bank license under Section 9 of the Central Bank Act 1971) | USD 5.8 m | — | USD 339 k | Retail | Secondary |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Bank (deposit-taker) Category 1 | USD 10 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Bank (deposit-taker) Category 1 | USD 10 m | USD 15 k | USD 100 k | Retail, with conditions | Rulebook |
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| Foreign bank branch Foreign bank branch (SAMA Licensing Guidelines and Minimum Criteria for Banks) | — | — | — | Retail, with conditions | Rulebook | |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Wholesale bank Conventional wholesale bank (Volume 1, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| QFCRA#28 Qatar · QFC | QFC bank Banking business firm (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Foreign bank branch Branch of a foreign bank | USD 27.23 m | — | — | Retail | Rulebook | |
| Restricted (wholesale) bank Restricted Licence Bank | USD 272.29 m | — | — | Professional only | Rulebook | |
| Americas | ||||||
| NYDFS#23 United States · New York | State-chartered bank New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | — | USD 12 k | — | Retail | To confirm |
| Foreign bank branch or agency Foreign bank branch, agency or representative office (Banking Law Article V) | — | USD 8 k | — | Retail, with conditions | To confirm | |
| BMA#27 Bermuda | Bermuda bank Bank license (Banks and Deposit Companies Act 1999) | USD 10 m | USD 50 k | USD 25 k | Retail | Rulebook |
| CIMA#29 Cayman Islands | Domestic and offshore bank Class A banking license | USD 488 k | USD 5 k | — | Retail | Secondary |
| Offshore bank Class B banking license (unrestricted) | USD 488 k | USD 5 k | — | Retail, with conditions | Secondary | |
| BVI FSC#34 British Virgin Islands | Bank General banking license (Banks and Trust Companies Act 1990) | USD 2 m | USD 175 k | USD 150 k | Retail | Rulebook |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| MAS#8 Singapore | Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan bank Labuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA) | USD 2.36 m | USD 500 (nominal) | USD 41 k | Retail, with conditions | Rulebook |
Not licensed by: CySEC, VARA, CMA UAE, CMA Saudi, SEC, CFTC · NFA, SCB Bahamas, SFC, ASIC, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Treasury & Liquidity Desk
Manages a group’s funding, liquidity and FX. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators19 of 34
Lowest capitalUSD 24 kCIMA
Median capitalUSD 1.54 m
Retail clients allowed18 regulators
A group treasury managing only its own group’s funding and FX is usually outside licensing. It needs a license when it deals or lends for third parties, holds client money, or provides payment services.
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Bank
- Capital
- USD 13.4 m
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 1.54 m
CIMA
USD 24 k
SECUSD 100 k
BaFinUSD 870 k
CSSFUSD 870 k
CBI IrelandUSD 870 k
CySECUSD 870 k
FCAUSD 998 k
BVI FSCUSD 1 m
Labuan FSAUSD 2.36 m
Bank of LithuaniaUSD 5.8 m
MFSAUSD 5.8 m
MASUSD 11.7 m
FINMAUSD 12.5 m
FSA JapanUSD 13.4 m
CBUAEUSD 27.23 m
CBBUSD 100 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
33 categories at 19 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook | |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary | |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| Bank Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 5.8 m | USD 37 k | USD 3 k | Retail | Rulebook | |
| CBI Ireland#7 Ireland | Bank Credit institution (bank license under Section 9 of the Central Bank Act 1971) | USD 5.8 m | — | USD 339 k | Retail | Secondary |
| Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| Foreign bank branch Foreign bank branch (SAMA Licensing Guidelines and Minimum Criteria for Banks) | — | — | — | Retail, with conditions | Rulebook | |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Wholesale bank Conventional wholesale bank (Volume 1, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| Islamic wholesale bank Islamic wholesale bank (Volume 2, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| QFCRA#28 Qatar · QFC | QFC bank Banking business firm (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Foreign bank branch Branch of a foreign bank | USD 27.23 m | — | — | Retail | Rulebook | |
| Restricted (wholesale) bank Restricted Licence Bank | USD 272.29 m | — | — | Professional only | Rulebook | |
| Americas | ||||||
| SEC#13 United States | Dealer / non-carrying principal broker-dealer Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)) | USD 100 k | USD 8 k | USD 1 k | Retail | Rulebook |
| NYDFS#23 United States · New York | State-chartered bank New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | — | USD 12 k | — | Retail | To confirm |
| Foreign bank branch or agency Foreign bank branch, agency or representative office (Banking Law Article V) | — | USD 8 k | — | Retail, with conditions | To confirm | |
| CIMA#29 Cayman Islands | Offshore bank Class B banking license (unrestricted) | USD 488 k | USD 5 k | — | Retail, with conditions | Secondary |
| In-house / family bank Restricted Class B banking license | USD 24 k | USD 5 k | — | Professional only | Secondary | |
| BVI FSC#34 British Virgin Islands | Restricted bank Restricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990) | USD 1 m | USD 175 k | USD 150 k | Professional only | Rulebook |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| MAS#8 Singapore | Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
| Merchant bank Banking Act: Merchant bank license | USD 11.7 m | USD 15 k | USD 27 k | Professional only | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan bank Labuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA) | USD 2.36 m | USD 500 (nominal) | USD 41 k | Retail, with conditions | Rulebook |
| Labuan investment bank Labuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | USD 500 (nominal) | USD 36 k | Retail, with conditions | Rulebook | |
Not licensed by: DFSA, FSRA, VARA, CMA UAE, CMA Saudi, CFTC · NFA, BMA, SCB Bahamas, SFC, ASIC, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Trade Finance House
Finances trade through credit, guarantees and receivables. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators18 of 34
Lowest capitalUSD 58 kCSSF
Median capitalUSD 3.59 m
Retail clients allowed18 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Bank
- Capital
- USD 5.8 m
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Lending PSF
- Capital
- USD 58 k
- Fees at start
- USD 35 k
- Every year
- USD 29 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Bank
- Capital
- USD 13.4 m
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 3.59 m
CSSF
USD 58 k
CIMAUSD 488 k
BMAUSD 1 m
Bank of LithuaniaUSD 1.16 m
FSRAUSD 2 m
DFSAUSD 2 m
BVI FSCUSD 2 m
Labuan FSAUSD 2.36 m
CBUAEUSD 5.45 m
BaFinUSD 5.8 m
MFSAUSD 5.8 m
FINMAUSD 12.5 m
SAMAUSD 13.33 m
FSA JapanUSD 13.4 m
MASUSD 78 m
CBBUSD 100 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
38 categories at 18 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Bank CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG | USD 5.8 m | — | — | Retail | Secondary |
| Lending institution Credit institution conducting lending business only (Kreditgeschäft, Section 32 KWG, non-CRR) | — | — | — | Retail | To confirm | |
| CSSF#2 Luxembourg | Bank Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | USD 10.09 m | USD 87 k | USD 135 k | Retail | Secondary |
| Lending PSF Professional performing lending operations (specialized PSF, Article 28-4 LFS) | USD 58 k | USD 35 k | USD 29 k | Retail | To confirm | |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| Specialized bank Specialised bank license (Law on Banks) | USD 1.16 m | — | — | Retail | Rulebook | |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Lending / FX / guarantee company Financial Institution license - traditional activities (First Schedule, other than paras. 4 and 10) | — | USD 12 k | USD 18 k | Retail, with conditions | Rulebook | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Bank (deposit-taker) Category 1 | USD 10 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Bank (deposit-taker) Category 1 | USD 10 m | USD 15 k | USD 100 k | Retail, with conditions | Rulebook |
| Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary | |
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| Foreign bank branch Foreign bank branch (SAMA Licensing Guidelines and Minimum Criteria for Banks) | — | — | — | Retail, with conditions | Rulebook | |
| Finance company Finance company - finance activities other than real estate (Implementing Regulation of the Finance Companies Control Law, Art. 8) | USD 26.67 m | USD 53 k | — | Retail | Rulebook | |
| SME finance company Finance company - SME finance only (Implementing Regulation of the Finance Companies Control Law, Art. 8) | USD 13.33 m | USD 53 k | — | Professional only | Rulebook | |
| CBB#20 Bahrain | Retail bank Conventional retail bank (Volume 1, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Wholesale bank Conventional wholesale bank (Volume 1, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| Islamic retail bank Islamic retail bank (Volume 2, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook | |
| Islamic wholesale bank Islamic wholesale bank (Volume 2, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| QFCRA#28 Qatar · QFC | QFC bank Banking business firm (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CBUAE#33 UAE · Federal | Commercial bank Licensed Bank (conventional, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Foreign bank branch Branch of a foreign bank | USD 27.23 m | — | — | Retail | Rulebook | |
| Restricted (wholesale) bank Restricted Licence Bank | USD 272.29 m | — | — | Professional only | Rulebook | |
| Non-bank lender Finance Company (Finance Companies Regulation) | USD 5.45 m | — | — | Retail | Rulebook | |
| Americas | ||||||
| NYDFS#23 United States · New York | State-chartered bank New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | — | USD 12 k | — | Retail | To confirm |
| Foreign bank branch or agency Foreign bank branch, agency or representative office (Banking Law Article V) | — | USD 8 k | — | Retail, with conditions | To confirm | |
| BMA#27 Bermuda | Deposit company Deposit company license (Banks and Deposit Companies Act 1999) | USD 1 m | USD 50 k | USD 20 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Domestic and offshore bank Class A banking license | USD 488 k | USD 5 k | — | Retail | Secondary |
| Offshore bank Class B banking license (unrestricted) | USD 488 k | USD 5 k | — | Retail, with conditions | Secondary | |
| BVI FSC#34 British Virgin Islands | Bank General banking license (Banks and Trust Companies Act 1990) | USD 2 m | USD 175 k | USD 150 k | Retail | Rulebook |
| Financing company Financing business license, Class C (Financing and Money Services Act 2009) | — | — | — | Retail, with conditions | Rulebook | |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook |
| MAS#8 Singapore | Full bank Banking Act: Full bank license (including qualifying full bank) | USD 156 m | USD 15 k | USD 96 k | Retail | Secondary |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
| Digital wholesale bank Banking Act: Digital wholesale bank (DWB) license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Rulebook | |
| Labuan FSA#24 Malaysia · Labuan | Labuan bank Labuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA) | USD 2.36 m | USD 500 (nominal) | USD 41 k | Retail, with conditions | Rulebook |
Not licensed by: FCA, CySEC, CBI Ireland, VARA, CMA UAE, CMA Saudi, SEC, CFTC · NFA, SCB Bahamas, SFC, ASIC, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Digital Asset Exchange
A trading platform for crypto and virtual assets. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators29 of 34
Lowest capitalUSD 5 kSEC
Median capitalUSD 174 k
Retail clients allowed29 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: CASP Class 3
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: CASP Class 3
- Capital
- USD 174 k
- Fees at start
- USD 17 k
- Every year
- USD 29 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Automated trading venue
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 174 k
SEC
USD 5 k
BMAUSD 10 k
FSA JapanUSD 67 k
FSA SeychellesUSD 100 k
FSC MauritiusUSD 141 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
Bank of LithuaniaUSD 174 k
MFSAUSD 174 k
CySECUSD 174 k
MASUSD 195 k
FCAUSD 200 k
DFSAUSD 200 k
VARAUSD 218 k
CMA UAEUSD 272 k
SFCUSD 642 k
CBBUSD 798 k
FINMAUSD 1.25 m
SEC NigeriaUSD 1.33 m
1k10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
39 categories at 29 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | CASP Class 3 MiCA crypto-asset service provider - Class 3 | USD 174 k | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | CASP Class 3 MiCA crypto-asset service provider - Class 3 | USD 174 k | USD 17 k | USD 29 k | Retail | Secondary |
| FCA#5 United Kingdom | Crypto AML registration Cryptoasset exchange / custodian wallet provider registration (MLRs 2017, current regime) | — | USD 15 k | — | Retail | Secondary |
| Crypto trading platform (UK QCATP) Operating a qualifying cryptoasset trading platform (new FSMA regime, from 25 October 2027) | USD 200 k | USD 37 k | — | Retail, with conditions | To confirm | |
| CBI Ireland#7 Ireland | CASP Class 3 MiCA crypto-asset service provider - Class 3 | USD 174 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | DLT trading facility DLT trading facility (FinMIA Art. 73a) | USD 1.25 m | — | USD 9 k | Retail | Rulebook |
| Bank of Lithuania#11 Lithuania | Crypto-asset trading platform MiCA CASP - Class 3 | USD 174 k | — | — | Retail | Secondary |
| MFSA#14 Malta | Crypto-asset trading platform MiCA CASP - Class 3 | USD 174 k | USD 12 k | USD 12 k | Retail | Secondary |
| CySEC#16 Cyprus | CASP Class 3 MiCA crypto-asset service provider - Class 3 | USD 174 k | — | — | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Virtual asset exchange (MTF) Operating an MTF using Virtual Assets | — | USD 125 k | USD 60 k | Retail, with conditions | Secondary |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary |
| Crypto token firm (dealing, ATS, custody, managing, advising) Crypto Token activities (GEN Chapter 3A) | — | USD 15 k | — | Retail, with conditions | Rulebook | |
| CBB#20 Bahrain | Licensed crypto-asset exchange Crypto-asset service licensee Category 4 (CRA-1.1.15; CRA-3.1.2) | USD 798 k | USD 270 (nominal) | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | VA trading platform Seventh Category – Virtual Assets Service Providers (Virtual asset platform operator) | USD 272 k | USD 125 k | USD 60 k | Retail, with conditions | Rulebook |
| VARA#26 UAE · Dubai | VA exchange Exchange Services | USD 218 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook |
| Americas | ||||||
| SEC#13 United States | Alternative trading system Alternative trading system (Regulation ATS, Rules 300-304; Form ATS or Form ATS-N) | USD 5 k | USD 8 k | USD 1 k | Retail, with conditions | Secondary |
| CFTC · NFA#15 United States | DCM (futures exchange) Designated contract market (CEA s.5; Part 38) | — | — | — | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Digital asset exchange Digital asset exchange registration (DARE Act, 2024, ss.21-24; Form 5) | — | USD 16 k | USD 12 k | Retail | Rulebook |
| NYDFS#23 United States · New York | BitLicense Virtual currency business activity license (BitLicense, 23 NYCRR Part 200) | — | USD 5 k | — | Retail | Rulebook |
| Conditional BitLicense Conditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c)) | — | USD 5 k | — | Retail | Secondary | |
| Limited purpose trust company Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100) | — | USD 12 k | — | Retail | Rulebook | |
| BMA#27 Bermuda | Digital asset test license DABA Class T license (Digital Asset Business Act 2018) | USD 10 k | USD 1 k | USD 1 k | Retail, with conditions | Rulebook |
| Digital asset modified license DABA Class M license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| Digital asset full license DABA Class F license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| CIMA#29 Cayman Islands | Licensed VASP (custody / trading platform) VASP license (Virtual Asset (Service Providers) Act, as amended 2024) | — | USD 43 k | USD 37 k | Retail, with conditions | To confirm |
| BVI FSC#34 British Virgin Islands | Registered VASP VASP registration (Virtual Assets Service Providers Act 2022) | — | USD 12 k | USD 8 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Automated trading venue Type 7 – Providing automated trading services | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| Virtual asset trading platform Virtual Asset Trading Platform (VATP) license (AMLO Part 5B), usually held with Types 1 and 7 under the SFO | USD 642 k | USD 609 (nominal) | — | Retail | Secondary | |
| FSA Japan#4 Japan | Crypto-asset exchange Crypto-Asset Exchange Service Provider registration (Payment Services Act Art. 63-2) | USD 67 k | — | — | Retail | Rulebook |
| ASIC#6 Australia | Licensed market operator Australian market license (Corporations Act Part 7.2) | — | — | USD 4 k | Retail, with conditions | Secondary |
| Digital asset platform / tokenized custody AFSL – digital asset platform (DAP) and tokenized custody platform (TCP) authorizations (Corporations Amendment (Digital Assets Framework) Act 2026) | — | USD 2 k | — | Retail | To confirm | |
| MAS#8 Singapore | Recognised market operator Recognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | USD 3 k | — | Retail, with conditions | Secondary |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| DTSP (overseas-only digital token services) Digital Token Service Provider (DTSP) license under Part 9 of the Financial Services and Markets Act 2022 | USD 195 k | — | — | Professional only | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan exchange Labuan exchange approval (LFSSA s. 134; Form LEB) | — | USD 500 (nominal) | USD 14 k | Retail, with conditions | To confirm |
| Africa | ||||||
| FSCA#17 South Africa | Crypto asset service provider (CASP) FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | — | USD 154 (nominal) | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | VA exchange Virtual Asset Service Provider, Class I (Virtual Asset Market Place), VAITOS Act 2021 | USD 141 k | USD 3 k | USD 5 k | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Digital asset exchange Digital Assets Exchange (DAX) | USD 1.33 m | — | — | Retail | Rulebook |
| FSA Seychelles#32 Seychelles | VA exchange VASP license: Virtual Asset Exchange (VASP Act 2024, First Schedule) | USD 100 k | USD 5 k | USD 31 k | Retail | Rulebook |
OTC Digital Asset Desk
Bilateral dealing and brokerage in digital assets. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators26 of 34
Lowest capitalUSD 10 kBMA
Median capitalUSD 72 k
Retail clients allowed25 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: CASP Class 1
- Capital
- USD 58 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: CASP Class 1
- Capital
- USD 58 k
- Fees at start
- USD 17 k
- Every year
- USD 29 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Crypto-asset exchange
- Capital
- USD 67 k
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 72 k
BMA
USD 10 k
FSC MauritiusUSD 43 k
FSA SeychellesUSD 50 k
BaFinUSD 58 k
CSSFUSD 58 k
CBI IrelandUSD 58 k
Bank of LithuaniaUSD 58 k
MFSAUSD 58 k
CySECUSD 58 k
FSA JapanUSD 67 k
MASUSD 78 k
VARAUSD 109 k
CBBUSD 266 k
SEC NigeriaUSD 333 k
Labuan FSAUSD 354 k
FSRAUSD 500 k
CMA UAEUSD 545 k
FCAUSD 998 k
FINMAUSD 1.88 m
DFSAUSD 2 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
45 categories at 26 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | CASP Class 1 MiCA crypto-asset service provider - Class 1 | USD 58 k | — | — | Retail | Secondary |
| CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | — | — | Retail | Secondary | |
| CSSF#2 Luxembourg | CASP Class 1 MiCA crypto-asset service provider - Class 1 | USD 58 k | USD 17 k | USD 29 k | Retail | Secondary |
| CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | USD 17 k | USD 29 k | Retail | Secondary | |
| FCA#5 United Kingdom | Crypto AML registration Cryptoasset exchange / custodian wallet provider registration (MLRs 2017, current regime) | — | USD 15 k | — | Retail | Secondary |
| Crypto dealer (principal) Dealing in qualifying cryptoassets as principal (new FSMA regime, from 25 October 2027) | USD 998 k | USD 15 k | — | Retail, with conditions | To confirm | |
| CBI Ireland#7 Ireland | CASP Class 1 MiCA crypto-asset service provider - Class 1 | USD 58 k | — | USD 35 k | Retail | Secondary |
| CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | — | USD 35 k | Retail | Secondary | |
| FINMA#10 Switzerland | Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Crypto-asset service provider (Class 1) MiCA CASP - Class 1 | USD 58 k | — | — | Retail | Secondary |
| Crypto-asset service provider (Class 2) MiCA CASP - Class 2 | USD 145 k | — | — | Retail | Secondary | |
| Crypto-asset trading platform MiCA CASP - Class 3 | USD 174 k | — | — | Retail | Secondary | |
| MFSA#14 Malta | Crypto-asset service provider (Class 1) MiCA CASP - Class 1 | USD 58 k | USD 12 k | USD 12 k | Retail | Secondary |
| Crypto-asset service provider (Class 2) MiCA CASP - Class 2 | USD 145 k | USD 12 k | USD 12 k | Retail | Secondary | |
| Crypto-asset trading platform MiCA CASP - Class 3 | USD 174 k | USD 12 k | USD 12 k | Retail | Secondary | |
| CySEC#16 Cyprus | CASP Class 1 MiCA crypto-asset service provider - Class 1 | USD 58 k | — | — | Retail | Secondary |
| CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | — | — | Retail | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| Matched-principal / agency broker Category 3A | USD 500 k | USD 40 k | USD 50 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| Crypto token firm (dealing, ATS, custody, managing, advising) Crypto Token activities (GEN Chapter 3A) | — | USD 15 k | — | Retail, with conditions | Rulebook | |
| CBB#20 Bahrain | Crypto agency broker / manager / custodian Crypto-asset service licensee Category 2 (CRA-1.1.11; CRA-3.1.2) | USD 266 k | USD 270 (nominal) | — | Retail | Rulebook |
| Crypto principal dealer Crypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2) | USD 532 k | USD 270 (nominal) | — | Retail | Rulebook | |
| CMA UAE#25 UAE · Federal | VA broker Seventh Category – Virtual Assets Service Providers (Virtual assets broker) | USD 545 k | USD 22 k | USD 15 k | Retail, with conditions | Rulebook |
| VARA#26 UAE · Dubai | VA broker-dealer / OTC desk Broker-Dealer Services | USD 109 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook |
| Americas | ||||||
| SCB Bahamas#21 The Bahamas | Digital asset business Digital asset business registration (DARE Act, 2024, Part III, s.6(1)) | — | USD 16 k | USD 12 k | Retail | Rulebook |
| NYDFS#23 United States · New York | BitLicense Virtual currency business activity license (BitLicense, 23 NYCRR Part 200) | — | USD 5 k | — | Retail | Rulebook |
| Conditional BitLicense Conditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c)) | — | USD 5 k | — | Retail | Secondary | |
| Limited purpose trust company Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100) | — | USD 12 k | — | Retail | Rulebook | |
| BMA#27 Bermuda | Digital asset test license DABA Class T license (Digital Asset Business Act 2018) | USD 10 k | USD 1 k | USD 1 k | Retail, with conditions | Rulebook |
| Digital asset modified license DABA Class M license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| Digital asset full license DABA Class F license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| CIMA#29 Cayman Islands | Registered VASP VASP registration (Virtual Asset (Service Providers) Act) | — | USD 3 k | USD 3 k | Retail, with conditions | To confirm |
| BVI FSC#34 British Virgin Islands | Registered VASP VASP registration (Virtual Assets Service Providers Act 2022) | — | USD 12 k | USD 8 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Crypto-asset exchange Crypto-Asset Exchange Service Provider registration (Payment Services Act Art. 63-2) | USD 67 k | — | — | Retail | Rulebook |
| Stablecoin intermediary Electronic Payment Instruments Exchange Service Provider registration (Payment Services Act, in force June 2023) | USD 67 k | — | — | Retail | Rulebook | |
| ASIC#6 Australia | Digital asset platform / tokenized custody AFSL – digital asset platform (DAP) and tokenized custody platform (TCP) authorizations (Corporations Amendment (Digital Assets Framework) Act 2026) | — | USD 2 k | — | Retail | To confirm |
| MAS#8 Singapore | Standard payment institution Payment Services Act: Standard Payment Institution (SPI) license | USD 78 k | USD 770 (nominal) | USD 4 k | Retail | Rulebook |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| DTSP (overseas-only digital token services) Digital Token Service Provider (DTSP) license under Part 9 of the Financial Services and Markets Act 2022 | USD 195 k | — | — | Professional only | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Money broker (FX and digital assets) Labuan money broking license (LFSSA Part VI), with digital asset activities | USD 354 k | USD 500 (nominal) | USD 11 k | Professional only | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | Crypto asset service provider (CASP) FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | — | USD 154 (nominal) | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | VA broker-dealer Virtual Asset Service Provider, Class M (Virtual Asset Broker-Dealer), VAITOS Act 2021 | USD 43 k | USD 1 k | USD 2 k | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Digital asset intermediary Digital Assets Intermediary (DAI) | USD 333 k | — | — | Retail | Rulebook |
| FSA Seychelles#32 Seychelles | VA broker VASP license: Virtual Asset Broking (VASP Act 2024, First Schedule) | USD 50 k | USD 5 k | USD 16 k | Retail | Rulebook |
Not licensed by: CBUAE, CMA Saudi, SAMA, QFCRA, SEC, CFTC · NFA, SFC, CMA Kenya.
Custody & Wallet Infrastructure
Safekeeping of digital assets and keys. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators29 of 34
Lowest capitalUSD 10 kBMA
Median capitalUSD 178 k
Retail clients allowed29 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: CASP Class 2
- Capital
- USD 145 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: CASP Class 2
- Capital
- USD 145 k
- Fees at start
- USD 17 k
- Every year
- USD 29 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Virtual asset trading platform
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 178 k
BMA
USD 10 k
FSA JapanUSD 67 k
FSA SeychellesUSD 75 k
FSC MauritiusUSD 109 k
BaFinUSD 145 k
CSSFUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
CySECUSD 145 k
VARAUSD 163 k
MASUSD 195 k
FCAUSD 200 k
FSRAUSD 250 k
SECUSD 250 k
CBBUSD 266 k
FINMAUSD 375 k
CBUAEUSD 408 k
SFCUSD 642 k
CMA UAEUSD 1.09 m
SEC NigeriaUSD 1.33 m
ASICUSD 7 m
10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
49 categories at 29 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | — | — | Retail | Secondary |
| CSSF#2 Luxembourg | CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | USD 17 k | USD 29 k | Retail | Secondary |
| FCA#5 United Kingdom | Crypto AML registration Cryptoasset exchange / custodian wallet provider registration (MLRs 2017, current regime) | — | USD 15 k | — | Retail | Secondary |
| Crypto custodian Safeguarding qualifying cryptoassets (new FSMA regime, from 25 October 2027) | USD 200 k | USD 15 k | — | Retail, with conditions | To confirm | |
| CBI Ireland#7 Ireland | CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Banking license light FinTech license (Art. 1b Banking Act) | USD 375 k | — | USD 4 k | Retail | Secondary | |
| DLT trading facility DLT trading facility (FinMIA Art. 73a) | USD 1.25 m | — | USD 9 k | Retail | Rulebook | |
| Bank of Lithuania#11 Lithuania | Crypto-asset service provider (Class 2) MiCA CASP - Class 2 | USD 145 k | — | — | Retail | Secondary |
| Crypto-asset trading platform MiCA CASP - Class 3 | USD 174 k | — | — | Retail | Secondary | |
| MFSA#14 Malta | Crypto-asset service provider (Class 2) MiCA CASP - Class 2 | USD 145 k | USD 12 k | USD 12 k | Retail | Secondary |
| Crypto-asset trading platform MiCA CASP - Class 3 | USD 174 k | USD 12 k | USD 12 k | Retail | Secondary | |
| CySEC#16 Cyprus | CASP Class 2 MiCA crypto-asset service provider - Class 2 | USD 145 k | — | — | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Public fund custodian / investment trust trustee Category 3B | USD 4 m | USD 25 k | USD 25 k | Professional only | Rulebook |
| Asset / wealth manager; custodian Category 3C (Managing Assets / Custody / PSIAr / express trustee) | USD 250 k | USD 25 k | USD 25 k | Retail, with conditions | Rulebook | |
| DFSA#12 UAE · Dubai, DIFC | Custodian / fund trustee Category 3B | — | USD 15 k | — | Retail, with conditions | To confirm |
| Crypto token firm (dealing, ATS, custody, managing, advising) Crypto Token activities (GEN Chapter 3A) | — | USD 15 k | — | Retail, with conditions | Rulebook | |
| CBB#20 Bahrain | Crypto agency broker / manager / custodian Crypto-asset service licensee Category 2 (CRA-1.1.11; CRA-3.1.2) | USD 266 k | USD 270 (nominal) | — | Retail | Rulebook |
| Crypto principal dealer Crypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2) | USD 532 k | USD 270 (nominal) | — | Retail | Rulebook | |
| Licensed crypto-asset exchange Crypto-asset service licensee Category 4 (CRA-1.1.15; CRA-3.1.2) | USD 798 k | USD 270 (nominal) | — | Retail | Rulebook | |
| CMA UAE#25 UAE · Federal | Custodian / clearing member Third Category – Custody, Clearing and Registration | USD 13.61 m | — | — | Retail, with conditions | Rulebook |
| VA custodian Seventh Category – Virtual Assets Service Providers (Custody of virtual assets) | USD 1.09 m | USD 22 k | USD 15 k | Retail, with conditions | Rulebook | |
| VARA#26 UAE · Dubai | VA custodian Custody Services | USD 163 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook |
| QFCRA#28 Qatar · QFC | Tokenization service provider Token services for investment tokens (QFC Digital Asset Regulations 2024; QFCRA Investment Token Rules 2024) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CBUAE#33 UAE · Federal | Payment token custodian / converter Payment Token Custody and Transfer / Conversion provider (Payment Token Services Regulation) | USD 408 k | — | — | Retail, with conditions | Rulebook |
| Americas | ||||||
| SEC#13 United States | Carrying / clearing broker-dealer Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)) | USD 250 k | USD 8 k | USD 1 k | Retail | Rulebook |
| SCB Bahamas#21 The Bahamas | Digital asset business Digital asset business registration (DARE Act, 2024, Part III, s.6(1)) | — | USD 16 k | USD 12 k | Retail | Rulebook |
| NYDFS#23 United States · New York | BitLicense Virtual currency business activity license (BitLicense, 23 NYCRR Part 200) | — | USD 5 k | — | Retail | Rulebook |
| Conditional BitLicense Conditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c)) | — | USD 5 k | — | Retail | Secondary | |
| Limited purpose trust company Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100) | — | USD 12 k | — | Retail | Rulebook | |
| BMA#27 Bermuda | Digital asset test license DABA Class T license (Digital Asset Business Act 2018) | USD 10 k | USD 1 k | USD 1 k | Retail, with conditions | Rulebook |
| Digital asset modified license DABA Class M license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| Digital asset full license DABA Class F license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| CIMA#29 Cayman Islands | Licensed VASP (custody / trading platform) VASP license (Virtual Asset (Service Providers) Act, as amended 2024) | — | USD 43 k | USD 37 k | Retail, with conditions | To confirm |
| BVI FSC#34 British Virgin Islands | Registered VASP VASP registration (Virtual Assets Service Providers Act 2022) | — | USD 12 k | USD 8 k | Retail, with conditions | Secondary |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Depositary of SFC-authorized funds Type 13 – Providing depositary services for relevant collective investment schemes | USD 1.28 m | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Virtual asset trading platform Virtual Asset Trading Platform (VATP) license (AMLO Part 5B), usually held with Types 1 and 7 under the SFO | USD 642 k | USD 609 (nominal) | — | Retail | Secondary | |
| FSA Japan#4 Japan | Crypto-asset exchange Crypto-Asset Exchange Service Provider registration (Payment Services Act Art. 63-2) | USD 67 k | — | — | Retail | Rulebook |
| Stablecoin intermediary Electronic Payment Instruments Exchange Service Provider registration (Payment Services Act, in force June 2023) | USD 67 k | — | — | Retail | Rulebook | |
| Trust company Trust company license or registration (Trust Business Act) | USD 335 k | — | — | Retail | Rulebook | |
| ASIC#6 Australia | Custodian AFSL – provide custodial or depository services (non-incidental) | USD 7 m | USD 2 k | USD 836 (nominal) | Retail | Rulebook |
| Digital asset platform / tokenized custody AFSL – digital asset platform (DAP) and tokenized custody platform (TCP) authorizations (Corporations Amendment (Digital Assets Framework) Act 2026) | — | USD 2 k | — | Retail | To confirm | |
| MAS#8 Singapore | Custodian CMS license: Providing custodial services | USD 780 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Crypto asset service provider (CASP) FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | — | USD 154 (nominal) | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | VA wallet provider Virtual Asset Service Provider, Class O (Virtual Asset Wallet Services), VAITOS Act 2021 | — | USD 1 k | USD 2 k | Retail | Rulebook |
| VA custodian Virtual Asset Service Provider, Class R (Virtual Asset Custodian), VAITOS Act 2021 | USD 109 k | USD 2 k | USD 2 k | Retail | Rulebook | |
| SEC Nigeria#22 Nigeria | Digital asset custodian Digital Assets Custodian | USD 1.33 m | — | — | Retail | Rulebook |
| FSA Seychelles#32 Seychelles | VA wallet / custody VASP license: Virtual Asset Wallet Provider (VASP Act 2024, First Schedule) | USD 75 k | USD 5 k | USD 26 k | Retail | Rulebook |
Not licensed by: CMA Saudi, SAMA, CFTC · NFA, Labuan FSA, CMA Kenya.
Tokenization Platform
Issues and administers tokenized securities and assets. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators27 of 34
Lowest capitalUSD 5 kSEC
Median capitalUSD 195 k
Retail clients allowed27 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (client money / MTF)
- Capital
- USD 174 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (holds client money/assets or operates MTF)
- Capital
- USD 174 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities dealer
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 195 k
SEC
USD 5 k
BMAUSD 10 k
FSRAUSD 50 k
VARAUSD 109 k
Labuan FSAUSD 118 k
BaFinUSD 174 k
CSSFUSD 174 k
CBI IrelandUSD 174 k
CySECUSD 174 k
MASUSD 195 k
FCAUSD 200 k
DFSAUSD 200 k
SEC NigeriaUSD 333 k
FSA JapanUSD 335 k
Bank of LithuaniaUSD 406 k
MFSAUSD 406 k
CBBUSD 532 k
SFCUSD 642 k
FINMAUSD 1.25 m
1k10k100k1m10m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
45 categories at 27 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (client money / MTF) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000 | USD 174 k | — | — | Retail | Rulebook |
| Crypto securities registrar Crypto securities registrar (Kryptowertpapierregisterführung, KWG financial service under the eWpG) | — | — | — | Retail, with conditions | To confirm | |
| CSSF#2 Luxembourg | Investment firm (holds client money/assets or operates MTF) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000 | USD 174 k | USD 58 k | USD 19 k | Retail | Rulebook |
| FCA#5 United Kingdom | Investment firm (client money / MTF) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000 | USD 200 k | USD 15 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | Investment firm (holds client money/assets or operates MTF) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000 | USD 174 k | — | USD 35 k | Retail | Secondary |
| FINMA#10 Switzerland | DLT trading facility DLT trading facility (FinMIA Art. 73a) | USD 1.25 m | — | USD 9 k | Retail | Rulebook |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| ART issuer MiCA issuer of asset-referenced tokens | USD 406 k | — | — | Retail | Secondary | |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| ART issuer MiCA issuer of asset-referenced tokens (Title III) | USD 406 k | USD 9 k | USD 2 k | Retail | Secondary | |
| CySEC#16 Cyprus | Investment firm (holds client money/assets or operates MTF) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000 | USD 174 k | USD 8 k | USD 8 k | Retail | Secondary |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Adviser / arranger / MTF-OTF operator Category 4 | USD 50 k | USD 20 k | USD 15 k | Retail, with conditions | Rulebook |
| Virtual asset exchange (MTF) Operating an MTF using Virtual Assets | — | USD 125 k | USD 60 k | Retail, with conditions | Secondary | |
| DFSA#12 UAE · Dubai, DIFC | Agency broker / ATS operator Category 3A | USD 200 k | USD 40 k | USD 25 k | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Crypto principal dealer Crypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2) | USD 532 k | USD 270 (nominal) | — | Retail | Rulebook |
| Licensed crypto-asset exchange Crypto-asset service licensee Category 4 (CRA-1.1.15; CRA-3.1.2) | USD 798 k | USD 270 (nominal) | — | Retail | Rulebook | |
| VARA#26 UAE · Dubai | VA broker-dealer / OTC desk Broker-Dealer Services | USD 109 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook |
| Real-world-asset token issuer Category 1 VA Issuance – Asset-Referenced Virtual Assets (ARVA) | USD 408 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook | |
| QFCRA#28 Qatar · QFC | Tokenization service provider Token services for investment tokens (QFC Digital Asset Regulations 2024; QFCRA Investment Token Rules 2024) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| Americas | ||||||
| SEC#13 United States | Alternative trading system Alternative trading system (Regulation ATS, Rules 300-304; Form ATS or Form ATS-N) | USD 5 k | USD 8 k | USD 1 k | Retail, with conditions | Secondary |
| Transfer agent Registered transfer agent (Exchange Act s.17A(c); Form TA-1; Rules 17Ac2-1 and 17Ad-1 to 17Ad-27) | — | — | — | Retail, with conditions | Secondary | |
| SCB Bahamas#21 The Bahamas | Digital asset business Digital asset business registration (DARE Act, 2024, Part III, s.6(1)) | — | USD 16 k | USD 12 k | Retail | Rulebook |
| Token offering Initial token offering registration (DARE Act, 2024, Part IV, ss.36-55) | — | — | — | Retail | Rulebook | |
| NYDFS#23 United States · New York | BitLicense Virtual currency business activity license (BitLicense, 23 NYCRR Part 200) | — | USD 5 k | — | Retail | Rulebook |
| Limited purpose trust company Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100) | — | USD 12 k | — | Retail | Rulebook | |
| BMA#27 Bermuda | Digital asset test license DABA Class T license (Digital Asset Business Act 2018) | USD 10 k | USD 1 k | USD 1 k | Retail, with conditions | Rulebook |
| Digital asset modified license DABA Class M license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| Digital asset full license DABA Class F license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| CIMA#29 Cayman Islands | Registered VASP VASP registration (Virtual Asset (Service Providers) Act) | — | USD 3 k | USD 3 k | Retail, with conditions | To confirm |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| Automated trading venue Type 7 – Providing automated trading services | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook | |
| Virtual asset trading platform Virtual Asset Trading Platform (VATP) license (AMLO Part 5B), usually held with Types 1 and 7 under the SFO | USD 642 k | USD 609 (nominal) | — | Retail | Secondary | |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| Proprietary trading system (PTS) PTS operation authorization (FIEA Art. 30) for a Type I firm | USD 2.01 m | — | — | Retail, with conditions | Rulebook | |
| Trust company Trust company license or registration (Trust Business Act) | USD 335 k | — | — | Retail | Rulebook | |
| ASIC#6 Australia | Licensed market operator Australian market license (Corporations Act Part 7.2) | — | — | USD 4 k | Retail, with conditions | Secondary |
| Digital asset platform / tokenized custody AFSL – digital asset platform (DAP) and tokenized custody platform (TCP) authorizations (Corporations Amendment (Digital Assets Framework) Act 2026) | — | USD 2 k | — | Retail | To confirm | |
| MAS#8 Singapore | Recognised market operator Recognised Market Operator (RMO) under Part 2 of the SFA | USD 195 k | USD 3 k | — | Retail, with conditions | Secondary |
| Labuan FSA#24 Malaysia · Labuan | Security token issuer Labuan securities token offering (Guidelines on Labuan Securities Token Offering, 6 Oct 2023) | USD 118 k | — | USD 1 k | Retail, with conditions | Secondary |
| Africa | ||||||
| FSC Mauritius#19 Mauritius | ITO issuer Issuer of Initial Token Offerings (registration under VAITOS Act 2021) | — | USD 2 k | — | Retail, with conditions | Rulebook |
| SEC Nigeria#22 Nigeria | Digital asset platform operator Digital Assets Platform Operator (DAPO), including token issuers | USD 333 k | — | — | Retail, with conditions | Rulebook |
| Digital asset offering platform Digital Assets Offering Platform (DAOP) | USD 667 k | — | — | Retail | Rulebook | |
| RWA tokenization platform Real-world Assets Tokenization and Offering Platform (RATOP) | USD 667 k | — | — | Retail | Rulebook | |
| CMA Kenya#30 Kenya | Regulatory sandbox Regulatory Sandbox admission (CMA Regulatory Sandbox Policy Guidance Note 2019) | — | — | — | Retail, with conditions | Secondary |
| FSA Seychelles#32 Seychelles | Securities exchange Securities Exchange license (Securities Act 2007) | — | USD 5 k | USD 10 k | Retail | Rulebook |
Not licensed by: CMA UAE, CBUAE, CMA Saudi, SAMA, CFTC · NFA, BVI FSC, FSCA.
Stablecoin Issuance Structure
Issues a fiat-referenced token. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators20 of 34
Lowest capitalUSD 10 kBMA
Median capitalUSD 406 k
Retail clients allowed20 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: E-money institution
- Capital
- USD 406 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: ART issuer
- Capital
- USD 406 k
- Fees at start
- USD 17 k
- Every year
- USD 12 k
#4 overall Tier 1
FSA Japan
Japan
Apply for: Stablecoin intermediary
- Capital
- USD 67 k
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 406 k
BMA
USD 10 k
FSA JapanUSD 67 k
MASUSD 195 k
SEC NigeriaUSD 333 k
BaFinUSD 406 k
CSSFUSD 406 k
CBI IrelandUSD 406 k
Bank of LithuaniaUSD 406 k
MFSAUSD 406 k
CySECUSD 406 k
VARAUSD 408 k
FCAUSD 466 k
CBBUSD 665 k
FSRAUSD 2 m
CBUAEUSD 4.08 m
FINMAUSD 12.5 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
35 categories at 20 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | E-money institution Electronic money institution (Section 11 ZAG) | USD 406 k | — | — | Retail | Secondary |
| ART issuer MiCA issuer of asset-referenced tokens (Title III authorization) | USD 406 k | — | — | Retail | Secondary | |
| CSSF#2 Luxembourg | E-money institution Electronic money institution (Law of 10 November 2009 on payment services) | USD 406 k | USD 35 k | USD 29 k | Retail | Secondary |
| ART issuer MiCA issuer of asset-referenced tokens (Title III authorization) | USD 406 k | USD 17 k | USD 12 k | Retail | Secondary | |
| FCA#5 United Kingdom | Stablecoin issuer Issuing qualifying stablecoins in the UK (new FSMA regime, from 25 October 2027) | USD 466 k | USD 15 k | — | Retail, with conditions | To confirm |
| CBI Ireland#7 Ireland | E-money institution Electronic money institution (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011) | USD 406 k | — | — | Retail | Secondary |
| ART issuer MiCA issuer of asset-referenced tokens (Title III authorization) | USD 406 k | — | — | Retail | Secondary | |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Bank of Lithuania#11 Lithuania | Bank Bank license (Law on Banks) | USD 5.8 m | — | — | Retail | Rulebook |
| Specialized bank Specialised bank license (Law on Banks) | USD 1.16 m | — | — | Retail | Rulebook | |
| Electronic money institution Electronic money institution license | USD 406 k | — | — | Retail | Rulebook | |
| ART issuer MiCA issuer of asset-referenced tokens | USD 406 k | — | — | Retail | Secondary | |
| MFSA#14 Malta | Bank Credit institution license (Banking Act, Cap. 371) | USD 5.8 m | USD 41 k | USD 58 k | Retail | Secondary |
| Electronic money institution Financial Institution license - electronic money institution | USD 406 k | USD 18 k | USD 41 k | Retail | Secondary | |
| ART issuer MiCA issuer of asset-referenced tokens (Title III) | USD 406 k | USD 9 k | USD 2 k | Retail | Secondary | |
| CySEC#16 Cyprus | ART issuer MiCA issuer of asset-referenced tokens (Title III authorization) | USD 406 k | — | — | Retail | To confirm |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fiat-referenced token (stablecoin) issuer Category 3C (Issuing a Fiat-Referenced Token) | USD 2 m | — | — | Retail, with conditions | Rulebook |
| CBB#20 Bahrain | Stablecoin issuer Stablecoin issuer license (Volume 6, Module SIO, SIO-4.1.1) | USD 665 k | — | — | Retail | Rulebook |
| VARA#26 UAE · Dubai | Stablecoin issuer (non-AED) Category 1 VA Issuance – Fiat-Referenced Virtual Assets (FRVA) | USD 408 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook |
| CBUAE#33 UAE · Federal | Stablecoin / payment token issuer Payment Token Issuer (Payment Token Services Regulation, Circular No. 2/2024) | USD 4.08 m | — | — | Retail, with conditions | Rulebook |
| Americas | ||||||
| SCB Bahamas#21 The Bahamas | Digital asset business Digital asset business registration (DARE Act, 2024, Part III, s.6(1)) | — | USD 16 k | USD 12 k | Retail | Rulebook |
| Token offering Initial token offering registration (DARE Act, 2024, Part IV, ss.36-55) | — | — | — | Retail | Rulebook | |
| NYDFS#23 United States · New York | BitLicense Virtual currency business activity license (BitLicense, 23 NYCRR Part 200) | — | USD 5 k | — | Retail | Rulebook |
| Limited purpose trust company Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100) | — | USD 12 k | — | Retail | Rulebook | |
| BMA#27 Bermuda | Digital asset test license DABA Class T license (Digital Asset Business Act 2018) | USD 10 k | USD 1 k | USD 1 k | Retail, with conditions | Rulebook |
| Digital asset modified license DABA Class M license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| Digital asset full license DABA Class F license (Digital Asset Business Act 2018) | USD 100 k | USD 2 k | — | Retail | Rulebook | |
| CIMA#29 Cayman Islands | Registered VASP VASP registration (Virtual Asset (Service Providers) Act) | — | USD 3 k | USD 3 k | Retail, with conditions | To confirm |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Stablecoin intermediary Electronic Payment Instruments Exchange Service Provider registration (Payment Services Act, in force June 2023) | USD 67 k | — | — | Retail | Rulebook |
| Funds transfer, Type 2 Funds Transfer Service Provider – Type 2 (registration, Payment Services Act) | — | — | — | Retail | Secondary | |
| Bank Bank license (Banking Act Art. 4) | USD 13.4 m | — | — | Retail | Rulebook | |
| Trust company Trust company license or registration (Trust Business Act) | USD 335 k | — | — | Retail | Rulebook | |
| ASIC#6 Australia | Non-cash payment facility provider AFSL – issue and deal in non-cash payment facilities | — | USD 2 k | — | Retail | To confirm |
| MAS#8 Singapore | Major payment institution Payment Services Act: Major Payment Institution (MPI) license | USD 195 k | USD 1 k | USD 8 k | Retail | Rulebook |
| Africa | ||||||
| SEC Nigeria#22 Nigeria | Digital asset platform operator Digital Assets Platform Operator (DAPO), including token issuers | USD 333 k | — | — | Retail, with conditions | Rulebook |
Not licensed by: DFSA, CMA UAE, CMA Saudi, SAMA, QFCRA, SEC, CFTC · NFA, BVI FSC, SFC, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya.
Digital Asset Fund
A fund investing in digital assets. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators26 of 34
Lowest capitalUSD 13 kSFC
Median capitalUSD 105 k
Retail clients allowed25 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 39 k
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Authorized AIFM
- Capital
- USD 145 k
- Fees at start
- USD 21 k
- Every year
- USD 49 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Asset manager (non-custodial)
- Capital
- USD 13 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 105 k
SFC
USD 13 k
FSC MauritiusUSD 22 k
FSA SeychellesUSD 25 k
DFSAUSD 40 k
FSRAUSD 50 k
CySECUSD 58 k
FSA JapanUSD 67 k
Labuan FSAUSD 71 k
VARAUSD 76 k
ASICUSD 105 k
BaFinUSD 145 k
CSSFUSD 145 k
FCAUSD 145 k
CBI IrelandUSD 145 k
Bank of LithuaniaUSD 145 k
MFSAUSD 145 k
MASUSD 195 k
FINMAUSD 250 k
CBBUSD 266 k
10k100k1m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
54 categories at 26 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Authorized AIFM AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | USD 145 k | USD 39 k | — | Retail, with conditions | Secondary |
| CSSF#2 Luxembourg | Authorized AIFM Authorized AIFM (Law of 12 July 2013 on AIFMs) | USD 145 k | USD 21 k | USD 49 k | Retail, with conditions | Secondary |
| SIF (regulated fund) Specialised investment fund (SIF), Law of 13 February 2007 | USD 1.45 m | USD 5 k | USD 5 k | Professional only | Secondary | |
| FCA#5 United Kingdom | Full-scope AIFM Full-scope UK AIFM (Part 4A permission, managing an AIF) | USD 145 k | USD 15 k | USD 3 k | Retail, with conditions | Secondary |
| Small authorized AIFM Small authorized UK AIFM (Part 4A permission, sub-threshold) | — | — | USD 3 k | Retail, with conditions | To confirm | |
| CBI Ireland#7 Ireland | Authorized AIFM Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | USD 145 k | — | USD 22 k | Retail, with conditions | Secondary |
| FINMA#10 Switzerland | Asset manager of funds / pension assets Manager of collective assets (FinIA) | USD 250 k | USD 5 k | USD 6 k | Retail, with conditions | Rulebook |
| Swiss fund (product approval) Swiss collective investment scheme approval (CISA) | — | USD 5 k | USD 750 (nominal) | Retail | To confirm | |
| Unapproved qualified-investor fund Limited Qualified Investor Fund (L-QIF) | — | — | — | Professional only | Rulebook | |
| Bank of Lithuania#11 Lithuania | Fund management company Management company (UCITS and/or AIF) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| MFSA#14 Malta | Alternative investment fund manager Investment Services Licence Category 2 (full-scope AIFM) | USD 145 k | — | — | Retail, with conditions | Rulebook |
| Licensed alternative fund Licensed AIF (Professional or Qualifying Investors) | — | USD 4 k | USD 5 k | Professional only | Secondary | |
| Notified alternative fund Notified AIF (NAIF) | — | — | — | Professional only | Secondary | |
| Professional investor fund Professional Investor Fund (PIF) for Qualifying Investors | — | USD 3 k | USD 4 k | Professional only | Secondary | |
| CySEC#16 Cyprus | Authorized AIFM Alternative Investment Fund Manager (AIFM Law 56(I)/2013) | USD 145 k | — | — | Retail, with conditions | Secondary |
| Sub-threshold fund manager Mini-AIFM / sub-threshold AIFM (Law 81(I)/2020) | USD 58 k | — | — | Professional only | Secondary | |
| Private AIF (up to 50 investors) Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018 | USD 58 k | — | — | Professional only | Secondary | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Fund manager Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 50 k | USD 10 k | USD 10 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Fund manager (public, exempt, qualified investor, venture capital funds) Category 3C (Fund Manager – Managing a Collective Investment Fund) | USD 40 k | USD 15 k | — | Retail, with conditions | Secondary |
| Crypto token firm (dealing, ATS, custody, managing, advising) Crypto Token activities (GEN Chapter 3A) | — | USD 15 k | — | Retail, with conditions | Rulebook | |
| CBB#20 Bahrain | Crypto agency broker / manager / custodian Crypto-asset service licensee Category 2 (CRA-1.1.11; CRA-3.1.2) | USD 266 k | USD 270 (nominal) | — | Retail | Rulebook |
| Crypto principal dealer Crypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2) | USD 532 k | USD 270 (nominal) | — | Retail | Rulebook | |
| VARA#26 UAE · Dubai | VA portfolio / investment manager VA Management and Investment Services | USD 76 k | USD 27 k | USD 54 k | Retail, with conditions | Rulebook |
| Americas | ||||||
| SEC#13 United States | SEC-registered investment adviser Registered investment adviser (Advisers Act s.203; Form ADV) | — | USD 40 (nominal) | USD 40 (nominal) | Retail | Rulebook |
| Exempt reporting adviser (private funds under USD 150m) Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1) | — | USD 150 (nominal) | USD 150 (nominal) | Professional only | Rulebook | |
| CFTC · NFA#15 United States | CPO Commodity pool operator (CEA s.1a(11); Part 4) | — | USD 950 (nominal) | USD 750 (nominal) | Retail, with conditions | Rulebook |
| SCB Bahamas#21 The Bahamas | Investment fund manager Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | — | USD 1 k | USD 800 (nominal) | Retail, with conditions | To confirm |
| Professional fund Professional fund (Investment Funds Act, 2019) | — | USD 2 k | USD 3 k | Professional only | Secondary | |
| SMART fund SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | — | USD 2 k | USD 3 k | Retail, with conditions | Secondary | |
| Digital asset business Digital asset business registration (DARE Act, 2024, Part III, s.6(1)) | — | USD 16 k | USD 12 k | Retail | Rulebook | |
| BMA#27 Bermuda | Bermuda investment fund Investment funds (Investment Funds Act 2006): authorized and registered funds | — | USD 950 (nominal) | USD 1 k | Retail, with conditions | Rulebook |
| CIMA#29 Cayman Islands | Registered open-ended fund Registered mutual fund (Mutual Funds Act s. 4(3)) | — | — | USD 5 k | Professional only | Rulebook |
| Administered fund Administered mutual fund (Mutual Funds Act s. 4(1)(b)) | — | — | — | Retail, with conditions | Rulebook | |
| Limited investor fund Limited investor fund (Mutual Funds Act s. 4(4)) | — | — | — | Professional only | Rulebook | |
| Closed-ended fund Private fund (Private Funds Act 2020) | — | — | USD 5 k | Professional only | Secondary | |
| BVI FSC#34 British Virgin Islands | Investment manager SIBA Category 3: Investment management | — | USD 3 k | USD 2 k | Retail, with conditions | Secondary |
| Approved manager Approved manager (Investment Business (Approved Managers) Regulations 2012) | — | USD 1 k | USD 2 k | Professional only | Secondary | |
| Private fund Private fund (SIBA; Mutual Funds Regulations 2010) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Professional fund Professional fund (SIBA; Mutual Funds Regulations 2010) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Incubator fund Incubator fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Approved fund Approved fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015) | — | USD 2 k | USD 1 k | Professional only | Secondary | |
| Closed-ended private investment fund Private investment fund (closed-ended; SIBA as amended 2019) | — | USD 850 (nominal) | USD 1 k | Professional only | Secondary | |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Asset manager (non-custodial) Type 9 – Asset management (no client assets) | USD 13 k | USD 609 (nominal) | USD 609 (nominal) | Retail, with conditions | Rulebook |
| FSA Japan#4 Japan | Pro investment manager Investment Management Business for Qualified Investors (FIEA Art. 29-5) | USD 67 k | USD 1 k | — | Professional only | Rulebook |
| ASIC#6 Australia | Wholesale fund manager AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | — | USD 1 k | — | Professional only | Secondary |
| Responsible entity (retail fund operator) AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | USD 105 k | USD 2 k | — | Retail | Secondary | |
| MAS#8 Singapore | A/I licensed fund manager CMS license: Fund management (Accredited/Institutional LFMC) | USD 195 k | USD 770 (nominal) | USD 3 k | Professional only | Rulebook |
| Variable Capital Company Variable Capital Company (VCC Act 2018) – fund vehicle, not a license | — | — | — | Retail, with conditions | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Fund manager Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | USD 71 k | USD 500 (nominal) | USD 4 k | Retail, with conditions | Rulebook |
| Private fund Labuan private fund (LFSSA s. 28) | — | — | USD 1 k | Professional only | Rulebook | |
| Africa | ||||||
| FSCA#17 South Africa | Crypto asset service provider (CASP) FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | — | USD 154 (nominal) | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | CIS / CEF manager CIS Manager (Securities Act 2005; also manages Closed-End Funds) | USD 22 k | USD 1 k | USD 2 k | Retail | Rulebook |
| Fund vehicle Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | — | USD 1 k | USD 4 k | Retail, with conditions | Secondary | |
| FSA Seychelles#32 Seychelles | VA investment provider VASP license: Virtual Asset Investment Provider (VASP Act 2024, First Schedule) | USD 25 k | USD 5 k | USD 10 k | Retail | Rulebook |
Not licensed by: CMA UAE, CBUAE, CMA Saudi, SAMA, QFCRA, NYDFS, CMA Kenya, SEC Nigeria.
Mining & Validation Operation
Mining, staking and validation infrastructure. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators2 of 34
Lowest capitalUSD 200 kFCA
Median capitalUSD 200 k
Retail clients allowed2 regulators
Mining and validation are generally not licensed financial activities. A license becomes necessary when the operation stakes or holds digital assets for others, pools client assets, or offers yield products, which are covered under Custody & Wallet Infrastructure and Digital Asset Exchange.
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
Every fitting category
2 categories at 2 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| FCA#5 United Kingdom | Crypto staking provider Arranging qualifying cryptoasset staking (new FSMA regime, from 25 October 2027) | USD 200 k | USD 4 k | — | Retail, with conditions | To confirm |
| Americas | ||||||
| SCB Bahamas#21 The Bahamas | Digital asset business Digital asset business registration (DARE Act, 2024, Part III, s.6(1)) | — | USD 16 k | USD 12 k | Retail | Rulebook |
Not licensed by: CySEC, BaFin, CSSF, CBI Ireland, MFSA, FINMA, Bank of Lithuania, DFSA, FSRA, VARA, CMA UAE, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, SEC, CFTC · NFA, NYDFS, CIMA, BVI FSC, BMA, MAS, SFC, ASIC, FSA Japan, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya, SEC Nigeria.
Commodities Trading House
Physical and derivative commodity trading. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators8 of 34
Lowest capitalUSD 33 kSEC Nigeria
Median capitalUSD 870 k
Retail clients allowed7 regulators
Physical commodity trading is generally not a licensed financial activity. A license is needed for dealing in commodity derivatives for clients, operating a commodity exchange, or managing commodity funds, and those categories are listed here.
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- Not recorded
- Every year
- Not recorded
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Investment firm (dealing on own account)
- Capital
- USD 870 k
- Fees at start
- USD 58 k
- Every year
- USD 19 k
#5 overall Tier 1
FCA
United Kingdom
Apply for: Investment firm (dealing on own account)
- Capital
- USD 998 k
- Fees at start
- USD 15 k
- Every year
- USD 3 k
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 870 k
SEC Nigeria
USD 33 k
BaFinUSD 870 k
CSSFUSD 870 k
CBI IrelandUSD 870 k
CySECUSD 870 k
FCAUSD 998 k
CFTC · NFAUSD 20 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
8 categories at 8 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Investment firm (dealing on own account) Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000 | USD 870 k | — | — | Retail | Rulebook |
| CSSF#2 Luxembourg | Investment firm (dealing on own account) Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | USD 870 k | USD 58 k | USD 19 k | Retail | Secondary |
| FCA#5 United Kingdom | Investment firm (dealing on own account) MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | USD 998 k | USD 15 k | USD 3 k | Retail | Secondary |
| CBI Ireland#7 Ireland | Investment firm (dealing on own account) MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | USD 870 k | — | USD 35 k | Retail | Secondary |
| CySEC#16 Cyprus | Investment firm (dealing on own account) Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | USD 870 k | USD 8 k | USD 8 k | Retail | Secondary |
| Americas | ||||||
| CFTC · NFA#15 United States | Swap dealer Swap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | USD 298 k | USD 282 k | Professional only | Rulebook |
| SCB Bahamas#21 The Bahamas | FCSP (financial services) Financial and corporate service provider license, financial services (Financial and Corporate Service Providers Act, 2020) | — | — | — | Retail, with conditions | Secondary |
| Africa | ||||||
| SEC Nigeria#22 Nigeria | Commodities broker-dealer Commodities Broker/Dealer | USD 33 k | USD 200 (nominal) | — | Retail | Rulebook |
Not licensed by: MFSA, FINMA, Bank of Lithuania, DFSA, FSRA, VARA, CMA UAE, CBUAE, CMA Saudi, SAMA, CBB, QFCRA, SEC, NYDFS, CIMA, BVI FSC, BMA, MAS, SFC, ASIC, FSA Japan, Labuan FSA, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya.
Insurance & Reinsurance Vehicle
An insurer, reinsurer or captive. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators20 of 34
Lowest capitalUSD 25 kFSA Seychelles
Median capitalUSD 199 k
Retail clients allowed19 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#1 overall Tier 1
BaFin
Germany
Apply for: Insurer / reinsurer
- Capital
- USD 1.51 m
- Fees at start
- Not recorded
- Every year
- Not recorded
#4 overall Tier 1
FSA Japan
Japan
Apply for: Insurer
- Capital
- USD 6.7 m
- Fees at start
- Not recorded
- Every year
- Not recorded
#5 overall Tier 1
FCA
United Kingdom
Apply for: Insurer / reinsurer
- Capital
- USD 1.6 m
- Fees at start
- USD 37 k
- Every year
- USD 3 k
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 199 k
FSA Seychelles
USD 25 k
FSC MauritiusUSD 65 k
Labuan FSAUSD 71 k
CIMAUSD 100 k
BVI FSCUSD 100 k
BMAUSD 120 k
QFCRAUSD 148 k
DFSAUSD 150 k
NYDFSUSD 150 k
CBBUSD 199 k
BaFinUSD 1.51 m
CBI IrelandUSD 1.51 m
Bank of LithuaniaUSD 1.51 m
MFSAUSD 1.51 m
FCAUSD 1.6 m
FINMAUSD 3.75 m
MASUSD 3.9 m
FSA JapanUSD 6.7 m
CBUAEUSD 27.23 m
10k100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
54 categories at 20 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| BaFin#1 Germany | Insurer / reinsurer Insurance or reinsurance undertaking (Insurance Supervision Act, VAG) | USD 1.51 m | — | — | Retail | Rulebook |
| FCA#5 United Kingdom | Insurer / reinsurer Insurer / reinsurer (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | USD 1.6 m | USD 37 k | USD 3 k | Retail | Rulebook |
| CBI Ireland#7 Ireland | Insurer / reinsurer Insurance or reinsurance undertaking (European Union (Insurance and Reinsurance) Regulations 2015, S.I. 485/2015) | USD 1.51 m | — | USD 37 k | Retail | Rulebook |
| FINMA#10 Switzerland | Insurer / reinsurer / captive Insurance undertaking license (Insurance Supervision Act) | USD 3.75 m | — | — | Retail | Rulebook |
| Bank of Lithuania#11 Lithuania | Insurer Insurance / reinsurance undertaking (Law on Insurance) | USD 1.51 m | — | — | Retail | Secondary |
| MFSA#14 Malta | Non-life insurer or captive Insurance undertaking - non-life (Insurance Business Act, Cap. 403) | USD 3.13 m | — | — | Retail | Secondary |
| Life insurer Insurance undertaking - life | USD 4.64 m | — | — | Retail | Secondary | |
| Reinsurer / captive reinsurer Reinsurance undertaking | USD 1.51 m | — | — | Professional only | Secondary | |
| Insurance cell company Protected Cell Company / Incorporated Cell Company (insurance) | — | — | — | Retail, with conditions | To confirm | |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Insurer, reinsurer or captive Insurer (Effecting and Carrying Out Contracts of Insurance, PIN rules) | — | USD 5 k | USD 5 k | Retail, with conditions | To confirm |
| DFSA#12 UAE · Dubai, DIFC | Insurer, reinsurer or takaful operator (non-captive) Insurer (Effecting and Carrying Out Contracts of Insurance, PIN module) | — | USD 15 k | USD 50 k | Retail, with conditions | To confirm |
| Captive insurer Captive Insurer (Class 1, 2 or 3, PIN module) | USD 150 k | USD 15 k | — | Professional only | Secondary | |
| CBB#20 Bahrain | Insurer Bahraini insurance firm (Volume 3, CA-1.2.1) | USD 13.3 m | — | — | Retail | Rulebook |
| Reinsurer Bahraini reinsurance firm (Volume 3, CA-1.2.1) | USD 26.6 m | — | — | Professional only | Rulebook | |
| Captive insurer (C1) Captive insurer Category C1 (Volume 3, CA-2.1.5(e)) | USD 199 k | — | — | Professional only | Rulebook | |
| Captive insurer (C2) Captive insurer Category C2 (Volume 3, CA-2.1.5(f)) | USD 798 k | — | — | Professional only | Rulebook | |
| QFCRA#28 Qatar · QFC | Insurance and reinsurance Insurer / reinsurer (Insurance Business Rules 2006, PINS) | USD 9.89 m | USD 10 k | USD 5 k | Retail, with conditions | Secondary |
| Captive insurer QFC captive insurer, Classes 1 to 4 (Captive Insurance Business Rules 2011, CAPI) | USD 148 k | USD 10 k | USD 5 k | Professional only | Secondary | |
| CBUAE#33 UAE · Federal | Insurer / reinsurer / takaful Insurance / Reinsurance Company license | USD 27.23 m | — | — | Retail | Rulebook |
| Americas | ||||||
| NYDFS#23 United States · New York | Domestic insurance company Domestic insurer license (New York Insurance Law; capital and surplus under ss.4103 and 4202) | USD 150 k | — | — | Retail | Rulebook |
| Captive insurer Captive insurance company (New York Insurance Law Article 70) | USD 250 k | — | — | Professional only | Rulebook | |
| BMA#27 Bermuda | Pure captive Insurance Class 1 (Insurance Act 1978) | USD 120 k | USD 3 k | USD 2 k | Professional only | Rulebook |
| Multi-owner / limited third-party captive Insurance Class 2 (Insurance Act 1978) | USD 250 k | USD 3 k | USD 2 k | Professional only | Rulebook | |
| Small commercial / captive with third-party business Insurance Class 3 (Insurance Act 1978) | USD 1 m | USD 3 k | USD 2 k | Retail, with conditions | Rulebook | |
| Small commercial insurer Insurance Class 3A (Insurance Act 1978) | USD 1 m | USD 3 k | USD 2 k | Retail, with conditions | Rulebook | |
| Large commercial insurer Insurance Class 3B (Insurance Act 1978) | USD 1 m | USD 3 k | USD 2 k | Retail, with conditions | Rulebook | |
| Large commercial insurer/reinsurer Insurance Class 4 (Insurance Act 1978) | USD 100 m | USD 3 k | USD 2 k | Professional only | Rulebook | |
| Long-term pure captive Long-term insurance Class A (Insurance Act 1978) | USD 120 k | USD 3 k | USD 2 k | Professional only | Rulebook | |
| Long-term multi-owner captive Long-term insurance Class B (Insurance Act 1978) | USD 250 k | USD 3 k | USD 2 k | Professional only | Rulebook | |
| Small commercial life insurer Long-term insurance Class C (Insurance Act 1978) | USD 500 k | USD 800 (nominal) | — | Retail, with conditions | Rulebook | |
| Mid-size commercial life insurer Long-term insurance Class D (Insurance Act 1978) | USD 4 m | USD 800 (nominal) | — | Retail, with conditions | Rulebook | |
| Large commercial life insurer Long-term insurance Class E (Insurance Act 1978) | USD 8 m | USD 800 (nominal) | — | Retail, with conditions | Secondary | |
| ILS / fully collateralized vehicle Special Purpose Insurer (SPI) (Insurance Act 1978) | USD 1 (nominal) | USD 3 k | USD 2 k | Professional only | Rulebook | |
| Collateralized reinsurance vehicle Collateralized Insurer (Insurance Act 1978) | USD 250 k | USD 3 k | USD 2 k | Professional only | Secondary | |
| Innovative (sandbox) insurer Innovative insurer classes IIGB and IILT (Insurance Act 1978, Insurance Regulatory Sandbox) | USD 120 k | USD 800 (nominal) | — | Retail, with conditions | Rulebook | |
| CIMA#29 Cayman Islands | Domestic insurer Class A insurer license | USD 366 k | — | — | Retail | Rulebook |
| Pure captive Class B(i) insurer license | USD 100 k | — | — | Professional only | Rulebook | |
| Captive with significant third-party business Class B(ii) insurer license | USD 150 k | — | — | Professional only | Rulebook | |
| Commercial / open-market captive Class B(iii) insurer license | USD 200 k | — | — | Professional only | Rulebook | |
| Collateralized reinsurer / ILS vehicle Class C insurer license | USD 500 (nominal) | — | — | Professional only | Rulebook | |
| Open-market reinsurer Class D insurer license | USD 50 m | — | — | Professional only | Rulebook | |
| BVI FSC#34 British Virgin Islands | Insurer / captive Insurer license (Insurance Act 2008), domestic or captive | USD 100 k | — | — | Retail, with conditions | Rulebook |
| Asia-Pacific | ||||||
| FSA Japan#4 Japan | Insurer Insurance business license (Insurance Business Act) | USD 6.7 m | — | — | Retail | Rulebook |
| MAS#8 Singapore | Direct insurer / reinsurer Insurance Act 1966: Licensed direct insurer or reinsurer | USD 3.9 m | — | — | Retail | Secondary |
| Captive insurer Insurance Act 1966: Captive insurer license | — | — | — | Professional only | To confirm | |
| Labuan FSA#24 Malaysia · Labuan | Direct insurer Labuan direct insurer license, general or life (LFSSA; takaful operators under LIFSSA) | USD 1.77 m | USD 500 (nominal) | USD 26 k | Retail, with conditions | Rulebook |
| Reinsurer Labuan reinsurer license (retakaful under LIFSSA) | USD 2.36 m | USD 500 (nominal) | USD 26 k | Professional only | Rulebook | |
| Captive insurer Labuan captive insurer license: pure, group, association or multi-owner captive | USD 71 k | USD 500 (nominal) | USD 5 k | Professional only | Rulebook | |
| Rent-a-captive / cell captive Labuan captive insurer license: rent-a-captive or protected cell captive | USD 118 k | USD 500 (nominal) | USD 2 k | Professional only | Rulebook | |
| Africa | ||||||
| FSC Mauritius#19 Mauritius | Captive insurer Captive Insurance (Captive Insurance Act 2015): pure captive, multi-owner pure captive, Class 1, 2 and 3 third-party captives | USD 65 k | USD 1 k | USD 2 k | Professional only | Rulebook |
| Insurer / reinsurer Insurer license (Insurance Act 2005): general insurance, long-term insurance, reinsurance | USD 543 k | USD 2 k | USD 4 k | Retail | Rulebook | |
| FSA Seychelles#32 Seychelles | Non-domestic insurer Non-domestic insurer: general, long-term or combined (Insurance Act 2008; Insurance (Non-Domestic Insurance Business) Regulations 2009) | USD 100 k | — | — | Professional only | Rulebook |
| Reinsurer Non-domestic reinsurer (Insurance Act 2008; Regulations 2009) | USD 50 k | — | — | Professional only | Rulebook | |
| Captive insurer Non-domestic captive insurer (Insurance Act 2008; Regulations 2009) | USD 25 k | — | — | Professional only | Rulebook | |
Not licensed by: CySEC, CSSF, VARA, CMA UAE, CMA Saudi, SAMA, SEC, CFTC · NFA, SCB Bahamas, SFC, ASIC, FSCA, CMA Kenya, SEC Nigeria.
Islamic Finance Structure
A Shari’a-compliant institution or window. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators10 of 34
Lowest capitalUSD 35 kLabuan FSA
Median capitalUSD 9.62 m
Retail clients allowed10 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#9 overall Tier 1
FSRA
UAE · Abu Dhabi, ADGM
Apply for: Islamic Financial Institution (PSIAu)
- Capital
- USD 10 m
- Fees at start
- USD 30 k
- Every year
- Not recorded
#12 overall Tier 1
DFSA
UAE · Dubai, DIFC
Apply for: Islamic Financial Institution (PSIAu)
- Capital
- USD 10 m
- Fees at start
- USD 15 k
- Every year
- Not recorded
#18 overall Tier 2
SAMA
Saudi Arabia
Apply for: Commercial bank
- Capital
- Not recorded
- Fees at start
- Not recorded
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 9.62 m
Labuan FSA
USD 35 k
SEC NigeriaUSD 1.33 m
CMA SaudiUSD 5.33 m
CMA UAEUSD 9.53 m
QFCRAUSD 9.62 m
FSRAUSD 10 m
DFSAUSD 10 m
CBBUSD 100 m
CBUAEUSD 544.59 m
10k100k1m10m100m1bn
USD, logarithmic scale. Conversions are approximate.
Every fitting category
15 categories at 10 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Islamic Financial Institution (PSIAu) Category 5 | USD 10 m | USD 30 k | — | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Islamic Financial Institution (PSIAu) Category 5 | USD 10 m | USD 15 k | — | Retail, with conditions | Rulebook |
| Islamic window of a conventional firm Islamic Window endorsement | — | USD 15 k | — | Retail, with conditions | Secondary | |
| SAMA#18 Saudi Arabia | Commercial bank Locally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018) | — | — | — | Retail | Rulebook |
| CBB#20 Bahrain | Islamic retail bank Islamic retail bank (Volume 2, LR-2.5.2A) | USD 265.96 m | USD 35 k | — | Retail | Rulebook |
| Islamic wholesale bank Islamic wholesale bank (Volume 2, LR-2.5.2B) | USD 100 m | USD 35 k | — | Retail, with conditions | Rulebook | |
| CMA UAE#25 UAE · Federal | PSIA manager (Islamic) Second Category – Dealing in Investment (Managing a profit-sharing investment account) | USD 9.53 m | — | — | Retail, with conditions | Secondary |
| QFCRA#28 Qatar · QFC | Islamic bank (PSIA) Islamic financial institution operating a profit-sharing investment account (Islamic Banking Business Prudential Rules 2015, IBANK) | USD 9.62 m | USD 10 k | USD 5 k | Retail, with conditions | Secondary |
| Islamic window Islamic window or Islamic financial business (QFCRA Islamic Finance Rules, ISFI) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm | |
| CMA Saudi#31 Saudi Arabia | Asset and fund manager Managing investments and operating funds (CMIR Art. 6(g)(2)) | USD 5.33 m | — | — | Retail | Rulebook |
| CBUAE#33 UAE · Federal | Islamic bank Licensed Bank (Islamic, incorporated in the UAE) | USD 544.59 m | — | — | Retail | Rulebook |
| Asia-Pacific | ||||||
| Labuan FSA#24 Malaysia · Labuan | Islamic digital bank (sandbox) Labuan Islamic digital bank under sandbox regulatory requirements (iBOX) | — | — | USD 1 k | Retail, with conditions | To confirm |
| Islamic financial institution Labuan Islamic financial business (LIFSSA 2010): Islamic bank, Islamic investment bank, takaful and retakaful, Islamic fund manager, Islamic securities licensee | USD 35 k | — | USD 1 k | Retail, with conditions | Rulebook | |
| Africa | ||||||
| SEC Nigeria#22 Nigeria | Fund manager, full scope Tier 1 Fund/Portfolio Manager (Full Scope) | USD 3.33 m | USD 7 k | — | Retail | Rulebook |
| Fund manager, limited scope Tier 2 Fund/Portfolio Manager (Limited Scope) | USD 1.33 m | USD 7 k | — | Retail | Rulebook | |
Not licensed by: FCA, CySEC, BaFin, CSSF, CBI Ireland, MFSA, FINMA, Bank of Lithuania, VARA, SEC, CFTC · NFA, NYDFS, CIMA, BVI FSC, BMA, SCB Bahamas, MAS, SFC, ASIC, FSA Japan, FSCA, FSC Mauritius, FSA Seychelles, CMA Kenya.
Structured Products Issuer
Issues notes, certificates and structured instruments. The tables below list every category, among the thirty-four regulators, under which it may be built.
Regulators22 of 34
Lowest capitalUSD 100 kSEC
Median capitalUSD 1.28 m
Retail clients allowed19 regulators
Where to build it
The three highest-ranked homes
By the balanced ranking of the regulators, with the lowest-capital category that fits.
#2 overall Tier 1
CSSF
Luxembourg
Apply for: Securitization vehicle (CSSF-authorized)
- Capital
- Not recorded
- Fees at start
- USD 7 k
- Every year
- USD 10 k
#3 overall Tier 1
SFC
Hong Kong
Apply for: Securities dealer
- Capital
- USD 642 k
- Fees at start
- USD 609 (nominal)
- Every year
- USD 609 (nominal)
#4 overall Tier 1
FSA Japan
Japan
Apply for: Securities firm (Type I FIBO)
- Capital
- USD 335 k
- Fees at start
- USD 1 k
- Every year
- Not recorded
Capital
Minimum capital of the lowest fitting category
Tier 1Tier 2OffshoreMiddle halfMedian USD 1.28 m
SEC
USD 100 k
FSC MauritiusUSD 217 k
BMAUSD 250 k
SCB BahamasUSD 300 k
FSA JapanUSD 335 k
MASUSD 390 k
SFCUSD 642 k
Bank of LithuaniaUSD 870 k
MFSAUSD 870 k
FINMAUSD 1.88 m
FSRAUSD 2 m
DFSAUSD 2 m
Labuan FSAUSD 2.36 m
CBBUSD 2.66 m
SEC NigeriaUSD 4.67 m
CMA UAEUSD 8.17 m
CMA SaudiUSD 13.33 m
CFTC · NFAUSD 20 m
100k1m10m100m
USD, logarithmic scale. Conversions are approximate.
Every fitting category
27 categories at 22 regulators
Fees at start add the application fee to the fee on grant. Amounts in USD; a dash means none is recorded.
| Regulator | Category | Capital | Fees at start | Every year | Clients | Reading |
|---|---|---|---|---|---|---|
| Europe | ||||||
| CSSF#2 Luxembourg | Securitization vehicle (CSSF-authorized) Authorized securitization undertaking (Law of 22 March 2004 on securitization) | — | USD 7 k | USD 10 k | Retail | To confirm |
| FINMA#10 Switzerland | Bank Bank license (Banking Act) | USD 12.5 m | USD 12 k | USD 19 k | Retail | Secondary |
| Securities firm / broker-dealer Securities firm (FinIA) | USD 1.88 m | USD 12 k | USD 12 k | Retail | Secondary | |
| Bank of Lithuania#11 Lithuania | Dealer / underwriter Financial brokerage firm - EUR 750,000 band | USD 870 k | — | — | Retail | Rulebook |
| MFSA#14 Malta | Dealer / market maker / MTF operator Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | USD 870 k | USD 8 k | USD 8 k | Retail | Rulebook |
| Middle East | ||||||
| FSRA#9 UAE · Abu Dhabi, ADGM | Principal dealer / credit provider Category 2 | USD 2 m | USD 70 k | USD 100 k | Retail, with conditions | Rulebook |
| DFSA#12 UAE · Dubai, DIFC | Principal dealer / credit provider Category 2 | USD 2 m | USD 55 k | USD 100 k | Retail, with conditions | Secondary |
| CBB#20 Bahrain | Full-scope investment firm Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | USD 2.66 m | USD 2 k | — | Retail | Rulebook |
| CMA UAE#25 UAE · Federal | Securities broker / dealer First Category – Dealing in Securities (trading broker, trading and clearing broker, international markets broker, financial products dealer) | USD 8.17 m | — | — | Retail | Rulebook |
| Custodian / clearing member Third Category – Custody, Clearing and Registration | USD 13.61 m | — | — | Retail, with conditions | Rulebook | |
| QFCRA#28 Qatar · QFC | Principal dealer / broker Investment firm dealing as principal (Banking Business Prudential Rules 2014, BANK) | — | USD 10 k | USD 5 k | Retail, with conditions | To confirm |
| CMA Saudi#31 Saudi Arabia | Dealing / brokerage Dealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1)) | USD 13.33 m | — | — | Retail | Rulebook |
| Americas | ||||||
| SEC#13 United States | Dealer / non-carrying principal broker-dealer Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)) | USD 100 k | USD 8 k | USD 1 k | Retail | Rulebook |
| CFTC · NFA#15 United States | Swap dealer Swap dealer (CEA s.4s; Regulations 23.100-23.106) | USD 20 m | USD 298 k | USD 282 k | Professional only | Rulebook |
| SCB Bahamas#21 The Bahamas | Securities dealer (principal and agent) Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2) | USD 300 k | USD 16 k | USD 8 k | Retail | To confirm |
| Token offering Initial token offering registration (DARE Act, 2024, Part IV, ss.36-55) | — | — | — | Retail | Rulebook | |
| BMA#27 Bermuda | Investment dealer (principal) Investment business standard license: investment provider acting as principal (Investment Business Act 2003) | USD 250 k | USD 3 k | USD 3 k | Retail, with conditions | Rulebook |
| Asia-Pacific | ||||||
| SFC#3 Hong Kong | Securities dealer Type 1 – Dealing in securities (general case) | USD 642 k | USD 609 (nominal) | USD 609 (nominal) | Retail | Rulebook |
| FSA Japan#4 Japan | Securities firm (Type I FIBO) Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29) | USD 335 k | USD 1 k | — | Retail | Rulebook |
| ASIC#6 Australia | Wholesale-only AFSL AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | — | USD 1 k | — | Professional only | Rulebook |
| MAS#8 Singapore | OTC derivatives / CFD dealer CMS license: Dealing in capital markets products (OTC derivatives) | USD 390 k | USD 770 (nominal) | USD 2 k | Retail | Rulebook |
| Wholesale bank Banking Act: Wholesale bank license | USD 78 m | USD 15 k | USD 77 k | Retail, with conditions | Secondary | |
| Merchant bank Banking Act: Merchant bank license | USD 11.7 m | USD 15 k | USD 27 k | Professional only | Secondary | |
| Labuan FSA#24 Malaysia · Labuan | Labuan investment bank Labuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | USD 2.36 m | USD 500 (nominal) | USD 36 k | Retail, with conditions | Rulebook |
| Africa | ||||||
| FSCA#17 South Africa | OTC derivative provider Authorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | — | USD 3 k | — | Retail | Secondary |
| FSC Mauritius#19 Mauritius | Full-service dealer with underwriting Investment Dealer (Full Service Dealer, including Underwriting) | USD 217 k | USD 3 k | USD 10 k | Retail | Rulebook |
| SEC Nigeria#22 Nigeria | Issuing house with underwriting Issuing House, Tier 2 (with Underwriting) | USD 4.67 m | — | — | Professional only | Rulebook |
Not licensed by: FCA, CySEC, BaFin, CBI Ireland, VARA, CBUAE, SAMA, NYDFS, CIMA, BVI FSC, FSA Seychelles, CMA Kenya.
The regulators
Every regulator, every category
Thirty-four regulators in order of the balanced ranking. Each sheet gives the categories the regulator grants, what each permits, its capital and its fees, the clients it may serve and the systems it fits.
BaFin#1
Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht)
Germany
Germany
Balanced score 85 of 100
CSSF#2
Commission de Surveillance du Secteur Financier
Luxembourg
Luxembourg
Balanced score 85 of 100
SFC#3
Securities and Futures Commission
Hong Kong
Hong Kong
Balanced score 80 of 100
FSA Japan#4
Financial Services Agency
Japan
Japan
Balanced score 80 of 100
FCA#5
Financial Conduct Authority
United Kingdom
United Kingdom
Balanced score 80 of 100
ASIC#6
Australian Securities and Investments Commission
Australia
Australia
Balanced score 79 of 100
CBI Ireland#7
Central Bank of Ireland
Ireland
Ireland
Balanced score 79 of 100
MAS#8
Monetary Authority of Singapore
Singapore
Singapore
Balanced score 78 of 100
FSRA#9
Financial Services Regulatory Authority (Abu Dhabi Global Market)
UAE · Abu Dhabi, ADGM
UAE · Abu Dhabi, ADGM
Balanced score 76 of 100
FINMA#10
Swiss Financial Market Supervisory Authority
Switzerland
Switzerland
Balanced score 75 of 100
Bank of Lithuania#11
Bank of Lithuania
Lithuania
Lithuania
Balanced score 75 of 100
DFSA#12
Dubai Financial Services Authority
UAE · Dubai, DIFC
UAE · Dubai, DIFC
Balanced score 75 of 100
SEC#13
US Securities and Exchange Commission
United States
United States
Balanced score 74 of 100
MFSA#14
Malta Financial Services Authority
Malta
Malta
Balanced score 73 of 100
CFTC · NFA#15
Commodity Futures Trading Commission
United States
United States
Balanced score 68 of 100
CySEC#16
Cyprus Securities and Exchange Commission
Cyprus
Cyprus
Balanced score 68 of 100
FSCA#17
Financial Sector Conduct Authority
South Africa
South Africa
Balanced score 66 of 100
SAMA#18
Saudi Central Bank
Saudi Arabia
Saudi Arabia
Balanced score 62 of 100
FSC Mauritius#19
Financial Services Commission
Mauritius
Mauritius
Balanced score 60 of 100
CBB#20
Central Bank of Bahrain
Bahrain
Bahrain
Balanced score 60 of 100
SCB Bahamas#21
Securities Commission of The Bahamas
The Bahamas
The Bahamas
Balanced score 59 of 100
SEC Nigeria#22
Securities and Exchange Commission
Nigeria
Nigeria
Balanced score 59 of 100
NYDFS#23
New York State Department of Financial Services
United States · New York
United States · New York
Balanced score 58 of 100
Labuan FSA#24
Labuan Financial Services Authority
Malaysia · Labuan
Malaysia · Labuan
Balanced score 56 of 100
CMA UAE#25
Capital Market Authority (formerly Securities and Commodities Authority)
UAE · Federal
UAE · Federal
Balanced score 56 of 100
VARA#26
Virtual Assets Regulatory Authority
UAE · Dubai
UAE · Dubai
Balanced score 53 of 100
BMA#27
Bermuda Monetary Authority
Bermuda
Bermuda
Balanced score 53 of 100
QFCRA#28
Qatar Financial Centre Regulatory Authority
Qatar · QFC
Qatar · QFC
Balanced score 52 of 100
CIMA#29
Cayman Islands Monetary Authority
Cayman Islands
Cayman Islands
Balanced score 52 of 100
CMA Kenya#30
Capital Markets Authority
Kenya
Kenya
Balanced score 52 of 100
CMA Saudi#31
Capital Market Authority
Saudi Arabia
Saudi Arabia
Balanced score 51 of 100
FSA Seychelles#32
Financial Services Authority
Seychelles
Seychelles
Balanced score 50 of 100
CBUAE#33
Central Bank of the UAE
UAE · Federal
UAE · Federal
Balanced score 49 of 100
BVI FSC#34
British Virgin Islands Financial Services Commission
British Virgin Islands
British Virgin Islands
Balanced score 44 of 100
Breadth
Systems each regulator can license, of forty-seven
Tier 1Tier 2Offshore
FCA
42
BaFin42
CSSF42
MAS42
CBI Ireland41
MFSA41
Bank of Lithuania41
FSRA41
DFSA40
FSA Japan40
FINMA38
CBB37
CySEC32
CIMA32
BVI FSC32
ASIC32
SEC29
BMA29
SCB Bahamas29
SFC28
Labuan FSA28
FSC Mauritius28
SEC Nigeria28
CMA UAE27
QFCRA26
FSCA26
FSA Seychelles20
CMA Saudi19
CMA Kenya19
NYDFS16
CBUAE15
CFTC · NFA15
SAMA11
VARA7
01020304047
Europe · United Kingdom
FCA
Financial Conduct Authority
The FCA authorizes and supervises the conduct of about 42,000 UK financial firms under the Financial Services and Markets Act 2000 (FSMA). It is the sole prudential regulator for investment firms, fund managers, payment and e-money institutions and (from October 2027) cryptoasset firms. Banks, building societies, insurers and a few designated investment firms are dual-regulated: the Prudential Regulation Authority (PRA, part of the Bank of England) authorizes them and supervises their prudential soundness, and the FCA supervises their conduct.
#5of 34
Balanced score
80 of 100
80 of 100
Scorecard
Credibility ×35%100Breadth ×15%89Entry threshold ×20%67Speed ×15%70Reach ×15%49
Categories23
Systems covered42 of 47
Typical timeline3–12 monthsstatutory
Lowest capitalUSD 23 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 1 k–299 k13 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 870–3 k4 items · Recurring fees and levies
OtherUSD 370–9003 items · Mandatory charges that arise in operation
Application fees are modest, but the annual bill grows with the firm: periodic fees are tariff-based on income or funds above the GBP 2,200 minimum, and FSCS levies, the FOS levy and GBP 680 per FOS case come on top. Banks and insurers also pay the PRA.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Part 4A application fee, investment firm without client money (pricing category 4 or 6)Advisers and arrangers (fee-block A.13) are straightforward, category 4 (GBP 2,820). MiFID investment managers / portfolio managers (fee-block A.7) are moderately complex, category 6 (GBP 11,260). 2026/27 pricing categories (PS26/14, in force 2 July 2026; up from GBP 2,790 and GBP 11,150 in 2025/26). Non-refundable. Where several fee-blocks apply, the highest category is charged. | GBP 2,820 (category 4, straightforward) to GBP 11,260 (category 6, moderately complex)≈ USD 4 k | MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000 | Read in the rulebook |
| Part 4A application fee, brokers, CFD firms, principal traders (pricing category 6; MTF/OTF category 8)FCA lists most CFD firms, principal trading firms and MiFID investment managers at category 6; dealers as principal (fee-block A.10) are moderately complex. MTF/OTF operators are category 8 (GBP 56,300). 2026/27 amounts (PS26/14); 2025/26 were GBP 11,150 and GBP 55,740. | GBP 11,260 (category 6); GBP 56,300 (category 8) if operating an MTF or OTF≈ USD 15 k | MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000 | Read in the rulebook |
| Application fee, banks and insurers (pricing category 7)Category 7 as listed by the FCA for banks and insurance companies (complex fee-blocks A.1, A.3, A.4). Dual-regulated: PRA authorizes; the fee page does not say whether the PRA charges an additional amount, so confirm with the PRA. 2025/26 figure was GBP 27,870. | GBP 28,150≈ USD 37 k | Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct); Insurer / reinsurer (Part 4A permission; PRA-authorized, FCA-regulated for conduct) | Read in the rulebook |
| Recognition fee, UK recognized investment exchange (pricing category 10)Category 10. A UK RIE offering safeguarding and administration only is category 8 (GBP 56,300). 2025/26 figure was GBP 222,940. | GBP 225,170≈ USD 299 k | Recognised investment exchange (RIE) - recognition order under FSMA Part XVIII | Read in the rulebook |
| Part 4A application fee, UCITS management company and full-scope AIFM (pricing category 6)FCA AIFM fees page sets new full-scope UK AIFM authorization at category 6; adding an AIFM permission by variation is 50% of category 6. UCITS managers fall in fee-blocks A.7/A.9, which the FCA classes as moderately complex (category 6); the FCA does not list the UCITS manager fee separately. Small authorized AIFMs also apply under Part 4A; their category is not stated on the AIFM page. | GBP 11,260≈ USD 15 k | UCITS management company / authorized fund manager (Part 4A permission); Full-scope UK AIFM (Part 4A permission, managing an AIF) | Read in the rulebook |
| Registration fee, small registered UK AIFMFixed fee stated on the FCA UK AIFM and NPPR fees page (updated 6 August 2026). | GBP 750≈ USD 1 k | Small registered UK AIFM (registration, not Part 4A) | Read in the rulebook |
| Application fee, authorized e-money institution or full-scope payment institution (pricing category 5)Authorized EMIs, and authorized PIs providing services (a) to (e) of PSRs 2017 Sch. 1 Part 1, pay category 5. 2025/26 figure was GBP 5,580. | GBP 5,640≈ USD 8 k | Authorized electronic money institution (Electronic Money Regulations 2011); Authorized payment institution - other payment services (PSRs 2017) | Read in the rulebook |
| Application fee, authorized PI for money remittance or payment initiation only (pricing category 4)Authorized PIs providing only services (f) to (h) (money remittance, payment initiation, account information) pay category 4. | GBP 2,820≈ USD 4 k | Authorized payment institution - money remittance only (PSRs 2017); Authorized payment institution - payment initiation services only (PSRs 2017) | Read in the rulebook |
| Registration fee, small payment institution or small e-money institution (pricing category 3)Category 3 (2025/26: GBP 1,120). The FCA changed small PI application fees on 11 April 2025. | GBP 1,130≈ USD 2 k | Small payment institution (PSRs 2017 reg. 13); Small electronic money institution (EMRs 2011 reg. 13) | Read in the rulebook |
| Registration fee, cryptoasset business under the MLRs (fee-block G.23, pricing category 6)Current AML registration regime. A firm applying for both a new-regime Part 4A permission and MLR registration pays one fee at the highest category (FEES 3.2.2G as amended by FCA 2026/58). | GBP 11,260≈ USD 15 k | Cryptoasset exchange / custodian wallet provider registration (MLRs 2017, current regime) | Read in the rulebook |
| Application fee, operating a qualifying cryptoasset trading platform (pricing category 7)Cryptoasset Activities (Periodic and Application Fees) Instrument 2026 (FCA 2026/58), made 24 September 2026 (Handbook Notice 144). Gateway open 30 September 2026 to 28 February 2027. | GBP 28,150≈ USD 37 k | Operating a qualifying cryptoasset trading platform (new FSMA regime, from 25 October 2027) | From a secondary source |
| Application fee, dealing as principal, safeguarding, or issuing a qualifying stablecoin (pricing category 6)FCA 2026/58 (Handbook Notice 144, September 2026). One fee at the highest applicable category where several activities or MLR registration are applied for together. | GBP 11,260≈ USD 15 k | Dealing in qualifying cryptoassets as principal (new FSMA regime, from 25 October 2027); Safeguarding qualifying cryptoassets (new FSMA regime, from 25 October 2027); Issuing qualifying stablecoins in the UK (new FSMA regime, from 25 October 2027) | From a secondary source |
| Application fee, arranging cryptoasset staking (pricing category 4)FCA 2026/58 groups arranging deals, dealing as agent and arranging staking at category 4. | GBP 2,820≈ USD 4 k | Arranging qualifying cryptoasset staking (new FSMA regime, from 25 October 2027) | From a secondary source |
| Every year | |||
| Periodic fee, small registered UK AIFMFixed annual periodic fee stated on the FCA UK AIFM and NPPR fees page. | GBP 750 per year≈ USD 1 k | Small registered UK AIFM (registration, not Part 4A) | Read in the rulebook |
| Flat periodic fee, small payment institution (fee-block G.4)2025/26: GBP 646. Small EMIs and authorized PIs/EMIs pay tariff-based G-block fees instead (not quantified here). | GBP 652 per year (2026/27)≈ USD 870 | Small payment institution (PSRs 2017 reg. 13) | Read in the rulebook |
| FCA periodic fee, A.0 minimum fee (2026/27)Minimum fee for Part 4A firms, up from GBP 2,000 in 2025/26; the FCA says this is the last staged increase. Fee year 1 April 2026 to 31 March 2027. Variable fee-block tariffs (on income, funds under management, client money etc.) are charged on top for firms above the tariff thresholds. Dual-regulated banks and insurers also pay PRA periodic fees. | GBP 2,200 per year, plus fee-block tariffs≈ USD 3 k | MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000; Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) and 4 more | Read in the rulebook |
| FCA variable periodic fees, FOS general levy and FSCS leviesFCA annual funding requirement for 2026/27 is GBP 788.9m (PS26/14). Instalments: on-account payment due the last working day of March, balance the last working day of August. FSCS levies apply to firms in FSCS funding classes (investment intermediation, deposit-taking etc.). | Formula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class levies | All categories | Read in the rulebook |
| Other | |||
| Financial Ombudsman Service case feeStandard case fee from 1 April 2026 (PS26/14). Applies to firms within the FOS compulsory jurisdiction that receive chargeable complaints. | GBP 680 per chargeable case≈ USD 900 | All categories | Read in the rulebook |
| Senior management function (SMF) approval application (pricing category 1)Category 1 under SM&CR. Unchanged from 2025/26. | GBP 280 per application≈ USD 370 | MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000; Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) and 4 more | Read in the rulebook |
| Variation of permission within the same fee-block (pricing category 2)Adding a new fee-block is charged at 50% of the relevant category (e.g. 50% of category 6 to add an AIFM permission). Removing permissions is free. | GBP 560≈ USD 740 | MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000; MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000; Deposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct) and 4 more | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 200 k
Payment institution (money remittance)Authorized payment institution - money remittance only (PSRs 2017)
USD 23 k
Payment institution (payment initiation)Authorized payment institution - payment initiation services only (PSRs 2017)
USD 58 k
Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000
USD 100 k
UCITS management companyUCITS management company / authorized fund manager (Part 4A permission)
USD 145 k
Full-scope AIFMFull-scope UK AIFM (Part 4A permission, managing an AIF)
USD 145 k
Payment institution (full)Authorized payment institution - other payment services (PSRs 2017)
USD 145 k
Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000
USD 200 k
Crypto trading platform (UK QCATP)Operating a qualifying cryptoasset trading platform (new FSMA regime, from 25 October 2027)
USD 200 k
Crypto custodianSafeguarding qualifying cryptoassets (new FSMA regime, from 25 October 2027)
USD 200 k
Crypto staking providerArranging qualifying cryptoasset staking (new FSMA regime, from 25 October 2027)
USD 200 k
E-money institutionAuthorized electronic money institution (Electronic Money Regulations 2011)
USD 406 k
Stablecoin issuerIssuing qualifying stablecoins in the UK (new FSMA regime, from 25 October 2027)
USD 466 k
Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000
USD 998 k
Crypto dealer (principal)Dealing in qualifying cryptoassets as principal (new FSMA regime, from 25 October 2027)
USD 998 k
Insurer / reinsurerInsurer / reinsurer (Part 4A permission; PRA-authorized, FCA-regulated for conduct)
USD 1.6 m
BankDeposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct)
USD 5.8 m
10k100k1m10m
16 of 23 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
23 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Investment firm (agency, no client money)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 75,000USD 100 kMinimum capital
- Permits
- Arranging deals, making arrangements, advising on investments, managing investments and executing orders as agent (reception and transmission, execution, portfolio management, advice, placing without firm commitment), where the firm has no permission to hold client money or client assets.
- Minimum capital
- GBP 75,000 permanent minimum requirement (MIFIDPRU 4.4). Own funds requirement is the highest of the PMR, the fixed overheads requirement (one quarter of prior-year fixed overheads) and, for non-SNI firms, the K-factor requirement (MIFIDPRU 4.3). (≈USD 100 k)
- Fees
- Part 4A application fee, investment firm without client money (pricing category 4 or 6)GBP 2,820 (category 4, straightforward) to GBP 11,260 (category 6, moderately complex)FCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail permitted
- Conditions
- Requires an ICARA process and liquid assets equal to at least one third of the fixed overheads requirement plus 1.6% of guarantees. Consumer Duty applies to retail business. SM&CR approval is needed for senior managers.
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family OfficeAsset Management CompanyPension & Endowment Manager
- Reading
- From a secondary source
- Sources
02Investment firm (client money / MTF)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 150,000USD 200 kMinimum capital
- Permits
- Agency investment services where the firm has permission to hold client money or safeguard client assets, and operating a multilateral trading facility (MTF), or an OTF without dealing on own account.
- Minimum capital
- GBP 150,000 permanent minimum requirement (MIFIDPRU 4.4), subject to the same fixed overheads and K-factor tests. (≈USD 200 k)
- Fees
- Part 4A application fee, brokers, CFD firms, principal traders (pricing category 6; MTF/OTF category 8)GBP 11,260 (category 6); GBP 56,300 (category 8) if operating an MTF or OTFFCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail permitted
- Conditions
- CASS client money and custody rules apply, plus an annual CASS audit. Retail CFDs follow COBS 22.5: leverage caps of 30:1 to 2:1, 50% margin close-out, negative balance protection, standardized risk warnings and a ban on binary options. Retail crypto derivatives have been banned since January 2021. Tokenized-securities venues can test under the Bank of England/FCA Digital Securities Sandbox.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageECN & DMA VenueWealth Management FirmMulti-Family OfficeTokenization Platform
- Reading
- From a secondary source
- Sources
03Investment firm (dealing on own account)MIFIDPRU investment firm (Part 4A permission) - PMR GBP 750,000USD 998 kMinimum capital
- Permits
- Dealing in investments as principal (dealing on own account), underwriting or placing on a firm commitment basis, and operating an OTF where the firm may deal on own account, together with the agency services.
- Minimum capital
- GBP 750,000 permanent minimum requirement (MIFIDPRU 4.4), subject to the fixed overheads and K-factor tests. (≈USD 998 k)
- Fees
- Part 4A application fee, brokers, CFD firms, principal traders (pricing category 6; MTF/OTF category 8)GBP 11,260 (category 6); GBP 56,300 (category 8) if operating an MTF or OTFFCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail permitted
- Conditions
- Standard license for a market-making FX/CFD broker, principal-model prime-of-prime and a non-bank prime services provider. The COBS 22.5 retail CFD restrictions apply. A proprietary trader that deals only for itself and does not hold itself out may fall within RAO Art. 15 or the MiFID own-account exemptions, unless it uses high-frequency algorithmic trading. Funded-trader evaluation models need a separate legal review of whether they are regulated activities. Commodity traders may use the ancillary-activity exemption.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskMulti-Asset BrokerageInvestment BankTreasury & Liquidity DeskCommodities Trading House
- Reading
- From a secondary source
- Sources
04Appointed representative (white-label)Appointed representative / tied agent (SUP 12)No fixed figureMinimum capital
- Permits
- Carries on regulated activities for which its principal firm accepts responsibility (for example arranging and advising), under a written contract with an FCA-authorized principal. The AR does not hold its own Part 4A permission.
- Minimum capital
- None. No capital requirement applies to the AR; the principal firm is responsible for the AR's regulated activities (FSMA s.39; SUP 12).
- Fees
- FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail, with conditions
- Conditions
- Since December 2022 the AR regime has been tightened: principals must notify the FCA 30 days before appointing an AR, provide extra information, and oversee and review ARs annually. An AR cannot deal as principal or hold client money in its own right, so a white-label broker relies on the principal's execution and client-money arrangements.
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
05Recognised investment exchangeRecognised investment exchange (RIE) - recognition order under FSMA Part XVIIINo fixed figureMinimum capital
- Permits
- Operating a UK regulated market (an exchange) under a recognition order, which exempts the exchange from the general prohibition for that business.
- Minimum capital
- No fixed minimum is set. REC 2.3 requires financial resources sufficient to perform the exchange's functions and to cover an orderly wind-down. The House could not confirm a specific figure in the Handbook text.
- Fees
- Recognition fee, UK recognized investment exchange (pricing category 10)GBP 225,170FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- A recognition order is not a Part 4A permission. The process is heavier than for an MTF, and most new venues start as MTFs under the GBP 150,000 or 750,000 MIFIDPRU tiers.
- Systems
- ECN & DMA Venue
- Reading
- To be confirmed
- Sources
06BankDeposit-taking (Part 4A permission; PRA-authorized, FCA-regulated for conduct)USD 5.8 mMinimum capital
- Permits
- Accepting deposits, together with lending, payments, custody and investment services, under a Part 4A permission granted by the PRA with FCA consent.
- Minimum capital
- EUR 5 million base capital resources requirement for banks (PRA Rulebook, Definition of Capital 12.1). The table also shows a lower base of the higher of EUR 1 million and GBP 1 million for small specialist banks and building societies. Pillar 1, Pillar 2A, buffers and the liquidity (LCR/NSFR) requirements apply on top. (≈USD 5.8 m)
- Fees
- Application fee, banks and insurers (pricing category 7)GBP 28,150FCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail permitted
- Conditions
- Dual-regulated: the PRA leads authorization and prudential supervision, and the FCA regulates conduct. New banks can take a restricted license with a mobilization period of up to 12 months (deposits capped) to raise capital and build infrastructure; the PRA sets the mobilization capital case by case. SS3/21 (updated January 2026) sets the approach to new and growing banks. FSCS deposit protection applies.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructurePrime BrokerageTreasury & Liquidity Desk
- Reading
- Read in the rulebook
- Sources
07Insurer / reinsurerInsurer / reinsurer (Part 4A permission; PRA-authorized, FCA-regulated for conduct)USD 1.6 mMinimum capital
- Permits
- Effecting and carrying out contracts of insurance (general or long-term) or reinsurance, including captive reinsurance, under Solvency UK.
- Minimum capital
- Absolute floor of the Minimum Capital Requirement (PRA Rulebook, Minimum Capital Requirement 3.2): GBP 2,400,000 non-life (GBP 3,500,000 if classes 10-15 are covered), GBP 3,500,000 life, GBP 3,500,000 pure reinsurance, GBP 1,200,000 captive pure reinsurance, GBP 5,900,000 composite. The SCR applies on top. (≈USD 1.6 m)
- Fees
- Application fee, banks and insurers (pricing category 7)GBP 28,150FCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail permitted
- Conditions
- Dual-regulated with the PRA as lead authority. Solvency UK reforms took effect 31 December 2024, and the AMCR is now set in GBP. Lloyd's syndicates and managing agents are a separate route, through Lloyd's and the PRA/FCA.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
08UCITS management companyUCITS management company / authorized fund manager (Part 4A permission)USD 145 kMinimum capital
- Permits
- Managing UK UCITS and other authorized funds (NURS, QIS, LTAF) as authorized fund manager, with optional top-up permissions for discretionary portfolio management and advice.
- Minimum capital
- EUR 125,000 initial capital, plus 0.02% of funds under management above EUR 250 million, capped at EUR 10 million in total, and never less than the fixed overheads requirement (IPRU-INV 11.3; firms with MiFID top-ups are CPMI firms and also apply MIFIDPRU). (≈USD 145 k)
- Fees
- Part 4A application fee, UCITS management company and full-scope AIFM (pricing category 6)GBP 11,260FCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail permitted
- Conditions
- UK UCITS are no longer EU UCITS; marketing into the EEA uses each state's private placement or a separate EU fund. EEA UCITS can be recognized in the UK under the Overseas Funds Regime. Assessment of value and Consumer Duty apply.
- Systems
- Mutual Fund & UCITSETF PlatformFund Management CompanyAsset Management Company
- Reading
- From a secondary source
- Sources
09Full-scope AIFMFull-scope UK AIFM (Part 4A permission, managing an AIF)USD 145 kMinimum capital
- Permits
- Managing alternative investment funds (portfolio and risk management) above the AIFMD thresholds, or below them for firms that opt in.
- Minimum capital
- EUR 125,000 initial capital for an external AIFM, or EUR 300,000 for an internally managed AIF, plus 0.02% of AUM above EUR 250 million (total capped at EUR 10 million), plus professional indemnity insurance or 0.01% additional own funds (IPRU-INV 11.3). (≈USD 145 k)
- Fees
- Part 4A application fee, UCITS management company and full-scope AIFM (pricing category 6)GBP 11,260FCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail, with conditions
- Conditions
- Requires a depositary for each UK AIF and annual Annex IV reporting. Retail marketing is restricted. Thresholds: AUM of EUR 100 million (leveraged) or EUR 500 million (unleveraged with a 5-year lock-up). See notes for the proposed 2028 replacement regime.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundQuantitative Trading DeskPension & Endowment Manager
- Reading
- From a secondary source
- Sources
10Small authorized AIFMSmall authorized UK AIFM (Part 4A permission, sub-threshold)No fixed figureMinimum capital
- Permits
- Managing AIFs below the AIFMD thresholds under a lighter UK regime. Usually used where the fund is an unregulated collective investment scheme or the manager needs other permissions.
- Minimum capital
- Not confirmed. The prudential category depends on the firm's other permissions (IPRU-INV or MIFIDPRU). The House could not confirm a single figure from the Handbook.
- Fees
- FCA periodic fee, A.0 minimum fee (2026/27)GBP 2,200 per year, plus fee-block tariffsFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable caseSenior management function (SMF) approval application (pricing category 1)GBP 280 per applicationVariation of permission within the same fee-block (pricing category 2)GBP 560
- Clients
- Retail, with conditions
- Conditions
- Lighter conduct rules than full-scope managers, and no depositary requirement. Retail promotion is restricted by the financial promotion rules for non-mainstream pooled investments.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- To be confirmed
- Sources
11Registered AIFMSmall registered UK AIFM (registration, not Part 4A)No fixed figureMinimum capital
- Permits
- Managing sub-threshold AIFs that are unauthorised, unlisted bodies corporate (typically venture capital, private equity or real estate company structures), or EuVECA/EuSEF-type funds.
- Minimum capital
- None. No capital requirement applies at registration.
- Fees
- Registration fee, small registered UK AIFMGBP 750Periodic fee, small registered UK AIFMGBP 750 per yearFCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Professional only
- Conditions
- Registration route only. The firm must not carry on other regulated activities without a Part 4A permission, and it must file regular reports with the FCA.
- Systems
- Private Equity FirmVenture Capital FirmReal Estate Investment VehiclePrivate Credit Fund
- Reading
- From a secondary source
- Sources
12E-money institutionAuthorized electronic money institution (Electronic Money Regulations 2011)USD 406 kMinimum capital
- Permits
- Issuing e-money and providing payment services not linked to e-money issuance.
- Minimum capital
- EUR 350,000 initial capital (EMRs 2011 Sch. 2 Part 1), plus ongoing own funds of at least 2% of average outstanding e-money. (≈USD 406 k)
- Fees
- Application fee, authorized e-money institution or full-scope payment institution (pricing category 5)GBP 5,640FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- Safeguarding moved to the new CASS 15 regime on 7 May 2026, which added monthly safeguarding returns, daily reconciliations, resolution packs and an annual safeguarding audit. A firm issuing a sterling stablecoin uses the new qualifying-stablecoin regime, not e-money.
- Systems
- Electronic Money InstitutionCard Issuing ProgramPayment Service Provider
- Reading
- From a secondary source
- Sources
13Small EMISmall electronic money institution (EMRs 2011 reg. 13)No fixed figureMinimum capital
- Permits
- E-money issuance where average outstanding e-money does not exceed EUR 5 million (and related payment volumes stay under the small-PI limit).
- Minimum capital
- No initial capital for authorization. Whether an ongoing own funds requirement applies depends on the e-money outstanding, and the House could not confirm the figure from the regulations text.
- Fees
- Registration fee, small payment institution or small e-money institution (pricing category 3)GBP 1,130FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- UK only, no passport. CASS 15 safeguarding applies. Must apply to become an authorized EMI once over the thresholds.
- Systems
- Electronic Money Institution
- Reading
- To be confirmed
- Sources
14Payment institution (money remittance)Authorized payment institution - money remittance only (PSRs 2017)USD 23 kMinimum capital
- Permits
- Money remittance only.
- Minimum capital
- EUR 20,000 initial capital (Payment Services Regulations 2017 Sch. 3 Part 1). (≈USD 23 k)
- Fees
- Application fee, authorized PI for money remittance or payment initiation only (pricing category 4)GBP 2,820FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- CASS 15 safeguarding applies from 7 May 2026. A bureau de change, cheque cashing or other money service business that does not provide payment services registers with HMRC for AML instead.
- Systems
- Money Services Business
- Reading
- From a secondary source
- Sources
15Payment institution (payment initiation)Authorized payment institution - payment initiation services only (PSRs 2017)USD 58 kMinimum capital
- Permits
- Payment initiation services only.
- Minimum capital
- EUR 50,000 initial capital (PSRs 2017 Sch. 3 Part 1), plus professional indemnity insurance. (≈USD 58 k)
- Fees
- Application fee, authorized PI for money remittance or payment initiation only (pricing category 4)GBP 2,820FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- Account information service providers register with the FCA instead and need professional indemnity insurance, not capital.
- Systems
- Payment Service Provider
- Reading
- From a secondary source
- Sources
16Payment institution (full)Authorized payment institution - other payment services (PSRs 2017)USD 145 kMinimum capital
- Permits
- Payment accounts, cash placement and withdrawal, execution of payment transactions, issuing payment instruments, acquiring payment transactions, money remittance and payment initiation.
- Minimum capital
- EUR 125,000 initial capital (PSRs 2017 Sch. 3 Part 1). Ongoing own funds are calculated by Method A, B or C. (≈USD 145 k)
- Fees
- Application fee, authorized e-money institution or full-scope payment institution (pricing category 5)GBP 5,640FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- CASS 15 safeguarding applies from 7 May 2026. Card-scheme acquiring also needs scheme membership or sponsorship.
- Systems
- Payment Service ProviderMerchant AcquiringCard Issuing ProgramMoney Services Business
- Reading
- From a secondary source
- Sources
17Small payment institutionSmall payment institution (PSRs 2017 reg. 13)No fixed figureMinimum capital
- Permits
- Payment services (other than payment initiation and account information) where monthly average payment transactions do not exceed EUR 3 million.
- Minimum capital
- None. No initial capital applies.
- Fees
- Registration fee, small payment institution or small e-money institution (pricing category 3)GBP 1,130Flat periodic fee, small payment institution (fee-block G.4)GBP 652 per year (2026/27)FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- UK only, with no passporting. Must become authorized if it exceeds the threshold.
- Systems
- Payment Service ProviderMoney Services Business
- Reading
- From a secondary source
- Sources
18Crypto AML registrationCryptoasset exchange / custodian wallet provider registration (MLRs 2017, current regime)No fixed figureMinimum capital
- Permits
- Registration with the FCA for AML/CTF purposes to carry on cryptoasset exchange and custodian wallet business in the UK until the new authorization regime starts.
- Minimum capital
- None. The MLRs set no capital requirement.
- Fees
- Registration fee, cryptoasset business under the MLRs (fee-block G.23, pricing category 6)GBP 11,260FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail permitted
- Conditions
- Registration covers AML only and is not authorization. The financial promotions regime applies to cryptoasset promotions (since October 2023). Registered firms must apply for authorization in the gateway (30 September 2026 to 28 February 2027) to keep operating after 25 October 2027.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
19Crypto trading platform (UK QCATP)Operating a qualifying cryptoasset trading platform (new FSMA regime, from 25 October 2027)USD 200 kMinimum capital
- Permits
- Operating a UK qualifying cryptoasset trading platform.
- Minimum capital
- GBP 150,000 permanent minimum requirement under the cryptoasset prudential regime (PS26/12, COREPRU), not confirmed in the final text. (≈USD 200 k)
- Fees
- Application fee, operating a qualifying cryptoasset trading platform (pricing category 7)GBP 28,150FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail, with conditions
- Conditions
- PMR figure is from FCA consultation CP25/15/CP25/42 as reported by law firms. Final rules were published in PS26/12 (30 June 2026) and changed some K-factor elements; the House could not confirm the final PMR in the Handbook text, so treat it as unconfirmed. Authorization is required from 25 October 2027. The application gateway is open 30 September 2026 to 28 February 2027, and firms that apply in that window benefit from the saving provision. Platforms face admissions and disclosure (PS26/9) and market abuse rules, and Consumer Duty applies.
- Systems
- Digital Asset Exchange
- Reading
- To be confirmed
- Sources
20Crypto dealer (principal)Dealing in qualifying cryptoassets as principal (new FSMA regime, from 25 October 2027)USD 998 kMinimum capital
- Permits
- Dealing in qualifying cryptoassets as principal, including cryptoasset lending and borrowing.
- Minimum capital
- GBP 750,000 permanent minimum requirement (consultation figure, PS26/12). (≈USD 998 k)
- Fees
- Application fee, dealing as principal, safeguarding, or issuing a qualifying stablecoin (pricing category 6)GBP 11,260FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail, with conditions
- Conditions
- PMR figure is from FCA consultation CP25/15/CP25/42 as reported by law firms. Final rules were published in PS26/12 (30 June 2026) and changed some K-factor elements; the House could not confirm the final PMR in the Handbook text, so treat it as unconfirmed. Authorization is required from 25 October 2027. The application gateway is open 30 September 2026 to 28 February 2027, and firms that apply in that window benefit from the saving provision. An agency-only desk (dealing as agent or arranging) carries a GBP 75,000 PMR (consultation figure). Retail restrictions apply to cryptoasset lending, borrowing and staking.
- Systems
- OTC Digital Asset Desk
- Reading
- To be confirmed
- Sources
21Crypto custodianSafeguarding qualifying cryptoassets (new FSMA regime, from 25 October 2027)USD 200 kMinimum capital
- Permits
- Safeguarding and administering qualifying cryptoassets and specified investment cryptoassets for clients.
- Minimum capital
- GBP 150,000 permanent minimum requirement (consultation figure, PS26/12). (≈USD 200 k)
- Fees
- Application fee, dealing as principal, safeguarding, or issuing a qualifying stablecoin (pricing category 6)GBP 11,260FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail, with conditions
- Conditions
- PMR figure is from FCA consultation CP25/15/CP25/42 as reported by law firms. Final rules were published in PS26/12 (30 June 2026) and changed some K-factor elements; the House could not confirm the final PMR in the Handbook text, so treat it as unconfirmed. Authorization is required from 25 October 2027. The application gateway is open 30 September 2026 to 28 February 2027, and firms that apply in that window benefit from the saving provision. Client cryptoassets must be held on trust under CASS 7 rules adapted for crypto.
- Systems
- Custody & Wallet Infrastructure
- Reading
- To be confirmed
- Sources
22Stablecoin issuerIssuing qualifying stablecoins in the UK (new FSMA regime, from 25 October 2027)USD 466 kMinimum capital
- Permits
- Issuing a qualifying stablecoin (fiat-referenced) from an establishment in the UK.
- Minimum capital
- GBP 350,000 permanent minimum requirement (consultation figure). Final PS26/12 reduced the K-SII issuance coefficient from 2% to 1% of average stablecoin in issue. (≈USD 466 k)
- Fees
- Application fee, dealing as principal, safeguarding, or issuing a qualifying stablecoin (pricing category 6)GBP 11,260FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail, with conditions
- Conditions
- PMR figure is from FCA consultation CP25/15/CP25/42 as reported by law firms. Final rules were published in PS26/12 (30 June 2026) and changed some K-factor elements; the House could not confirm the final PMR in the Handbook text, so treat it as unconfirmed. Authorization is required from 25 October 2027. The application gateway is open 30 September 2026 to 28 February 2027, and firms that apply in that window benefit from the saving provision. Requires a backing asset pool held with an unconnected custodian on statutory trust and redemption at par by end of the next business day (PS26/10). Systemic stablecoins designated by HM Treasury move to Bank of England supervision.
- Systems
- Stablecoin Issuance Structure
- Reading
- To be confirmed
- Sources
23Crypto staking providerArranging qualifying cryptoasset staking (new FSMA regime, from 25 October 2027)USD 200 kMinimum capital
- Permits
- Arranging or carrying out staking of qualifying cryptoassets for clients.
- Minimum capital
- GBP 150,000 permanent minimum requirement (consultation figure, PS26/12). (≈USD 200 k)
- Fees
- Application fee, arranging cryptoasset staking (pricing category 4)GBP 2,820FCA variable periodic fees, FOS general levy and FSCS leviesFormula: fee-block tariff rates applied to each firm's tariff data (e.g. income, funds under management, transaction value), plus FOS general levy and FSCS class leviesFinancial Ombudsman Service case feeGBP 680 per chargeable case
- Clients
- Retail, with conditions
- Conditions
- PMR figure is from FCA consultation CP25/15/CP25/42 as reported by law firms. Final rules were published in PS26/12 (30 June 2026) and changed some K-factor elements; the House could not confirm the final PMR in the Handbook text, so treat it as unconfirmed. Authorization is required from 25 October 2027. The application gateway is open 30 September 2026 to 28 February 2027, and firms that apply in that window benefit from the saving provision. A validator staking only its own assets is not caught. The license matters only where client assets are staked.
- Systems
- Mining & Validation Operation
- Reading
- To be confirmed
- Sources
Reach
None. UK firms lost EEA passporting rights on 31 December 2020. EEA access needs a separately authorized EU entity or national third-country regimes. Inbound, EEA UCITS can be recognized under the Overseas Funds Regime.
Passage
Statutory: FSMA s.55V requires a decision within 6 months of a complete application, or 12 months from receipt of an incomplete one. PSRs 2017 and EMRs 2011: 3 months from a complete application, 12 months at most. Banks: the same FSMA deadline, often followed by a mobilization period of up to 12 months. Cryptoassets: gateway open 30 September 2026 to 28 February 2027, with the regime live 25 October 2027.
Licensed elsewhere
PRA (Bank of England): authorizes and prudentially supervises banks, building societies, credit unions, insurers and designated investment firms (jointly with the FCA for conduct). Bank of England: systemic payment systems, CCPs, CSDs and systemic stablecoins. HMRC: AML supervision of money service businesses that only exchange currency or cash cheques, and of trust and company service providers. The Pensions Regulator: occupational pension schemes (the FCA covers personal pensions and the asset managers). Not licensed at all: sovereign investment vehicles, crypto mining/validation on own account, physical commodity trading, issuing structured notes (prospectus approval only, under the Public Offers and Admissions to Trading Regulations 2024), and single-family offices that manage only family assets (usually outside authorization through group or family exclusions; check case by case). Islamic finance has no separate license; Islamic banks and funds use the standard PRA/FCA categories. Commercial lending and trade finance to businesses is generally not regulated unless it involves deposit-taking.
Notes. 2024-2026 changes: (1) The cryptoasset regime was finalized in PS26/9-PS26/13 (30 June 2026). It commences 25 October 2027, and the application gateway runs 30 September 2026 to 28 February 2027. (2) A new safeguarding regime for payment and e-money firms (CASS 15) has applied since 7 May 2026. (3) HM Treasury and the FCA (CP26/28) propose replacing the AIFM regime with small (<GBP 750m NAV), medium (GBP 750m-5bn) and large (>GBP 5bn) tiers, expected to take effect around 2028, with a final policy statement expected in 2027. (4) The retail ban on crypto ETNs was lifted from 8 October 2025. (5) Consumer Duty applies to all retail business. (6) The government announced in 2025 that the Payment Systems Regulator will be consolidated into the FCA. USD conversions use approx. EUR 1 = USD 1.16 and GBP 1 = USD 1.33 (October 2026).
Europe · Cyprus
CySEC
Cyprus Securities and Exchange Commission
CySEC is the Cyprus capital markets regulator under the CySEC Law 73(I)/2009. It licenses investment firms (CIFs), UCITS management companies, AIFMs and mini-AIFMs, authorizes funds, supervises the Cyprus Stock Exchange, and is the MiCA authority for crypto-asset service providers. Cyprus is the largest EU base for retail FX/CFD brokers, so CySEC scrutinizes cross-border retail marketing, affiliate networks and product governance closely.
#16of 34
Balanced score
68 of 100
68 of 100
Scorecard
Credibility ×35%65Breadth ×15%68Entry threshold ×20%71Speed ×15%47Reach ×15%90
Categories12
Systems covered32 of 47
Typical timeline6–16 monthsmarket practice
Lowest capitalUSD 58 k
IOSCO MMoUA
PassportEU/EEA
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 8 k1 item · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 2 k–8 k3 items · Recurring fees and levies
OtherUSD 2 k–3 k2 items · Mandatory charges that arise in operation
Licence fees are charged per investment service, and the annual levy scales with turnover up to a EUR 150,000 cap. Retail brokers must also fund the Investor Compensation Fund. 2026 consultations propose higher CIF fees (and new fund-sector fees of up to EUR 45,000); adoption is unconfirmed, and CySEC's MiCA CASP and fund manager fees were not located.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| CIF license application fee, per investment serviceFee is cumulative per service, e.g. services 1, 2, 4 and 5 = EUR 28,000. Algorithmic trading application EUR 2,000. CySEC consultation CP-2026-01 (12 January 2026) proposes EUR 8,000 per service, EUR 30,000 for MTF/OTF and EUR 5,000 for algorithmic trading; the House could not confirm adoption as of November 2026, so the in-force figures are shown. | EUR 7,000 per investment service (services 1-7); EUR 25,000 for MTF/OTF operation (services 8-9); EUR 500 per ancillary service≈ USD 8 k | Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | From a secondary source |
| Every year | |||
| CySEC annual fee (levy) for CIFsMTF operators additionally pay EUR 7,000 a year plus 11% of MTF revenue each half-year, outside the cap. CySEC's January 2026 proposals would revise the methodology and raise the cap to EUR 600,000; adoption not confirmed as of November 2026. | EUR 6,500, EUR 8,000 or EUR 10,000 by capital tier, plus turnover-based add-on (0.75% falling to 0.0975% by band on turnover above EUR 500,000), EUR 3,000 CFD add-on and EUR 2,000 algorithmic trading add-on; capped at EUR 150,000≈ USD 8 k | Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | From a secondary source |
| CySEC DORA supervision feeCharged from 15 August 2025. | EUR 2,000 to EUR 20,000 a year by firm size≈ USD 2 k | Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | From a secondary source |
| Investor Compensation Fund (ICF) contributionsAs reported for the March 2019 ICF reform: risk-based rate of 5 per thousand of eligible client assets with an 80% discount for timely filing and an unmodified audit opinion. Contributions are non-refundable. Rates not verified against the current ICF directive. | Formula: flat EUR 700 a year (members holding client assets) or EUR 100 (not holding eligible funds), plus a risk-based contribution on eligible client assets; minimum cash buffer of 3 per thousand of client assets held in a separate account | Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | To be confirmed |
| Other | |||
| Tied agent registration feeCP-2026-01 proposes EUR 5,000; adoption not confirmed. | EUR 3,000≈ USD 3 k | Tied agent of a CIF (CySEC public register) | From a secondary source |
| Board member (management body) change feeCP-2026-01 proposes EUR 2,500 per person. Licence extension currently EUR 3,500 flat (proposed EUR 8,000 per service); branch establishment EUR 3,000 (proposed EUR 5,000). | EUR 2,000 per person≈ USD 2 k | Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000; Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000 | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 145 k
Sub-threshold fund managerMini-AIFM / sub-threshold AIFM (Law 81(I)/2020)
USD 58 k
Private AIF (up to 50 investors)Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018
USD 58 k
CASP Class 1MiCA crypto-asset service provider - Class 1
USD 58 k
Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000
USD 87 k
UCITS management companyUCITS management company (Open-Ended Undertakings for Collective Investment Law 78(I)/2012)
USD 145 k
Authorized AIFMAlternative Investment Fund Manager (AIFM Law 56(I)/2013)
USD 145 k
CASP Class 2MiCA crypto-asset service provider - Class 2
USD 145 k
Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000
USD 174 k
CASP Class 3MiCA crypto-asset service provider - Class 3
USD 174 k
ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)
USD 406 k
Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000
USD 870 k
10k100k1m
11 of 12 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
12 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Investment firm (agency, no client money)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 75,000USD 87 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, portfolio management, investment advice, and placing without a firm commitment, where the firm may not hold client money or securities.
- Minimum capital
- EUR 75,000 initial capital (Investment Services and Activities and Regulated Markets Law 87(I)/2017; Investment Firms Law 165(I)/2021 transposing IFD; IFD Art. 9(2)). (≈USD 87 k)
- Fees
- CIF license application fee, per investment serviceEUR 7,000 per investment service (services 1-7); EUR 25,000 for MTF/OTF operation (services 8-9); EUR 500 per ancillary serviceCySEC annual fee (levy) for CIFsEUR 6,500, EUR 8,000 or EUR 10,000 by capital tier, plus turnover-based add-on (0.75% falling to 0.0975% by band on turnover above EUR 500,000), EUR 3,000 CFD add-on and EUR 2,000 algorithmic trading add-on; capped at EUR 150,000CySEC DORA supervision feeEUR 2,000 to EUR 20,000 a year by firm sizeInvestor Compensation Fund (ICF) contributionsFormula: flat EUR 700 a year (members holding client assets) or EUR 100 (not holding eligible funds), plus a risk-based contribution on eligible client assets; minimum cash buffer of 3 per thousand of client assets held in a separate accountBoard member (management body) change feeEUR 2,000 per person
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Client money and assets must be held by a bank or custodian, not by the firm. CySEC expects substance in Cyprus: at least two executive directors (four-eyes principle) and local compliance, risk and AML functions. CySEC national measures restricting retail CFDs mirror the ESMA measures. CySEC closely reviews cross-border retail marketing and affiliate or introducing-broker networks.
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family OfficeAsset Management CompanyPension & Endowment Manager
- Reading
- From a secondary source
- Sources
02Investment firm (holds client money/assets or operates MTF)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 150,000USD 174 kMinimum capital
- Permits
- The same agency services where the firm holds client money or financial instruments, plus operating a multilateral trading facility (MTF) or an OTF without own-account dealing.
- Minimum capital
- EUR 150,000 initial capital (Investment Services and Activities and Regulated Markets Law 87(I)/2017; Investment Firms Law 165(I)/2021 transposing IFD; IFD Art. 9(3)). (≈USD 174 k)
- Fees
- CIF license application fee, per investment serviceEUR 7,000 per investment service (services 1-7); EUR 25,000 for MTF/OTF operation (services 8-9); EUR 500 per ancillary serviceCySEC annual fee (levy) for CIFsEUR 6,500, EUR 8,000 or EUR 10,000 by capital tier, plus turnover-based add-on (0.75% falling to 0.0975% by band on turnover above EUR 500,000), EUR 3,000 CFD add-on and EUR 2,000 algorithmic trading add-on; capped at EUR 150,000CySEC DORA supervision feeEUR 2,000 to EUR 20,000 a year by firm sizeInvestor Compensation Fund (ICF) contributionsFormula: flat EUR 700 a year (members holding client assets) or EUR 100 (not holding eligible funds), plus a risk-based contribution on eligible client assets; minimum cash buffer of 3 per thousand of client assets held in a separate accountBoard member (management body) change feeEUR 2,000 per person
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Retail CFD sales are subject to the ESMA-derived national product intervention measures: leverage caps of 30:1 (major FX) down to 2:1 (crypto), 50% margin close-out, negative balance protection and standardized risk warnings. This tier fits an agency (STP/no-dealing-desk) broker that holds client money. Under the EU DLT Pilot Regime, a DLT MTF is also operated under this kind of license. CySEC expects substance in Cyprus: at least two executive directors (four-eyes principle) and local compliance, risk and AML functions. CySEC national measures restricting retail CFDs mirror the ESMA measures. CySEC closely reviews cross-border retail marketing and affiliate or introducing-broker networks.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageECN & DMA VenueWealth Management FirmMulti-Family OfficeTokenization Platform
- Reading
- From a secondary source
- Sources
03Investment firm (dealing on own account)Cyprus Investment Firm (CIF), Law 87(I)/2017 - initial capital EUR 750,000USD 870 kMinimum capital
- Permits
- Dealing on own account and/or underwriting or placing on a firm commitment basis (and operating an OTF where the firm deals on own account), together with the agency services.
- Minimum capital
- EUR 750,000 initial capital (Investment Services and Activities and Regulated Markets Law 87(I)/2017; Investment Firms Law 165(I)/2021 transposing IFD; IFD Art. 9(1)). (≈USD 870 k)
- Fees
- CIF license application fee, per investment serviceEUR 7,000 per investment service (services 1-7); EUR 25,000 for MTF/OTF operation (services 8-9); EUR 500 per ancillary serviceCySEC annual fee (levy) for CIFsEUR 6,500, EUR 8,000 or EUR 10,000 by capital tier, plus turnover-based add-on (0.75% falling to 0.0975% by band on turnover above EUR 500,000), EUR 3,000 CFD add-on and EUR 2,000 algorithmic trading add-on; capped at EUR 150,000CySEC DORA supervision feeEUR 2,000 to EUR 20,000 a year by firm sizeInvestor Compensation Fund (ICF) contributionsFormula: flat EUR 700 a year (members holding client assets) or EUR 100 (not holding eligible funds), plus a risk-based contribution on eligible client assets; minimum cash buffer of 3 per thousand of client assets held in a separate accountBoard member (management body) change feeEUR 2,000 per person
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Retail CFD sales are subject to the ESMA-derived national product intervention measures: leverage caps of 30:1 (major FX) down to 2:1 (crypto), 50% margin close-out, negative balance protection and standardized risk warnings. Required for market-making (B-book) FX/CFD brokers, liquidity redistribution as principal, and matched-principal prime-of-prime models. Firms with consolidated assets of EUR 30bn or more that deal on own account or underwrite must instead be authorized as credit institutions (CRR Art. 4(1)(1)(b)). Pure own-account traders that do not deal for clients, make markets or use high-frequency trading can rely on the MiFID II Art. 2(1)(d) exemption. Commodity-derivative traders can rely on the ancillary-activity exemption (Art. 2(1)(j)) if they stay within its tests. CySEC expects substance in Cyprus: at least two executive directors (four-eyes principle) and local compliance, risk and AML functions. CySEC national measures restricting retail CFDs mirror the ESMA measures. CySEC closely reviews cross-border retail marketing and affiliate or introducing-broker networks.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskMulti-Asset BrokerageInvestment BankTreasury & Liquidity DeskCommodities Trading House
- Reading
- From a secondary source
- Sources
04Tied agent (white-label under another firm's license)Tied agent of a CIF (CySEC public register)No fixed figureMinimum capital
- Permits
- Promotes investment services, receives and transmits orders, places instruments and gives advice on behalf of a single authorized investment firm or bank. The agent operates under that principal's license.
- Minimum capital
- None. The tied agent holds no license and has no capital requirement; the principal firm is fully and unconditionally responsible for it (MiFID II Art. 29).
- Fees
- Tied agent registration feeEUR 3,000
- Clients
- Retail permitted
- Conditions
- Must be entered on the public register of tied agents. It may not hold client money or instruments and may act for only one principal. CySEC keeps the tied-agent register for CIFs.
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
05UCITS management companyUCITS management company (Open-Ended Undertakings for Collective Investment Law 78(I)/2012)USD 145 kMinimum capital
- Permits
- Collective management of UCITS (and, where authorized, AIFs). May add discretionary portfolio management, investment advice and safekeeping as non-core services (UCITS Directive Art. 6(3)).
- Minimum capital
- EUR 125,000 initial capital, plus 0.02% of assets under management above EUR 250 million, capped at EUR 10 million in total; own funds never below one quarter of prior-year fixed overheads (Law 78(I)/2012; UCITS Directive Art. 7(1)(a)). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Needs at least two conducting persons, local infrastructure, and separate risk, compliance and internal audit functions. A self-managed UCITS investment company needs EUR 300,000 instead. The EU UCITS passport covers both cross-border management and distribution. A self-managed UCITS needs EUR 300,000 (Chambers 2026). Indicative timeline is 5-6 months (market practice).
- Systems
- Mutual Fund & UCITSETF PlatformFund Management CompanyAsset Management Company
- Reading
- From a secondary source
- Sources
06Authorized AIFMAlternative Investment Fund Manager (AIFM Law 56(I)/2013)USD 145 kMinimum capital
- Permits
- Portfolio management and risk management of alternative investment funds (hedge, private equity, venture, private credit, real estate, digital-asset funds). May also be licensed for discretionary mandates and advice (AIFMD Art. 6(4)).
- Minimum capital
- EUR 125,000 initial capital for an external AIFM, or EUR 300,000 for an internally managed AIF, plus 0.02% of AUM above EUR 250 million, capped at EUR 10 million. Also requires professional indemnity insurance or extra own funds of 0.01% of AUM (Law 56(I)/2013; AIFMD Art. 9; Delegated Reg. 231/2013 Art. 14). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- The AIFMD passport covers marketing to professional investors only; retail marketing depends on national fund rules or ELTIF status. Needs a depositary for each AIF, plus a valuation function and liquidity management. AIFMD II (Directive (EU) 2024/927) applies from 16 April 2026. It adds loan-origination rules for private credit funds (leverage caps, 5% risk retention, a concentration limit) and mandatory liquidity management tools. Cyprus had not fully transposed AIFMD II by the April 2026 deadline (bills pending, per Chambers 2026). CySEC Circular C743 (19 December 2025) required managers of open-ended AIFs and UCITS ManCos to select at least two liquidity management tools by 27 February 2026. Can manage Cyprus AIFs, AIFLNPs and RAIFs. A RAIF is registered rather than authorized (about 1 month) and must be managed by a full AIFM or UCITS ManCo.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundQuantitative Trading DeskPension & Endowment Manager
- Reading
- From a secondary source
- Sources
07Sub-threshold fund managerMini-AIFM / sub-threshold AIFM (Law 81(I)/2020)USD 58 kMinimum capital
- Permits
- Managing AIFs as an external manager where AUM stays below the AIFMD thresholds (EUR 100 million, or EUR 500 million unleveraged with a 5-year lock-up).
- Minimum capital
- EUR 50,000 minimum initial paid-up capital, plus own funds of 0.02% of the managed portfolio above EUR 125 million (Law 81(I)/2020). (≈USD 58 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- May market to professional and well-informed investors in Cyprus, and to such investors in other EU states after notifying CySEC (no AIFMD passport). Indicative authorization time is 3-4 months (market practice).
- Systems
- Private Equity FirmVenture Capital FirmReal Estate Investment VehiclePrivate Credit FundHedge FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
08Private AIF (up to 50 investors)Alternative Investment Fund with Limited Number of Persons (AIFLNP), AIF Law 124(I)/2018USD 58 kMinimum capital
- Permits
- A CySEC-authorized AIF with no more than 50 investors, all well-informed or professional. Can be self-managed, and is often used for family and club deals.
- Minimum capital
- EUR 50,000 minimum capital if self-managed, rising to EUR 250,000 within 12 months (extendable to 24) (AIF Law 124(I)/2018, per Chambers 2026). (≈USD 58 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Authorization takes about 3-5 months (market practice). Externally managed AIFLNPs need a CIF, UCITS ManCo, AIFM or mini-AIFM as manager. The fund is a product authorization, not a manager license.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmReal Estate Investment VehiclePrivate Credit FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
09CASP Class 1MiCA crypto-asset service provider - Class 1USD 58 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice on crypto-assets and portfolio management of crypto-assets (MiCA Art. 3(1)(16)).
- Minimum capital
- EUR 50,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 1). (≈USD 58 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. CySEC is the competent authority for CASPs in Cyprus. Fits an agency-only crypto brokerage or RFQ desk that does not deal as principal or hold client assets. Cyprus allowed an 18-month grandfathering period, which ended 1 July 2026. CySEC required existing national registrants to apply by 27 February 2026 or submit a wind-down plan.
- Systems
- OTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
10CASP Class 2MiCA crypto-asset service provider - Class 2USD 145 kMinimum capital
- Permits
- Class 1 services plus custody and administration of crypto-assets on behalf of clients, and exchange of crypto-assets for funds or for other crypto-assets.
- Minimum capital
- EUR 125,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 2). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. CySEC is the competent authority for CASPs in Cyprus. This is the class for a principal OTC desk, a broker-style crypto exchange (the firm is the counterparty) and a custodian or wallet provider. Cyprus allowed an 18-month grandfathering period, which ended 1 July 2026. CySEC required existing national registrants to apply by 27 February 2026 or submit a wind-down plan.
- Systems
- OTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
11CASP Class 3MiCA crypto-asset service provider - Class 3USD 174 kMinimum capital
- Permits
- Class 2 services plus operation of a trading platform for crypto-assets.
- Minimum capital
- EUR 150,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 3). (≈USD 174 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. CySEC is the competent authority for CASPs in Cyprus. Trading platforms must have non-discretionary rules, may not deal on own account on their own platform, and must publish pre- and post-trade data. Cyprus allowed an 18-month grandfathering period, which ended 1 July 2026. CySEC required existing national registrants to apply by 27 February 2026 or submit a wind-down plan.
- Systems
- Digital Asset Exchange
- Reading
- From a secondary source
- Sources
12ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)USD 406 kMinimum capital
- Permits
- Offering to the public, or seeking admission to trading of, asset-referenced tokens (stablecoins referencing a basket of assets, commodities or currencies) in the EU.
- Minimum capital
- Own funds of the highest of EUR 350,000, 2% of the average reserve of assets, or one quarter of prior-year fixed overheads (MiCA Art. 35(1)). (≈USD 406 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Authorized by the Cyprus MiCA competent authority (the House could not confirm whether CySEC or the Central Bank of Cyprus handles ART issuers). A credit institution can issue ARTs on notification instead (MiCA Art. 17). Must keep a fully backed, segregated reserve of assets and a redemption right, and cannot pay interest. Significant ARTs move to EBA supervision and need extra own funds. Fiat single-currency stablecoins are EMTs, which require an EMI or bank license. Capital figure is certain (MiCA). Which Cyprus authority receives ART applications is not confirmed. EMT issuers must be banks or EMIs licensed by the Central Bank of Cyprus.
- Systems
- Stablecoin Issuance Structure
- Reading
- To be confirmed
- Sources
Reach
Full EU/EEA passporting: MiFID II for CIFs (services and branches), UCITS, AIFMD (professional investors), and MiCA for CASPs. Mini-AIFMs and AIFLNPs do not get the AIFMD passport.
Passage
Statutory: CIFs 6 months from a complete application (MiFID II Art. 7(3), Law 87(I)/2017), but market practice is often 12-16 months in total. AIFM 3 months, extendable to 6 (AIFMD Art. 8(5)). UCITS ManCo 6 months (UCITS Directive Art. 7(3)). CASP: 25 working days for the completeness check, then 40 working days for assessment (MiCA Art. 63). Mini-AIFM about 3-4 months and RAIF registration about 1 month (market practice).
Licensed elsewhere
Central Bank of Cyprus: banks (with the ECB, which grants all euro-area bank licenses), payment institutions, e-money institutions (and so EMT stablecoin issuers), and money remittance and currency exchange. Insurance Companies Control Service: insurers and reinsurers. Registrar of Occupational Retirement Benefit Funds: pension funds. Not licensed: sovereign vehicles, mining/validation on own account, physical commodity trading, and single-family offices managing only family wealth (often structured as an AIFLNP or a private holding company). Structured products are issued by banks or investment firms, with prospectus approval from CySEC. Islamic finance has no dedicated regime.
Notes. MiCA transition: Cyprus chose 18 months (ESMA list), ending 1 July 2026. CySEC stopped accepting national CASP registrations on 17 October 2024 and set an application deadline of 27 February 2026. Firms that did not apply had to file wind-down plans. AIFMD II transposition was pending after the 16 April 2026 deadline. Cyprus corporate tax rose from 12.5% to 15% from 1 January 2026. DORA has applied since 17 January 2025. USD conversions use approx. EUR 1 = USD 1.16 and GBP 1 = USD 1.33 (October 2026).
Europe · Germany
BaFin
Federal Financial Supervisory Authority (Bundesanstalt für Finanzdienstleistungsaufsicht)
BaFin is Germany's integrated financial regulator under the FinDAG. It covers banks and financial service institutions (KWG), securities institutions (WpIG), fund managers (KAGB), payment and e-money institutions (ZAG), crypto-asset service providers and token issuers (MiCAR/KMAG), and insurers and pension funds (VAG). Bank licenses are granted by the ECB under the Single Supervisory Mechanism, and the Bundesbank carries out much of the day-to-day banking supervision. Germany treats commercial lending itself as a licensable banking business.
#1of 34
Balanced score
85 of 100
85 of 100
Scorecard
Credibility ×35%100Breadth ×15%89Entry threshold ×20%69Speed ×15%60Reach ×15%95
Categories19
Systems covered42 of 47
Typical timeline6–12 monthsmarket practice
Lowest capitalUSD 23 k
IOSCO MMoUA
PassportEU/EEA
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
Application—0 items · Paid once, when the application is filed
On grantUSD 4 k–39 k5 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every year—0 items · Recurring fees and levies
OtherUSD 2 k1 item · Mandatory charges that arise in operation
One-off license fees are fixed for KVGs and multi-service payment institutions but charged by time spent for banks and single-service licenses. The larger ongoing cost is BaFin's annual cost allocation (Umlage) under FinDAG, a formula share of supervisory costs, plus compensation-scheme contributions (EdW for securities institutions, deposit guarantee for banks). Fixed fees for WpIG securities institutions and MiCAR CASPs were not located.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| On grant | |||
| Licence fee, UCITS or AIF management company (KVG) under Sections 20-22 KAGBFinDAGebV fee schedule item 15.1.2.2.1, charged for the licensing decision. The Anlage was last amended 25 September 2026 (BGBl. 2026 I Nr. 275); the figure was read in the consolidated text on gesetze-im-internet.de. | EUR 33,477≈ USD 39 k | UCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB); AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | Read in the rulebook |
| Registration fee, registered AIF management company (Section 44 KAGB)FinDAGebV item 15.1.2.2.4. | EUR 3,029≈ USD 4 k | Registered AIF management company (registrierte KVG, Section 2(4)-(5) and Section 44 KAGB) | Read in the rulebook |
| Licence fee, payment institution for several or all payment services (Section 10 ZAG)FinDAGebV item 11.1.1.2. A license for a single payment service (item 11.1.1.1) is charged by time spent. | EUR 13,523≈ USD 16 k | Payment institution - full scope (Section 10 and Section 12 ZAG) | Read in the rulebook |
| Licence fee, single-service payment institution or e-money institution (Sections 10-11 ZAG)FinDAGebV items 11.1.1.1 (single payment service) and 11.1.2 (e-money license). No fixed amount. | Charged by time spent (nach Zeitaufwand) | Payment institution - money remittance only (Section 10 and Section 12 ZAG); Payment institution - payment initiation services only (Section 10 and Section 12 ZAG); Electronic money institution (Section 11 ZAG) | Read in the rulebook |
| Licence fee, banking business under Section 32 KWGFinDAGebV items 5.1.12.2.1 (banking business) and 5.1.12.1.4 (crypto securities register). CRR bank licenses are granted by the ECB on BaFin's proposal. Change-of-control (Inhaberkontrolle) and manager-related decisions are also time-based. | Charged by time spent (nach Zeitaufwand) | CRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG; Credit institution conducting lending business only (Kreditgeschäft, Section 32 KWG, non-CRR); Crypto securities registrar (Kryptowertpapierregisterführung, KWG financial service under the eWpG) | Read in the rulebook |
| Other | |||
| KVG license extension and material-change reviewFinDAGebV items 15.1.2.2.2 and 15.1.2.2.3. | EUR 14,673 (license extension); EUR 1,298 (review of notified material changes, Section 34 KAGB)≈ USD 2 k | UCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB); AIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 145 k
Payment institution (money remittance)Payment institution - money remittance only (Section 10 and Section 12 ZAG)
USD 23 k
Payment institution (payment initiation)Payment institution - payment initiation services only (Section 10 and Section 12 ZAG)
USD 58 k
CASP Class 1MiCA crypto-asset service provider - Class 1
USD 58 k
Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000
USD 87 k
UCITS management companyUCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB)
USD 145 k
Authorized AIFMAIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB)
USD 145 k
Payment institution (full)Payment institution - full scope (Section 10 and Section 12 ZAG)
USD 145 k
CASP Class 2MiCA crypto-asset service provider - Class 2
USD 145 k
Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000
USD 174 k
CASP Class 3MiCA crypto-asset service provider - Class 3
USD 174 k
E-money institutionElectronic money institution (Section 11 ZAG)
USD 406 k
ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)
USD 406 k
Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000
USD 870 k
Insurer / reinsurerInsurance or reinsurance undertaking (Insurance Supervision Act, VAG)
USD 1.51 m
BankCRR credit institution (Einlagenkreditinstitut), license under Section 32 KWG
USD 5.8 m
10k100k1m10m
15 of 19 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
19 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BankCRR credit institution (Einlagenkreditinstitut), license under Section 32 KWGUSD 5.8 mMinimum capital
- Permits
- Deposit-taking combined with lending (CRR credit institution), plus any other banking business (custody, underwriting, guarantees, giro) and financial or investment services.
- Minimum capital
- EUR 5 million initial capital (Section 33(1) KWG; CRD Art. 12). CRR Pillar 1 ratios, Pillar 2 and buffers apply on top. (≈USD 5.8 m)
- Fees
- Licence fee, banking business under Section 32 KWGCharged by time spent (nach Zeitaufwand)
- Clients
- Retail permitted
- Conditions
- In the euro area the ECB grants and withdraws all CRR credit institution licenses on BaFin's proposal. Significant institutions are supervised directly by the ECB, and less significant ones by BaFin and the Bundesbank. Needs at least two qualified, reliable managing directors (four-eyes principle) and MaRisk-compliant organization. Statutory deposit guarantee membership is required. A securities institution that reaches EUR 30 billion in assets must be authorized as a CRR credit institution.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructurePrime BrokerageTreasury & Liquidity DeskTrade Finance House
- Reading
- From a secondary source
- Sources
02Lending institutionCredit institution conducting lending business only (Kreditgeschäft, Section 32 KWG, non-CRR)No fixed figureMinimum capital
- Permits
- Commercial lending (Kreditgeschäft) or guarantee business without taking deposits. In Germany, commercial lending is itself a banking business that needs a license.
- Minimum capital
- Not confirmed. Section 33(1) KWG sets the initial capital by institution type, and the House could not confirm the figure for non-deposit-taking credit institutions.
- Fees
- Licence fee, banking business under Section 32 KWGCharged by time spent (nach Zeitaufwand)
- Clients
- Retail permitted
- Conditions
- Relevant for trade finance houses and direct lenders operating outside a fund. AIFs managed by a licensed KVG may originate loans under the KAGB without a KWG license.
- Systems
- Trade Finance HousePrivate Credit Fund
- Reading
- To be confirmed
- Sources
03Investment firm (dealing on own account)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 750,000USD 870 kMinimum capital
- Permits
- Proprietary trading for others (Eigenhandel), underwriting business (Emissionsgeschäft), operating an OTF with own-account dealing, or custody and securities lending business.
- Minimum capital
- EUR 750,000 initial capital (Section 17(1) no. 1 WpIG). (≈USD 870 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- The IFR applies for own funds (highest of PMR, fixed overheads and K-factors). BaFin's 2019 general administrative act on CFDs imposes the ESMA leverage caps, negative balance protection and the ban on additional payment obligations for retail clients. Own-account traders and commodity firms can use the MiFID exemptions.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskMulti-Asset BrokerageInvestment BankTreasury & Liquidity DeskCommodities Trading House
- Reading
- Read in the rulebook
- Sources
04Investment firm (client money / MTF)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 150,000USD 174 kMinimum capital
- Permits
- Any other securities services not covered by the EUR 75,000 or EUR 750,000 tiers, for example agency brokerage that may hold client money or securities, and operating an MTF or an OTF without own-account dealing.
- Minimum capital
- EUR 150,000 initial capital (Section 17(1) no. 3 WpIG). (≈USD 174 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Fits an agency broker that holds client money, or an MTF operator (including a DLT MTF under the EU DLT Pilot Regime). Public stock exchanges (Börsen) are licensed by the state exchange supervisory authorities, not BaFin.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageECN & DMA VenueWealth Management FirmMulti-Family OfficeTokenization Platform
- Reading
- Read in the rulebook
- Sources
05Investment firm (agency, no client money)Securities institution (Wertpapierinstitut), license under Section 15 WpIG - EUR 75,000USD 87 kMinimum capital
- Permits
- Investment brokerage (Anlagevermittlung), contract brokerage (Abschlussvermittlung), portfolio management (Finanzportfolioverwaltung), investment advice and placement business, where the license excludes holding client money or securities.
- Minimum capital
- EUR 75,000 initial capital (Section 17(1) no. 2 WpIG). (≈USD 87 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Most discretionary wealth managers and independent advisers use this tier. Advisers and brokers dealing only in funds can instead use a trade license under Section 34f GewO (chamber of commerce, not BaFin).
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family OfficeAsset Management CompanyPension & Endowment Manager
- Reading
- Read in the rulebook
- Sources
06Tied agent (white-label under another firm's license)Tied agent (vertraglich gebundener Vermittler, Section 3(2) WpIG / Section 2(10) KWG)No fixed figureMinimum capital
- Permits
- Promotes investment services, receives and transmits orders, places instruments and gives advice on behalf of a single authorized investment firm or bank. The agent operates under that principal's license.
- Minimum capital
- None. The tied agent holds no license and has no capital requirement; the principal firm is fully and unconditionally responsible for it (MiFID II Art. 29).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Must be entered on the public register of tied agents. It may not hold client money or instruments and may act for only one principal. Registered with BaFin by the liable institution.
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
07UCITS management companyUCITS management company (OGAW-Kapitalverwaltungsgesellschaft, Sections 20-21 KAGB)USD 145 kMinimum capital
- Permits
- Collective management of UCITS (OGAW) and, with the relevant license, retail and special AIFs, plus permitted ancillary services (individual portfolio management, advice).
- Minimum capital
- EUR 125,000 initial capital for an external KVG, or EUR 300,000 for an internally managed investment company, plus 0.02% of AUM above EUR 250 million, capped at EUR 10 million (Section 25 KAGB; UCITS Directive Art. 7). (≈USD 145 k)
- Fees
- Licence fee, UCITS or AIF management company (KVG) under Sections 20-22 KAGBEUR 33,477KVG license extension and material-change reviewEUR 14,673 (license extension); EUR 1,298 (review of notified material changes, Section 34 KAGB)
- Clients
- Retail permitted
- Conditions
- Statutory decision within 6 months (Section 21 KAGB). Needs two managing directors and a depositary. German retail funds and ETFs are typically domiciled in Germany, Luxembourg or Ireland.
- Systems
- Mutual Fund & UCITSETF PlatformFund Management CompanyAsset Management Company
- Reading
- From a secondary source
- Sources
08Authorized AIFMAIF management company (AIF-Kapitalverwaltungsgesellschaft, Sections 20 and 22 KAGB)USD 145 kMinimum capital
- Permits
- Managing open-ended and closed-ended AIFs, including special AIFs (Spezial-AIF) for professional and semi-professional investors and retail AIFs (Publikums-AIF).
- Minimum capital
- EUR 125,000 initial capital for an external KVG, or EUR 300,000 for an internally managed AIF, plus 0.02% of AUM above EUR 250 million, capped at EUR 10 million, plus professional liability cover (Section 25 KAGB; AIFMD Art. 9). (≈USD 145 k)
- Fees
- Licence fee, UCITS or AIF management company (KVG) under Sections 20-22 KAGBEUR 33,477KVG license extension and material-change reviewEUR 14,673 (license extension); EUR 1,298 (review of notified material changes, Section 34 KAGB)
- Clients
- Retail, with conditions
- Conditions
- Statutory decision within 3 months, extendable by 3 (Section 22 KAGB). Semi-professional investors (minimum EUR 200,000) can invest in Spezial-AIFs. Loan-originating AIFs are permitted under the KAGB. AIFMD II rules apply from 16 April 2026; we did not confirm the German implementing act.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundQuantitative Trading DeskPension & Endowment Manager
- Reading
- From a secondary source
- Sources
09Registered (sub-threshold) AIFMRegistered AIF management company (registrierte KVG, Section 2(4)-(5) and Section 44 KAGB)No fixed figureMinimum capital
- Permits
- Managing special AIFs below the AIFMD thresholds (or closed-ended retail AIFs under Section 2(5), up to EUR 100 million) under a registration rather than a license.
- Minimum capital
- No initial capital requirement under the KAGB for the registration-only route.
- Fees
- Registration fee, registered AIF management company (Section 44 KAGB)EUR 3,029
- Clients
- Professional only
- Conditions
- No EU passport, and limited conduct rules. Becomes subject to the full license once over the thresholds. Common for German venture capital and small private equity or real estate managers.
- Systems
- Private Equity FirmVenture Capital FirmReal Estate Investment VehiclePrivate Credit Fund
- Reading
- From a secondary source
- Sources
10Crypto securities registrarCrypto securities registrar (Kryptowertpapierregisterführung, KWG financial service under the eWpG)No fixed figureMinimum capital
- Permits
- Keeping a crypto securities register for electronic securities issued on a DLT system under the Electronic Securities Act (eWpG).
- Minimum capital
- Not confirmed. This is a KWG financial service and the initial capital comes from Section 33(1) KWG, but the House could not confirm the amount for this service.
- Fees
- Licence fee, banking business under Section 32 KWGCharged by time spent (nach Zeitaufwand)
- Clients
- Retail, with conditions
- Conditions
- This is the German route for tokenized bonds, fund units and (since the Future Financing Act of December 2023) shares. Crypto-assets within MiCA's scope moved to the MiCA regime from 30 December 2024.
- Systems
- Tokenization Platform
- Reading
- To be confirmed
- Sources
11Payment institution (money remittance)Payment institution - money remittance only (Section 10 and Section 12 ZAG)USD 23 kMinimum capital
- Permits
- Money remittance only: transferring funds from a payer to a payee without payment accounts (PSD2 Annex I(6)).
- Minimum capital
- EUR 20,000 initial capital (Section 10 and Section 12 ZAG; PSD2 Art. 7(a)). (≈USD 23 k)
- Fees
- Licence fee, single-service payment institution or e-money institution (Sections 10-11 ZAG)Charged by time spent (nach Zeitaufwand)
- Clients
- Retail permitted
- Conditions
- Must safeguard client funds by segregation or insurance/guarantee and maintain ongoing own funds under PSD2 Art. 9. Currency exchange alone (bureau de change) is not a PSD2 payment service. Statutory decision within 3 months of a complete application (Section 10 ZAG).
- Systems
- Money Services Business
- Reading
- From a secondary source
- Sources
12Payment institution (payment initiation)Payment institution - payment initiation services only (Section 10 and Section 12 ZAG)USD 58 kMinimum capital
- Permits
- Payment initiation services only (PSD2 Annex I(7)).
- Minimum capital
- EUR 50,000 initial capital (Section 10 and Section 12 ZAG; PSD2 Art. 7(b)), plus professional indemnity insurance. (≈USD 58 k)
- Fees
- Licence fee, single-service payment institution or e-money institution (Sections 10-11 ZAG)Charged by time spent (nach Zeitaufwand)
- Clients
- Retail permitted
- Conditions
- Does not hold client funds. Account information services alone need registration and professional indemnity insurance, not initial capital. Statutory decision within 3 months of a complete application (Section 10 ZAG).
- Systems
- Payment Service Provider
- Reading
- From a secondary source
- Sources
13Payment institution (full)Payment institution - full scope (Section 10 and Section 12 ZAG)USD 145 kMinimum capital
- Permits
- Payment accounts, cash placement and withdrawal, execution of payment transactions (including credit transfers and direct debits), issuing payment instruments and acquiring payment transactions (PSD2 Annex I(1)-(5)), plus remittance and payment initiation.
- Minimum capital
- EUR 125,000 initial capital (Section 10 and Section 12 ZAG; PSD2 Art. 7(c)). (≈USD 145 k)
- Fees
- Licence fee, payment institution for several or all payment services (Section 10 ZAG)EUR 13,523
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are calculated under PSD2 Art. 9 (Method A/B/C). May grant credit only if it is ancillary and short-term (12 months or less). Cannot issue e-money. Can use agents and distributors and passport across the EEA. Statutory decision within 3 months of a complete application (Section 10 ZAG).
- Systems
- Payment Service ProviderMerchant AcquiringCard Issuing ProgramMoney Services Business
- Reading
- From a secondary source
- Sources
14E-money institutionElectronic money institution (Section 11 ZAG)USD 406 kMinimum capital
- Permits
- Issuing electronic money and providing all payment services. Under MiCA (Art. 48), an EMI may also issue e-money tokens (EMTs, fiat-referenced stablecoins).
- Minimum capital
- EUR 350,000 initial capital (Section 11 ZAG; EMD2 Art. 4). Ongoing own funds are at least 2% of average outstanding e-money (Method D). (≈USD 406 k)
- Fees
- Licence fee, single-service payment institution or e-money institution (Sections 10-11 ZAG)Charged by time spent (nach Zeitaufwand)
- Clients
- Retail permitted
- Conditions
- Must safeguard funds received for e-money. Cannot pay interest on e-money. Can distribute through agents and distributors. Issuing an EMT also requires a MiCA white paper notified to the regulator, reserve and redemption-at-par rules, and extra own funds if the token is designated significant.
- Systems
- Electronic Money InstitutionCard Issuing ProgramPayment Service ProviderStablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
15CASP Class 1MiCA crypto-asset service provider - Class 1USD 58 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice on crypto-assets and portfolio management of crypto-assets (MiCA Art. 3(1)(16)).
- Minimum capital
- EUR 50,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 1). (≈USD 58 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. BaFin is the competent authority under the KMAG (Kryptomärkteaufsichtsgesetz). Fits an agency-only crypto brokerage or RFQ desk that does not deal as principal or hold client assets. Germany used a 12-month grandfathering period that ended at the end of December 2025 (Section 50 KMAG). Existing KWG crypto custody and financial-service license holders could use the simplified MiCA procedure.
- Systems
- OTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
16CASP Class 2MiCA crypto-asset service provider - Class 2USD 145 kMinimum capital
- Permits
- Class 1 services plus custody and administration of crypto-assets on behalf of clients, and exchange of crypto-assets for funds or for other crypto-assets.
- Minimum capital
- EUR 125,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 2). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. BaFin is the competent authority under the KMAG (Kryptomärkteaufsichtsgesetz). This is the class for a principal OTC desk, a broker-style crypto exchange (the firm is the counterparty) and a custodian or wallet provider. Germany used a 12-month grandfathering period that ended at the end of December 2025 (Section 50 KMAG). Existing KWG crypto custody and financial-service license holders could use the simplified MiCA procedure.
- Systems
- OTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
17CASP Class 3MiCA crypto-asset service provider - Class 3USD 174 kMinimum capital
- Permits
- Class 2 services plus operation of a trading platform for crypto-assets.
- Minimum capital
- EUR 150,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 3). (≈USD 174 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. BaFin is the competent authority under the KMAG (Kryptomärkteaufsichtsgesetz). Trading platforms must have non-discretionary rules, may not deal on own account on their own platform, and must publish pre- and post-trade data. Germany used a 12-month grandfathering period that ended at the end of December 2025 (Section 50 KMAG). Existing KWG crypto custody and financial-service license holders could use the simplified MiCA procedure.
- Systems
- Digital Asset Exchange
- Reading
- From a secondary source
- Sources
18ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)USD 406 kMinimum capital
- Permits
- Offering to the public, or seeking admission to trading of, asset-referenced tokens (stablecoins referencing a basket of assets, commodities or currencies) in the EU.
- Minimum capital
- Own funds of the highest of EUR 350,000, 2% of the average reserve of assets, or one quarter of prior-year fixed overheads (MiCA Art. 35(1)). (≈USD 406 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Authorized by BaFin. A credit institution can issue ARTs on notification instead (MiCA Art. 17). Must keep a fully backed, segregated reserve of assets and a redemption right, and cannot pay interest. Significant ARTs move to EBA supervision and need extra own funds. Fiat single-currency stablecoins are EMTs, which require an EMI or bank license.
- Systems
- Stablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
19Insurer / reinsurerInsurance or reinsurance undertaking (Insurance Supervision Act, VAG)USD 1.51 mMinimum capital
- Permits
- Direct life or non-life insurance, or reinsurance, including captive (re)insurance, under Solvency II.
- Minimum capital
- Solvency II absolute floor of the Minimum Capital Requirement (Directive 2009/138/EC Art. 129(1)(d), revised amounts from 19 October 2022): EUR 2.7 million non-life (EUR 4.0 million if liability, credit or suretyship classes 10-15 are covered), EUR 4.0 million life, EUR 3.9 million reinsurance, EUR 1.3 million captive reinsurance. The Solvency Capital Requirement applies on top. (≈USD 1.51 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Authorized and supervised by BaFin. Requires an ORSA, a system of governance with four key functions, and Pillar 3 reporting. The Solvency II review (Directive (EU) 2025/2) applies from 30 January 2027.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
Full EU/EEA passporting under CRD (banks), MiFID II (securities institutions), UCITS, AIFMD (professional investors), PSD2/EMD2 (payments and e-money) and MiCA (CASPs). Registered KVGs have no passport.
Passage
Statutory: CRR credit institutions 6 months from a complete application, 12 months at most (CRD Art. 15, ECB decision). Securities institutions 6 months (MiFID II Art. 7(3)). OGAW-KVG 6 months (Section 21 KAGB). AIF-KVG 3 months, extendable by 3 (Section 22 KAGB). Payment and e-money institutions 3 months (ZAG). CASPs 25 working days for completeness plus 40 working days for assessment (MiCA Art. 63). Market practice is longer, often 6-12 months for securities institutions and 12+ months for banks.
Licensed elsewhere
ECB: grants all CRR credit institution licenses and directly supervises significant banks. State exchange supervisory authorities (Börsenaufsicht der Länder): public stock exchanges such as the Frankfurt Stock Exchange. Chambers of commerce and trade offices: financial investment intermediaries and fee-based advisers under Sections 34f/34h GewO (fund-only advice and brokerage). Not licensed: sovereign vehicles, mining/validation on own account, physical commodity trading, and single-family offices managing only their own family's assets (BaFin assesses case by case; any third-party element can trigger a license). Structured product issuance needs prospectus approval (also from BaFin), not a license, although many issuers are banks. Islamic finance has no separate regime and uses standard licenses. Occupational pension funds (Pensionskassen, Pensionsfonds) are supervised by BaFin under the VAG, not listed here as a separate category.
Notes. MiCAR has applied since 30 December 2024 through the KMAG. Germany's 12-month grandfathering period ended in December 2025. The Crypto Markets Notification Ordinance (KMAnzV) has applied since 1 July 2026. The WpIG has applied since 26 June 2021, and KWG licenses for investment services were converted into WpIG licenses. AIFMD II (application from 16 April 2026) and CRD VI third-country branch rules (from 11 January 2027) apply; we did not confirm the status of the German implementing acts. DORA has applied since 17 January 2025. USD conversions use approx. EUR 1 = USD 1.16 and GBP 1 = USD 1.33 (October 2026).
Europe · Luxembourg
CSSF
Commission de Surveillance du Secteur Financier
The CSSF supervises Luxembourg banks (with the ECB), professionals of the financial sector (investment firms, specialized PSF and support PSF), payment and e-money institutions, investment funds (UCITS, Part II UCIs, SIFs, SICARs), UCITS management companies and AIFMs, authorized securitization undertakings and pension funds (SEPCAV/ASSEP), and crypto-asset service providers under MiCA. It operates under the Law of 23 December 1998. Luxembourg is the largest EU fund domicile, and the RAIF (Law of 23 July 2016) lets a fund launch without CSSF product approval if it has an authorized AIFM.
#2of 34
Balanced score
85 of 100
85 of 100
Scorecard
Credibility ×35%100Breadth ×15%89Entry threshold ×20%69Speed ×15%60Reach ×15%92
Categories21
Systems covered42 of 47
Typical timeline6–12 monthsstatutory
Lowest capitalUSD 23 k
IOSCO MMoUA
PassportEU/EEA
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 5 k–87 k10 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 5 k–135 k10 items · Recurring fees and levies
OtherUSD 17 k1 item · Mandatory charges that arise in operation
CSSF fees are fixed, not income-based, and high for small firms: EUR 30,000-75,000 to apply and EUR 25,000-520,000 a year, charged per service for investment firms. Banks and investment firms also contribute to the FGDL deposit guarantee and SIIL investor compensation schemes.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Instruction fee, credit institution authorization (point I.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 75,000≈ USD 87 k | Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | Read in the rulebook |
| Instruction fee, investment firm authorization (point VII.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. One fee regardless of investment firm type. | EUR 50,000; EUR 15,000 to extend to further services or statuses≈ USD 58 k | Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000; Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000; Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | Read in the rulebook |
| Instruction fee, specialized PSF (point VIII.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 30,000; EUR 12,500 to add a status≈ USD 35 k | Family office (specialized PSF, Article 28-6 LFS; Law of 21 December 2012 on family office activity); Professional performing lending operations (specialized PSF, Article 28-4 LFS) | Read in the rulebook |
| Instruction fee, Chapter 15 management company or authorized AIFM (point V.A.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. Chapter 16/17 management companies EUR 9,600. | EUR 18,000≈ USD 21 k | Management company - Chapter 15 of the Law of 17 December 2010 (UCI Law); Authorized AIFM (Law of 12 July 2013 on AIFMs) | Read in the rulebook |
| Registration fee, registered AIFM (point V.A.4)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. Registered EuVECA/EuSEF managers EUR 4,800 each. | EUR 7,200≈ USD 8 k | Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | Read in the rulebook |
| Instruction fee, SIF or SICAR (point IV.A.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 4,650 (single fund); EUR 9,250 (multi-compartment); EUR 17,500 (internally managed SIF-AIF or SICAR-AIF)≈ USD 5 k | Specialised investment fund (SIF), Law of 13 February 2007; Investment company in risk capital (SICAR), Law of 15 June 2004 | Read in the rulebook |
| Instruction fee, authorized securitization undertaking (point XV.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 5,775 (single); EUR 9,250 (multi-compartment)≈ USD 7 k | Authorized securitization undertaking (Law of 22 March 2004 on securitization) | Read in the rulebook |
| Instruction fee, payment institution or e-money institution (points X.1 and XII.1)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 30,000; extension EUR 8,000 (PI) or EUR 6,000 (EMI)≈ USD 35 k | Payment institution - money remittance only (Law of 10 November 2009 on payment services); Payment institution - payment initiation services only (Law of 10 November 2009 on payment services); Payment institution - full scope (Law of 10 November 2009 on payment services); Electronic money institution (Law of 10 November 2009 on payment services) | Read in the rulebook |
| Instruction fee, MiCA CASP authorization (point XXXI.D.1)MiCA fees added to the 2022 regulation by the 2026 amendment; figures read in the consolidated text annexed to the Chamber of Commerce opinion on the draft (file 6957), not in the CSSF-published consolidation. | EUR 30,000; EUR 15,000 if already CSSF-authorised under another status; EUR 8,000 to extend services≈ USD 17 k | MiCA crypto-asset service provider - Class 1; MiCA crypto-asset service provider - Class 2; MiCA crypto-asset service provider - Class 3 | From a secondary source |
| Instruction fees, ART issuer authorization and white paper (point XXXI.B.1)Credit institution issuers pay only the EUR 10,000 white paper fee. Source as for the CASP fees. | EUR 30,000 authorization (EUR 15,000 if already CSSF-authorised) plus EUR 10,000 white paper; EUR 2,500 per modified white paper≈ USD 17 k | MiCA issuer of asset-referenced tokens (Title III authorization) | From a secondary source |
| Every year | |||
| Annual flat fee, credit institution (points I.2 and I.8)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. Additional fees for consolidated supervision, branches and transaction reporting (EUR 2,000 fixed plus variable, capped at EUR 20,000). | EUR 116,500 (balance sheet up to EUR 500m); EUR 190,000 (EUR 500m-2.5bn); EUR 520,000 (above EUR 2.5bn); plus deposit guarantee fee EUR 4,000-35,000≈ USD 135 k | Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | Read in the rulebook |
| Annual flat fee, investment firm, per investment service (point VII.2)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. Fees are set per investment service and by IFR class; how fees for several services combine was not confirmed. Plus deposit guarantee fee EUR 1,400-4,900 by service (VII.8) and EUR 16,500 per EEA branch (VII.3). | Per service, Class 2 / Class 3 firm: investment advice EUR 24,750 / 16,500; reception and transmission EUR 37,125 / 24,750; execution EUR 41,250 / 27,500; portfolio management EUR 66,000 / 44,000; placement without firm commitment EUR 115,500 / 77,000; own-account dealing and underwriting EUR 123,750 (Class 2); MTF or OTF operation EUR 74,250 (Class 2)≈ USD 19 k | Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000; Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000; Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000 | Read in the rulebook |
| Annual flat fee, specialized PSF (point VIII.2)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 25,000 (family office); EUR 90,000 (lending professionals)≈ USD 29 k | Family office (specialized PSF, Article 28-6 LFS; Law of 21 December 2012 on family office activity); Professional performing lending operations (specialized PSF, Article 28-4 LFS) | Read in the rulebook |
| Annual flat fee, Chapter 15 management company or authorized AIFM (point V.C)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. Chapter 15 branch EUR 18,000. | EUR 42,000 (with base strategy); EUR 3,000 per extra strategy≈ USD 49 k | Management company - Chapter 15 of the Law of 17 December 2010 (UCI Law); Authorized AIFM (Law of 12 July 2013 on AIFMs) | Read in the rulebook |
| Annual flat fee, registered AIFM (point V.C)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 10,000≈ USD 12 k | Registered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013) | Read in the rulebook |
| Annual fee, SIF or SICAR (point IV.A.3)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 4,650 (single fund); multi-compartment EUR 9,250 (1-5), 17,500 (6-20), 27,750 (21-50), 40,500 (over 50 compartments)≈ USD 5 k | Specialised investment fund (SIF), Law of 13 February 2007; Investment company in risk capital (SICAR), Law of 15 June 2004 | Read in the rulebook |
| Annual fee, authorized securitization undertaking (point XV.2)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. | EUR 8,660 (single); multi-compartment on the SIF/SICAR tiers≈ USD 10 k | Authorized securitization undertaking (Law of 22 March 2004 on securitization) | Read in the rulebook |
| Annual flat fee, payment institution or e-money institution (points X.2-X.3, XII.2-XII.3)Grand-ducal regulation of 23 December 2022 on CSSF fees, as amended by the Grand-ducal regulation of 8 January 2026. EEA branch EUR 11,000. | EUR 30,000 (payment volume up to EUR 1bn); EUR 40,000 (above EUR 1bn); EUR 25,000 for firms authorized three years or less with volume up to EUR 1bn≈ USD 29 k | Payment institution - money remittance only (Law of 10 November 2009 on payment services); Payment institution - payment initiation services only (Law of 10 November 2009 on payment services); Payment institution - full scope (Law of 10 November 2009 on payment services); Electronic money institution (Law of 10 November 2009 on payment services) | Read in the rulebook |
| Annual flat fee, MiCA CASP (point XXXI.D.2)Source as for the CASP instruction fee. Former Luxembourg VASPs paid EUR 15,000 a year under point XXVI. | EUR 40,000 (EUR 25,000 if already CSSF-authorised); plus EUR 25,000 per crypto-asset trading platform operated and EUR 20,000 if significant≈ USD 29 k | MiCA crypto-asset service provider - Class 1; MiCA crypto-asset service provider - Class 2; MiCA crypto-asset service provider - Class 3 | From a secondary source |
| Annual flat fee, ART issuer (point XXXI.B.2)Significant ART issuers are supervised by the EBA, with no additional CSSF annual fee. | EUR 40,000 (EUR 25,000 if already CSSF-authorised; EUR 10,000 for credit institutions)≈ USD 12 k | MiCA issuer of asset-referenced tokens (Title III authorization) | From a secondary source |
| Other | |||
| Qualifying holding notification, credit institution (new point I.7)Added by the 8 January 2026 amendment. | EUR 15,000≈ USD 17 k | Credit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 145 k
Payment institution (money remittance)Payment institution - money remittance only (Law of 10 November 2009 on payment services)
USD 23 k
Family office PSFFamily office (specialized PSF, Article 28-6 LFS; Law of 21 December 2012 on family office activity)
USD 58 k
Lending PSFProfessional performing lending operations (specialized PSF, Article 28-4 LFS)
USD 58 k
Payment institution (payment initiation)Payment institution - payment initiation services only (Law of 10 November 2009 on payment services)
USD 58 k
CASP Class 1MiCA crypto-asset service provider - Class 1
USD 58 k
Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000
USD 87 k
UCITS management companyManagement company - Chapter 15 of the Law of 17 December 2010 (UCI Law)
USD 145 k
Authorized AIFMAuthorized AIFM (Law of 12 July 2013 on AIFMs)
USD 145 k
Payment institution (full)Payment institution - full scope (Law of 10 November 2009 on payment services)
USD 145 k
CASP Class 2MiCA crypto-asset service provider - Class 2
USD 145 k
Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000
USD 174 k
CASP Class 3MiCA crypto-asset service provider - Class 3
USD 174 k
E-money institutionElectronic money institution (Law of 10 November 2009 on payment services)
USD 406 k
ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)
USD 406 k
Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000
USD 870 k
SICAR (venture/PE vehicle)Investment company in risk capital (SICAR), Law of 15 June 2004
USD 1.16 m
SIF (regulated fund)Specialised investment fund (SIF), Law of 13 February 2007
USD 1.45 m
BankCredit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS)
USD 10.09 m
10k100k1m10m100m
18 of 21 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
21 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BankCredit institution (bank), authorization under the Law of 5 April 1993 on the financial sector (LFS)USD 10.09 mMinimum capital
- Permits
- Taking deposits or other repayable funds from the public and granting credit for own account, plus investment services and other LFS activities.
- Minimum capital
- EUR 8.7 million minimum share capital (LFS; per Arendt/Mondaq banking authorization guide). This is higher than the EU CRD minimum of EUR 5 million. CRR own funds requirements apply on top. (≈USD 10.09 m)
- Fees
- Instruction fee, credit institution authorization (point I.1)EUR 75,000Annual flat fee, credit institution (points I.2 and I.8)EUR 116,500 (balance sheet up to EUR 500m); EUR 190,000 (EUR 500m-2.5bn); EUR 520,000 (above EUR 2.5bn); plus deposit guarantee fee EUR 4,000-35,000Qualifying holding notification, credit institution (new point I.7)EUR 15,000
- Clients
- Retail permitted
- Conditions
- The CSSF assesses the application and proposes it to the ECB, which grants the license. Needs at least two managers (dirigeants) with adequate experience, a central administration in Luxembourg, and FGDL deposit guarantee membership. Under the CRD VI transposition law of 5 May 2026, suitability applications must be filed 30 working days before an appointment, and the chair and CEO roles may not be combined.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructurePrime BrokerageTreasury & Liquidity DeskTrade Finance House
- Reading
- From a secondary source
- Sources
02Investment firm (agency, no client money)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 75,000USD 87 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, portfolio management, investment advice, and placing without a firm commitment, where the firm may not hold client money or securities.
- Minimum capital
- EUR 75,000 initial capital (LFS; IFD Art. 9(2)). (≈USD 87 k)
- Fees
- Instruction fee, investment firm authorization (point VII.1)EUR 50,000; EUR 15,000 to extend to further services or statusesAnnual flat fee, investment firm, per investment service (point VII.2)Per service, Class 2 / Class 3 firm: investment advice EUR 24,750 / 16,500; reception and transmission EUR 37,125 / 24,750; execution EUR 41,250 / 27,500; portfolio management EUR 66,000 / 44,000; placement without firm commitment EUR 115,500 / 77,000; own-account dealing and underwriting EUR 123,750 (Class 2); MTF or OTF operation EUR 74,250 (Class 2)
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Client money and assets must be held by a bank or custodian, not by the firm. CSSF requires a central administration and registered office in Luxembourg, at least two persons for day-to-day management, and an approved auditor (réviseur d'entreprises agréé). The CSSF page quotes the EUR 75,000 and EUR 150,000 tiers directly. The EUR 750,000 tier for dealing on own account follows IFD Art. 9(1), and we did not confirm the LFS article.
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family OfficeAsset Management CompanyPension & Endowment Manager
- Reading
- Read in the rulebook
- Sources
03Investment firm (holds client money/assets or operates MTF)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 150,000USD 174 kMinimum capital
- Permits
- The same agency services where the firm holds client money or financial instruments, plus operating a multilateral trading facility (MTF) or an OTF without own-account dealing.
- Minimum capital
- EUR 150,000 initial capital (LFS; IFD Art. 9(3)). (≈USD 174 k)
- Fees
- Instruction fee, investment firm authorization (point VII.1)EUR 50,000; EUR 15,000 to extend to further services or statusesAnnual flat fee, investment firm, per investment service (point VII.2)Per service, Class 2 / Class 3 firm: investment advice EUR 24,750 / 16,500; reception and transmission EUR 37,125 / 24,750; execution EUR 41,250 / 27,500; portfolio management EUR 66,000 / 44,000; placement without firm commitment EUR 115,500 / 77,000; own-account dealing and underwriting EUR 123,750 (Class 2); MTF or OTF operation EUR 74,250 (Class 2)
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Retail CFD sales are subject to the ESMA-derived national product intervention measures: leverage caps of 30:1 (major FX) down to 2:1 (crypto), 50% margin close-out, negative balance protection and standardized risk warnings. This tier fits an agency (STP/no-dealing-desk) broker that holds client money. Under the EU DLT Pilot Regime, a DLT MTF is also operated under this kind of license. CSSF requires a central administration and registered office in Luxembourg, at least two persons for day-to-day management, and an approved auditor (réviseur d'entreprises agréé). The CSSF page quotes the EUR 75,000 and EUR 150,000 tiers directly. The EUR 750,000 tier for dealing on own account follows IFD Art. 9(1), and we did not confirm the LFS article.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageECN & DMA VenueWealth Management FirmMulti-Family OfficeTokenization Platform
- Reading
- Read in the rulebook
- Sources
04Investment firm (dealing on own account)Investment firm (PSF), Articles 24-1 to 24-9 LFS - initial capital EUR 750,000USD 870 kMinimum capital
- Permits
- Dealing on own account and/or underwriting or placing on a firm commitment basis (and operating an OTF where the firm deals on own account), together with the agency services.
- Minimum capital
- EUR 750,000 initial capital (LFS; IFD Art. 9(1)). (≈USD 870 k)
- Fees
- Instruction fee, investment firm authorization (point VII.1)EUR 50,000; EUR 15,000 to extend to further services or statusesAnnual flat fee, investment firm, per investment service (point VII.2)Per service, Class 2 / Class 3 firm: investment advice EUR 24,750 / 16,500; reception and transmission EUR 37,125 / 24,750; execution EUR 41,250 / 27,500; portfolio management EUR 66,000 / 44,000; placement without firm commitment EUR 115,500 / 77,000; own-account dealing and underwriting EUR 123,750 (Class 2); MTF or OTF operation EUR 74,250 (Class 2)
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Retail CFD sales are subject to the ESMA-derived national product intervention measures: leverage caps of 30:1 (major FX) down to 2:1 (crypto), 50% margin close-out, negative balance protection and standardized risk warnings. Required for market-making (B-book) FX/CFD brokers, liquidity redistribution as principal, and matched-principal prime-of-prime models. Firms with consolidated assets of EUR 30bn or more that deal on own account or underwrite must instead be authorized as credit institutions (CRR Art. 4(1)(1)(b)). Pure own-account traders that do not deal for clients, make markets or use high-frequency trading can rely on the MiFID II Art. 2(1)(d) exemption. Commodity-derivative traders can rely on the ancillary-activity exemption (Art. 2(1)(j)) if they stay within its tests. CSSF requires a central administration and registered office in Luxembourg, at least two persons for day-to-day management, and an approved auditor (réviseur d'entreprises agréé). The CSSF page quotes the EUR 75,000 and EUR 150,000 tiers directly. The EUR 750,000 tier for dealing on own account follows IFD Art. 9(1), and we did not confirm the LFS article.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskMulti-Asset BrokerageInvestment BankTreasury & Liquidity DeskCommodities Trading House
- Reading
- From a secondary source
- Sources
05Tied agent (white-label under another firm's license)Tied agent of a Luxembourg investment firm or bank (LFS)No fixed figureMinimum capital
- Permits
- Promotes investment services, receives and transmits orders, places instruments and gives advice on behalf of a single authorized investment firm or bank. The agent operates under that principal's license.
- Minimum capital
- None. The tied agent holds no license and has no capital requirement; the principal firm is fully and unconditionally responsible for it (MiFID II Art. 29).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Must be entered on the public register of tied agents. It may not hold client money or instruments and may act for only one principal. Tied agents are recorded on a public register.
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
06Family office PSFFamily office (specialized PSF, Article 28-6 LFS; Law of 21 December 2012 on family office activity)USD 58 kMinimum capital
- Permits
- Professional family office activity: advice and services of a property, financial or non-financial nature to families or family wealth entities, without providing MiFID investment services.
- Minimum capital
- EUR 50,000 minimum share capital (Article 28-6 LFS, per Mondaq summary). The CSSF states that specialized PSF capital ranges from EUR 50,000 to EUR 730,000 depending on the category. (≈USD 58 k)
- Fees
- Instruction fee, specialized PSF (point VIII.1)EUR 30,000; EUR 12,500 to add a statusAnnual flat fee, specialized PSF (point VIII.2)EUR 25,000 (family office); EUR 90,000 (lending professionals)
- Clients
- Retail permitted
- Conditions
- Since the 2012 law, family office activity in Luxembourg may only be carried out by a listed regulated professional (bank, investment firm, lawyer, auditor, chartered accountant and so on) or an authorized family office PSF. Discretionary management or investment advice needs an investment firm license as well. Whether an in-house office serving one family falls in scope depends on its structure.
- Systems
- Multi-Family Office
- Reading
- From a secondary source
- Sources
07Lending PSFProfessional performing lending operations (specialized PSF, Article 28-4 LFS)USD 58 kMinimum capital
- Permits
- Granting loans to the public for own account on a professional basis (including financial leasing and factoring), without taking deposits.
- Minimum capital
- Not confirmed. The CSSF states that specialized PSF minimum capital is between EUR 50,000 and EUR 730,000 depending on the category, and the House could not confirm the Article 28-4 figure. (≈USD 58 k)
- Fees
- Instruction fee, specialized PSF (point VIII.1)EUR 30,000; EUR 12,500 to add a statusAnnual flat fee, specialized PSF (point VIII.2)EUR 25,000 (family office); EUR 90,000 (lending professionals)
- Clients
- Retail permitted
- Conditions
- Relevant for a trade finance house or direct lender operating outside a fund. Securitization vehicles and AIFs can originate or acquire loans without this license.
- Systems
- Trade Finance House
- Reading
- To be confirmed
- Sources
08UCITS management companyManagement company - Chapter 15 of the Law of 17 December 2010 (UCI Law)USD 145 kMinimum capital
- Permits
- Collective management of UCITS (and, where authorized, AIFs). May add discretionary portfolio management, investment advice and safekeeping as non-core services (UCITS Directive Art. 6(3)).
- Minimum capital
- EUR 125,000 initial capital, plus 0.02% of assets under management above EUR 250 million, capped at EUR 10 million in total; own funds never below one quarter of prior-year fixed overheads (UCI Law 2010, Chapter 15; UCITS Directive Art. 7(1)(a)). (≈USD 145 k)
- Fees
- Instruction fee, Chapter 15 management company or authorized AIFM (point V.A.1)EUR 18,000Annual flat fee, Chapter 15 management company or authorized AIFM (point V.C)EUR 42,000 (with base strategy); EUR 3,000 per extra strategy
- Clients
- Retail permitted
- Conditions
- Needs at least two conducting persons, local infrastructure, and separate risk, compliance and internal audit functions. A self-managed UCITS investment company needs EUR 300,000 instead. The EU UCITS passport covers both cross-border management and distribution. The CSSF page states 'a share capital of at least 125,000 euros', fully paid in cash. The company must be authorized before it is incorporated. Requires at least two dirigeants and separate compliance, risk and internal audit holders. A Part I UCITS fund must reach EUR 1.25 million of net assets within 6 months.
- Systems
- Mutual Fund & UCITSETF PlatformFund Management CompanyAsset Management Company
- Reading
- Read in the rulebook
- Sources
09Authorized AIFMAuthorized AIFM (Law of 12 July 2013 on AIFMs)USD 145 kMinimum capital
- Permits
- Portfolio management and risk management of alternative investment funds (hedge, private equity, venture, private credit, real estate, digital-asset funds). May also be licensed for discretionary mandates and advice (AIFMD Art. 6(4)).
- Minimum capital
- EUR 125,000 initial capital for an external AIFM, or EUR 300,000 for an internally managed AIF, plus 0.02% of AUM above EUR 250 million, capped at EUR 10 million. Also requires professional indemnity insurance or extra own funds of 0.01% of AUM (AIFM Law 2013; AIFMD Art. 9; Delegated Reg. 231/2013 Art. 14). (≈USD 145 k)
- Fees
- Instruction fee, Chapter 15 management company or authorized AIFM (point V.A.1)EUR 18,000Annual flat fee, Chapter 15 management company or authorized AIFM (point V.C)EUR 42,000 (with base strategy); EUR 3,000 per extra strategy
- Clients
- Retail, with conditions
- Conditions
- The AIFMD passport covers marketing to professional investors only; retail marketing depends on national fund rules or ELTIF status. Needs a depositary for each AIF, plus a valuation function and liquidity management. AIFMD II (Directive (EU) 2024/927) applies from 16 April 2026. It adds loan-origination rules for private credit funds (leverage caps, 5% risk retention, a concentration limit) and mandatory liquidity management tools. Luxembourg AIFMs can manage RAIFs, which are not CSSF-supervised but must have an authorized AIFM, as well as SIFs, SICARs and Part II UCIs. A Chapter 16 management company is a separate route for non-UCITS managers.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundQuantitative Trading DeskPension & Endowment Manager
- Reading
- From a secondary source
- Sources
10Registered AIFMRegistered AIFM (sub-threshold, Article 3 of the Law of 12 July 2013)No fixed figureMinimum capital
- Permits
- Managing AIFs below the AIFMD thresholds under registration with the CSSF.
- Minimum capital
- No initial capital requirement under the AIFM Law for registered AIFMs.
- Fees
- Registration fee, registered AIFM (point V.A.4)EUR 7,200Annual flat fee, registered AIFM (point V.C)EUR 10,000
- Clients
- Professional only
- Conditions
- No AIFMD passport. Commonly used for SIF or SICAR structures and family or club vehicles. Cannot manage a RAIF, which requires an authorized AIFM.
- Systems
- Private Equity FirmVenture Capital FirmReal Estate Investment VehiclePrivate Credit FundHedge Fund
- Reading
- From a secondary source
- Sources
11SIF (regulated fund)Specialised investment fund (SIF), Law of 13 February 2007USD 1.45 mMinimum capital
- Permits
- A CSSF-authorized, lightly regulated multi-strategy fund reserved for well-informed investors (professional investors, or others investing at least EUR 125,000 or with a bank or investment firm assessment).
- Minimum capital
- Subscribed capital plus share premium (net assets) of at least EUR 1.25 million within 12 months of authorization (SIF Law 2007). (≈USD 1.45 m)
- Fees
- Instruction fee, SIF or SICAR (point IV.A.1)EUR 4,650 (single fund); EUR 9,250 (multi-compartment); EUR 17,500 (internally managed SIF-AIF or SICAR-AIF)Annual fee, SIF or SICAR (point IV.A.3)EUR 4,650 (single fund); multi-compartment EUR 9,250 (1-5), 17,500 (6-20), 27,750 (21-50), 40,500 (over 50 compartments)
- Clients
- Professional only
- Conditions
- A product authorization: the fund must be managed by an authorized or registered AIFM (if it is an AIF). Since the RAIF was introduced in 2016, many new private funds use the RAIF instead to avoid CSSF product approval.
- Systems
- Hedge FundPrivate Equity FirmReal Estate Investment VehiclePrivate Credit FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
12SICAR (venture/PE vehicle)Investment company in risk capital (SICAR), Law of 15 June 2004USD 1.16 mMinimum capital
- Permits
- A CSSF-supervised vehicle that invests in risk capital (private equity and venture capital) for well-informed investors.
- Minimum capital
- Subscribed capital of at least EUR 1 million within 12 months of authorization (SICAR Law 2004). (≈USD 1.16 m)
- Fees
- Instruction fee, SIF or SICAR (point IV.A.1)EUR 4,650 (single fund); EUR 9,250 (multi-compartment); EUR 17,500 (internally managed SIF-AIF or SICAR-AIF)Annual fee, SIF or SICAR (point IV.A.3)EUR 4,650 (single fund); multi-compartment EUR 9,250 (1-5), 17,500 (6-20), 27,750 (21-50), 40,500 (over 50 compartments)
- Clients
- Professional only
- Conditions
- Must invest in risk capital only. It has a specific tax treatment, and its manager must be an AIFM where the SICAR is an AIF.
- Systems
- Private Equity FirmVenture Capital Firm
- Reading
- From a secondary source
- Sources
13Securitization vehicle (CSSF-authorized)Authorized securitization undertaking (Law of 22 March 2004 on securitization)No fixed figureMinimum capital
- Permits
- A securitization vehicle (company or fund, with compartments) that issues securities to the public on a continuous basis. Widely used for structured notes, repackaging and tokenized debt.
- Minimum capital
- Not confirmed. The House could not find a minimum capital set by the Securitization Law specifically for authorized undertakings beyond company-law minimums.
- Fees
- Instruction fee, authorized securitization undertaking (point XV.1)EUR 5,775 (single); EUR 9,250 (multi-compartment)Annual fee, authorized securitization undertaking (point XV.2)EUR 8,660 (single); multi-compartment on the SIF/SICAR tiers
- Clients
- Retail permitted
- Conditions
- CSSF authorization is needed only if the vehicle issues to the public on a continuous basis (more than three issues a year, per CSSF guidance). Otherwise it is unregulated. Prospectus approval is separate.
- Systems
- Structured Products Issuer
- Reading
- To be confirmed
- Sources
14Payment institution (money remittance)Payment institution - money remittance only (Law of 10 November 2009 on payment services)USD 23 kMinimum capital
- Permits
- Money remittance only: transferring funds from a payer to a payee without payment accounts (PSD2 Annex I(6)).
- Minimum capital
- EUR 20,000 initial capital (Law of 10 November 2009 on payment services; PSD2 Art. 7(a)). (≈USD 23 k)
- Fees
- Instruction fee, payment institution or e-money institution (points X.1 and XII.1)EUR 30,000; extension EUR 8,000 (PI) or EUR 6,000 (EMI)Annual flat fee, payment institution or e-money institution (points X.2-X.3, XII.2-XII.3)EUR 30,000 (payment volume up to EUR 1bn); EUR 40,000 (above EUR 1bn); EUR 25,000 for firms authorized three years or less with volume up to EUR 1bn
- Clients
- Retail permitted
- Conditions
- Must safeguard client funds by segregation or insurance/guarantee and maintain ongoing own funds under PSD2 Art. 9. Currency exchange alone (bureau de change) is not a PSD2 payment service. Statutory decision within 3 months (PSD2 Art. 12). Luxembourg is a hub for EU e-money and payments groups after Brexit.
- Systems
- Money Services Business
- Reading
- From a secondary source
- Sources
15Payment institution (payment initiation)Payment institution - payment initiation services only (Law of 10 November 2009 on payment services)USD 58 kMinimum capital
- Permits
- Payment initiation services only (PSD2 Annex I(7)).
- Minimum capital
- EUR 50,000 initial capital (Law of 10 November 2009 on payment services; PSD2 Art. 7(b)), plus professional indemnity insurance. (≈USD 58 k)
- Fees
- Instruction fee, payment institution or e-money institution (points X.1 and XII.1)EUR 30,000; extension EUR 8,000 (PI) or EUR 6,000 (EMI)Annual flat fee, payment institution or e-money institution (points X.2-X.3, XII.2-XII.3)EUR 30,000 (payment volume up to EUR 1bn); EUR 40,000 (above EUR 1bn); EUR 25,000 for firms authorized three years or less with volume up to EUR 1bn
- Clients
- Retail permitted
- Conditions
- Does not hold client funds. Account information services alone need registration and professional indemnity insurance, not initial capital. Statutory decision within 3 months (PSD2 Art. 12). Luxembourg is a hub for EU e-money and payments groups after Brexit.
- Systems
- Payment Service Provider
- Reading
- From a secondary source
- Sources
16Payment institution (full)Payment institution - full scope (Law of 10 November 2009 on payment services)USD 145 kMinimum capital
- Permits
- Payment accounts, cash placement and withdrawal, execution of payment transactions (including credit transfers and direct debits), issuing payment instruments and acquiring payment transactions (PSD2 Annex I(1)-(5)), plus remittance and payment initiation.
- Minimum capital
- EUR 125,000 initial capital (Law of 10 November 2009 on payment services; PSD2 Art. 7(c)). (≈USD 145 k)
- Fees
- Instruction fee, payment institution or e-money institution (points X.1 and XII.1)EUR 30,000; extension EUR 8,000 (PI) or EUR 6,000 (EMI)Annual flat fee, payment institution or e-money institution (points X.2-X.3, XII.2-XII.3)EUR 30,000 (payment volume up to EUR 1bn); EUR 40,000 (above EUR 1bn); EUR 25,000 for firms authorized three years or less with volume up to EUR 1bn
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are calculated under PSD2 Art. 9 (Method A/B/C). May grant credit only if it is ancillary and short-term (12 months or less). Cannot issue e-money. Can use agents and distributors and passport across the EEA. Statutory decision within 3 months (PSD2 Art. 12). Luxembourg is a hub for EU e-money and payments groups after Brexit.
- Systems
- Payment Service ProviderMerchant AcquiringCard Issuing ProgramMoney Services Business
- Reading
- From a secondary source
- Sources
17E-money institutionElectronic money institution (Law of 10 November 2009 on payment services)USD 406 kMinimum capital
- Permits
- Issuing electronic money and providing all payment services. Under MiCA (Art. 48), an EMI may also issue e-money tokens (EMTs, fiat-referenced stablecoins).
- Minimum capital
- EUR 350,000 initial capital (Law of 10 November 2009 on payment services; EMD2 Art. 4). Ongoing own funds are at least 2% of average outstanding e-money (Method D). (≈USD 406 k)
- Fees
- Instruction fee, payment institution or e-money institution (points X.1 and XII.1)EUR 30,000; extension EUR 8,000 (PI) or EUR 6,000 (EMI)Annual flat fee, payment institution or e-money institution (points X.2-X.3, XII.2-XII.3)EUR 30,000 (payment volume up to EUR 1bn); EUR 40,000 (above EUR 1bn); EUR 25,000 for firms authorized three years or less with volume up to EUR 1bn
- Clients
- Retail permitted
- Conditions
- Must safeguard funds received for e-money. Cannot pay interest on e-money. Can distribute through agents and distributors. Issuing an EMT also requires a MiCA white paper notified to the regulator, reserve and redemption-at-par rules, and extra own funds if the token is designated significant.
- Systems
- Electronic Money InstitutionCard Issuing ProgramPayment Service ProviderStablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
18CASP Class 1MiCA crypto-asset service provider - Class 1USD 58 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice on crypto-assets and portfolio management of crypto-assets (MiCA Art. 3(1)(16)).
- Minimum capital
- EUR 50,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 1). (≈USD 58 k)
- Fees
- Instruction fee, MiCA CASP authorization (point XXXI.D.1)EUR 30,000; EUR 15,000 if already CSSF-authorised under another status; EUR 8,000 to extend servicesAnnual flat fee, MiCA CASP (point XXXI.D.2)EUR 40,000 (EUR 25,000 if already CSSF-authorised); plus EUR 25,000 per crypto-asset trading platform operated and EUR 20,000 if significant
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. The CSSF is the competent authority for MiCA in Luxembourg. Fits an agency-only crypto brokerage or RFQ desk that does not deal as principal or hold client assets. Luxembourg allowed an 18-month grandfathering period for VASPs registered before 30 December 2024, which ended 1 July 2026.
- Systems
- OTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
19CASP Class 2MiCA crypto-asset service provider - Class 2USD 145 kMinimum capital
- Permits
- Class 1 services plus custody and administration of crypto-assets on behalf of clients, and exchange of crypto-assets for funds or for other crypto-assets.
- Minimum capital
- EUR 125,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 2). (≈USD 145 k)
- Fees
- Instruction fee, MiCA CASP authorization (point XXXI.D.1)EUR 30,000; EUR 15,000 if already CSSF-authorised under another status; EUR 8,000 to extend servicesAnnual flat fee, MiCA CASP (point XXXI.D.2)EUR 40,000 (EUR 25,000 if already CSSF-authorised); plus EUR 25,000 per crypto-asset trading platform operated and EUR 20,000 if significant
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. The CSSF is the competent authority for MiCA in Luxembourg. This is the class for a principal OTC desk, a broker-style crypto exchange (the firm is the counterparty) and a custodian or wallet provider. Luxembourg allowed an 18-month grandfathering period for VASPs registered before 30 December 2024, which ended 1 July 2026.
- Systems
- OTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
20CASP Class 3MiCA crypto-asset service provider - Class 3USD 174 kMinimum capital
- Permits
- Class 2 services plus operation of a trading platform for crypto-assets.
- Minimum capital
- EUR 150,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 3). (≈USD 174 k)
- Fees
- Instruction fee, MiCA CASP authorization (point XXXI.D.1)EUR 30,000; EUR 15,000 if already CSSF-authorised under another status; EUR 8,000 to extend servicesAnnual flat fee, MiCA CASP (point XXXI.D.2)EUR 40,000 (EUR 25,000 if already CSSF-authorised); plus EUR 25,000 per crypto-asset trading platform operated and EUR 20,000 if significant
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. The CSSF is the competent authority for MiCA in Luxembourg. Trading platforms must have non-discretionary rules, may not deal on own account on their own platform, and must publish pre- and post-trade data. Luxembourg allowed an 18-month grandfathering period for VASPs registered before 30 December 2024, which ended 1 July 2026.
- Systems
- Digital Asset Exchange
- Reading
- From a secondary source
- Sources
21ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)USD 406 kMinimum capital
- Permits
- Offering to the public, or seeking admission to trading of, asset-referenced tokens (stablecoins referencing a basket of assets, commodities or currencies) in the EU.
- Minimum capital
- Own funds of the highest of EUR 350,000, 2% of the average reserve of assets, or one quarter of prior-year fixed overheads (MiCA Art. 35(1)). (≈USD 406 k)
- Fees
- Instruction fees, ART issuer authorization and white paper (point XXXI.B.1)EUR 30,000 authorization (EUR 15,000 if already CSSF-authorised) plus EUR 10,000 white paper; EUR 2,500 per modified white paperAnnual flat fee, ART issuer (point XXXI.B.2)EUR 40,000 (EUR 25,000 if already CSSF-authorised; EUR 10,000 for credit institutions)
- Clients
- Retail permitted
- Conditions
- Authorized by the CSSF. A credit institution can issue ARTs on notification instead (MiCA Art. 17). Must keep a fully backed, segregated reserve of assets and a redemption right, and cannot pay interest. Significant ARTs move to EBA supervision and need extra own funds. Fiat single-currency stablecoins are EMTs, which require an EMI or bank license.
- Systems
- Stablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
Reach
Full EU/EEA passporting: CRD, MiFID II, UCITS, AIFMD (professional investors), PSD2/EMD2 and MiCA. Registered AIFMs and family office PSFs have no passport.
Passage
Statutory: banks, investment firms and specialized PSF decision within 6 months of a complete file, and in any event within 12 months; silence is deemed refusal (LFS, per CSSF). UCITS ManCo 6 months (UCITS Directive Art. 7(3)). AIFM 3 months, extendable by 3. Payment and e-money institutions 3 months. CASPs 25 + 40 working days (MiCA Art. 63). Bank licenses are granted by the ECB on CSSF proposal.
Licensed elsewhere
ECB: grants bank licenses and supervises significant banks. Commissariat aux Assurances (CAA): insurers, reinsurers (Luxembourg is a large captive reinsurance center) and pension funds under the insurance law. RAIFs: not CSSF-supervised; formed before a notary and supervised through their authorized AIFM. Luxembourg Stock Exchange: operator of a regulated market and the Euro MTF, supervised by the CSSF (Article 27 LFS). Not licensed: sovereign vehicles, mining/validation on own account, physical commodity trading, and unregulated securitization vehicles (non-public or non-continuous issuance). Islamic finance has no separate regime, but Luxembourg funds and securitization vehicles are used for sukuk and Shariah-compliant funds. Pension managers use the AIFM/ManCo licenses or the CSSF-supervised SEPCAV/ASSEP pension vehicles (not listed as a category).
Notes. The Law of 5 May 2026 transposed CRD VI and EMIR 3. Third-country branches of non-EU banks need a Luxembourg branch authorization from 11 January 2027, and contracts before 11 July 2026 are grandfathered. The MiCA grandfathering period for VASPs ended 1 July 2026. AIFMD II applies from 16 April 2026; we did not confirm the status of the Luxembourg implementing law. Luxembourg's 'Blockchain' laws allow securities to be issued and held on DLT. USD conversions use approx. EUR 1 = USD 1.16 and GBP 1 = USD 1.33 (October 2026).
Europe · Ireland
CBI Ireland
Central Bank of Ireland
The Central Bank of Ireland is a single integrated regulator: central bank, prudential supervisor and conduct regulator, under the Central Bank Acts 1942-2023. It authorizes banks (with the ECB), insurers and reinsurers, MiFID investment firms, UCITS and AIF management companies and funds, payment and e-money institutions, crypto-asset service providers under MiCA, credit unions and retail intermediaries. Ireland is a leading EU domicile for ETFs, UCITS and QIAIFs and a major EU base for payment and crypto groups after Brexit. The CBI is known for detailed substance and fitness-and-probity expectations.
#7of 34
Balanced score
79 of 100
79 of 100
Scorecard
Credibility ×35%100Breadth ×15%87Entry threshold ×20%70Speed ×15%17Reach ×15%93
Categories18
Systems covered41 of 47
Typical timeline6–25 monthsmarket practice
Lowest capitalUSD 23 k
IOSCO MMoUA
PassportEU/EEA
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
Application—0 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 8 k–339 k7 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
The CBI's 2026 funding guide shows no application fee. Cost comes through the annual industry funding levy, billed in arrears and set by PRISM impact rating, so a low-impact MiFID firm pays about EUR 29,778 and a bank at least EUR 292,226. Investment firms also contribute to the Investor Compensation Company (ICCL) and banks to the deposit guarantee scheme.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Every year | |||
| Industry funding levy, Irish credit institution (category A1)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. EEA branches (A2/A3) pay a flat EUR 34,600. | Minimum EUR 292,226 plus variable levy: V = [(S + G) x 50%] x C, where S is the share of total assets and G the share of risk exposure≈ USD 339 k | Credit institution (bank license under Section 9 of the Central Bank Act 1971) | Read in the rulebook |
| Industry funding levy, MiFID investment firm (category D, PRISM impact-based)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. The guide's table lists four impact-based amounts without explicit column labels; we read them as High to Low, so the lowest is shown. | EUR 29,778 to EUR 2,343,673 by PRISM impact rating; plus client asset supplementary levy (EUR 6,639 to 476,453) for firms holding client assets and BRRD supplementary levy (EUR 14,821 to 151,184) where applicable≈ USD 35 k | MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000; MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000; MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000 | Read in the rulebook |
| Industry funding levy, fund management company (category E2, PRISM impact-based)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. Same four-level impact table as investment firms; EEA branches pay a flat EUR 18,908. | EUR 18,908 to EUR 1,488,134 by PRISM impact rating≈ USD 22 k | UCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019); Authorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013) | Read in the rulebook |
| Industry funding levy, investment fund (category E1)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. The former 50 sub-fund cap was removed. | Minimum EUR 8,952 per fund; umbrellas with more than one sub-fund also pay EUR 593 per sub-fund, including the first≈ USD 10 k | Qualifying Investor AIF (QIAIF), authorized under the CBI AIF Rulebook | Read in the rulebook |
| Industry funding levy, payment institution (category N)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. E-money institutions also fall in category N, but the guide extract did not show their separate figure. | Minimum EUR 6,625 plus variable levy on the firm's share of total transaction value; 'Ultra High' AML-risk firms also pay a flat EUR 496,875≈ USD 8 k | Payment institution - money remittance only (European Union (Payment Services) Regulations 2018, S.I. 6/2018); Payment institution - payment initiation services only (European Union (Payment Services) Regulations 2018, S.I. 6/2018); Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018) | Read in the rulebook |
| Industry funding levy, MiCA CASP (category Q)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. Pro rata for part-year authorization; VASPs were excluded from the 2025 levy. | EUR 30,000 flat per full year≈ USD 35 k | MiCA crypto-asset service provider - Class 1; MiCA crypto-asset service provider - Class 2; MiCA crypto-asset service provider - Class 3 | Read in the rulebook |
| Industry funding levy, Irish (re)insurance undertaking (category B, PRISM impact-based)Central Bank Act 1942 (Section 32D) Regulations 2026, effective 20 July 2026; the 2026 levy recovers 2025 regulatory costs, invoiced in arrears and payable within 28 days. Pro rata from the date of authorization. Branch and SPRV levies are separate. | EUR 31,626 to EUR 2,239,750 by PRISM impact rating≈ USD 37 k | Insurance or reinsurance undertaking (European Union (Insurance and Reinsurance) Regulations 2015, S.I. 485/2015) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 145 k
Payment institution (money remittance)Payment institution - money remittance only (European Union (Payment Services) Regulations 2018, S.I. 6/2018)
USD 23 k
Payment institution (payment initiation)Payment institution - payment initiation services only (European Union (Payment Services) Regulations 2018, S.I. 6/2018)
USD 58 k
CASP Class 1MiCA crypto-asset service provider - Class 1
USD 58 k
Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000
USD 87 k
UCITS management companyUCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019)
USD 145 k
Authorized AIFMAuthorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013)
USD 145 k
Payment institution (full)Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018)
USD 145 k
CASP Class 2MiCA crypto-asset service provider - Class 2
USD 145 k
Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000
USD 174 k
CASP Class 3MiCA crypto-asset service provider - Class 3
USD 174 k
E-money institutionElectronic money institution (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011)
USD 406 k
ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)
USD 406 k
Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000
USD 870 k
Insurer / reinsurerInsurance or reinsurance undertaking (European Union (Insurance and Reinsurance) Regulations 2015, S.I. 485/2015)
USD 1.51 m
BankCredit institution (bank license under Section 9 of the Central Bank Act 1971)
USD 5.8 m
10k100k1m10m
15 of 18 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
18 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BankCredit institution (bank license under Section 9 of the Central Bank Act 1971)USD 5.8 mMinimum capital
- Permits
- Accepting deposits and granting credit, plus investment, payment and other banking services.
- Minimum capital
- EUR 5 million initial capital (CRD Art. 12, as transposed by the European Union (Capital Requirements) Regulations 2014). (≈USD 5.8 m)
- Fees
- Industry funding levy, Irish credit institution (category A1)Minimum EUR 292,226 plus variable levy: V = [(S + G) x 50%] x C, where S is the share of total assets and G the share of risk exposure
- Clients
- Retail permitted
- Conditions
- The ECB grants the license on CBI proposal. The Individual Accountability Framework (SEAR) applies, along with PCF fitness and probity approvals and a real Irish head office with local senior management. In 2025, the average credit institution authorization took 355 days, and the one approval was the first Irish-domiciled bank authorization since 2019.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructurePrime BrokerageTreasury & Liquidity Desk
- Reading
- From a secondary source
- Sources
02Investment firm (agency, no client money)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 75,000USD 87 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, portfolio management, investment advice, and placing without a firm commitment, where the firm may not hold client money or securities.
- Minimum capital
- EUR 75,000 initial capital (MiFID Regulations 2017 / Investment Firms Regulations 2021; IFD Art. 9(2)). (≈USD 87 k)
- Fees
- Industry funding levy, MiFID investment firm (category D, PRISM impact-based)EUR 29,778 to EUR 2,343,673 by PRISM impact rating; plus client asset supplementary levy (EUR 6,639 to 476,453) for firms holding client assets and BRRD supplementary levy (EUR 14,821 to 151,184) where applicable
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Client money and assets must be held by a bank or custodian, not by the firm. The CBI process runs from a preliminary meeting to a Key Facts Document, then a formal application, with PCF Individual Questionnaires. In 2025 the average time was 245 calendar days. CBI national CFD measures mirror the ESMA restrictions.
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family OfficeAsset Management CompanyPension & Endowment Manager
- Reading
- From a secondary source
- Sources
03Investment firm (holds client money/assets or operates MTF)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 150,000USD 174 kMinimum capital
- Permits
- The same agency services where the firm holds client money or financial instruments, plus operating a multilateral trading facility (MTF) or an OTF without own-account dealing.
- Minimum capital
- EUR 150,000 initial capital (MiFID Regulations 2017 / Investment Firms Regulations 2021; IFD Art. 9(3)). (≈USD 174 k)
- Fees
- Industry funding levy, MiFID investment firm (category D, PRISM impact-based)EUR 29,778 to EUR 2,343,673 by PRISM impact rating; plus client asset supplementary levy (EUR 6,639 to 476,453) for firms holding client assets and BRRD supplementary levy (EUR 14,821 to 151,184) where applicable
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Retail CFD sales are subject to the ESMA-derived national product intervention measures: leverage caps of 30:1 (major FX) down to 2:1 (crypto), 50% margin close-out, negative balance protection and standardized risk warnings. This tier fits an agency (STP/no-dealing-desk) broker that holds client money. Under the EU DLT Pilot Regime, a DLT MTF is also operated under this kind of license. The CBI process runs from a preliminary meeting to a Key Facts Document, then a formal application, with PCF Individual Questionnaires. In 2025 the average time was 245 calendar days. CBI national CFD measures mirror the ESMA restrictions.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageECN & DMA VenueWealth Management FirmMulti-Family OfficeTokenization Platform
- Reading
- From a secondary source
- Sources
04Investment firm (dealing on own account)MiFID investment firm (European Union (Markets in Financial Instruments) Regulations 2017) - initial capital EUR 750,000USD 870 kMinimum capital
- Permits
- Dealing on own account and/or underwriting or placing on a firm commitment basis (and operating an OTF where the firm deals on own account), together with the agency services.
- Minimum capital
- EUR 750,000 initial capital (MiFID Regulations 2017 / Investment Firms Regulations 2021; IFD Art. 9(1)). (≈USD 870 k)
- Fees
- Industry funding levy, MiFID investment firm (category D, PRISM impact-based)EUR 29,778 to EUR 2,343,673 by PRISM impact rating; plus client asset supplementary levy (EUR 6,639 to 476,453) for firms holding client assets and BRRD supplementary levy (EUR 14,821 to 151,184) where applicable
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are the highest of the permanent minimum, one quarter of prior-year fixed overheads, and (for non-small firms) the IFR K-factor requirement. Needs at least two people who effectively direct the business, and real local management. Retail CFD sales are subject to the ESMA-derived national product intervention measures: leverage caps of 30:1 (major FX) down to 2:1 (crypto), 50% margin close-out, negative balance protection and standardized risk warnings. Required for market-making (B-book) FX/CFD brokers, liquidity redistribution as principal, and matched-principal prime-of-prime models. Firms with consolidated assets of EUR 30bn or more that deal on own account or underwrite must instead be authorized as credit institutions (CRR Art. 4(1)(1)(b)). Pure own-account traders that do not deal for clients, make markets or use high-frequency trading can rely on the MiFID II Art. 2(1)(d) exemption. Commodity-derivative traders can rely on the ancillary-activity exemption (Art. 2(1)(j)) if they stay within its tests. The CBI process runs from a preliminary meeting to a Key Facts Document, then a formal application, with PCF Individual Questionnaires. In 2025 the average time was 245 calendar days. CBI national CFD measures mirror the ESMA restrictions.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskMulti-Asset BrokerageInvestment BankTreasury & Liquidity DeskCommodities Trading House
- Reading
- From a secondary source
- Sources
05Tied agent (white-label under another firm's license)Tied agent of an Irish MiFID firm or bankNo fixed figureMinimum capital
- Permits
- Promotes investment services, receives and transmits orders, places instruments and gives advice on behalf of a single authorized investment firm or bank. The agent operates under that principal's license.
- Minimum capital
- None. The tied agent holds no license and has no capital requirement; the principal firm is fully and unconditionally responsible for it (MiFID II Art. 29).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Must be entered on the public register of tied agents. It may not hold client money or instruments and may act for only one principal. The CBI keeps the register of tied agents.
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
06UCITS management companyUCITS management company (European Communities (UCITS) Regulations 2011, S.I. 352/2011; CBI UCITS Regulations 2019)USD 145 kMinimum capital
- Permits
- Collective management of UCITS (and, where authorized, AIFs). May add discretionary portfolio management, investment advice and safekeeping as non-core services (UCITS Directive Art. 6(3)).
- Minimum capital
- EUR 125,000 initial capital, plus 0.02% of assets under management above EUR 250 million, capped at EUR 10 million in total; own funds never below one quarter of prior-year fixed overheads (S.I. 352/2011; UCITS Directive Art. 7(1)(a)). (≈USD 145 k)
- Fees
- Industry funding levy, fund management company (category E2, PRISM impact-based)EUR 18,908 to EUR 1,488,134 by PRISM impact rating
- Clients
- Retail permitted
- Conditions
- Needs at least two conducting persons, local infrastructure, and separate risk, compliance and internal audit functions. A self-managed UCITS investment company needs EUR 300,000 instead. The EU UCITS passport covers both cross-border management and distribution. The CBI fund management company framework (CP86) sets designated managerial functions, director residency (at least two Irish-resident directors) and organizational effectiveness expectations. Ireland is the largest European ETF domicile.
- Systems
- Mutual Fund & UCITSETF PlatformFund Management CompanyAsset Management Company
- Reading
- From a secondary source
- Sources
07Authorized AIFMAuthorized AIFM (European Union (Alternative Investment Fund Managers) Regulations 2013, S.I. 257/2013)USD 145 kMinimum capital
- Permits
- Portfolio management and risk management of alternative investment funds (hedge, private equity, venture, private credit, real estate, digital-asset funds). May also be licensed for discretionary mandates and advice (AIFMD Art. 6(4)).
- Minimum capital
- EUR 125,000 initial capital for an external AIFM, or EUR 300,000 for an internally managed AIF, plus 0.02% of AUM above EUR 250 million, capped at EUR 10 million. Also requires professional indemnity insurance or extra own funds of 0.01% of AUM (S.I. 257/2013; AIFMD Art. 9; Delegated Reg. 231/2013 Art. 14). (≈USD 145 k)
- Fees
- Industry funding levy, fund management company (category E2, PRISM impact-based)EUR 18,908 to EUR 1,488,134 by PRISM impact rating
- Clients
- Retail, with conditions
- Conditions
- The AIFMD passport covers marketing to professional investors only; retail marketing depends on national fund rules or ELTIF status. Needs a depositary for each AIF, plus a valuation function and liquidity management. AIFMD II (Directive (EU) 2024/927) applies from 16 April 2026. It adds loan-origination rules for private credit funds (leverage caps, 5% risk retention, a concentration limit) and mandatory liquidity management tools. On authorization the CBI expects capital to cover projected requirements for the first year. The QIAIF is the main Irish AIF; the ILP (Investment Limited Partnership) suits private equity and venture capital, and the L-QIAIF suits loan origination.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundQuantitative Trading DeskPension & Endowment Manager
- Reading
- From a secondary source
- Sources
08Registered AIFMRegistered AIFM (sub-threshold, Regulation 5 of S.I. 257/2013)No fixed figureMinimum capital
- Permits
- Managing AIFs below the AIFMD thresholds under registration with the Central Bank.
- Minimum capital
- No initial capital requirement for registration.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- No AIFMD passport. Can manage certain QIAIFs within CBI AIF Rulebook limits.
- Systems
- Private Equity FirmVenture Capital FirmReal Estate Investment VehiclePrivate Credit Fund
- Reading
- From a secondary source
- Sources
09QIAIF (regulated private fund)Qualifying Investor AIF (QIAIF), authorized under the CBI AIF RulebookNo fixed figureMinimum capital
- Permits
- A CBI-authorized AIF for qualifying (professional or high-minimum) investors, set up as an ICAV, plc, unit trust, CCF or ILP. It can be single-strategy, loan-originating (L-QIAIF), real estate, private equity or hedge.
- Minimum capital
- No fund-level minimum capital. Minimum subscription is EUR 100,000 per investor (AIF Rulebook).
- Fees
- Industry funding levy, investment fund (category E1)Minimum EUR 8,952 per fund; umbrellas with more than one sub-fund also pay EUR 593 per sub-fund, including the first
- Clients
- Professional only
- Conditions
- A product authorization with a 24-hour fast-track approval when the AIFM and depositary are in place and the documents are certified. It must have an authorized (or, for some, registered) AIFM and an Irish depositary. The CBI has historically limited direct crypto exposure in authorized funds; check the current position before using a QIAIF as a digital-asset fund.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment Vehicle
- Reading
- From a secondary source
- Sources
10Payment institution (money remittance)Payment institution - money remittance only (European Union (Payment Services) Regulations 2018, S.I. 6/2018)USD 23 kMinimum capital
- Permits
- Money remittance only: transferring funds from a payer to a payee without payment accounts (PSD2 Annex I(6)).
- Minimum capital
- EUR 20,000 initial capital (European Union (Payment Services) Regulations 2018, S.I. 6/2018; PSD2 Art. 7(a)). (≈USD 23 k)
- Fees
- Industry funding levy, payment institution (category N)Minimum EUR 6,625 plus variable levy on the firm's share of total transaction value; 'Ultra High' AML-risk firms also pay a flat EUR 496,875
- Clients
- Retail permitted
- Conditions
- Must safeguard client funds by segregation or insurance/guarantee and maintain ongoing own funds under PSD2 Art. 9. Currency exchange alone (bureau de change) is not a PSD2 payment service. Statutory decision within 3 months of a complete application, but in 2025 the average PI/EMI authorization took 763 days. The CBI now runs a streamlined PI process for CASPs that need PI authorization for EMT-related services.
- Systems
- Money Services Business
- Reading
- From a secondary source
- Sources
11Payment institution (payment initiation)Payment institution - payment initiation services only (European Union (Payment Services) Regulations 2018, S.I. 6/2018)USD 58 kMinimum capital
- Permits
- Payment initiation services only (PSD2 Annex I(7)).
- Minimum capital
- EUR 50,000 initial capital (European Union (Payment Services) Regulations 2018, S.I. 6/2018; PSD2 Art. 7(b)), plus professional indemnity insurance. (≈USD 58 k)
- Fees
- Industry funding levy, payment institution (category N)Minimum EUR 6,625 plus variable levy on the firm's share of total transaction value; 'Ultra High' AML-risk firms also pay a flat EUR 496,875
- Clients
- Retail permitted
- Conditions
- Does not hold client funds. Account information services alone need registration and professional indemnity insurance, not initial capital. Statutory decision within 3 months of a complete application, but in 2025 the average PI/EMI authorization took 763 days. The CBI now runs a streamlined PI process for CASPs that need PI authorization for EMT-related services.
- Systems
- Payment Service Provider
- Reading
- From a secondary source
- Sources
12Payment institution (full)Payment institution - full scope (European Union (Payment Services) Regulations 2018, S.I. 6/2018)USD 145 kMinimum capital
- Permits
- Payment accounts, cash placement and withdrawal, execution of payment transactions (including credit transfers and direct debits), issuing payment instruments and acquiring payment transactions (PSD2 Annex I(1)-(5)), plus remittance and payment initiation.
- Minimum capital
- EUR 125,000 initial capital (European Union (Payment Services) Regulations 2018, S.I. 6/2018; PSD2 Art. 7(c)). (≈USD 145 k)
- Fees
- Industry funding levy, payment institution (category N)Minimum EUR 6,625 plus variable levy on the firm's share of total transaction value; 'Ultra High' AML-risk firms also pay a flat EUR 496,875
- Clients
- Retail permitted
- Conditions
- Ongoing own funds are calculated under PSD2 Art. 9 (Method A/B/C). May grant credit only if it is ancillary and short-term (12 months or less). Cannot issue e-money. Can use agents and distributors and passport across the EEA. Statutory decision within 3 months of a complete application, but in 2025 the average PI/EMI authorization took 763 days. The CBI now runs a streamlined PI process for CASPs that need PI authorization for EMT-related services.
- Systems
- Payment Service ProviderMerchant AcquiringCard Issuing ProgramMoney Services Business
- Reading
- From a secondary source
- Sources
13E-money institutionElectronic money institution (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011)USD 406 kMinimum capital
- Permits
- Issuing electronic money and providing all payment services. Under MiCA (Art. 48), an EMI may also issue e-money tokens (EMTs, fiat-referenced stablecoins).
- Minimum capital
- EUR 350,000 initial capital (European Communities (Electronic Money) Regulations 2011, S.I. 183/2011; EMD2 Art. 4). Ongoing own funds are at least 2% of average outstanding e-money (Method D). (≈USD 406 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Must safeguard funds received for e-money. Cannot pay interest on e-money. Can distribute through agents and distributors. Issuing an EMT also requires a MiCA white paper notified to the regulator, reserve and redemption-at-par rules, and extra own funds if the token is designated significant.
- Systems
- Electronic Money InstitutionCard Issuing ProgramPayment Service ProviderStablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
14CASP Class 1MiCA crypto-asset service provider - Class 1USD 58 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders on behalf of clients, placing of crypto-assets, transfer services, advice on crypto-assets and portfolio management of crypto-assets (MiCA Art. 3(1)(16)).
- Minimum capital
- EUR 50,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 1). (≈USD 58 k)
- Fees
- Industry funding levy, MiCA CASP (category Q)EUR 30,000 flat per full year
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. The Central Bank of Ireland is the competent authority for MiCA. Fits an agency-only crypto brokerage or RFQ desk that does not deal as principal or hold client assets. Ireland used a 12-month grandfathering period that ended 30 December 2025. In 2025 the CBI received 11 CASP applications and approved 10, averaging 171 days.
- Systems
- OTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
15CASP Class 2MiCA crypto-asset service provider - Class 2USD 145 kMinimum capital
- Permits
- Class 1 services plus custody and administration of crypto-assets on behalf of clients, and exchange of crypto-assets for funds or for other crypto-assets.
- Minimum capital
- EUR 125,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 2). (≈USD 145 k)
- Fees
- Industry funding levy, MiCA CASP (category Q)EUR 30,000 flat per full year
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. The Central Bank of Ireland is the competent authority for MiCA. This is the class for a principal OTC desk, a broker-style crypto exchange (the firm is the counterparty) and a custodian or wallet provider. Ireland used a 12-month grandfathering period that ended 30 December 2025. In 2025 the CBI received 11 CASP applications and approved 10, averaging 171 days.
- Systems
- OTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
16CASP Class 3MiCA crypto-asset service provider - Class 3USD 174 kMinimum capital
- Permits
- Class 2 services plus operation of a trading platform for crypto-assets.
- Minimum capital
- EUR 150,000 minimum own funds (MiCA Art. 67 and Annex IV, Class 3). (≈USD 174 k)
- Fees
- Industry funding levy, MiCA CASP (category Q)EUR 30,000 flat per full year
- Clients
- Retail permitted
- Conditions
- Own funds are the higher of the class minimum and one quarter of prior-year fixed overheads (MiCA Art. 67), held as capital or an insurance policy. Requires a registered office and at least one director resident in the EU, plus place of effective management in the EU. MiCA passport across the EEA. The Central Bank of Ireland is the competent authority for MiCA. Trading platforms must have non-discretionary rules, may not deal on own account on their own platform, and must publish pre- and post-trade data. Ireland used a 12-month grandfathering period that ended 30 December 2025. In 2025 the CBI received 11 CASP applications and approved 10, averaging 171 days.
- Systems
- Digital Asset Exchange
- Reading
- From a secondary source
- Sources
17ART issuerMiCA issuer of asset-referenced tokens (Title III authorization)USD 406 kMinimum capital
- Permits
- Offering to the public, or seeking admission to trading of, asset-referenced tokens (stablecoins referencing a basket of assets, commodities or currencies) in the EU.
- Minimum capital
- Own funds of the highest of EUR 350,000, 2% of the average reserve of assets, or one quarter of prior-year fixed overheads (MiCA Art. 35(1)). (≈USD 406 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Authorized by the Central Bank of Ireland. A credit institution can issue ARTs on notification instead (MiCA Art. 17). Must keep a fully backed, segregated reserve of assets and a redemption right, and cannot pay interest. Significant ARTs move to EBA supervision and need extra own funds. Fiat single-currency stablecoins are EMTs, which require an EMI or bank license.
- Systems
- Stablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
18Insurer / reinsurerInsurance or reinsurance undertaking (European Union (Insurance and Reinsurance) Regulations 2015, S.I. 485/2015)USD 1.51 mMinimum capital
- Permits
- Direct life or non-life insurance, or reinsurance, including captive (re)insurance, under Solvency II.
- Minimum capital
- Solvency II absolute floor of the Minimum Capital Requirement (Directive 2009/138/EC Art. 129(1)(d), revised amounts from 19 October 2022): EUR 2.7 million non-life (EUR 4.0 million if liability, credit or suretyship classes 10-15 are covered), EUR 4.0 million life, EUR 3.9 million reinsurance, EUR 1.3 million captive reinsurance. The Solvency Capital Requirement applies on top. (≈USD 1.51 m)
- Fees
- Industry funding levy, Irish (re)insurance undertaking (category B, PRISM impact-based)EUR 31,626 to EUR 2,239,750 by PRISM impact rating
- Clients
- Retail permitted
- Conditions
- Authorized and supervised by the Central Bank of Ireland. Requires an ORSA, a system of governance with four key functions, and Pillar 3 reporting. The Solvency II review (Directive (EU) 2025/2) applies from 30 January 2027.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
Full EU/EEA passporting: CRD, MiFID II, UCITS, AIFMD (professional investors), Solvency II, PSD2/EMD2 and MiCA. Registered AIFMs have no passport.
Passage
Statutory: MiFID firms 6 months from a complete application (MiFID II Art. 7(3)). PI/EMI 3 months. CASPs 25 + 40 working days (MiCA Art. 63). QIAIF 24-hour fast-track. Actual 2025 averages from the CBI Authorizations and Gatekeeping Report: MiFID 245 days, CASPs 171 days, PI/EMI 763 days, credit institutions 355 days, funds 91 days, (re)insurance undertakings 208 days. The CBI's pre-application (Key Facts Document) stage is lengthy and should be planned for.
Licensed elsewhere
ECB: grants bank licenses and supervises significant banks. Pensions Authority: occupational pension schemes and PRSAs (managers use AIFM, UCITS ManCo or MiFID licenses). Euronext Dublin: regulated market operator, itself authorized by the CBI (a new venue would be an MTF under the MiFID EUR 150,000 tier). Bureaux de change are authorized by the CBI under a separate national regime (Central Bank Act 1997 Part V), not covered here. Not licensed: sovereign vehicles (Ireland's ISIF sits within the NTMA), mining/validation on own account, physical commodity trading, and single-family offices managing only their own family's wealth. Section 110 securitization SPVs used for structured products are not authorized (they only file statistical reports with the CBI), and the CBI approves the prospectus. Commercial lending to corporates is not licensed, though lending to individuals and SMEs can need a retail credit firm authorization. Islamic finance has no separate regime.
Notes. The revised Consumer Protection Code took effect 24 March 2026; it expanded the small-business consumer threshold to EUR 5 million turnover and added rules separating regulated from unregulated activities. The Individual Accountability Framework (SEAR) has applied to banks, insurers and certain investment firms since 1 July 2024. The MiCA grandfathering period ended 30 December 2025. AIFMD II, which applies from 16 April 2026, adds EU loan-origination rules alongside the CBI's L-QIAIF rules; we did not confirm the Irish transposition instrument. CRD VI third-country branch rules apply from 11 January 2027. USD conversions use approx. EUR 1 = USD 1.16 and GBP 1 = USD 1.33 (October 2026).
Europe · Malta
MFSA
Malta Financial Services Authority
Malta's single financial regulator. It licenses investment firms and fund managers under the Investment Services Act, funds, financial institutions (payment and e-money institutions) under the Financial Institutions Act, insurers and cell companies under the Insurance Business Act, and crypto-asset service providers under MiCA. Bank licenses are granted by the ECB under the Single Supervisory Mechanism on the MFSA's proposal. Investment services licenses come in Categories 1A, 1B, 2, 3, 4A and 4B, and capital now follows the EU IFR/IFD bands rather than the category label.
#14of 34
Balanced score
73 of 100
73 of 100
Scorecard
Credibility ×35%65Breadth ×15%87Entry threshold ×20%71Speed ×15%70Reach ×15%82
Categories26
Systems covered41 of 47
Typical timeline3–12 monthsstatutory
Lowest capitalUSD 23 k
IOSCO MMoUA
PassportEU/EEA
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 3 k–41 k11 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 2 k–58 k13 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
MFSA fees were overhauled from 1 January 2025 (eight legal notices of 24 December 2024) and step up every year to 2029, so budget above the 2025 figures quoted here; application fees are non-refundable. Investment firms also contribute to the Investor Compensation Scheme and banks to the Depositor Compensation Scheme; fees for UCITS management companies and AIFMs were not found in this pass.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Investment firm application fee, IFD Art. 9(2) band (Reg. 3(1)(a))Investment Services Act (Fees) Regulations 2024 (LN 370 of 2024), in force 1 January 2025, phase in increases; the 2026 step lies between the two figures and was not verified. Pre-2025 fee was EUR 2,500. The source lists fees by regulation paragraph (Reg. 3(1)(a)-(e)) without naming the license type; the mapping of (a)-(e) to the EUR 75k / 150k / 750k bands, depositary and depositary lite is inferred by matching the pre-2025 MFSA table (CSB Group), whose minimum supervisory fees (EUR 2,000 / 2,750 / 4,500 / 15,000 / 5,000) line up with the 2025 minimums. | EUR 3,500 (2025), stepping up to EUR 5,000 by 2027≈ USD 4 k | Investment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A); Investment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | From a secondary source |
| Investment firm application fee, IFD Art. 9(3) band (Reg. 3(1)(b))LN 370 of 2024, phased; 2026 step not verified. Pre-2025 fee EUR 3,000. The source lists fees by regulation paragraph (Reg. 3(1)(a)-(e)) without naming the license type; the mapping of (a)-(e) to the EUR 75k / 150k / 750k bands, depositary and depositary lite is inferred by matching the pre-2025 MFSA table (CSB Group), whose minimum supervisory fees (EUR 2,000 / 2,750 / 4,500 / 15,000 / 5,000) line up with the 2025 minimums. | EUR 4,000 (2025), stepping up to EUR 6,000 by 2027≈ USD 5 k | Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | From a secondary source |
| Investment firm application fee, IFD Art. 9(1) band (Reg. 3(1)(c))LN 370 of 2024, phased; end year and 2026 step not stated in the source. Pre-2025 fee EUR 5,000. Firms providing complex services fall under Reg. 3(2): EUR 19,000 rising to up to EUR 26,500. The source lists fees by regulation paragraph (Reg. 3(1)(a)-(e)) without naming the license type; the mapping of (a)-(e) to the EUR 75k / 150k / 750k bands, depositary and depositary lite is inferred by matching the pre-2025 MFSA table (CSB Group), whose minimum supervisory fees (EUR 2,000 / 2,750 / 4,500 / 15,000 / 5,000) line up with the 2025 minimums. | EUR 6,500 (2025), rising to EUR 8,000≈ USD 8 k | Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | From a secondary source |
| Depositary and depositary lite application fee (Reg. 3(1)(d) and (e))Lowest figure is the Depositary Lite 2025 fee. Mapping of (d) and (e) to depositaries is inferred (see other MFSA entries); the pre-2025 application fees were EUR 17,000 and EUR 7,500, so treat with caution. | Depositary EUR 11,500 (2025) rising to EUR 19,000 (2027); Depositary Lite EUR 6,000 rising to EUR 7,500≈ USD 7 k | Investment Services Licence: Depositary (legacy Category 4A); Investment Services Licence: Depositary Lite (legacy Category 4B) | To be confirmed |
| Fund application fee, UCITS, retail AIF and licensed AIFPer scheme. Sub-funds: UCITS and retail AIF EUR 1,000 each for the first five, then EUR 600 each; the source gives no separate AIF sub-fund application figure. 2026 step not verified. | Third-party managed EUR 3,750 (2025) rising to EUR 5,250 (2027); self-managed EUR 5,000 rising to EUR 6,500≈ USD 4 k | UCITS Scheme; Retail AIF; Licensed AIF (Professional or Qualifying Investors) | From a secondary source |
| Fund application fee, PIFPer scheme. Sub-funds EUR 750 each for the first five, then EUR 315 each. 2026 step not verified. | Third-party managed EUR 2,250 (2025) rising to EUR 3,750 (2027); self-managed EUR 3,000 rising to EUR 4,500≈ USD 3 k | Professional Investor Fund (PIF) for Qualifying Investors | From a secondary source |
| Credit institution license application feeFrom 2025 under the Banking Act fee regulations of December 2024. Adding activities later costs EUR 26,250; removing activities EUR 1,000. Pre-2025 application fee was EUR 12,500. | EUR 35,000≈ USD 41 k | Credit institution license (Banking Act, Cap. 371) | From a secondary source |
| Financial institution application fee, payment institutionFrom 1 January 2025: EUR 10,000 for one or more Category 1 (traditional) activities and/or one Category 2 activity (payment services); previously EUR 3,500 flat. Adding activities later attracts a 25% reduction. Category 2 = payment services and e-money issuance (First Schedule paras. 4 and 10). | EUR 10,000≈ USD 12 k | Financial Institution license - payment institution; Financial Institution license - traditional activities (First Schedule, other than paras. 4 and 10) | From a secondary source |
| Financial institution application fee, electronic money institutionFrom 1 January 2025, for both Category 2 activities (payment services and e-money issuance), with or without Category 1 activities. Previously EUR 3,500. | EUR 15,000≈ USD 18 k | Financial Institution license - electronic money institution | From a secondary source |
| MiCA CASP application feeMarkets in Crypto-Assets Act (Fees) Regulations (December 2024). The highest applicable class fee applies where several classes are sought. The 50% reduction for VFA license holders applied only to applications up to 1 July 2026 and has lapsed. | Class 1 EUR 10,000; Class 2 EUR 20,000; Class 3 EUR 25,000≈ USD 12 k | MiCA CASP - Class 1; MiCA CASP - Class 2; MiCA CASP - Class 3 | From a secondary source |
| ART white paper submission feeAdditional ARTs EUR 3,000 each; white paper modification EUR 1,000. | EUR 8,000 (EUR 3,000 for a credit institution)≈ USD 9 k | MiCA issuer of asset-referenced tokens (Title III) | From a secondary source |
| Every year | |||
| Annual supervisory fee, IFD Art. 9(2) band (Reg. 4(1)(a))Scales between the minimum and maximum (the pre-2025 regime scaled with revenue). Phased annual increases to 2029 under LN 370 of 2024; 2026 figure not verified. The source lists fees by regulation paragraph (Reg. 3(1)(a)-(e)) without naming the license type; the mapping of (a)-(e) to the EUR 75k / 150k / 750k bands, depositary and depositary lite is inferred by matching the pre-2025 MFSA table (CSB Group), whose minimum supervisory fees (EUR 2,000 / 2,750 / 4,500 / 15,000 / 5,000) line up with the 2025 minimums. | Minimum EUR 3,400 (2025) rising to EUR 6,000 (2029); maximum EUR 16,700 rising to EUR 19,300≈ USD 4 k | Investment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A); Investment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B) | From a secondary source |
| Annual supervisory fee, IFD Art. 9(3) band (Reg. 4(1)(b))Phased to 2029; 2026 figure not verified. The source lists fees by regulation paragraph (Reg. 3(1)(a)-(e)) without naming the license type; the mapping of (a)-(e) to the EUR 75k / 150k / 750k bands, depositary and depositary lite is inferred by matching the pre-2025 MFSA table (CSB Group), whose minimum supervisory fees (EUR 2,000 / 2,750 / 4,500 / 15,000 / 5,000) line up with the 2025 minimums. | Minimum EUR 4,000 (2025) rising to EUR 7,000 (2029); maximum EUR 17,300 rising to EUR 20,300≈ USD 5 k | Investment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm) | From a secondary source |
| Annual supervisory fee, IFD Art. 9(1) band (Reg. 4(1)(c))Phased to 2029; 2026 figure not verified. Firms providing complex services (Reg. 4(4)) pay EUR 20,500 (2025) rising to up to EUR 36,000 (2029). The source lists fees by regulation paragraph (Reg. 3(1)(a)-(e)) without naming the license type; the mapping of (a)-(e) to the EUR 75k / 150k / 750k bands, depositary and depositary lite is inferred by matching the pre-2025 MFSA table (CSB Group), whose minimum supervisory fees (EUR 2,000 / 2,750 / 4,500 / 15,000 / 5,000) line up with the 2025 minimums. | Minimum EUR 6,500 (2025) rising to EUR 11,000 (2029); maximum EUR 19,800 rising to EUR 26,200≈ USD 8 k | Investment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3) | From a secondary source |
| Annual supervisory fee, depositary and depositary lite (Reg. 4(1)(d) and (e))Mapping of (d) and (e) to depositaries inferred; see other MFSA entries. | Depositary: minimum EUR 15,000 (2025) rising to EUR 22,500 (2029), maximum EUR 28,300 rising to EUR 40,200. Depositary Lite: minimum EUR 6,000 rising to EUR 7,500≈ USD 7 k | Investment Services Licence: Depositary (legacy Category 4A); Investment Services Licence: Depositary Lite (legacy Category 4B) | To be confirmed |
| Fund annual supervisory fee, UCITS and retail AIFPhased to 2029 under the 2024 fee regulations; 2026 figure not verified. | Third-party managed EUR 4,000 (2025) rising to EUR 8,500 (2029); self-managed EUR 6,000 rising to EUR 10,500; per sub-fund EUR 650 rising to EUR 800≈ USD 5 k | UCITS Scheme; Retail AIF | From a secondary source |
| Fund annual supervisory fee, licensed AIFPhased to 2029; 2026 figure not verified. | Third-party managed EUR 4,000 (2025) rising to EUR 8,000 (2029); self-managed EUR 6,000 rising to EUR 10,000; per sub-fund EUR 650 rising to EUR 800≈ USD 5 k | Licensed AIF (Professional or Qualifying Investors) | From a secondary source |
| Fund annual supervisory fee, PIFPhased to 2029; 2026 figure not verified. | Third-party managed EUR 3,000 (2025) rising to EUR 6,000 (2029); self-managed EUR 4,000 rising to EUR 7,000; per sub-fund EUR 650 rising to EUR 700≈ USD 4 k | Professional Investor Fund (PIF) for Qualifying Investors | From a secondary source |
| Credit institution annual supervisory feeamount_local is the 2025 minimum. Under the pre-2025 regime the minimum was EUR 25,000 and the maximum EUR 1.2 million (MaltaToday). 2026 rate and minimum lie on the phase-in path and were not verified. | 0.022% of deposits (2025) rising to 0.030% (2029); minimum EUR 50,000 rising to EUR 75,000; maximum EUR 1,700,000≈ USD 58 k | Credit institution license (Banking Act, Cap. 371) | From a secondary source |
| Financial institution annual supervisory fee, traditional activities onlyFrom 1 January 2025; amount_local is the fixed element. Previously 0.02% of total assets with a EUR 2,500 minimum. Payable in two instalments. | EUR 15,000 fixed plus 0.02% of total assets≈ USD 18 k | Financial Institution license - traditional activities (First Schedule, other than paras. 4 and 10) | From a secondary source |
| Financial institution annual supervisory fee, payment institutionFrom 1 January 2025; amount_local is the fixed element. Mondaq (MK Fintech, July 2025) notes the variable calculation base is capped at EUR 250,000. Previously 0.02% of total assets, minimum EUR 2,500. | EUR 25,000 fixed plus the higher of 0.02% of total assets, 0.0003% of payment transaction value or 0.01% of average daily outstanding e-money≈ USD 29 k | Financial Institution license - payment institution | From a secondary source |
| Financial institution annual supervisory fee, electronic money institutionFrom 1 January 2025; amount_local is the fixed element. Previously 0.02% of total assets, minimum EUR 2,500. | EUR 35,000 fixed plus the higher of 0.02% of total assets, or 0.0003% of payment transaction value plus 0.01% of average daily outstanding e-money≈ USD 41 k | Financial Institution license - electronic money institution | From a secondary source |
| MiCA CASP annual supervisory feeamount_local is the Class 1 fixed element; Class 2 EUR 20,000, Class 3 EUR 25,000. No separate minimum stated. Modification to drop some services EUR 1,000. | Class amount (EUR 10,000 / 20,000 / 25,000) plus EUR 2,000 per authorized service plus 0.05% of transaction volume, capped at EUR 250,000≈ USD 12 k | MiCA CASP - Class 1; MiCA CASP - Class 2; MiCA CASP - Class 3 | From a secondary source |
| ART issuer annual supervisory feeamount_local is the minimum. First year pro rata. | 0.01% of average outstanding ARTs over the last six months; minimum EUR 2,000, cap EUR 250,000≈ USD 2 k | MiCA issuer of asset-referenced tokens (Title III) | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 145 k
Payment institutionFinancial Institution license - payment institution
USD 23 k
Crypto-asset service provider (Class 1)MiCA CASP - Class 1
USD 58 k
Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A)
USD 87 k
Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B)
USD 87 k
Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm)
USD 87 k
UCITS management companyInvestment Services Licence Category 2 (UCITS management company)
USD 145 k
Alternative investment fund managerInvestment Services Licence Category 2 (full-scope AIFM)
USD 145 k
Sub-threshold fund managerInvestment Services Licence Category 2 (de minimis AIFM)
USD 145 k
Depositary-liteInvestment Services Licence: Depositary Lite (legacy Category 4B)
USD 145 k
Crypto-asset service provider (Class 2)MiCA CASP - Class 2
USD 145 k
Crypto-asset trading platformMiCA CASP - Class 3
USD 174 k
Electronic money institutionFinancial Institution license - electronic money institution
USD 406 k
ART issuerMiCA issuer of asset-referenced tokens (Title III)
USD 406 k
Depositary / trustee of collective investment schemesInvestment Services Licence: Depositary (legacy Category 4A)
USD 847 k
Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3)
USD 870 k
Reinsurer / captive reinsurerReinsurance undertaking
USD 1.51 m
Non-life insurer or captiveInsurance undertaking - non-life (Insurance Business Act, Cap. 403)
USD 3.13 m
Life insurerInsurance undertaking - life
USD 4.64 m
BankCredit institution license (Banking Act, Cap. 371)
USD 5.8 m
10k100k1m10m
19 of 26 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
26 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Introducing broker / adviserInvestment Services Licence: investment firm in the IFD Art. 9(2) band (legacy Category 1A)USD 87 kMinimum capital
- Permits
- Receiving and transmitting orders, investment advice and/or placing instruments without a firm commitment. The holder may not hold or control client money or assets, and the license excludes managing collective investment schemes.
- Minimum capital
- EUR 75,000 initial capital for firms providing reception and transmission of orders, execution of orders, portfolio management, investment advice or placing without a firm commitment, and not holding or controlling client money or assets (MFSA Investment Services Rules Part A, R9-9.3.1; IFD Art. 9(2)). The pre-IFR figure was EUR 50,000. (≈USD 87 k)
- Fees
- Investment firm application fee, IFD Art. 9(2) band (Reg. 3(1)(a))EUR 3,500 (2025), stepping up to EUR 5,000 by 2027Annual supervisory fee, IFD Art. 9(2) band (Reg. 4(1)(a))Minimum EUR 3,400 (2025) rising to EUR 6,000 (2029); maximum EUR 16,700 rising to EUR 19,300
- Clients
- Retail permitted
- Conditions
- Cannot hold client money or assets, so client orders must go to an authorized broker. Effective management by at least two individuals (dual control, Part BI R1-1.4.3), with derogation possible for single-person firms. Own funds must also cover the IFR fixed overheads requirement (and K-factors for non-Class 3 firms). The MFSA's current rulebooks (Part A v13.00 and Part BI v21.00, both 6 August 2026) no longer use the Category 1A/1B/2/3 labels for investment firms; they apply IFD Art. 9 bands by activity and IFR Classes 1, 1 minus, 2 and 3. The legacy label is kept here because the market still uses it.
- Systems
- Investment Advisory FirmWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
02Adviser / RTO for professional clients onlyInvestment Services Licence: investment firm serving professional clients only, IFD Art. 9(2) band (legacy Category 1B)USD 87 kMinimum capital
- Permits
- Same services as Category 1A (reception and transmission of orders, investment advice, placing without firm commitment) but only for professional clients and/or eligible counterparties. No holding of client money or assets.
- Minimum capital
- EUR 75,000 initial capital, the same IFD Art. 9(2) band as other firms that do not hold client money (MFSA Part A, R9-9.3.1). The MFSA's current initial capital table has no reduced figure for professional-only firms. The pre-IFR Category 1B figures (EUR 20,000 with professional indemnity cover, EUR 50,000 without) no longer appear in the rules. (≈USD 87 k)
- Fees
- Investment firm application fee, IFD Art. 9(2) band (Reg. 3(1)(a))EUR 3,500 (2025), stepping up to EUR 5,000 by 2027Annual supervisory fee, IFD Art. 9(2) band (Reg. 4(1)(a))Minimum EUR 3,400 (2025) rising to EUR 6,000 (2029); maximum EUR 16,700 rising to EUR 19,300
- Clients
- Professional only
- Conditions
- Professional clients and eligible counterparties only; no holding of client money or assets. IFR fixed overheads requirement applies. The MFSA's current rulebooks (Part A v13.00 and Part BI v21.00, both 6 August 2026) no longer use the Category 1A/1B/2/3 labels for investment firms; they apply IFD Art. 9 bands by activity and IFR Classes 1, 1 minus, 2 and 3. The legacy label is kept here because the market still uses it. Older guides quoting EUR 20,000 are out of date.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
03Portfolio manager / agency brokerInvestment Services Licence: investment firm in the IFD Art. 9(3) band (legacy Category 2, MiFID firm)USD 87 kMinimum capital
- Permits
- Any investment service except dealing on own account, underwriting or placing on a firm-commitment basis, and operating a multilateral trading facility. The holder may hold and control client money and assets.
- Minimum capital
- EUR 150,000 initial capital where the firm provides reception and transmission, execution, portfolio management, advice or placing without firm commitment and holds or controls client money or assets (MFSA Part A, R9-9.3.1; Part BI R1-5.1.2; IFD Art. 9(3)). Since the September 2025 amendment, R1-5.1.2 also applies EUR 150,000 to any investment firm outside the IFD Art. 9(1), 9(2) and 9(4) bands, including MTF/OTF operators that do not deal on own account. A firm in this scope that does not hold client money falls in the EUR 75,000 band. Pre-IFR figure was EUR 125,000. (≈USD 87 k)
- Fees
- Investment firm application fee, IFD Art. 9(3) band (Reg. 3(1)(b))EUR 4,000 (2025), stepping up to EUR 6,000 by 2027Annual supervisory fee, IFD Art. 9(3) band (Reg. 4(1)(b))Minimum EUR 4,000 (2025) rising to EUR 7,000 (2029); maximum EUR 17,300 rising to EUR 20,300
- Clients
- Retail permitted
- Conditions
- IFR K-factor and fixed overheads requirements apply on an ongoing basis. Client money and asset safeguarding rules. Dual control and MFSA prior approval of directors and senior managers (Part BI R1-1.4). Retail CFD/FX restrictions apply to anyone distributing CFDs to retail clients (ESMA product intervention as adopted in Malta). The MFSA's current rulebooks (Part A v13.00 and Part BI v21.00, both 6 August 2026) no longer use the Category 1A/1B/2/3 labels for investment firms; they apply IFD Art. 9 bands by activity and IFR Classes 1, 1 minus, 2 and 3. The legacy label is kept here because the market still uses it.
- Systems
- Wealth Management FirmAsset Management CompanyMulti-Family OfficeInstitutional BrokerageInvestment Advisory Firm
- Reading
- Read in the rulebook
- Sources
04UCITS management companyInvestment Services Licence Category 2 (UCITS management company)USD 145 kMinimum capital
- Permits
- Management of UCITS schemes, with optional MiFID top-up services (discretionary portfolio management, advice, safekeeping) as permitted by the UCITS Directive.
- Minimum capital
- EUR 125,000 initial capital (MFSA Part A, R9-9.3.1), plus 0.02% of assets under management above EUR 250 million, capped at EUR 10 million in total (UCITS Directive Art. 7(1)(a), transposed in MFSA Part BII). Own funds must never fall below one quarter of the previous year's fixed overheads. (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Standard license conditions in Part BII. Needs a UCITS depositary in Malta for Maltese UCITS. Can passport management services across the EU.
- Systems
- Fund Management CompanyMutual Fund & UCITSETF PlatformAsset Management Company
- Reading
- Read in the rulebook
- Sources
05Alternative investment fund managerInvestment Services Licence Category 2 (full-scope AIFM)USD 145 kMinimum capital
- Permits
- Management (portfolio and risk management) of alternative investment funds, with optional MiFID top-up services where permitted under AIFMD.
- Minimum capital
- EUR 125,000 initial capital for an external AIFM (MFSA Part A, R9-9.3.1); EUR 300,000 for an internally managed (self-managed) AIF (AIFMD Art. 9(1)). Additional own funds of 0.02% of portfolios above EUR 250 million, capped at EUR 10 million, plus either additional own funds of 0.01% of AIF portfolios or professional indemnity cover (0.7% per claim, 0.9% aggregate) for professional liability (AIFMD Art. 9; MFSA Part BIII). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Retail access only through Retail AIFs. AIFMD II applies from 16 April 2026: liquidity management tool selection for open-ended AIFs, loan-origination rules, and new delegation reporting. Needs a depositary for each AIF.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
06Sub-threshold fund managerInvestment Services Licence Category 2 (de minimis AIFM)USD 145 kMinimum capital
- Permits
- Management of AIFs below the AIFMD thresholds (aggregate AUM up to EUR 100 million, or up to EUR 500 million where unleveraged with no redemption rights for five years).
- Minimum capital
- EUR 125,000 initial capital (MFSA Part A, R9-9.3.1, 'De minimis AIFMs'). Thresholds: AIF assets under management of up to EUR 100 million including leverage, or up to EUR 500 million where the AIFs are unleveraged and have no redemption rights for five years (Part A R4-4.1.3). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- No AIFMD marketing passport unless the manager opts in to the full regime. Must apply for full authorization within 30 days of breaching the thresholds. Typically manages PIFs or professional/qualifying-investor AIFs.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit Fund
- Reading
- Read in the rulebook
- Sources
07Dealer / market maker / MTF operatorInvestment Services Licence: investment firm in the IFD Art. 9(1) band (legacy Category 3)USD 870 kMinimum capital
- Permits
- Any investment service, including dealing on own account, underwriting or placing on a firm-commitment basis and operating a trading facility, with authority to hold and control client money and assets.
- Minimum capital
- EUR 750,000 initial capital for firms dealing on own account or underwriting/placing on a firm-commitment basis (IFD Art. 9(1)), and for OTF operators permitted to deal on own account (IFD Art. 9(4)); MFSA Part A R9-9.3.1 lists EUR 750,000 for firms providing any investment service and holding client money or assets. An MTF/OTF operator that does not deal on own account falls in the EUR 150,000 band (Part BI R1-5.1.2). Pre-IFR figure was EUR 730,000. (≈USD 870 k)
- Fees
- Investment firm application fee, IFD Art. 9(1) band (Reg. 3(1)(c))EUR 6,500 (2025), rising to EUR 8,000Annual supervisory fee, IFD Art. 9(1) band (Reg. 4(1)(c))Minimum EUR 6,500 (2025) rising to EUR 11,000 (2029); maximum EUR 19,800 rising to EUR 26,200
- Clients
- Retail permitted
- Conditions
- Firms subject to EUR 750,000 initial capital must also meet recovery and resolution rules (Part BI R1-1.11.1). CFD and rolling spot FX providers must keep real-time transaction data and records at the Maltese head office (Part BI R1-1.6.15). Retail CFD leverage caps follow ESMA product intervention (30:1 major FX down to 2:1 crypto) as adopted nationally. Large firms may fall under CRR as Class 1 or Class 1 Minus. The MFSA's current rulebooks (Part A v13.00 and Part BI v21.00, both 6 August 2026) no longer use the Category 1A/1B/2/3 labels for investment firms; they apply IFD Art. 9 bands by activity and IFR Classes 1, 1 minus, 2 and 3. The legacy label is kept here because the market still uses it.
- Systems
- Retail BrokerageMulti-Asset BrokeragePrime-of-PrimeECN & DMA VenueProprietary Trading FirmQuantitative Trading DeskInvestment BankTokenization PlatformStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
08Depositary / trustee of collective investment schemesInvestment Services Licence: Depositary (legacy Category 4A)USD 847 kMinimum capital
- Permits
- Acting as trustee or custodian (depositary) of collective investment schemes, including UCITS and full-scope AIFs.
- Minimum capital
- EUR 730,000 minimum initial capital for depositaries (MFSA Part A, R9-9.3.1), i.e. license holders authorized to act as trustee or custodian for all types of collective investment schemes (Part A R4-4.1.5). Eligibility is further limited to the institution types in Part BIV (credit institutions, qualifying investment firms, or Malta subsidiaries of qualifying foreign institutions backed by a guarantor with at least EUR 5 million paid-up capital). (≈USD 847 k)
- Fees
- Depositary and depositary lite application fee (Reg. 3(1)(d) and (e))Depositary EUR 11,500 (2025) rising to EUR 19,000 (2027); Depositary Lite EUR 6,000 rising to EUR 7,500Annual supervisory fee, depositary and depositary lite (Reg. 4(1)(d) and (e))Depositary: minimum EUR 15,000 (2025) rising to EUR 22,500 (2029), maximum EUR 28,300 rising to EUR 40,200. Depositary Lite: minimum EUR 6,000 rising to EUR 7,500
- Clients
- Professional only
- Conditions
- Eligibility is limited to the institution types listed in Part BIV. Own funds must at all times exceed the capital resources requirement (SLC 2.01).
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
09Depositary-liteInvestment Services Licence: Depositary Lite (legacy Category 4B)USD 145 kMinimum capital
- Permits
- Acting as custodian of certain AIFs (no redemption rights for five years and generally not investing in assets that must be held in custody) and of AIFs marketed in Malta by third-country AIFMs.
- Minimum capital
- EUR 125,000 minimum initial capital for Depositary Lite license holders (MFSA Part A, R9-9.3.1), authorized to act as trustee or custodian only for certain AIFs, such as those with no redemption rights for five years (Part A R4-4.1.6). (≈USD 145 k)
- Fees
- Depositary and depositary lite application fee (Reg. 3(1)(d) and (e))Depositary EUR 11,500 (2025) rising to EUR 19,000 (2027); Depositary Lite EUR 6,000 rising to EUR 7,500Annual supervisory fee, depositary and depositary lite (Reg. 4(1)(d) and (e))Depositary: minimum EUR 15,000 (2025) rising to EUR 22,500 (2029), maximum EUR 28,300 rising to EUR 40,200. Depositary Lite: minimum EUR 6,000 rising to EUR 7,500
- Clients
- Professional only
- Conditions
- Limited to private-equity and real-asset type AIFs and third-country AIF situations.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
10UCITS fundUCITS SchemeNo fixed figureMinimum capital
- Permits
- Open-ended retail collective investment scheme authorized under the UCITS Directive, marketable to retail investors across the EU.
- Minimum capital
- No minimum capital set for the fund itself when managed by an authorized management company. A self-managed UCITS investment company needs EUR 300,000 initial capital (UCITS Directive Art. 29).
- Fees
- Fund application fee, UCITS, retail AIF and licensed AIFThird-party managed EUR 3,750 (2025) rising to EUR 5,250 (2027); self-managed EUR 5,000 rising to EUR 6,500Fund annual supervisory fee, UCITS and retail AIFThird-party managed EUR 4,000 (2025) rising to EUR 8,500 (2029); self-managed EUR 6,000 rising to EUR 10,500; per sub-fund EUR 650 rising to EUR 800
- Clients
- Retail permitted
- Conditions
- Needs a Malta-based UCITS depositary and a licensed UCITS management company (or self-management). UCITS diversification, eligible-asset and liquidity rules apply.
- Systems
- Mutual Fund & UCITSETF Platform
- Reading
- From a secondary source
- Sources
11Retail alternative fundRetail AIFNo fixed figureMinimum capital
- Permits
- Alternative investment fund that may be marketed to retail investors in Malta.
- Minimum capital
- No minimum capital for the fund itself; capital sits with the AIFM.
- Fees
- Fund application fee, UCITS, retail AIF and licensed AIFThird-party managed EUR 3,750 (2025) rising to EUR 5,250 (2027); self-managed EUR 5,000 rising to EUR 6,500Fund annual supervisory fee, UCITS and retail AIFThird-party managed EUR 4,000 (2025) rising to EUR 8,500 (2029); self-managed EUR 6,000 rising to EUR 10,500; per sub-fund EUR 650 rising to EUR 800
- Clients
- Retail permitted
- Conditions
- Retail investor protections and investment restrictions apply. Non-UCITS Retail Schemes are being phased out in favor of Retail AIFs.
- Systems
- Mutual Fund & UCITSReal Estate Investment Vehicle
- Reading
- From a secondary source
- Sources
12Licensed alternative fundLicensed AIF (Professional or Qualifying Investors)No fixed figureMinimum capital
- Permits
- MFSA-licensed AIF marketed either to professional investors (as defined in MiFID II) or to qualifying investors with a minimum investment of EUR 100,000.
- Minimum capital
- No minimum capital for the fund itself; capital sits with the AIFM. A self-managed AIF needs EUR 300,000.
- Fees
- Fund application fee, UCITS, retail AIF and licensed AIFThird-party managed EUR 3,750 (2025) rising to EUR 5,250 (2027); self-managed EUR 5,000 rising to EUR 6,500Fund annual supervisory fee, licensed AIFThird-party managed EUR 4,000 (2025) rising to EUR 8,000 (2029); self-managed EUR 6,000 rising to EUR 10,000; per sub-fund EUR 650 rising to EUR 800
- Clients
- Professional only
- Conditions
- Requires an authorized AIFM and a depositary. Can be marketed across the EU through a full-scope AIFM passport.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- From a secondary source
- Sources
13Notified alternative fundNotified AIF (NAIF)No fixed figureMinimum capital
- Permits
- AIF that is not licensed by the MFSA but is set up by notification from a full-scope EU/EEA or Maltese AIFM, which takes full responsibility for compliance. Marketed to professional or qualifying investors.
- Minimum capital
- No minimum capital for the fund itself; capital sits with the full-scope AIFM.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Speed-to-market route: the MFSA does not review the fund, the AIFM does. Not available to de minimis managers. Investor eligibility restrictions apply.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- From a secondary source
- Sources
14Professional investor fundProfessional Investor Fund (PIF) for Qualifying InvestorsNo fixed figureMinimum capital
- Permits
- Non-AIFMD-scope or de minimis-managed fund for qualifying investors. Since 3 June 2016 only the Qualifying Investor PIF accepts new applications; Experienced and Extraordinary Investor PIFs are closed to new applicants. A Notified PIF variant was launched in January 2024.
- Minimum capital
- No minimum capital for the fund. Minimum investment per qualifying investor is EUR 100,000 (raised from EUR 75,000 at the 2016 consolidation).
- Fees
- Fund application fee, PIFThird-party managed EUR 2,250 (2025) rising to EUR 3,750 (2027); self-managed EUR 3,000 rising to EUR 4,500Fund annual supervisory fee, PIFThird-party managed EUR 3,000 (2025) rising to EUR 6,000 (2029); self-managed EUR 4,000 rising to EUR 7,000; per sub-fund EUR 650 rising to EUR 700
- Clients
- Professional only
- Conditions
- Common vehicle for family-office and small-manager funds and for funds investing in virtual financial assets. No EU marketing passport.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundSingle-Family Office
- Reading
- From a secondary source
- Sources
15BankCredit institution license (Banking Act, Cap. 371)USD 5.8 mMinimum capital
- Permits
- Taking deposits or other repayable funds from the public and granting credits for own account, plus the other banking activities listed in the Banking Act.
- Minimum capital
- EUR 5 million minimum initial capital (CRD Art. 12, transposed in Banking Act Art. 7). The MFSA's BR/01 authorization rule does not restate the figure. (≈USD 5.8 m)
- Fees
- Credit institution license application feeEUR 35,000Credit institution annual supervisory fee0.022% of deposits (2025) rising to 0.030% (2029); minimum EUR 50,000 rising to EUR 75,000; maximum EUR 1,700,000
- Clients
- Retail permitted
- Conditions
- ECB takes the authorization decision under the SSM; the MFSA receives and assesses the application jointly. A Statement of Intent and MFSA no-objection come first; documents follow within 40 working days. CRR capital, liquidity and governance rules apply.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HousePrime BrokerageCard Issuing ProgramMerchant AcquiringStablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
16Electronic money institutionFinancial Institution license - electronic money institutionUSD 406 kMinimum capital
- Permits
- Issuing electronic money (First Schedule para. 10 of the Financial Institutions Act) plus payment services and related operational services.
- Minimum capital
- EUR 350,000 initial capital (EMD2 Art. 4). Ongoing own funds at least 2% of average outstanding e-money (Method D). (≈USD 406 k)
- Fees
- Financial institution application fee, electronic money institutionEUR 15,000Financial institution annual supervisory fee, electronic money institutionEUR 35,000 fixed plus the higher of 0.02% of total assets, or 0.0003% of payment transaction value plus 0.01% of average daily outstanding e-money
- Clients
- Retail permitted
- Conditions
- Safeguarding of client funds. EMT (e-money token) issuance under MiCA is open to EMIs and banks. Detailed requirements in Financial Institutions Rulebook Chapter 3 (FIR/03).
- Systems
- Electronic Money InstitutionPayment Service ProviderCard Issuing ProgramMerchant AcquiringStablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
17Payment institutionFinancial Institution license - payment institutionUSD 23 kMinimum capital
- Permits
- Payment services listed in the Second Schedule of the Financial Institutions Act (PSD2 Annex I services).
- Minimum capital
- Initial capital by service (PSD2 Art. 7): EUR 20,000 for money remittance only; EUR 50,000 for payment initiation only; EUR 125,000 for other payment services such as account-based payments, issuing instruments and acquiring. FIR/01 points to FIR/03 for the figures. Account information service providers register instead and need professional indemnity cover. (≈USD 23 k)
- Fees
- Financial institution application fee, payment institutionEUR 10,000Financial institution annual supervisory fee, payment institutionEUR 25,000 fixed plus the higher of 0.02% of total assets, 0.0003% of payment transaction value or 0.01% of average daily outstanding e-money
- Clients
- Retail permitted
- Conditions
- Safeguarding of client funds. Own funds calculated under PSD2 Methods A to C.
- Systems
- Payment Service ProviderMoney Services BusinessMerchant AcquiringCard Issuing Program
- Reading
- From a secondary source
- Sources
18Lending / FX / guarantee companyFinancial Institution license - traditional activities (First Schedule, other than paras. 4 and 10)No fixed figureMinimum capital
- Permits
- Non-bank activities listed in the First Schedule of the Financial Institutions Act, such as lending (including consumer credit and factoring), financial leasing, guarantees and commitments, trading in foreign exchange for own account or clients (bureau de change), and money broking.
- Minimum capital
- No fixed figure. The MFSA sets initial capital case by case according to the risks in the business plan (FIR/01 R1-2.3.10(I)).
- Fees
- Financial institution application fee, payment institutionEUR 10,000Financial institution annual supervisory fee, traditional activities onlyEUR 15,000 fixed plus 0.02% of total assets
- Clients
- Retail, with conditions
- Conditions
- Cannot take deposits from the public. Retail lending also triggers consumer credit rules.
- Systems
- Trade Finance HouseMoney Services Business
- Reading
- Read in the rulebook
- Sources
19Crypto-asset service provider (Class 1)MiCA CASP - Class 1USD 58 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders, placing of crypto-assets, transfer services, advice and portfolio management on crypto-assets.
- Minimum capital
- EUR 50,000 minimum permanent capital, or one quarter of prior-year fixed overheads if higher (MiCA Art. 67 and Annex IV). (≈USD 58 k)
- Fees
- MiCA CASP application feeClass 1 EUR 10,000; Class 2 EUR 20,000; Class 3 EUR 25,000MiCA CASP annual supervisory feeClass amount (EUR 10,000 / 20,000 / 25,000) plus EUR 2,000 per authorized service plus 0.05% of transaction volume, capped at EUR 250,000
- Clients
- Retail permitted
- Conditions
- Registered office and effective management in the EU, at least one EU-resident director. No custody or exchange against funds at this class.
- Systems
- OTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
20Crypto-asset service provider (Class 2)MiCA CASP - Class 2USD 145 kMinimum capital
- Permits
- Class 1 services plus custody and administration of crypto-assets on behalf of clients and exchange of crypto-assets for funds or other crypto-assets.
- Minimum capital
- EUR 125,000 minimum permanent capital, or one quarter of prior-year fixed overheads if higher (MiCA Art. 67 and Annex IV). (≈USD 145 k)
- Fees
- MiCA CASP application feeClass 1 EUR 10,000; Class 2 EUR 20,000; Class 3 EUR 25,000MiCA CASP annual supervisory feeClass amount (EUR 10,000 / 20,000 / 25,000) plus EUR 2,000 per authorized service plus 0.05% of transaction volume, capped at EUR 250,000
- Clients
- Retail permitted
- Conditions
- Client crypto-asset segregation and custody policy (MiCA Art. 75). Outsourcing custody to non-authorized entities is prohibited.
- Systems
- OTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
21Crypto-asset trading platformMiCA CASP - Class 3USD 174 kMinimum capital
- Permits
- Class 2 services plus operating a trading platform for crypto-assets.
- Minimum capital
- EUR 150,000 minimum permanent capital, or one quarter of prior-year fixed overheads if higher (MiCA Art. 67 and Annex IV). (≈USD 174 k)
- Fees
- MiCA CASP application feeClass 1 EUR 10,000; Class 2 EUR 20,000; Class 3 EUR 25,000MiCA CASP annual supervisory feeClass amount (EUR 10,000 / 20,000 / 25,000) plus EUR 2,000 per authorized service plus 0.05% of transaction volume, capped at EUR 250,000
- Clients
- Retail permitted
- Conditions
- Operating rules, market abuse surveillance and pre/post-trade transparency (MiCA Art. 76).
- Systems
- Digital Asset ExchangeCustody & Wallet InfrastructureOTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
22ART issuerMiCA issuer of asset-referenced tokens (Title III)USD 406 kMinimum capital
- Permits
- Offering to the public or seeking admission to trading of asset-referenced tokens.
- Minimum capital
- Own funds of the highest of EUR 350,000, 2% of the average reserve of assets, or one quarter of prior-year fixed overheads (MiCA Art. 35). (≈USD 406 k)
- Fees
- ART white paper submission feeEUR 8,000 (EUR 3,000 for a credit institution)ART issuer annual supervisory fee0.01% of average outstanding ARTs over the last six months; minimum EUR 2,000, cap EUR 250,000
- Clients
- Retail permitted
- Conditions
- Reserve of assets, custody and recovery plan requirements. E-money tokens can only be issued by banks or EMIs, not under this authorization.
- Systems
- Stablecoin Issuance StructureTokenization Platform
- Reading
- From a secondary source
- Sources
23Non-life insurer or captiveInsurance undertaking - non-life (Insurance Business Act, Cap. 403)USD 3.13 mMinimum capital
- Permits
- Direct non-life insurance business, including affiliated (captive) insurance of a group's own risks.
- Minimum capital
- Solvency II absolute floor of the Minimum Capital Requirement: EUR 2.7 million, or EUR 4.0 million where classes 10 to 15 (liability, credit, suretyship) are written; revised amounts effective 19 October 2022 (Solvency II Art. 129(1)(d)). The SCR is usually higher. (≈USD 3.13 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Full Solvency II Pillars 1 to 3, applied proportionately to captives. Solvency II review amendments (Directive (EU) 2025/2) are due to apply from January 2027.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
24Life insurerInsurance undertaking - lifeUSD 4.64 mMinimum capital
- Permits
- Direct long-term (life) insurance business.
- Minimum capital
- Solvency II absolute MCR floor of EUR 4.0 million (revised 19 October 2022). (≈USD 4.64 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Full Solvency II regime.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
25Reinsurer / captive reinsurerReinsurance undertakingUSD 1.51 mMinimum capital
- Permits
- Reinsurance business only.
- Minimum capital
- Solvency II absolute MCR floor of EUR 3.9 million for reinsurers and EUR 1.3 million for captive reinsurers (revised 19 October 2022). (≈USD 1.51 m)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Captive reinsurance status requires the reinsurer to cover only risks of its own group.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
26Insurance cell companyProtected Cell Company / Incorporated Cell Company (insurance)No fixed figureMinimum capital
- Permits
- A PCC (or ICC) authorized under the Insurance Business Act whose cells write insurance or reinsurance for cell owners, often as rent-a-captive. Each incorporated cell in an ICC needs its own authorization.
- Minimum capital
- Not a single figure. The core and cells together must meet Solvency II MCR/SCR; since 2024 amendments, a cell carrying on affiliated insurance can keep a non-recourse clause only if it holds eligible basic own funds covering its SCR, with that SCR not less than the MCR.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- MFSA prior approval is required before any cell is created. Malta is the only EU member state with a PCC insurance regime.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- To be confirmed
- Sources
Reach
Full EU/EEA passporting for MiFID investment firms, credit institutions (CRD), payment and e-money institutions (PSD2/EMD2), UCITS management companies and UCITS, full-scope AIFMs and their AIFs, MiCA CASPs and token issuers, and Solvency II insurers. De minimis AIFMs and PIFs have no marketing passport.
Passage
Investment services license: decision within 6 months of a complete application (MiFID II Art. 7(3), statutory). Banks: 6 months from a complete application, 12 months at most, with the ECB taking the final decision (MFSA Banking Rule BR/01, statutory). Payment and e-money institutions: 3 months (PSD2 Art. 12, statutory). MiCA CASPs: 25 working days for completeness plus 40 working days for assessment (MiCA Arts. 62-63, statutory). Full-scope AIFM: 3 months, extendable by 3 (AIFMD Art. 8(5)); UCITS management company: 6 months (UCITS Directive Art. 7(3)). In practice, the pre-application and fitness-and-propriety stages add several months (market practice).
Licensed elsewhere
Bank licenses are decided by the ECB (SSM) with the MFSA. AML/CFT supervision sits with the FIAU. No separate money-services regime exists: remittance is a payment service (PI license). Not licensed by any Maltese regulator: sovereign investment vehicles, mining and validation, physical commodity trading (commodity derivatives fall under MiFID Category 3), single-family offices managing only family wealth, and Islamic finance as such (Sharia-compliant products use the ordinary fund, bank or insurance licenses). Pension schemes and retirement scheme administrators are licensed by the MFSA under the Retirement Pensions Act, which is outside the categories listed here.
Notes. MiCA transition in Malta ended 30 June 2026; from 1 July 2026 operating VASPs without a CASP license must wind down (MFSA/FIAU letter of 25 June 2026). The MFSA's minimum initial capital table is in Investment Services Rules Part A, R9-9.3.1 (v13.00, 6 August 2026): EUR 75,000 / 150,000 / 750,000 for investment firms by IFD Art. 9 band, EUR 125,000 for AIFMs, de minimis AIFMs and UCITS management companies, EUR 730,000 for depositaries and EUR 125,000 for Depositary Lite. September 2025 amendments (Act XXIX of 2025, L.N. 152-157 of 2025) extended Part BI R1-5.1.2 so that EUR 150,000 applies to any investment firm outside the IFD 9(1), 9(2) and 9(4) bands. The legacy Category 1A/1B/2/3 labels were dropped from the investment-firm rules with IFR/IFD in 2021. AIFMD II applies from 16 April 2026; MFSA updated Part BIII on 30 April 2026. Financial Institutions Rulebook Chapter 1 (FIR/01) was reissued in October 2025. Investment-firm figures commonly quoted online (EUR 50,000 / 20,000 / 125,000 / 730,000 for Categories 1A, 1B, 2, 3) predate IFR/IFD and should not be used; EUR 730,000 and EUR 125,000 remain correct only for depositaries and fund managers.
Europe · Switzerland
FINMA
Swiss Financial Market Supervisory Authority
Switzerland's integrated supervisor for banks, securities firms, fund management companies, managers of collective assets, insurers and financial market infrastructures, under the Banking Act, the Financial Institutions Act (FinIA), the Collective Investment Schemes Act, the Insurance Supervision Act and the Financial Market Infrastructure Act (FinMIA). Portfolio managers and trustees are licensed by FINMA but supervised day to day by FINMA-authorized supervisory organizations (SOs), and para-banking firms (payments, many crypto services) only join an AML self-regulatory organization (SRO). Switzerland is outside the EU, so there is no passport.
#10of 34
Balanced score
75 of 100
75 of 100
Scorecard
Credibility ×35%100Breadth ×15%81Entry threshold ×20%61Speed ×15%60Reach ×15%47
Categories13
Systems covered38 of 47
Typical timeline6–12 monthsmarket practice
Lowest capitalUSD 125 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 2 k–12 k5 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 750–75 k8 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
FINMA fees for licensing are charged by the hour within the ranges shown, and annual supervisory levies are a basic levy plus a share of the sector cost pool, so the bill rises with balance sheet, turnover or assets. Banks also join the esisuisse depositor protection scheme; portfolio managers and trustees pay their supervisory organization and must join an ombudsman.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Licensing decision fee, bank or securities firm (Annex no. 1.1)FINMA Fees and Levies Ordinance (FINMA-GebV, SR 956.122), version in force from 1 March 2024 as read; no 2025-2026 amendment was found. Fees are charged by time spent at CHF 100-500 per hour (Art. 8(4)) within the Annex range. | CHF 10,000 to CHF 100,000, by time spent≈ USD 12 k | Bank license (Banking Act); Securities firm (FinIA) | Read in the rulebook |
| Licensing decision fee, fund management company or manager of collective assets (Annex no. 2.1)FINMA Fees and Levies Ordinance (FINMA-GebV, SR 956.122), version in force from 1 March 2024 as read; no 2025-2026 amendment was found. Fees are charged by time spent at CHF 100-500 per hour (Art. 8(4)) within the Annex range. The same range covers custodian banks. | CHF 4,000 to CHF 50,000, by time spent≈ USD 5 k | Fund management company (FinIA); Manager of collective assets (FinIA) | Read in the rulebook |
| Licensing decision fee, SICAV, limited partnership for collective investment or SICAF (Annex no. 2.1a)FINMA Fees and Levies Ordinance (FINMA-GebV, SR 956.122), version in force from 1 March 2024 as read; no 2025-2026 amendment was found. Fees are charged by time spent at CHF 100-500 per hour (Art. 8(4)) within the Annex range. Applies to company-form schemes; the fee range for approving a contractual fund was not extracted in this pass. | CHF 4,000 to CHF 30,000, by time spent≈ USD 5 k | Swiss collective investment scheme approval (CISA) | Read in the rulebook |
| Licensing decision fee, portfolio manager or trustee (Annex no. 6.1)FINMA Fees and Levies Ordinance (FINMA-GebV, SR 956.122), version in force from 1 March 2024 as read; no 2025-2026 amendment was found. Fees are charged by time spent at CHF 100-500 per hour (Art. 8(4)) within the Annex range. The supervisory organization (SO) also charges its own affiliation and audit fees, not verified here. | CHF 2,000 to CHF 20,000, by time spent≈ USD 2 k | Portfolio manager (FinIA, supervised by an SO); Trustee (FinIA, supervised by an SO) | Read in the rulebook |
| Licensing decision fee, FinTech license, trading venue, DLT trading facility or payment systemFINMA Fees and Levies Ordinance (FINMA-GebV, SR 956.122), version in force from 1 March 2024 as read; no 2025-2026 amendment was found. Fees are charged by time spent at CHF 100-500 per hour (Art. 8(4)) within the Annex range. The Annex sets no range for these licenses, so Art. 8(3) applies (time and importance of the matter). | Time-based at CHF 100-500 per hour; no Annex range | FinTech license (Art. 1b Banking Act); Trading venue - stock exchange or multilateral trading facility (FinMIA); DLT trading facility (FinMIA Art. 73a); Payment system (FinMIA Art. 81) | Read in the rulebook |
| Every year | |||
| Supervisory levy, banksFINMA-GebV Art. 16(1)(b) and 17. Large banks pay CHF 500,000. The additional levy is split across the sector according to share of balance-sheet total (and securities turnover for banks with securities-firm status). amount_local is the basic levy only. | Basic levy CHF 15,000 per bank, plus an additional levy by balance-sheet total≈ USD 19 k | Bank license (Banking Act) | Read in the rulebook |
| Supervisory levy, securities firmsFINMA-GebV Art. 16(1)(b) and 17. amount_local is the basic levy only. | Basic levy CHF 10,000 per securities firm, plus an additional levy by balance-sheet total and securities turnover≈ USD 12 k | Securities firm (FinIA) | Read in the rulebook |
| Supervisory levy, FinTech license holdersFINMA-GebV Art. 19e-19f. amount_local is the basic levy only. | Basic levy CHF 3,000, plus an additional levy (2/10 by balance-sheet total, 8/10 by gross revenue)≈ USD 4 k | FinTech license (Art. 1b Banking Act) | Read in the rulebook |
| Supervisory levy, fund management companies and managers of collective assetsFINMA-GebV Art. 20 and 23: the additional levy is split half by gross revenue and half by size (fixed costs). Trustee add-on license adds CHF 5,000. | Basic levy CHF 5,000 (gross revenue under CHF 5m), CHF 10,000 (CHF 5-50m) or CHF 20,000 (CHF 50m or more), plus an additional levy≈ USD 6 k | Fund management company (FinIA); Manager of collective assets (FinIA) | Read in the rulebook |
| Supervisory levy, Swiss collective investment schemesFINMA-GebV Art. 20 and 22. Externally managed SICAV, SICAF and limited partnerships pay a CHF 5,000 basic levy. L-QIFs are not FINMA-approved and pay no product levy. | Basic levy CHF 600 per scheme or sub-fund, plus an additional levy by net assets capped at CHF 50,000 per fund or sub-fund≈ USD 750 | Swiss collective investment scheme approval (CISA) | Read in the rulebook |
| Supervisory levy, trading venuesFINMA-GebV Art. 19a-19b. | Basic levy CHF 15,000 (balance sheet under CHF 25m), CHF 100,000 (CHF 25-50m) or CHF 300,000 (over CHF 50m), plus an additional levy≈ USD 19 k | Trading venue - stock exchange or multilateral trading facility (FinMIA) | Read in the rulebook |
| Supervisory levy, DLT trading facilitiesFINMA-GebV Art. 19a(2) for small facilities. amount_local is the lowest basic levy. | Without custody/clearing services: CHF 15,000 / 100,000 / 300,000 by balance-sheet size; with them: CHF 100,000 / 225,000 / 550,000; small DLT trading facilities CHF 7,500 or CHF 50,000; plus an additional levy≈ USD 9 k | DLT trading facility (FinMIA Art. 73a) | Read in the rulebook |
| Supervisory levy, payment systemsFINMA-GebV Art. 19a. | Basic levy CHF 60,000 (gross revenue under CHF 20m) or CHF 100,000, plus an additional levy≈ USD 75 k | Payment system (FinMIA Art. 81) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 1.25 m
Independent wealth managerPortfolio manager (FinIA, supervised by an SO)
USD 125 k
Professional trusteeTrustee (FinIA, supervised by an SO)
USD 125 k
Asset manager of funds / pension assetsManager of collective assets (FinIA)
USD 250 k
Banking license lightFinTech license (Art. 1b Banking Act)
USD 375 k
Fund management companyFund management company (FinIA)
USD 1.25 m
Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA)
USD 1.25 m
DLT trading facilityDLT trading facility (FinMIA Art. 73a)
USD 1.25 m
Securities firm / broker-dealerSecurities firm (FinIA)
USD 1.88 m
Payment system operatorPayment system (FinMIA Art. 81)
USD 1.88 m
Insurer / reinsurer / captiveInsurance undertaking license (Insurance Supervision Act)
USD 3.75 m
BankBank license (Banking Act)
USD 12.5 m
100k1m10m100m
11 of 13 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
13 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BankBank license (Banking Act)USD 12.5 mMinimum capital
- Permits
- Accepting public deposits on a professional basis and lending, plus the full range of banking and securities services.
- Minimum capital
- CHF 10 million fully paid-up minimum capital (Banking Ordinance). Risk-based capital and liquidity rules (Capital Adequacy Ordinance, Basel III final reforms in force since 1 January 2025) usually require much more. (≈USD 12.5 m)
- Fees
- Licensing decision fee, bank or securities firm (Annex no. 1.1)CHF 10,000 to CHF 100,000, by time spentSupervisory levy, banksBasic levy CHF 15,000 per bank, plus an additional levy by balance-sheet total
- Clients
- Retail permitted
- Conditions
- Effective management in Switzerland, independent board, external audit by a FINMA-licensed audit firm, deposit insurance (esisuisse). Banks are classified in supervisory categories 1 to 5; small, highly liquid and well-capitalized banks can use the small banks regime.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HousePrime BrokerageCustody & Wallet InfrastructureStablecoin Issuance StructureStructured Products Issuer
- Reading
- From a secondary source
- Sources
02Banking license lightFinTech license (Art. 1b Banking Act)USD 375 kMinimum capital
- Permits
- Accepting public deposits (or crypto-assets held in collective custody) of up to CHF 100 million on a professional basis, provided they are neither invested nor interest-bearing.
- Minimum capital
- 3% of public deposits, minimum CHF 300,000 (Banking Ordinance implementing provisions). (≈USD 375 k)
- Fees
- Licensing decision fee, FinTech license, trading venue, DLT trading facility or payment systemTime-based at CHF 100-500 per hour; no Annex rangeSupervisory levy, FinTech license holdersBasic levy CHF 3,000, plus an additional levy (2/10 by balance-sheet total, 8/10 by gross revenue)
- Clients
- Retail permitted
- Conditions
- No lending with the deposits, no interest, no deposit insurance. Capital adequacy and liquidity rules do not apply; reduced accounting and audit requirements. A consultation (October 2025 to February 2026) proposes replacing it with a 'payment instrument institution' license without the CHF 100 million cap.
- Systems
- Digital BankElectronic Money InstitutionPayment Service ProviderCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
03Securities firm / broker-dealerSecurities firm (FinIA)USD 1.88 mMinimum capital
- Permits
- Professionally trading securities in its own name for clients, trading for own account on a short-term basis, market making, or underwriting and publicly offering securities. Covers client-account-holding firms and own-account dealers.
- Minimum capital
- CHF 1.5 million fully paid-up minimum capital (FinIA/FinIO). Ongoing own funds and risk diversification as for banks. (≈USD 1.88 m)
- Fees
- Licensing decision fee, bank or securities firm (Annex no. 1.1)CHF 10,000 to CHF 100,000, by time spentSupervisory levy, securities firmsBasic levy CHF 10,000 per securities firm, plus an additional levy by balance-sheet total and securities turnover
- Clients
- Retail permitted
- Conditions
- Effective management in Switzerland, separate board and management, risk management and compliance functions, external audit. Retail-facing derivatives (including CFDs) carry FinSA conduct and prospectus/KID requirements. Under FinSA Art. 70, structured products may be offered to retail investors only if issued or guaranteed by a bank, insurer or securities firm (or equivalent foreign institution).
- Systems
- Retail BrokerageInstitutional BrokerageMulti-Asset BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskInvestment BankOTC Digital Asset DeskStructured Products Issuer
- Reading
- From a secondary source
- Sources
04Fund management companyFund management company (FinIA)USD 1.25 mMinimum capital
- Permits
- Managing Swiss contractual investment funds in its own name for investors' account, including issuing and redeeming units, plus optional portfolio management and advice.
- Minimum capital
- CHF 1 million fully paid-up minimum capital (FinIA/FinIO), plus own funds scaled to assets under management. (≈USD 1.25 m)
- Fees
- Licensing decision fee, fund management company or manager of collective assets (Annex no. 2.1)CHF 4,000 to CHF 50,000, by time spentSupervisory levy, fund management companies and managers of collective assetsBasic levy CHF 5,000 (gross revenue under CHF 5m), CHF 10,000 (CHF 5-50m) or CHF 20,000 (CHF 50m or more), plus an additional levy
- Clients
- Retail permitted
- Conditions
- Must be a company limited by shares with registered office and head office in Switzerland. Needs a custodian bank for each fund.
- Systems
- Fund Management CompanyMutual Fund & UCITSETF PlatformReal Estate Investment VehicleAsset Management Company
- Reading
- From a secondary source
- Sources
05Asset manager of funds / pension assetsManager of collective assets (FinIA)USD 250 kMinimum capital
- Permits
- Managing assets of Swiss or foreign collective investment schemes and of Swiss pension schemes.
- Minimum capital
- CHF 200,000 fully paid-up minimum capital, maintained at all times (FinIO Art. 42(1)). FINMA can require more for managers of foreign schemes (Art. 42(6)). (≈USD 250 k)
- Fees
- Licensing decision fee, fund management company or manager of collective assets (Annex no. 2.1)CHF 4,000 to CHF 50,000, by time spentSupervisory levy, fund management companies and managers of collective assetsBasic levy CHF 5,000 (gross revenue under CHF 5m), CHF 10,000 (CHF 5-50m) or CHF 20,000 (CHF 50m or more), plus an additional levy
- Clients
- Retail, with conditions
- Conditions
- Managers below the de minimis thresholds (CHF 100 million AUM, or CHF 500 million unleveraged with a five-year lock-up) may operate as portfolio managers instead. Own funds of at least one quarter of fixed costs; professional liability insurance or extra own funds.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundDigital Asset FundPension & Endowment Manager
- Reading
- Read in the rulebook
- Sources
06Independent wealth managerPortfolio manager (FinIA, supervised by an SO)USD 125 kMinimum capital
- Permits
- Discretionary management of individual client portfolios; also de minimis managers of collective assets.
- Minimum capital
- CHF 100,000 fully paid-up minimum capital (FinIA), plus own funds of one quarter of fixed costs and adequate collateral or professional liability insurance. (≈USD 125 k)
- Fees
- Licensing decision fee, portfolio manager or trustee (Annex no. 6.1)CHF 2,000 to CHF 20,000, by time spent
- Clients
- Retail permitted
- Conditions
- FINMA grants the license; ongoing supervision by a FINMA-authorized supervisory organization (AOOS, OSFIN, OSIF, FINcontrol Suisse or SO-FIT). At least two qualified managers, effective management in Switzerland, ombudsman affiliation. Investment advice alone needs no license but FinSA client-adviser rules apply.
- Systems
- Wealth Management FirmMulti-Family OfficeInvestment Advisory FirmAsset Management Company
- Reading
- From a secondary source
- Sources
07Professional trusteeTrustee (FinIA, supervised by an SO)USD 125 kMinimum capital
- Permits
- Professionally managing or disposing of separate assets for beneficiaries under a trust.
- Minimum capital
- CHF 100,000 fully paid-up minimum capital (FinIA). (≈USD 125 k)
- Fees
- Licensing decision fee, portfolio manager or trustee (Annex no. 6.1)CHF 2,000 to CHF 20,000, by time spent
- Clients
- Retail, with conditions
- Conditions
- Same SO supervision model as portfolio managers. Relevant to family-office structures using trusts.
- Systems
- Multi-Family Office
- Reading
- From a secondary source
- Sources
08Swiss fund (product approval)Swiss collective investment scheme approval (CISA)No fixed figureMinimum capital
- Permits
- FINMA approval of Swiss open-ended funds (contractual funds and SICAVs: securities funds, real estate funds, other funds for traditional or alternative investments) and closed-ended vehicles (limited partnership for collective investment, SICAF).
- Minimum capital
- No capital for contractual funds (capital sits with the fund management company). SICAV and limited partnership minimum capital is set in the Collective Investment Schemes Ordinance; figures not verified.
- Fees
- Licensing decision fee, SICAV, limited partnership for collective investment or SICAF (Annex no. 2.1a)CHF 4,000 to CHF 30,000, by time spentSupervisory levy, Swiss collective investment schemesBasic levy CHF 600 per scheme or sub-fund, plus an additional levy by net assets capped at CHF 50,000 per fund or sub-fund
- Clients
- Retail permitted
- Conditions
- Retail funds need FINMA approval of fund documents. Limited partnerships for collective investment are restricted to qualified investors.
- Systems
- Mutual Fund & UCITSETF PlatformReal Estate Investment VehicleHedge FundPrivate Equity FirmDigital Asset Fund
- Reading
- To be confirmed
- Sources
09Unapproved qualified-investor fundLimited Qualified Investor Fund (L-QIF)No fixed figureMinimum capital
- Permits
- Swiss fund for qualified investors only that needs no FINMA approval, available since 1 March 2024. Must be managed by a FINMA-supervised institution (fund management company, manager of collective assets, bank, securities firm, or insurer for some forms).
- Minimum capital
- No capital for the fund; the managing institution carries its own capital requirement.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Qualified investors only. Relaxed investment rules; real estate and certain other L-QIFs have specific requirements.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundSingle-Family Office
- Reading
- Read in the rulebook
- Sources
10Exchange / MTFTrading venue - stock exchange or multilateral trading facility (FinMIA)USD 1.25 mMinimum capital
- Permits
- Operating a stock exchange or MTF for multilateral trading of securities.
- Minimum capital
- CHF 1 million minimum capital (FinMIO Art. 13(1)); FINMA may require up to 50% more (Art. 13(1bis)). (≈USD 1.25 m)
- Fees
- Licensing decision fee, FinTech license, trading venue, DLT trading facility or payment systemTime-based at CHF 100-500 per hour; no Annex rangeSupervisory levy, trading venuesBasic levy CHF 15,000 (balance sheet under CHF 25m), CHF 100,000 (CHF 25-50m) or CHF 300,000 (over CHF 50m), plus an additional levy
- Clients
- Retail, with conditions
- Conditions
- Self-regulation of admissions and trading, market surveillance. Organized trading facilities (OTFs) can also be run by banks or securities firms under their own license.
- Systems
- ECN & DMA Venue
- Reading
- Read in the rulebook
- Sources
11DLT trading facilityDLT trading facility (FinMIA Art. 73a)USD 1.25 mMinimum capital
- Permits
- Multilateral trading of DLT securities, which may be combined with central custody, clearing and settlement of DLT securities. Available since 1 August 2021; first license granted to BX Digital in 2025.
- Minimum capital
- CHF 1 million minimum capital without the custody/clearing/settlement services in FinMIA Art. 73a(1)(b) or (c); CHF 5 million with them (FinMIO Art. 13(1)). FINMA may require up to 50% more. (≈USD 1.25 m)
- Fees
- Licensing decision fee, FinTech license, trading venue, DLT trading facility or payment systemTime-based at CHF 100-500 per hour; no Annex rangeSupervisory levy, DLT trading facilitiesWithout custody/clearing services: CHF 15,000 / 100,000 / 300,000 by balance-sheet size; with them: CHF 100,000 / 225,000 / 550,000; small DLT trading facilities CHF 7,500 or CHF 50,000; plus an additional levy
- Clients
- Retail permitted
- Conditions
- Can admit retail participants directly, unlike traditional exchanges. Simplified rules exist for small DLT trading facilities.
- Systems
- Digital Asset ExchangeTokenization PlatformCustody & Wallet InfrastructureECN & DMA Venue
- Reading
- Read in the rulebook
- Sources
12Payment system operatorPayment system (FinMIA Art. 81)USD 1.88 mMinimum capital
- Permits
- Operating a payment system that clears and settles payment obligations. A license is required only where needed for the proper functioning of the financial market or protection of participants, and the system is not run by a bank.
- Minimum capital
- CHF 1.5 million minimum capital (FinMIO Art. 13(1)). (≈USD 1.88 m)
- Fees
- Licensing decision fee, FinTech license, trading venue, DLT trading facility or payment systemTime-based at CHF 100-500 per hour; no Annex rangeSupervisory levy, payment systemsBasic levy CHF 60,000 (gross revenue under CHF 20m) or CHF 100,000, plus an additional levy
- Clients
- Professional only
- Conditions
- Systemically important systems also face SNB requirements. Ordinary payment service providers do not need this license; they join an SRO.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
13Insurer / reinsurer / captiveInsurance undertaking license (Insurance Supervision Act)USD 3.75 mMinimum capital
- Permits
- Direct life, non-life, health or reinsurance business, licensed per insurance sector listed in Annex 1 of the Insurance Supervision Ordinance.
- Minimum capital
- CHF 3 million to CHF 20 million minimum capital depending on the sector (FINMA), plus an establishment (organization) fund. Swiss Solvency Test applies on an ongoing basis. (≈USD 3.75 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Direct life insurers may add only accident and health lines. The revised Insurance Supervision Act lightens supervision for reinsurers and for insurers serving only professional policyholders.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
No EU passport. Cross-border services rely on host-state rules, reverse solicitation or local licenses. Switzerland and the UK have a mutual-recognition agreement for certain wholesale financial services (Berne Financial Services Agreement).
Passage
No statutory decision deadline for first-time licenses. Market practice: 6 to 12 months from a complete file for banks, securities firms and fund management companies (8 to 12 months is commonly cited for securities firms); portfolio managers and trustees typically go faster because an SO review precedes the FINMA decision. FINMA offers a pre-application (authorization enquiry) assessment.
Licensed elsewhere
Para-banking financial intermediaries under the Anti-Money Laundering Act, such as money transmitters, payment service providers, crypto exchange offices, non-custodial or individual-custody wallet providers and lenders, join an SRO (for example VQF or PolyReg) rather than obtaining a FINMA license. Credit card issuers are governed by the Consumer Credit Act. Pension funds are supervised by cantonal/regional supervisory authorities and the Occupational Pension Supervisory Commission (OAK BV). Systemically important payment systems are overseen jointly with the Swiss National Bank. Single-family offices managing only family wealth need no FINMA license. Not licensed: sovereign vehicles, mining and validation, physical commodity trading (except AML for some precious-metals trading), Islamic finance as a separate regime.
Notes. On 22 October 2025 the Federal Council opened a consultation (closed 6 February 2026) on two new FinIA licenses: 'payment instrument institution' (replacing the FinTech license, allowing stablecoin issuance, no CHF 100 million cap) and 'crypto institution' (for crypto custody and trading services). Not adopted as of November 2026. Until then FINMA's stablecoin guidance (06/2024) generally requires stablecoin issuers to hold a banking license or rely on a bank default guarantee. L-QIF regime in force since 1 March 2024. Basel III final reforms apply to banks from 1 January 2025. Portfolio managers' FinIA transition ended 31 December 2022.
Europe · Lithuania
Bank of Lithuania
Bank of Lithuania
Lithuania's central bank is the single supervisor for banks, specialized banks, payment and e-money institutions, investment firms, fund managers, insurers, crowdfunding platforms and MiCA crypto-asset service providers. Bank and specialized bank licenses are decided with the ECB under the Single Supervisory Mechanism. The regulator publishes statutory decision periods for each license and runs a regulatory sandbox and newcomer program.
#11of 34
Balanced score
75 of 100
75 of 100
Scorecard
Credibility ×35%65Breadth ×15%87Entry threshold ×20%70Speed ×15%70Reach ×15%99
Categories18
Systems covered41 of 47
Typical timeline3–12 monthsstatutory
Lowest capitalUSD 23 k
IOSCO MMoUA
PassportEU/EEA
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
Application—0 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearFormula4 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
Lithuania charges no large fixed license fees; the main recurring cost is an income- or asset-based supervision contribution set yearly by the Bank of Lithuania. Banks and brokerage firms also contribute to the deposit and investment insurance scheme (Indėlių ir investicijų draudimas); application state fees and MiCA CASP fees were not verified in this pass.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Every year | |||
| Supervision contribution, banksRate set yearly by Bank of Lithuania Board resolution. The figure is the 2023 rate (Resolution No. 03-164 of 20 October 2022), the latest table the Bank of Lithuania page served; the 2026 rate was not verified. EEA bank branches paid 0.004845%. | 0.01445% of average annual assets (2023 rate) | Bank license (Law on Banks); Specialised bank license (Law on Banks) | To be confirmed |
| Supervision contribution, electronic money and payment institutionsRate set yearly by Bank of Lithuania Board resolution. The figure is the 2023 rate (Resolution No. 03-164 of 20 October 2022), the latest table the Bank of Lithuania page served; the 2026 rate was not verified. In March 2025 the Bank of Lithuania consulted on a new calculation method and maximum amounts for PIs and EMIs, so the 2026 basis may differ. A 2020 bill proposed a EUR 2,000 minimum (EUR 670 for restricted licenses) and a lower cap; whether a minimum applies in 2026 was not verified. | 0.585% of annual income from e-money and payment services (2023 rate) | Electronic money institution license; Payment institution license; Electronic money institution license for restricted activity; Payment institution license for restricted activities | To be confirmed |
| Supervision contribution, financial brokerage firmsRate set yearly by Bank of Lithuania Board resolution. The figure is the 2023 rate (Resolution No. 03-164 of 20 October 2022), the latest table the Bank of Lithuania page served; the 2026 rate was not verified. EEA branches paid 0.135%. | 0.27% of annual income (2023 rate) | Financial brokerage firm - EUR 75,000 band; Financial brokerage firm - EUR 150,000 band; Financial brokerage firm - EUR 750,000 band | To be confirmed |
| Supervision contribution, management companiesRate set yearly by Bank of Lithuania Board resolution. The figure is the 2023 rate (Resolution No. 03-164 of 20 October 2022), the latest table the Bank of Lithuania page served; the 2026 rate was not verified. | 0.045% of net assets of retail and supplementary pension funds; 0.018% of net assets of funds for informed and professional investors (2023 rates) | Management company (UCITS and/or AIF) | To be confirmed |
Threshold
Minimum capital, category by category
Middle halfMedian USD 174 k
Payment institutionPayment institution license
USD 23 k
Crowdfunding platformCrowdfunding service provider (Regulation (EU) 2020/1503)
USD 29 k
Crypto-asset service provider (Class 1)MiCA CASP - Class 1
USD 58 k
Investment firm without client assetsFinancial brokerage firm - EUR 75,000 band
USD 87 k
Fund management companyManagement company (UCITS and/or AIF)
USD 145 k
Crypto-asset service provider (Class 2)MiCA CASP - Class 2
USD 145 k
Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 band
USD 174 k
Pension fund managerPension accumulation company
USD 174 k
Crypto-asset trading platformMiCA CASP - Class 3
USD 174 k
Electronic money institutionElectronic money institution license
USD 406 k
ART issuerMiCA issuer of asset-referenced tokens
USD 406 k
Dealer / underwriterFinancial brokerage firm - EUR 750,000 band
USD 870 k
Specialized bankSpecialised bank license (Law on Banks)
USD 1.16 m
InsurerInsurance / reinsurance undertaking (Law on Insurance)
USD 1.51 m
BankBank license (Law on Banks)
USD 5.8 m
10k100k1m10m
15 of 18 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
18 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BankBank license (Law on Banks)USD 5.8 mMinimum capital
- Permits
- All financial services unless restricted by law, including deposit-taking, lending, payment services, e-money and investment services.
- Minimum capital
- EUR 5 million minimum capital; may be set higher depending on activities (Bank of Lithuania, authorization of banks). (≈USD 5.8 m)
- Fees
- Supervision contribution, banks0.01445% of average annual assets (2023 rate)
- Clients
- Retail permitted
- Conditions
- ECB and Bank of Lithuania assess jointly; ECB issues the license under Regulation (EU) No 468/2014. CRR/CRD prudential rules.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HousePrime BrokerageCard Issuing ProgramMerchant AcquiringStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
02Specialized bankSpecialised bank license (Law on Banks)USD 1.16 mMinimum capital
- Permits
- A bank whose permitted activities are listed exhaustively in Art. 4(5) of the Law on Banks: deposit-taking, lending, payment services and e-money issuance, with limits on investment services and some other financial services.
- Minimum capital
- EUR 1 million minimum capital; may be set higher depending on activities. (≈USD 1.16 m)
- Fees
- Supervision contribution, banks0.01445% of average annual assets (2023 rate)
- Clients
- Retail permitted
- Conditions
- Same authorization process and supervision as a full bank (ECB decision). Popular route for EMIs and fintechs upgrading to deposit-taking. Can convert to a full bank later by raising capital to EUR 5 million.
- Systems
- Digital BankCard Issuing ProgramMerchant AcquiringTrade Finance HouseStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
03Electronic money institutionElectronic money institution licenseUSD 406 kMinimum capital
- Permits
- Issuing e-money and providing payment services, in Lithuania and, after notification, across the EU.
- Minimum capital
- EUR 350,000 minimum initial capital. (≈USD 406 k)
- Fees
- Supervision contribution, electronic money and payment institutions0.585% of annual income from e-money and payment services (2023 rate)
- Clients
- Retail permitted
- Conditions
- Fitness and propriety checks on shareholders and managers; safeguarding; AML. EMIs may issue MiCA e-money tokens.
- Systems
- Electronic Money InstitutionPayment Service ProviderCard Issuing ProgramMerchant AcquiringStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
04Restricted EMIElectronic money institution license for restricted activityNo minimum setMinimum capital
- Permits
- E-money issuance in Lithuania only.
- Minimum capital
- No minimum initial capital requirement.
- Fees
- Supervision contribution, electronic money and payment institutions0.585% of annual income from e-money and payment services (2023 rate)
- Clients
- Retail permitted
- Conditions
- Average outstanding e-money over the previous 6 months may not exceed EUR 900,000 per month; must apply for a full EMI license within 30 days of exceeding it. No passport.
- Systems
- Electronic Money Institution
- Reading
- Read in the rulebook
- Sources
05Payment institutionPayment institution licenseUSD 23 kMinimum capital
- Permits
- Payment services under the Law on Payments (PSD2 services).
- Minimum capital
- Initial capital by service: EUR 20,000 for money remittance only; EUR 50,000 for payment initiation only; EUR 125,000 for cash placement/withdrawal, payment transactions, credit-line transactions, issuing payment instruments and/or acquiring. (≈USD 23 k)
- Fees
- Supervision contribution, electronic money and payment institutions0.585% of annual income from e-money and payment services (2023 rate)
- Clients
- Retail permitted
- Conditions
- Fitness and propriety of qualifying holders and managers; professional indemnity insurance for PIS/AIS providers; safeguarding.
- Systems
- Payment Service ProviderMoney Services BusinessMerchant AcquiringCard Issuing Program
- Reading
- Read in the rulebook
- Sources
06Restricted PIPayment institution license for restricted activitiesNo minimum setMinimum capital
- Permits
- Sandbox-style license for new entrants covering only the first five services in Art. 5 of the Law on Payments, valid in Lithuania only.
- Minimum capital
- No minimum initial capital requirement.
- Fees
- Supervision contribution, electronic money and payment institutions0.585% of annual income from e-money and payment services (2023 rate)
- Clients
- Retail permitted
- Conditions
- Lithuania only; no passport. Volume limits apply.
- Systems
- Payment Service ProviderMoney Services Business
- Reading
- Read in the rulebook
- Sources
07Investment firm without client assetsFinancial brokerage firm - EUR 75,000 bandUSD 87 kMinimum capital
- Permits
- Reception and transmission of orders, execution of orders, portfolio management, investment advice and placing without firm commitment, without holding client money or financial instruments.
- Minimum capital
- EUR 75,000 minimum initial capital (Law on Markets in Financial Instruments Art. 14; IFR Art. 9). (≈USD 87 k)
- Fees
- Supervision contribution, financial brokerage firms0.27% of annual income (2023 rate)
- Clients
- Retail permitted
- Conditions
- IFR fixed overheads and K-factor requirements. Retail CFD restrictions follow ESMA product intervention as adopted nationally.
- Systems
- Investment Advisory FirmWhite-Label BrokerageWealth Management Firm
- Reading
- Read in the rulebook
- Sources
08Investment firm holding client assetsFinancial brokerage firm - EUR 150,000 bandUSD 174 kMinimum capital
- Permits
- Investment services not in the EUR 75,000 or EUR 750,000 bands, including any service with holding of client money or instruments and operating an MTF.
- Minimum capital
- EUR 150,000 minimum initial capital (Law on Markets in Financial Instruments Art. 14). (≈USD 174 k)
- Fees
- Supervision contribution, financial brokerage firms0.27% of annual income (2023 rate)
- Clients
- Retail permitted
- Conditions
- Client asset safeguarding. IFR/IFD prudential regime.
- Systems
- Institutional BrokerageWealth Management FirmMulti-Family OfficeAsset Management CompanyECN & DMA Venue
- Reading
- Read in the rulebook
- Sources
09Dealer / underwriterFinancial brokerage firm - EUR 750,000 bandUSD 870 kMinimum capital
- Permits
- Dealing on own account and underwriting or placing on a firm-commitment basis; also OTF operators permitted to deal on own account.
- Minimum capital
- EUR 750,000 minimum initial capital (Law on Markets in Financial Instruments Art. 14). (≈USD 870 k)
- Fees
- Supervision contribution, financial brokerage firms0.27% of annual income (2023 rate)
- Clients
- Retail permitted
- Conditions
- Market-maker and CFD principal models require this band. Retail CFD leverage caps apply.
- Systems
- Retail BrokerageMulti-Asset BrokeragePrime-of-PrimeProprietary Trading FirmQuantitative Trading DeskInvestment BankStructured Products IssuerTokenization Platform
- Reading
- Read in the rulebook
- Sources
10Financial advisor companyFinancial advisor company licenseNo minimum setMinimum capital
- Permits
- Investment services under Art. 3(26)(1)-(5) of the Law on Markets in Financial Instruments for transferable securities and fund units only, without holding client funds or instruments.
- Minimum capital
- No capital requirement (exempt from Arts. 12 and 15). Professional civil liability insurance of at least EUR 29,000 per event and EUR 145,000 per year instead.
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- May pass client orders only to EU-licensed brokerage firms, credit institutions, equivalent third-country branches and certain funds. Not a MiFID passport.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
11Fund management companyManagement company (UCITS and/or AIF)USD 145 kMinimum capital
- Permits
- Managing UCITS and/or alternative collective investment undertakings, including Lithuanian informed-investor and closed-ended funds.
- Minimum capital
- EUR 125,000 minimum initial capital, plus 0.02% of portfolios above EUR 250 million, capped at EUR 10 million in total (Law on Managers of Alternative Collective Investment Undertakings; the same EUR 125,000 floor applies to UCITS management companies under the UCITS Directive). (≈USD 145 k)
- Fees
- Supervision contribution, management companies0.045% of net assets of retail and supplementary pension funds; 0.018% of net assets of funds for informed and professional investors (2023 rates)
- Clients
- Retail, with conditions
- Conditions
- Retail access only through UCITS or retail-permitted AIFs. AIFMD II applies from 16 April 2026.
- Systems
- Fund Management CompanyAsset Management CompanyMutual Fund & UCITSETF PlatformHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
12Pension fund managerPension accumulation companyUSD 174 kMinimum capital
- Permits
- Managing supplementary voluntary pension funds (third pillar) or pension funds financed from state social insurance contributions (second pillar).
- Minimum capital
- EUR 150,000 for supplementary voluntary pension accumulation; EUR 300,000 initial and authorized capital for second-pillar pension fund managers. (≈USD 174 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Separate license regime; figures as stated on the Bank of Lithuania's management company authorization page.
- Systems
- Pension & Endowment Manager
- Reading
- Read in the rulebook
- Sources
13Crypto-asset service provider (Class 1)MiCA CASP - Class 1USD 58 kMinimum capital
- Permits
- Reception and transmission of orders, execution, placing, transfer services, advice and portfolio management on crypto-assets.
- Minimum capital
- EUR 50,000 minimum permanent capital, or one quarter of fixed overheads if higher (MiCA Art. 67 and Annex IV). (≈USD 58 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Registered office in Lithuania, effective management in the EU, at least one EU-resident director.
- Systems
- OTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
14Crypto-asset service provider (Class 2)MiCA CASP - Class 2USD 145 kMinimum capital
- Permits
- Class 1 services plus custody and administration of crypto-assets and exchange of crypto-assets for funds or other crypto-assets.
- Minimum capital
- EUR 125,000 minimum permanent capital, or one quarter of fixed overheads if higher (MiCA Art. 67 and Annex IV). (≈USD 145 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Custody policy and client asset segregation. The Bank of Lithuania has rejected many applications for weak substance, governance and AML documentation.
- Systems
- OTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
15Crypto-asset trading platformMiCA CASP - Class 3USD 174 kMinimum capital
- Permits
- Class 2 services plus operating a crypto-asset trading platform.
- Minimum capital
- EUR 150,000 minimum permanent capital, or one quarter of fixed overheads if higher (MiCA Art. 67 and Annex IV). (≈USD 174 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Operating rules, market surveillance and transparency requirements.
- Systems
- Digital Asset ExchangeCustody & Wallet InfrastructureOTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
16ART issuerMiCA issuer of asset-referenced tokensUSD 406 kMinimum capital
- Permits
- Offering or seeking admission to trading of asset-referenced tokens.
- Minimum capital
- Own funds of the highest of EUR 350,000, 2% of the average reserve of assets, or one quarter of fixed overheads (MiCA Art. 35). (≈USD 406 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- E-money tokens are issued by banks, specialized banks or EMIs instead.
- Systems
- Stablecoin Issuance StructureTokenization Platform
- Reading
- From a secondary source
- Sources
17Crowdfunding platformCrowdfunding service provider (Regulation (EU) 2020/1503)USD 29 kMinimum capital
- Permits
- Facilitating business lending (loan-based) and placing of transferable securities or admitted instruments (investment-based) through a platform, up to EUR 5 million per project per 12 months.
- Minimum capital
- Prudential safeguards equal to the higher of EUR 25,000 or one quarter of prior-year fixed overheads, held as own funds or insurance (ECSPR Art. 11). The Bank of Lithuania page sets no separate figure. (≈USD 29 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Investor protection rules for non-sophisticated investors (entry test, loss simulation, cooling-off). Passportable across the EU after notification. Consumer peer-to-peer lending platforms fall under a separate national regime.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- From a secondary source
- Sources
18InsurerInsurance / reinsurance undertaking (Law on Insurance)USD 1.51 mMinimum capital
- Permits
- Life, non-life or reinsurance business under the Solvency II regime.
- Minimum capital
- Solvency II absolute MCR floors: EUR 2.7 million non-life (EUR 4.0 million for classes 10-15), EUR 4.0 million life, EUR 3.9 million reinsurance, EUR 1.3 million captive reinsurance (revised 19 October 2022). (≈USD 1.51 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Full Solvency II regime; figures are the EU-wide floors, not a Lithuanian-specific publication.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
Reach
Full EU/EEA passporting for credit institutions, PIs and EMIs (but not the restricted-activity PI/EMI licenses, which are valid in Lithuania only), investment firms, UCITS management companies, full-scope AIFMs, MiCA CASPs and issuers, crowdfunding service providers (ECSP) and Solvency II insurers.
Passage
Statutory periods published by the Bank of Lithuania: banks and specialized banks 6 months from a complete application, 12 months at most; investment firms and financial advisor companies 6 months; EMIs and PIs 3 months (2 months for restricted-activity licenses); AIF management companies 3 months, extendable by 3; crowdfunding service providers 25 working days for completeness plus 3 months; CASPs 25 working days for completeness plus 40 working days for assessment. A 5-business-day acceptance check precedes each. In practice information requests restart the clock.
Licensed elsewhere
Bank and specialized bank licenses are decided by the ECB with the Bank of Lithuania. AML for non-licensed entities sits with the Financial Crime Investigation Service (FNTT). No separate money-services regime: remittance is a PI service. Not licensed: sovereign investment vehicles, single-family offices managing only family wealth, mining and validation, physical commodity trading, and Islamic finance as a separate regime.
Notes. Lithuania's MiCA transitional period for pre-existing VASPs ended 31 December 2025, after which unlicensed firms had to cease operations; only a handful of CASP licenses had been granted by January 2026 (secondary source). Lithuania's national crowdfunding regime was replaced by the EU ECSP regulation after the transition ended in November 2023. AIFMD II applies from 16 April 2026. The Bank of Lithuania tightened its stance on EMIs in 2023-2025 after AML enforcement, so expect heavier scrutiny of shareholders and AML frameworks.
Middle East · UAE · Dubai, DIFC
DFSA
Dubai Financial Services Authority
The DFSA is the single integrated regulator of financial services conducted in or from the DIFC, a financial free zone in Dubai with its own common-law-based legislation (Regulatory Law, DIFC Law No. 1 of 2004). It licenses Authorized Firms into prudential Categories 1 to 5 under the PIB module, and also regulates Authorized Market Institutions, insurers, funds and crypto token activities. A DIFC license does not authorize business with clients in onshore UAE; onshore activity falls to the CBUAE and the CMA (formerly SCA).
#12of 34
Balanced score
75 of 100
75 of 100
Scorecard
Credibility ×35%100Breadth ×15%85Entry threshold ×20%65Speed ×15%60Reach ×15%32
Categories16
Systems covered40 of 47
Typical timeline6–12 monthsmarket practice
Lowest capitalUSD 30 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 15 k–40 k4 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 15 k–100 k5 items · Recurring fees and levies
OtherUSD 1 k–20 k5 items · Mandatory charges that arise in operation
DFSA fees are only part of the bill: DIFC Registrar fees (incorporation about USD 8,000 and a commercial license of roughly USD 12,000 to 15,000 a year) and data-protection registration are charged separately. Annual fees are per Financial Service and scale with expenditure, and a Retail Endorsement adds USD 20,000 one-off.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Application fee (range across Financial Services)DFSA states the application fee varies with the Financial Services applied for and ranges from USD 15,000 to USD 70,000 (top of range applies to deposit-taking). The DFSA e-services page for new Authorized Firm applications shows USD 2,000 to 140,000, the upper end reflecting the additional 100% charged to certain applicants (e.g. complex or unregulated group structures). Non-refundable. Detailed amounts sit in the FER module, which could not be fetched directly. | USD 15,000 to USD 70,000 | All categories | Read in the rulebook |
| Application fee, Advising / Arranging (Category 4)Adviser reports USD 15,000 or USD 30,000 depending on the applicant's structure (the doubled figure is the FER surcharge for certain applicants). Consistent with the low end of the DFSA's published USD 15,000 to 70,000 range. | USD 15,000 (USD 30,000 for certain group structures) | Category 4 | From a secondary source |
| Application fee, Dealing as Agent / Managing Assets (Category 3A, 3C asset manager)Two adviser sources give USD 25,000 for Dealing in Investments as Agent and for Managing Assets; one reports USD 50,000 where the structure attracts the surcharge. Fund manager (Managing a Collective Investment Fund) application fee not confirmed. | USD 25,000 (USD 50,000 for certain group structures) | Category 3A; Category 3C (Managing Assets, PSIAr, express trustee) | From a secondary source |
| Application fee, Dealing as Principal (Category 2)Reported by an adviser for Dealing in Investments as Principal; not read in FER itself. Applicants also seeking Providing Credit or Accepting Deposits pay more (up to the USD 70,000 top of the DFSA range). | USD 40,000 | Category 2 | From a secondary source |
| Every year | |||
| Annual fee, Category 4 (Advising / Arranging)Adviser reports annual renewal of USD 15,000 plus USD 1,000 per USD 1 million of expenditure plus USD 1,000 per additional Financial Service. Formula not verified in FER. | USD 15,000 base, plus expenditure-based and per-service add-ons | Category 4 | From a secondary source |
| Annual fee, Category 3A (Dealing as Agent)Adviser reports USD 25,000 plus USD 1,000 per USD 1 million of expenditure plus USD 1,000 per additional Financial Service. A 2026 crypto-focused adviser quotes about USD 35,000 for agency dealing; treat the base as approximate. | USD 25,000 base, plus expenditure-based and per-service add-ons | Category 3A | From a secondary source |
| Annual fee, Dealing as Principal (Category 2)The 2018 reform phased the principal-dealing annual fee from USD 40,000 to 45,000 (2018) and 50,000 (2019). A 2026 crypto-adviser article quotes USD 70,000 for proprietary/principal firms. Current FER figure not read directly; lowest figure used. | USD 50,000 (2019 phased level); one 2026 source cites USD 70,000 | Category 2 | To be confirmed |
| Annual fee, Accepting Deposits / Providing Credit (banks, credit providers)The 2018 reform phased the deposit-taking/credit annual fee from USD 70,000 to 85,000 (2018) and 100,000 (2019). Applies to Category 2 only where Providing Credit is held. Not re-verified against the current FER. | USD 100,000 (2019 phased level) | Category 1; Category 2 | From a secondary source |
| Annual fee, Insurer (Effecting/Carrying Out Contracts of Insurance)Phased from USD 40,000 to 45,000 (2018) and 50,000 (2019); insurance management services USD 20,000 from 2019. Not re-verified against the current FER. | USD 50,000 (2019 phased level) | Insurer (Effecting and Carrying Out Contracts of Insurance, PIN module) | From a secondary source |
| Other | |||
| Retail Endorsement fee (one-off)Payable only by firms seeking a Retail Endorsement. Raised from USD 5,000 to USD 20,000 in the 2018 fee reform; still quoted at USD 20,000 by an adviser in 2023/2024. | USD 20,000 | All categories | From a secondary source |
| Client Assets endorsement fee (one-off)Charged when a firm applies to hold or control Client Assets; reported for Category 3A. Not available to Category 4. | USD 5,000 | Category 3A | From a secondary source |
| Change in control / controller approvalPer DFSA e-services page for amendments to ownership or control structure. | USD 5,000 (USD 10,000 if complex) | All categories | Read in the rulebook |
| Public fund registrationPer DFSA e-services page; varies with fund type. Qualified Investor Fund passporting requests are USD 2,000 to 9,500. | USD 1,000 to USD 4,000 per fund | Category 3C (Fund Manager – Managing a Collective Investment Fund) | Read in the rulebook |
| Withdrawal of authorizationPer DFSA e-services page; set by complexity. | USD 1,500 to USD 5,000 | All categories | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 200 k
Adviser / arrangerCategory 4
USD 30 k
Fund manager (public, exempt, qualified investor, venture capital funds)Category 3C (Fund Manager – Managing a Collective Investment Fund)
USD 40 k
Asset / wealth managerCategory 3C (Managing Assets, PSIAr, express trustee)
USD 140 k
Money transmitter / crowdfunding operatorCategory 4 (Money Transmission / Crowdfunding Platform holding Client Assets)
USD 140 k
Captive insurerCaptive Insurer (Class 1, 2 or 3, PIN module)
USD 150 k
Agency broker / ATS operatorCategory 3A
USD 200 k
Payment services (money services other than stored value and money transmission)Category 3D
USD 200 k
Stored value (e-money) issuerCategory 3C (Providing Money Services – issuing Stored Value)
USD 500 k
Principal dealer / credit providerCategory 2
USD 2 m
Bank (deposit-taker)Category 1
USD 10 m
Islamic Financial Institution (PSIAu)Category 5
USD 10 m
10k100k1m10m
11 of 16 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
16 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Bank (deposit-taker)Category 1USD 10 mMinimum capital
- Permits
- Accepting Deposits or Managing a Profit Sharing Investment Account (Unrestricted) by a non-Islamic firm; such a firm may also carry on the lower-category activities on its license (dealing, providing credit, custody, advising).
- Minimum capital
- Base Capital Requirement USD 10 million (PIB 3.6.2), plus risk capital (credit, market, operational) and capital buffers under PIB. (≈USD 10 m)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Annual fee, Accepting Deposits / Providing Credit (banks, credit providers)USD 100,000 (2019 phased level)Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Retail business needs a Retail Endorsement on the license. DIFC firms are generally not permitted to accept deposits from, or deal in AED with, the onshore UAE market; the DIFC bank model is wholesale and private banking oriented. Full Basel-style PIB capital, liquidity and ICAAP apply.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTrade Finance House
- Reading
- Read in the rulebook
- Sources
02Principal dealer / credit providerCategory 2USD 2 mMinimum capital
- Permits
- Dealing in Investments as Principal (including, since the 2025 PIB amendments, as Matched Principal), market making, and Providing Credit.
- Minimum capital
- Base Capital Requirement USD 2 million (PIB 3.6.2), plus risk capital requirements. One secondary source reports a lower figure (USD 500,000) for firms dealing only as matched principal after matched-principal dealing moved from Category 3A to Category 2 in 2025; not confirmed in the rulebook. (≈USD 2 m)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Application fee, Dealing as Principal (Category 2)USD 40,000Retail Endorsement fee (one-off)USD 20,000Annual fee, Dealing as Principal (Category 2)USD 50,000 (2019 phased level); one 2026 source cites USD 70,000Annual fee, Accepting Deposits / Providing Credit (banks, credit providers)USD 100,000 (2019 phased level)Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Retail clients need a Retail Endorsement and the COB retail protections. Market-maker (B-book) CFD brokers fall here. The USD 2 million figure is confirmed in PIB 3.6.2; the matched-principal carve-out is unconfirmed. Crypto token dealing as principal is also Category 2 (crypto-specific GEN 3A rules apply).
- Systems
- Retail BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeMulti-Asset BrokerageOTC Digital Asset DeskStructured Products IssuerTrade Finance HouseInvestment Bank
- Reading
- From a secondary source
- Sources
03Agency broker / ATS operatorCategory 3AUSD 200 kMinimum capital
- Permits
- Dealing in Investments as Agent and, after the 2025 PIB amendments, Operating an Alternative Trading System (the DIFC term covering MTF and OTF venues), which moved from Category 4.
- Minimum capital
- Base Capital Requirement USD 200,000, reduced from USD 500,000 by the CP161 amendments (PIB Rule-Making Instrument No. 413 of 2025). From 1 July 2026, 3A firms also face an Activity-Based Capital Requirement (K-ASA 0.06%, K-AUM 0.02%, K-COH 0.10% cash / 0.01% derivatives) and a 20% capital buffer. (≈USD 200 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Application fee, Dealing as Agent / Managing Assets (Category 3A, 3C asset manager)USD 25,000 (USD 50,000 for certain group structures)Retail Endorsement fee (one-off)USD 20,000Client Assets endorsement fee (one-off)USD 5,000Annual fee, Category 3A (Dealing as Agent)USD 25,000 base, plus expenditure-based and per-service add-onsChange in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- USD 200,000 is reported consistently by ACA Group, Kayrouz & Associates and a guide citing PIB 3.6.2 VER54, but was not read in the consolidated rulebook (the publicly reachable PIB 3.6.2 page still shows the pre-2025 USD 500,000). Effective date: ACA, Waystone and the DFSA May 2025 notice (which lists the PIB instrument under the 1 July 2026 commencement) point to 1 July 2026; one adviser places the ATS move to 3A at 1 July 2025. Either way, USD 200,000 is the current figure as of October 2026. Retail Endorsement needed for retail clients. ATS operators must meet the market-integrity rules in the AMI/ATS modules.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageECN & DMA VenueDigital Asset ExchangeTokenization Platform
- Reading
- From a secondary source
- Sources
04Custodian / fund trusteeCategory 3BNo fixed figureMinimum capital
- Permits
- Providing Custody, acting as Trustee of a Fund, and operating or administering an Employee Money Purchase Scheme; custody of crypto tokens is placed here by most sources.
- Minimum capital
- Not confirmed. PIB 3.6.2 before the 2025 amendments set USD 4 million (primary, older version). After CP161, Kayrouz & Associates (October 2026) reports USD 500,000 to USD 2 million depending on activity, while Cavenwell (December 2025) still gives about USD 4 million and another 2026 guide says only 'typically in the millions'.
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Figure uncertain: the amended PIB text (Rule-Making Instrument No. 413 of 2025, appendix 7) could not be read and secondary sources conflict. Budget for USD 4 million until confirmed with the DFSA. EBCM continues to apply to custody firms; from 1 July 2026 the ABCR (K-ASA) applies and minimum PII cover standards are set for 3B firms.
- Systems
- Custody & Wallet Infrastructure
- Reading
- To be confirmed
- Sources
05Asset / wealth managerCategory 3C (Managing Assets, PSIAr, express trustee)USD 140 kMinimum capital
- Permits
- Managing Assets, Managing a Profit Sharing Investment Account (Restricted) and acting as trustee of an express trust.
- Minimum capital
- USD 140,000 where Managing Assets is the firm's only Category 3C activity (asset or portfolio manager); USD 500,000 for other Category 3C firms (restricted PSIA managers, or firms combining 3C activities), per advisers citing PIB 3.6.2 as amended by CP161. Expenditure-Based Capital Minimum applies only where the firm holds Client Assets (from 1 July 2025); ABCR (K-AUM 0.02%) applies from 1 July 2026. (≈USD 140 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Application fee, Dealing as Agent / Managing Assets (Category 3A, 3C asset manager)USD 25,000 (USD 50,000 for certain group structures)Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Figures from Kayrouz & Associates and a guide citing PIB 3.6.2 VER54, consistent with the CP161 proposal reported in March 2025; not read in the consolidated rulebook (the reachable older PIB 3.6.2 shows USD 500,000 for all 3C). Retail Endorsement needed for retail clients. Stored value issuers must safeguard client money.
- Systems
- Asset Management CompanyWealth Management FirmMulti-Family OfficePension & Endowment ManagerQuantitative Trading Desk
- Reading
- From a secondary source
- Sources
06Stored value (e-money) issuerCategory 3C (Providing Money Services – issuing Stored Value)USD 500 kMinimum capital
- Permits
- Providing Money Services by issuing Stored Value (e-money), alone or with other Category 3C activities.
- Minimum capital
- USD 500,000 base capital (PIB 3.6.2; the reduced USD 140,000 figure applies only where Managing Assets is the firm's only 3C activity). (≈USD 500 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Retail Endorsement needed for retail clients. Stored value issuers must safeguard client money. Figure from advisers citing PIB 3.6.2; not read in the consolidated rulebook.
- Systems
- Electronic Money Institution
- Reading
- From a secondary source
- Sources
07Fund manager (public, exempt, qualified investor, venture capital funds)Category 3C (Fund Manager – Managing a Collective Investment Fund)USD 40 kMinimum capital
- Permits
- Managing a Collective Investment Fund (Public Funds, Exempt Funds, Qualified Investor Funds, Credit Funds, Property Funds/REITs, Venture Capital Funds) where this is the firm's only Category 3C activity.
- Minimum capital
- USD 140,000 if the firm manages a Public Fund or a Credit Fund; USD 40,000 if it manages only funds for professional investors (Exempt and Qualified Investor Funds), per advisers citing PIB 3.6.2 as amended by CP161 (previously USD 140,000 / USD 70,000). Applies where managing a Collective Investment Fund is the firm's only 3C activity. Managers of Venture Capital Funds are excluded from the Expenditure-Based Capital Minimum. (≈USD 40 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Public fund registrationUSD 1,000 to USD 4,000 per fundWithdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- The USD 140,000 public-fund tier is confirmed in the older rulebook text; the USD 40,000 tier is reported by several advisers (and was the CP161 proposal, cutting USD 70,000 to USD 40,000) but was not read in the amended rulebook. One guide reports no base capital for VC-only managers; unconfirmed. Public Funds can be offered to retail investors; Exempt and Qualified Investor Funds are professional-only. VC Fund managers have no PII requirement from 1 July 2026.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleMutual Fund & UCITSETF PlatformDigital Asset Fund
- Reading
- From a secondary source
- Sources
08Payment services (money services other than stored value and money transmission)Category 3DUSD 200 kMinimum capital
- Permits
- Providing Money Services by operating a payment account, executing payment transactions on a payment account, or issuing payment instruments.
- Minimum capital
- Base Capital Requirement USD 200,000 (PIB 3.6.2). (≈USD 200 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Payment services in DIFC cannot extend to onshore UAE without CBUAE authorization. Safeguarding and EBCM apply to money services firms. PII removed for 3D from 1 July 2026.
- Systems
- Payment Service ProviderCard Issuing ProgramMerchant Acquiring
- Reading
- Read in the rulebook
- Sources
09Adviser / arrangerCategory 4USD 30 kMinimum capital
- Permits
- Advising on Financial Products, Arranging Deals in Investments, Arranging Custody, Insurance Intermediation and Insurance Management, Fund Administration, Arranging or Advising on Credit, and arranging or advising on money services.
- Minimum capital
- Base Capital Requirement USD 30,000 (PIB 3.6.2 as amended after CP161, per advisers citing VER54); previously USD 10,000. USD 140,000 applies to money transmission and crowdfunding platforms holding Client Assets (separate entry). (≈USD 30 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Application fee, Advising / Arranging (Category 4)USD 15,000 (USD 30,000 for certain group structures)Retail Endorsement fee (one-off)USD 20,000Annual fee, Category 4 (Advising / Arranging)USD 15,000 base, plus expenditure-based and per-service add-onsChange in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- USD 30,000 is reported by Kayrouz & Associates, Zitadelle and a guide citing PIB 3.6.2 VER54; the reachable older rulebook page shows USD 10,000, and a December 2025 article still quoted USD 10,000, so the increase most likely took effect with the 1 July 2026 amendments. Not read in the consolidated rulebook. Firms not holding Client Assets are no longer subject to EBCM from 1 July 2025. Usual route for introducing brokers and advisory-only family offices.
- Systems
- Investment Advisory FirmWhite-Label Brokerage
- Reading
- From a secondary source
- Sources
10Money transmitter / crowdfunding operatorCategory 4 (Money Transmission / Crowdfunding Platform holding Client Assets)USD 140 kMinimum capital
- Permits
- Providing Money Transmission (remittance) as a money service, or Operating a Crowdfunding Platform that holds Client Assets.
- Minimum capital
- Base Capital Requirement USD 140,000 (PIB 3.6.2 exception for Category 4). (≈USD 140 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Remittance to or from onshore UAE customers requires CBUAE licensing; DIFC money transmitters serve DIFC-based business. EBCM applies to money services.
- Systems
- Money Services Business
- Reading
- Read in the rulebook
- Sources
11Islamic Financial Institution (PSIAu)Category 5USD 10 mMinimum capital
- Permits
- An Islamic Financial Institution that manages a Profit Sharing Investment Account (Unrestricted), i.e. an Islamic bank model in DIFC.
- Minimum capital
- Base Capital Requirement USD 10 million (PIB 3.6.2), plus risk capital. (≈USD 10 m)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Must run its entire business as Islamic Financial Business with a Shari'a Supervisory Board (IFR module). Same onshore-deposit limits as Category 1.
- Systems
- Islamic Finance StructurePrivate Bank
- Reading
- Read in the rulebook
- Sources
12Islamic window of a conventional firmIslamic Window endorsementNo fixed figureMinimum capital
- Permits
- Lets a conventional Authorized Firm of any category carry on Islamic Financial Business through a separate window under the IFR module.
- Minimum capital
- No separate base capital; the firm's own category figure applies.
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Needs a Shari'a Supervisory Board, systems to segregate Islamic business, and IFR disclosures.
- Systems
- Islamic Finance Structure
- Reading
- From a secondary source
- Sources
13Crypto token firm (dealing, ATS, custody, managing, advising)Crypto Token activities (GEN Chapter 3A)No fixed figureMinimum capital
- Permits
- Ordinary financial services (dealing, arranging, advising, managing, custody, operating an ATS, fund management) carried on in relation to Crypto Tokens, which the DFSA treats as investments. The prudential category follows the activity (Category 2 principal dealing, 3A agency/ATS, 3B custody, 3C managing, 4 advising/arranging).
- Minimum capital
- No standalone crypto figure: the base capital of the category the activity falls into applies (see Categories 2 to 4); existing prudential requirements apply to crypto token activities.
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- From 12 January 2026 the DFSA no longer publishes a Recognised Crypto Token list; firms must document their own suitability assessment for each token and file monthly returns. Fiat Crypto Tokens (stablecoins) remain DFSA-determined (e.g. USDC, EURC, RLUSD). Privacy tokens and algorithmic tokens are prohibited. Representative offices cannot market crypto tokens.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
14Representative officeRepresentative OfficeNo fixed figureMinimum capital
- Permits
- Marketing financial services or products offered by its head office or group entities outside DIFC; no regulated activities may be carried on.
- Minimum capital
- No regulatory capital requirement.
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Professional only
- Conditions
- May not market crypto tokens. Useful as a first step for foreign firms testing the market.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- From a secondary source
- Sources
15Insurer, reinsurer or takaful operator (non-captive)Insurer (Effecting and Carrying Out Contracts of Insurance, PIN module)No fixed figureMinimum capital
- Permits
- Effecting and carrying out contracts of insurance as principal, including reinsurance; takaful operators also need an Islamic endorsement. May be set up as a subsidiary or a branch.
- Minimum capital
- Risk-based regulatory capital under the Prudential – Insurance Business (PIN) module, with a minimum capital requirement by type of insurer; the current non-captive minimum was not confirmed (a 2007 report put the long-term insurer minimum at USD 10 million after a cut from USD 100 million).
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Annual fee, Insurer (Effecting/Carrying Out Contracts of Insurance)USD 50,000 (2019 phased level)Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Retail, with conditions
- Conditions
- Insurers sit outside the PIB Categories 1 to 5. Branches may have the capital requirement waived if they provide a head office capital adequacy report (DFSA 2016 outreach). Check PIN for the current minimum by class.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- To be confirmed
- Sources
16Captive insurerCaptive Insurer (Class 1, 2 or 3, PIN module)USD 150 kMinimum capital
- Permits
- Insuring the risks of a parent and related companies (Class 1), mainly related risks with up to 20% unrelated business (Class 2), or acting as a group captive (Class 3); protected cell companies are allowed.
- Minimum capital
- Minimum capital USD 150,000 (Class 1), USD 250,000 (Class 2), USD 1,000,000 (Class 3); protected cell companies USD 50,000 cellular plus USD 50,000 non-cellular (Marsh summary of DFSA rules, 2016). (≈USD 150 k)
- Fees
- Application fee (range across Financial Services)USD 15,000 to USD 70,000Retail Endorsement fee (one-off)USD 20,000Change in control / controller approvalUSD 5,000 (USD 10,000 if complex)Withdrawal of authorizationUSD 1,500 to USD 5,000
- Clients
- Professional only
- Conditions
- Figures are from a 2016 broker summary and were not read in the current PIN module; confirm before budgeting.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
Reach
No passport. A DFSA license covers business in or from the DIFC only. Reaching onshore UAE clients requires onshore authorization or CMA promotion permissions (CMA Category 5 is open to free-zone firms). No EU or GCC passport.
Passage
Market practice: about 6 to 9 months from first meeting to license for a standard asset manager; Category 4 advisory/arranging files often 4 to 6 months, Category 3A brokers 8 to 12 months (adviser estimates). No statutory decision deadline was located.
Licensed elsewhere
Onshore UAE banks, finance companies, exchange houses, payment and stored value providers, payment token issuers and insurers: CBUAE. Onshore securities brokers, fund managers and VASPs outside Dubai: CMA (formerly SCA). Virtual asset firms in Dubai outside DIFC: VARA. Single family offices in DIFC register with the DIFC Authority under the Family Arrangements Regulations rather than being DFSA-licensed unless they carry on financial services for third parties. Sovereign vehicles, physical commodity trading houses (DMCC/DIFC Authority registration) and mining/validation operations are not DFSA-licensed activities. DFSA does not run a stablecoin issuance license; AED stablecoins are CBUAE-only.
Notes. CP161 (October 2024; feedback statement and final rules 21 May 2025) reshaped DFSA prudential rules in two phases: from 1 July 2025 the Expenditure-Based Capital Minimum stopped applying to Category 3 and 4 firms that hold no Client Assets (DFSA letter of 17 June 2025) and the expenditure factor fell from 18/52 to 13/52; from 1 July 2026 (PIB Rule-Making Instrument No. 413 of 2025, plus No. 414 made in October 2025) Category 3 firms are subject to an Activity-Based Capital Requirement (K-AUM, K-ASA, K-COH), base capital figures were revised (3A to USD 200,000; 3C asset managers USD 140,000; non-public fund managers USD 40,000; Category 4 USD 30,000, per advisers citing PIB VER54), ATS operators moved to 3A, matched-principal dealing moved to Category 2, and PII was removed for 3C and 3D. A separate operational-risk capital instrument (CP164) also took effect on 1 July 2026. The crypto token regime was overhauled on 12 January 2026 (firm-level suitability assessments). The consolidated amended PIB text could not be read directly (the reachable PIB 3.6.2 page shows the 2020 version), so the post-reform figures are marked secondary and Category 3B and non-captive insurer capital remain uncertain. Source for dates: https://regalert.today/document/91ea1a91-6c45-49db-8663-26163fbbbe46/text
Middle East · UAE · Abu Dhabi, ADGM
FSRA
Financial Services Regulatory Authority (Abu Dhabi Global Market)
The FSRA is the integrated regulator for financial services in ADGM, an Abu Dhabi financial free zone that applies English common law directly. It grants Financial Services Permissions under the Financial Services and Markets Regulations 2015 (FSMR) and assigns firms to prudential Categories 1, 2, 3A, 3B, 3C, 4 and 5 under the PRU rulebook. It runs one of the region's most developed virtual asset and fiat-referenced token regimes; like DIFC, an ADGM license does not authorize onshore UAE business.
#9of 34
Balanced score
76 of 100
76 of 100
Scorecard
Credibility ×35%100Breadth ×15%87Entry threshold ×20%64Speed ×15%70Reach ×15%30
Categories14
Systems covered41 of 47
Typical timeline3–12 monthsmarket practice
Lowest capitalUSD 50 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 5 k–125 k12 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 5 k–100 k11 items · Recurring fees and levies
OtherUSD 500–6 k4 items · Mandatory charges that arise in operation
FSRA fees stack per Regulated Activity, so a multi-activity broker pays several application and supervision fees, plus USD 40,000 a year extra for retail OTC leveraged products; foreign branches pay 50% of the highest relevant fee. ADGM Registration Authority company and commercial license fees are separate.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Application fee, Accepting Deposits / Providing CreditFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Applies to Category 2 only where Providing Credit is sought. Confirmed by a 2026 adviser article (providing credit USD 70,000). | USD 70,000 | Category 1; Category 2 | Read in the rulebook |
| Application fee, Dealing in Investments as Principal or AgentFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). The FEES table groups dealing as agent with dealing as principal. A 2026 adviser article instead quotes USD 25,000 for Category 3A agency/matched-principal dealing; the rulebook figure is used here. | USD 40,000 | Category 2; Category 3A | Read in the rulebook |
| Application fee, OTC leveraged products (add-on)Figures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Additional fee for firms dealing in OTC leveraged products (FX/CFDs); USD 40,000 where offered to Retail Clients. | USD 40,000 (retail clients); USD 5,000 (other clients) | Category 2; Category 3A | Read in the rulebook |
| Application fee, Managing Assets / Providing Custody / Trust servicesFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Acting as trustee of an investment trust (a 3B activity) is in the USD 10,000 band. | USD 25,000 | Category 3C (Managing Assets / Custody / PSIAr / express trustee); Category 3B | Read in the rulebook |
| Application fee, Managing a Collective Investment Fund / VC fund / fund administrationFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Same USD 10,000 band covers arranging credit, investment trust trustee, MTF/OTF operation (non-VA), credit rating and private financing platforms. | USD 10,000 | Category 3C (Fund Manager – Managing a Collective Investment Fund); Category 3C (Venture Capital Fund Manager) | Read in the rulebook |
| Application fee, Advising / Arranging (Category 4)Figures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Advising, arranging deals, arranging custody and insurance intermediation USD 15,000; the USD 10,000 band covers arranging credit, operating an MTF/OTF, fund administration and private financing platforms. Confirmed by a 2026 adviser article. | USD 15,000 (USD 10,000 for arranging credit, MTF/OTF, fund administration, private financing platform) | Category 4 | Read in the rulebook |
| Application fee, Providing Money ServicesFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 15,000 (currency exchange or remittance); USD 25,000 (payment services, or both) | Category 3C (Providing Money Services) | Read in the rulebook |
| Application fee, Operating an MTF using Virtual AssetsFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 125,000 | Operating an MTF using Virtual Assets | Read in the rulebook |
| Application fee, other Regulated Activities in relation to Virtual AssetsFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Applies per Regulated Activity carried on in relation to Virtual Assets other than operating an MTF (e.g. VA dealing, custody, management, advising). Whether it replaces or adds to the standard activity fee was not confirmed. Fees for issuing a fiat-referenced token (3C) were not located. | USD 20,000 per activity | Category 2; Category 3A; Category 3C (Managing Assets / Custody / PSIAr / express trustee); Category 4 | Read in the rulebook |
| Application / annual fee, Managing a Profit Sharing Investment AccountFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Mapped to Category 5 (PSIAu); a Category 5 firm also pays the deposit-taking fees where it accepts deposits. The same USD 30,000 is payable annually. | USD 30,000 application; USD 30,000 annual | Category 5 | Read in the rulebook |
| Application fee, InsurerFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Annual supervision USD 50,000 for insurers, USD 5,000 for captives/SPVs; cell companies add USD 8,000 plus USD 1,000 per cell. | USD 40,000 (captive insurer or insurance SPV USD 5,000) | Insurer (Effecting and Carrying Out Contracts of Insurance, PIN rules) | Read in the rulebook |
| Representative officeFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). The same amount is payable annually. | USD 5,000 application; USD 5,000 annual | Representative Office | Read in the rulebook |
| Every year | |||
| Annual supervision fee, Accepting Deposits / Providing CreditFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). An extra USD 10,000 applies where a firm both accepts deposits and provides credit (or manages a profit-sharing investment account and provides credit). | USD 100,000 (USD 110,000 if both) | Category 1; Category 2 | Read in the rulebook |
| Annual supervision fee, Dealing in Investments as Principal or AgentFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). A 2026 adviser article quotes USD 25,000 for Category 3A; rulebook figure used. | USD 50,000 | Category 2; Category 3A | Read in the rulebook |
| Annual supervision fee, OTC leveraged products (add-on)Figures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 40,000 (retail clients); USD 5,000 (other clients) | Category 2; Category 3A | Read in the rulebook |
| Annual supervision fee, Managing Assets / Providing Custody / Trust servicesFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 25,000 | Category 3C (Managing Assets / Custody / PSIAr / express trustee); Category 3B | Read in the rulebook |
| Annual supervision fee, Managing a Collective Investment Fund / VC fundFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 10,000 | Category 3C (Fund Manager – Managing a Collective Investment Fund); Category 3C (Venture Capital Fund Manager) | Read in the rulebook |
| Annual supervision fee, Advising / Arranging (Category 4)Figures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 15,000 (USD 10,000 band as above) | Category 4 | Read in the rulebook |
| Annual supervision fee, Providing Money ServicesFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 15,000 (currency exchange or remittance); USD 25,000 (payment services, or both) | Category 3C (Providing Money Services) | Read in the rulebook |
| Annual supervision fee, Operating an MTF using Virtual AssetsFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Plus a monthly levy on average daily trading value: 0.0015% up to USD 10m, 0.0012% for USD 10m to 50m, 0.0009% for USD 50m to 250m, 0.0006% above USD 250m. | USD 60,000 plus monthly trading levy | Operating an MTF using Virtual Assets | Read in the rulebook |
| Virtual asset MTF trading levyTiered by daily trading value (up to USD 10m: 0.0015%; 10m to 50m: 0.0012%; 50m to 250m: 0.0009%; above 250m: 0.0006%). | 0.0006% to 0.0015% of daily trading value, charged monthly | Operating an MTF using Virtual Assets | Read in the rulebook |
| Annual supervision fee, other Regulated Activities in relation to Virtual AssetsFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 15,000 per activity | Category 2; Category 3A; Category 3C (Managing Assets / Custody / PSIAr / express trustee); Category 4 | Read in the rulebook |
| Annual supervision fee, InsurerFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 50,000 (captive insurer or insurance SPV USD 5,000) | Insurer (Effecting and Carrying Out Contracts of Insurance, PIN rules) | Read in the rulebook |
| Other | |||
| Approved Person applicationFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Per application for an Approved Person (controlled function holder). | USD 500 per individual | All categories | Read in the rulebook |
| Controller applicationFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). | USD 1,000 per application | All categories | Read in the rulebook |
| Public fund registrationFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Umbrella funds: USD 6,000 for the first sub-fund and USD 3,000 per additional sub-fund. Exempt and Qualified Investor Funds pay a USD 2,000 annual notification fee (umbrella: plus USD 1,000 per extra sub-fund). Public fund prospectus filing USD 6,000. | USD 6,000 application; USD 6,000 annual renewal | Category 3C (Fund Manager – Managing a Collective Investment Fund) | Read in the rulebook |
| Exempt / Qualified Investor Fund notificationFigures from the ADGM FEES Rules text published by ADGM (amendments appendix, 2024 asset). Umbrella funds pay USD 2,000 plus USD 1,000 per additional sub-fund. | USD 2,000 per year | Category 3C (Fund Manager – Managing a Collective Investment Fund); Category 3C (Venture Capital Fund Manager) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 500 k
Fund managerCategory 3C (Fund Manager – Managing a Collective Investment Fund)
USD 50 k
Venture capital fund managerCategory 3C (Venture Capital Fund Manager)
USD 50 k
Adviser / arranger / MTF-OTF operatorCategory 4
USD 50 k
Asset / wealth manager; custodianCategory 3C (Managing Assets / Custody / PSIAr / express trustee)
USD 250 k
Money services firm (remittance, payment services, stored value, currency exchange)Category 3C (Providing Money Services)
USD 250 k
Matched-principal / agency brokerCategory 3A
USD 500 k
Principal dealer / credit providerCategory 2
USD 2 m
Fiat-referenced token (stablecoin) issuerCategory 3C (Issuing a Fiat-Referenced Token)
USD 2 m
Public fund custodian / investment trust trusteeCategory 3B
USD 4 m
Bank (deposit-taker)Category 1
USD 10 m
Islamic Financial Institution (PSIAu)Category 5
USD 10 m
10k100k1m10m
11 of 14 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
14 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Bank (deposit-taker)Category 1USD 10 mMinimum capital
- Permits
- Accepting Deposits (plus any lower-category activities on the permission).
- Minimum capital
- Base Capital Requirement USD 10 million (PRU, Appendix A3), plus Risk Capital Requirement (credit, market, operational and CVA risk). (≈USD 10 m)
- Fees
- Application fee, Accepting Deposits / Providing CreditUSD 70,000Annual supervision fee, Accepting Deposits / Providing CreditUSD 100,000 (USD 110,000 if both)Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- ADGM firms may not take deposits from the onshore UAE market in the way a CBUAE bank can; retail business carries additional conduct rules.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTrade Finance House
- Reading
- Read in the rulebook
- Sources
02Principal dealer / credit providerCategory 2USD 2 mMinimum capital
- Permits
- Dealing in Investments as Principal (not as Matched Principal) and Providing Credit.
- Minimum capital
- Base Capital Requirement USD 2 million (PRU), plus risk capital. (≈USD 2 m)
- Fees
- Application fee, Accepting Deposits / Providing CreditUSD 70,000Annual supervision fee, Accepting Deposits / Providing CreditUSD 100,000 (USD 110,000 if both)Application fee, Dealing in Investments as Principal or AgentUSD 40,000Annual supervision fee, Dealing in Investments as Principal or AgentUSD 50,000Application fee, OTC leveraged products (add-on)USD 40,000 (retail clients); USD 5,000 (other clients)Annual supervision fee, OTC leveraged products (add-on)USD 40,000 (retail clients); USD 5,000 (other clients)Application fee, other Regulated Activities in relation to Virtual AssetsUSD 20,000 per activityAnnual supervision fee, other Regulated Activities in relation to Virtual AssetsUSD 15,000 per activityApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Market-maker CFD/FX brokers, principal crypto dealers, direct lenders and structured product dealers sit here. Retail OTC leveraged products are subject to COBS retail protections.
- Systems
- Retail BrokerageInstitutional BrokeragePrime BrokeragePrime-of-PrimeMulti-Asset BrokerageOTC Digital Asset DeskStructured Products IssuerTrade Finance HouseInvestment Bank
- Reading
- Read in the rulebook
- Sources
03Matched-principal / agency brokerCategory 3AUSD 500 kMinimum capital
- Permits
- Dealing in Investments as Matched Principal and Dealing in Investments as Agent.
- Minimum capital
- Base Capital Requirement USD 500,000; USD 2 million where the firm deals as Matched Principal in OTC derivatives with Retail Clients (FSRA Getting Started Guide, May 2025). (≈USD 500 k)
- Fees
- Application fee, Dealing in Investments as Principal or AgentUSD 40,000Annual supervision fee, Dealing in Investments as Principal or AgentUSD 50,000Application fee, OTC leveraged products (add-on)USD 40,000 (retail clients); USD 5,000 (other clients)Annual supervision fee, OTC leveraged products (add-on)USD 40,000 (retail clients); USD 5,000 (other clients)Application fee, other Regulated Activities in relation to Virtual AssetsUSD 20,000 per activityAnnual supervision fee, other Regulated Activities in relation to Virtual AssetsUSD 15,000 per activityApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- The 2025 lower-risk-firm amendments did not change 3A. Risk-based requirements per PRU apply.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokerageOTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
04Public fund custodian / investment trust trusteeCategory 3BUSD 4 mMinimum capital
- Permits
- Providing Custody for a Public Fund and Acting as the Trustee of an Investment Trust.
- Minimum capital
- Base Capital Requirement USD 4 million (PRU). (≈USD 4 m)
- Fees
- Application fee, Managing Assets / Providing Custody / Trust servicesUSD 25,000Annual supervision fee, Managing Assets / Providing Custody / Trust servicesUSD 25,000Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Professional only
- Conditions
- From 19 August 2025 custody for funds other than Public Funds carries a USD 250,000 BCR instead (3C). IRAP reporting removed for 3B from 19 August 2025.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
05Asset / wealth manager; custodianCategory 3C (Managing Assets / Custody / PSIAr / express trustee)USD 250 kMinimum capital
- Permits
- Managing Assets, Providing Custody (other than for a Public Fund), Managing a Profit Sharing Investment Account (Restricted), and Providing Trust Services as trustee of an express trust.
- Minimum capital
- Base Capital Requirement USD 250,000 (PRU 3.3.2). Custody for non-public funds: USD 250,000 from 19 August 2025. Expenditure-Based Capital Minimum applies (13/52 of annual audited expenditure without client assets, 18/52 with client assets; 26/52 for custody of Virtual Assets). (≈USD 250 k)
- Fees
- Application fee, Managing Assets / Providing Custody / Trust servicesUSD 25,000Annual supervision fee, Managing Assets / Providing Custody / Trust servicesUSD 25,000Application fee, other Regulated Activities in relation to Virtual AssetsUSD 20,000 per activityAnnual supervision fee, other Regulated Activities in relation to Virtual AssetsUSD 15,000 per activityApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Lower requirements are available to qualifying digital investment managers (robo-advisers). Virtual asset custody adds the 26/52 EBCM.
- Systems
- Asset Management CompanyWealth Management FirmMulti-Family OfficePension & Endowment ManagerQuantitative Trading DeskCustody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
06Fund managerCategory 3C (Fund Manager – Managing a Collective Investment Fund)USD 50 kMinimum capital
- Permits
- Managing a Collective Investment Fund (Public, Exempt, Qualified Investor, Property/REIT and Venture Capital Funds).
- Minimum capital
- USD 250,000 in general; where managing funds is the only activity, USD 150,000 if it manages a Public Fund or any fund available to Retail Clients, and USD 50,000 for any other fund (PRU 3.3.2; FSRA Getting Started Guide, May 2025). (≈USD 50 k)
- Fees
- Application fee, Managing a Collective Investment Fund / VC fund / fund administrationUSD 10,000Annual supervision fee, Managing a Collective Investment Fund / VC fundUSD 10,000Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per applicationPublic fund registrationUSD 6,000 application; USD 6,000 annual renewalExempt / Qualified Investor Fund notificationUSD 2,000 per year
- Clients
- Retail, with conditions
- Conditions
- Public Funds may be offered to retail; Exempt and Qualified Investor Funds are professional-only. EBCM applies.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmPrivate Credit FundReal Estate Investment VehicleMutual Fund & UCITSETF PlatformDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
07Venture capital fund managerCategory 3C (Venture Capital Fund Manager)USD 50 kMinimum capital
- Permits
- Managing a Collective Investment Fund that is a Venture Capital Fund under the FSRA's VC Fund Manager framework.
- Minimum capital
- No separate figure is stated in the FSRA guide; a firm whose only activity is managing non-public funds falls under the USD 50,000 PRU 3.3.2 tier. FSRA authorization fee USD 10,000. (≈USD 50 k)
- Fees
- Application fee, Managing a Collective Investment Fund / VC fund / fund administrationUSD 10,000Annual supervision fee, Managing a Collective Investment Fund / VC fundUSD 10,000Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per applicationExempt / Qualified Investor Fund notificationUSD 2,000 per year
- Clients
- Professional only
- Conditions
- Professional investors only. Since 10 June 2025 Venture Capital Funds may also invest in virtual assets, directly or through a master fund. Reduced ADGM incorporation fees for the first three years.
- Systems
- Venture Capital Firm
- Reading
- From a secondary source
- Sources
08Money services firm (remittance, payment services, stored value, currency exchange)Category 3C (Providing Money Services)USD 250 kMinimum capital
- Permits
- Providing Money Services: currency exchange, money remittance, payment services (payment accounts, payment transactions, payment instruments, acquiring) and issuing stored value.
- Minimum capital
- Base Capital Requirement USD 250,000, or if higher the EBCM (PRU 3.7) and a Variable Capital Requirement (PRU 3.6A.2 for remitters, 3.6A.4 for payment service providers, 3.6A.6 for stored value providers). (≈USD 250 k)
- Fees
- Application fee, Providing Money ServicesUSD 15,000 (currency exchange or remittance); USD 25,000 (payment services, or both)Annual supervision fee, Providing Money ServicesUSD 15,000 (currency exchange or remittance); USD 25,000 (payment services, or both)Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Safeguarding of relevant money; VCR formula scales with payment volume or outstanding stored value. Onshore UAE customers require CBUAE licensing.
- Systems
- Electronic Money InstitutionPayment Service ProviderMoney Services BusinessCard Issuing ProgramMerchant Acquiring
- Reading
- Read in the rulebook
- Sources
09Fiat-referenced token (stablecoin) issuerCategory 3C (Issuing a Fiat-Referenced Token)USD 2 mMinimum capital
- Permits
- Issuing a Fiat-Referenced Token (single-fiat-backed stablecoin) in or from ADGM.
- Minimum capital
- Base Capital Requirement USD 2 million (PRU 3.3.2 exception), and EBCM of one year of annual audited expenditure. (≈USD 2 m)
- Fees
- Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Full reserve backing, redemption and disclosure rules. Algorithmic stablecoins are prohibited in ADGM. AED-referenced payment tokens are under CBUAE purview onshore.
- Systems
- Stablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
10Adviser / arranger / MTF-OTF operatorCategory 4USD 50 kMinimum capital
- Permits
- Arranging Credit or Deals in Investments, Advising on Investments or Credit, Arranging Custody, Administering a Benchmark, Insurance Intermediation and Management, Acting as Administrator of a Fund, Operating an MTF or OTF, Operating a Private Financing Platform, Providing Third Party Services, and trust services other than as express trustee.
- Minimum capital
- Base Capital Requirement USD 50,000 from 19 August 2025 (previously USD 10,000); USD 150,000 for a Private Financing Platform holding Client Assets. Firms that hold no Client Assets or Insurance Money are no longer subject to EBCM. (≈USD 50 k)
- Fees
- Application fee, Advising / Arranging (Category 4)USD 15,000 (USD 10,000 for arranging credit, MTF/OTF, fund administration, private financing platform)Annual supervision fee, Advising / Arranging (Category 4)USD 15,000 (USD 10,000 band as above)Application fee, other Regulated Activities in relation to Virtual AssetsUSD 20,000 per activityAnnual supervision fee, other Regulated Activities in relation to Virtual AssetsUSD 15,000 per activityApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- MTF/OTF operators stay subject to EBCM. PII minimum standards apply for renewals from 1 January 2026. Usual route for introducing brokers and advisory-only firms.
- Systems
- Investment Advisory FirmWhite-Label BrokerageECN & DMA VenueTokenization Platform
- Reading
- Read in the rulebook
- Sources
11Virtual asset exchange (MTF)Operating an MTF using Virtual AssetsNo fixed figureMinimum capital
- Permits
- Operating a Multilateral Trading Facility on which Accepted Virtual Assets are traded, often combined with custody.
- Minimum capital
- Regulatory capital equal to 6 months of operating expenses, plus, unless the FSRA directs otherwise, an additional buffer of up to 6 further months (rules as amended 10 June 2025). Before June 2025 the requirement was 12 months of operating expenses.
- Fees
- Application fee, Operating an MTF using Virtual AssetsUSD 125,000Annual supervision fee, Operating an MTF using Virtual AssetsUSD 60,000 plus monthly trading levyVirtual asset MTF trading levy0.0006% to 0.0015% of daily trading value, charged monthlyApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Virtual assets must meet the FSRA's Accepted Virtual Asset criteria (since June 2025 a firm self-assessment and notification process). Privacy tokens and algorithmic stablecoins are prohibited. FSRA authorization fee for MTF USD 125,000 (USD 145,000 with custody).
- Systems
- Digital Asset ExchangeTokenization Platform
- Reading
- From a secondary source
- Sources
12Islamic Financial Institution (PSIAu)Category 5USD 10 mMinimum capital
- Permits
- An Islamic Financial Institution managing a Profit Sharing Investment Account (Unrestricted).
- Minimum capital
- Base Capital Requirement USD 10 million, plus Risk Capital Requirement including the Displaced Commercial Bank Capital Requirement and CVA risk. (≈USD 10 m)
- Fees
- Application / annual fee, Managing a Profit Sharing Investment AccountUSD 30,000 application; USD 30,000 annualApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Shari'a Supervisory Board and Islamic Finance Rules (IFR) apply. Conventional firms can run an Islamic Window without changing category.
- Systems
- Islamic Finance StructurePrivate Bank
- Reading
- Read in the rulebook
- Sources
13Representative officeRepresentative OfficeNo fixed figureMinimum capital
- Permits
- Marketing the products and services of its head office or group; no regulated activities.
- Minimum capital
- No regulatory capital requirement set out in the materials reviewed.
- Fees
- Representative officeUSD 5,000 application; USD 5,000 annualApproved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Professional only
- Conditions
- Not a prudential category.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- To be confirmed
- Sources
14Insurer, reinsurer or captiveInsurer (Effecting and Carrying Out Contracts of Insurance, PIN rules)No fixed figureMinimum capital
- Permits
- Effecting and carrying out contracts of insurance, including reinsurance and captive insurance cells.
- Minimum capital
- Set by the FSRA Prudential – Insurance (PIN) rules; figures not confirmed.
- Fees
- Application fee, InsurerUSD 40,000 (captive insurer or insurance SPV USD 5,000)Annual supervision fee, InsurerUSD 50,000 (captive insurer or insurance SPV USD 5,000)Approved Person applicationUSD 500 per individualController applicationUSD 1,000 per application
- Clients
- Retail, with conditions
- Conditions
- Insurers are outside the PRU Categories 1 to 5 and subject to the PIN prudential rulebook.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- To be confirmed
- Sources
Reach
No passport. Permission covers business in or from ADGM; onshore UAE clients require CBUAE or CMA authorization (or CMA promotion permissions). No EU or GCC passport.
Passage
Market practice: roughly 6 to 12 months for conventional firms; 12 to 24 months for virtual asset firms (adviser estimates). The FSRA's Getting Started Guide (May 2025) sets out stages (initial meetings, application, review, in-principle approval, conditions, issue of permission) but no service standard.
Licensed elsewhere
Onshore UAE banks, finance companies, exchange houses, SVF and retail payment providers, payment token issuers and insurers: CBUAE. Onshore brokers, fund managers and VASPs: CMA (formerly SCA). Dubai virtual asset firms outside DIFC: VARA. Proprietary trading on own capital without clients and physical commodity trading are not FSRA-licensed activities as such; the ADGM Registration Authority handles single family office and holding/SPV structures (e.g. foundations), and sovereign vehicles are not FSRA-licensed. Mining and validation are not licensed activities.
Notes. Lower-risk-firm prudential amendments (Consultation Paper No. 2 of 2025) took effect 19 August 2025: Category 4 BCR raised to USD 50,000, EBCM removed for Category 4 firms not holding Client Assets or Insurance Money, custody of non-public funds cut to USD 250,000, IRAP removed for 3B/3C, PII removed for branches; PII minimum standards from 1 January 2026. Digital asset framework amendments (10 June 2025, following CP No. 11 of 2024) moved Accepted Virtual Asset approval to a notification process, aligned VA capital with traditional assets except MTF operators, added product intervention powers, and let VC funds invest in virtual assets. The fiat-referenced token regime (issuance as a 3C activity at USD 2 million) followed CP No. 7 of 2024.
Middle East · UAE · Dubai
VARA
Virtual Assets Regulatory Authority
Tier 2Official site
VARA, created by Dubai Law No. 4 of 2022, licenses and supervises virtual asset service providers in Dubai, including Dubai's free zones other than DIFC (which is DFSA territory). Licensing is activity-based under the Virtual Assets and Related Activities Regulations 2023 and a set of Compulsory and Activity Rulebooks. A firm also needs a commercial license from the Dubai Department of Economy and Tourism or a free-zone authority.
#26of 34
Balanced score
53 of 100
53 of 100
Scorecard
Credibility ×35%65Breadth ×15%15Entry threshold ×20%68Speed ×15%60Reach ×15%35
Categories10
Systems covered7 of 47
Typical timeline6–12 monthsmarket practice
Lowest capitalUSD 27 k
IOSCO MMoUN/A
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 11 k–27 k2 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 22 k–54 k2 items · Recurring fees and levies
OtherFormula2 items · Mandatory charges that arise in operation
VARA fees are charged per VA Activity and recur in full every year, so a full-stack exchange (exchange, broker-dealer, custody) faces AED 600,000 in annual supervision fees before any risk-based uplift. Trade license fees from DET or the relevant free zone are separate.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Licence Application Fee (one VA Activity), Advisory / Transfer and SettlementVARA Company Rulebook, Schedule 2. Payable on submission; VARA does not process an application until paid. | AED 40,000≈ USD 11 k | Advisory Services; VA Transfer and Settlement Services | Read in the rulebook |
| Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceVARA Company Rulebook, Schedule 2. The rulebook's table renders the extension column as a merged cell; the application and supervision figures were read the same way on two renderings. Category 1 VA Issuance (covering FRVA and ARVA since the May 2025 rulebooks) carries the same fees. | AED 100,000≈ USD 27 k | Broker-Dealer Services; Custody Services; Exchange Services; Lending and Borrowing Services and 3 more | Read in the rulebook |
| Every year | |||
| Annual Supervision Fee, Advisory / Transfer and SettlementVARA Company Rulebook, Schedule 2. Payable for each licensed VA Activity before carrying it on, and annually thereafter. | AED 80,000 per activity≈ USD 22 k | Advisory Services; VA Transfer and Settlement Services | Read in the rulebook |
| Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceVARA Company Rulebook, Schedule 2. Per activity, so an exchange that also offers broker-dealer and custody services pays AED 600,000 a year. VARA may impose additional supervision fees based on risk profile, market share, client base, complexity and compliance history. | AED 200,000 per activity≈ USD 54 k | Broker-Dealer Services; Custody Services; Exchange Services; Lending and Borrowing Services and 3 more | Read in the rulebook |
| Other | |||
| Licence Extension Fee (each additional VA Activity)VARA Company Rulebook, Schedule 2. Charged for each additional VA Activity applied for in the same application: e.g. AED 20,000 for an extra AED 40,000 activity or AED 50,000 for an extra AED 100,000 activity. | 50% of the lower Licence Application Fee(s) | All categories | Read in the rulebook |
| Issuance approval and whitepaper feesVARA Company Rulebook, Schedule 2. VARA may charge a fee, at its discretion, for approval to issue a virtual asset and for whitepaper submissions by Category 1 VA Issuance licensees; no amount is set in Schedule 2. | Discretionary (amount not published) | Category 1 VA Issuance – Fiat-Referenced Virtual Assets (FRVA); Category 1 VA Issuance – Asset-Referenced Virtual Assets (ARVA); Category 2 VA Issuance | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 136 k
VA adviserAdvisory Services
USD 27 k
VA portfolio / investment managerVA Management and Investment Services
USD 76 k
VA broker-dealer / OTC deskBroker-Dealer Services
USD 109 k
VA lending and borrowingLending and Borrowing Services
USD 136 k
VA transfer and settlementVA Transfer and Settlement Services
USD 136 k
VA custodianCustody Services
USD 163 k
VA exchangeExchange Services
USD 218 k
Stablecoin issuer (non-AED)Category 1 VA Issuance – Fiat-Referenced Virtual Assets (FRVA)
USD 408 k
Real-world-asset token issuerCategory 1 VA Issuance – Asset-Referenced Virtual Assets (ARVA)
USD 408 k
10k100k1m
9 of 10 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
10 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01VA adviserAdvisory ServicesUSD 27 kMinimum capital
- Permits
- Giving advice or recommendations on virtual assets or VA activities.
- Minimum capital
- Paid-up capital AED 100,000 (Company Rulebook VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 27 k)
- Fees
- Licence Application Fee (one VA Activity), Advisory / Transfer and SettlementAED 40,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Advisory / Transfer and SettlementAED 80,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2).
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
02VA broker-dealer / OTC deskBroker-Dealer ServicesUSD 109 kMinimum capital
- Permits
- Arranging orders, dealing on own account or for clients, matched-principal and OTC trading in virtual assets, and placement or distribution of VA issuances.
- Minimum capital
- Paid-up capital: the higher of AED 400,000 or 15% of fixed annual overheads where a VARA-licensed custodian or approved arrangement is used; otherwise the higher of AED 600,000 or 25% of fixed annual overheads (VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 109 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2). Category 2 VA issuances must be distributed through a licensed distributor (a Broker-Dealer).
- Systems
- OTC Digital Asset DeskTokenization Platform
- Reading
- Read in the rulebook
- Sources
03VA custodianCustody ServicesUSD 163 kMinimum capital
- Permits
- Safekeeping virtual assets and private keys on behalf of clients.
- Minimum capital
- Paid-up capital: the higher of AED 600,000 or 25% of fixed annual overheads (VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 163 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2).
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
04VA exchangeExchange ServicesUSD 218 kMinimum capital
- Permits
- Operating a venue that matches orders between buyers and sellers of virtual assets, including fiat-to-VA and VA-to-VA trading.
- Minimum capital
- Paid-up capital: the higher of AED 800,000 or 15% of fixed annual overheads where a VARA-licensed custodian or approved arrangement is used; otherwise the higher of AED 1,500,000 or 25% of fixed annual overheads (VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 218 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2).
- Systems
- Digital Asset Exchange
- Reading
- Read in the rulebook
- Sources
05VA lending and borrowingLending and Borrowing ServicesUSD 136 kMinimum capital
- Permits
- Lending or borrowing virtual assets, or arranging such transactions, for clients.
- Minimum capital
- Paid-up capital: the higher of AED 500,000 or 25% of fixed annual overheads (VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 136 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2).
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
06VA portfolio / investment managerVA Management and Investment ServicesUSD 76 kMinimum capital
- Permits
- Managing virtual asset portfolios or investments on a discretionary basis, including VA-focused investment vehicles.
- Minimum capital
- Paid-up capital: the higher of AED 280,000 or 15% of fixed annual overheads where a VARA-licensed custodian or approved arrangement is used; otherwise the higher of AED 500,000 or 25% of fixed annual overheads (VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 76 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2). A fund vehicle offered to investors may also need fund regulation from the relevant securities regulator.
- Systems
- Digital Asset Fund
- Reading
- Read in the rulebook
- Sources
07VA transfer and settlementVA Transfer and Settlement ServicesUSD 136 kMinimum capital
- Permits
- Transferring virtual assets between wallets or persons and settling VA transactions for clients.
- Minimum capital
- Paid-up capital: the higher of AED 500,000 or 25% of fixed annual overheads (VI.B.1). Ongoing: Net Liquid Assets of at least 1.2 times monthly operating expenses (Company Rulebook VI.C.1) and reserve assets equal to 100% of client liabilities held 1:1 in the same virtual asset (VI.E). (≈USD 136 k)
- Fees
- Licence Application Fee (one VA Activity), Advisory / Transfer and SettlementAED 40,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Advisory / Transfer and SettlementAED 80,000 per activity
- Clients
- Retail, with conditions
- Conditions
- Retail, qualified and institutional investors are distinguished in the Market Conduct and activity rulebooks; retail access is allowed subject to those rules. Insurance cover (PI, D&O, hot-wallet crime) required (VI.D). Where several VA activities are licensed, paid-up capital is required for each activity separately (VI.B.2).
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
08Stablecoin issuer (non-AED)Category 1 VA Issuance – Fiat-Referenced Virtual Assets (FRVA)USD 408 kMinimum capital
- Permits
- Issuing a virtual asset that references one or more fiat currencies, with VARA approval for each FRVA.
- Minimum capital
- Paid-up capital: AED 1,500,000 plus 2% of the value of the FRVA's available supply (VA Issuance Rulebook, FRVA Rules III.F.1); 100% reserve backing (III.B.1). (≈USD 408 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activityIssuance approval and whitepaper feesDiscretionary (amount not published)
- Clients
- Retail, with conditions
- Conditions
- Requires a VARA license and prior approval of each FRVA. AED-pegged FRVAs are under the sole purview of the CBUAE and cannot be approved by VARA (FRVA Rules I.B.4). Licence may be revoked if no issuance within six months of approval. Whitepaper and risk disclosure required.
- Systems
- Stablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
09Real-world-asset token issuerCategory 1 VA Issuance – Asset-Referenced Virtual Assets (ARVA)USD 408 kMinimum capital
- Permits
- Issuing a virtual asset that represents ownership of, or rights to, real-world assets such as commodities, real estate or financial instruments, with VARA approval for each ARVA.
- Minimum capital
- Paid-up capital: the higher of AED 1,500,000 or 2% of the average market value of the reserve assets over the preceding 24 months (VA Issuance Rulebook, ARVA Rules III.G.1). (≈USD 408 k)
- Fees
- Licence Application Fee (one VA Activity), Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 100,000Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Annual Supervision Fee, Broker-Dealer / Custody / Exchange / Lending and Borrowing / VA Management and Investment / Category 1 VA IssuanceAED 200,000 per activityIssuance approval and whitepaper feesDiscretionary (amount not published)
- Clients
- Retail, with conditions
- Conditions
- Requires a VARA license and prior approval of each ARVA; reserve assets and six-monthly audits of circulation and reserves. ARVAs that are in substance securities may also engage securities law.
- Systems
- Tokenization Platform
- Reading
- Read in the rulebook
- Sources
10Other token issuance (no license)Category 2 VA IssuanceNo fixed figureMinimum capital
- Permits
- Issuing any virtual asset that is not Category 1 or Exempt, without a VARA license or prior approval.
- Minimum capital
- No license and no capital requirement for the issuer; placement or distribution must go through a VARA Licensed Distributor (VA Issuance Rulebook I.E.1).
- Fees
- Licence Extension Fee (each additional VA Activity)50% of the lower Licence Application Fee(s)Issuance approval and whitepaper feesDiscretionary (amount not published)
- Clients
- Retail, with conditions
- Conditions
- Whitepaper and risk disclosure required; the distributor must check the issuer's compliance. VARA does not treat these tokens as approved.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
Reach
None. A VARA license covers Dubai only. Virtual asset activity in other emirates falls to the CMA (formerly SCA), in ADGM to the FSRA, and in DIFC to the DFSA.
Passage
Market practice: staged process (initial disclosure, provisional approval, minimum viable product phase, full operational license), typically 6 to 12 months or longer. No statutory deadline located.
Licensed elsewhere
VARA covers only virtual asset activities in Dubai outside DIFC. DIFC crypto: DFSA. ADGM crypto: FSRA. Other emirates and onshore federal VA: CMA (formerly SCA). AED-referenced stablecoins and payment tokens: CBUAE. All conventional banking, payments, insurance, brokerage and fund management in Dubai mainland: CBUAE or CMA. Mining and validation are not VARA license activities in the rulebooks reviewed.
Notes. VARA updated all its rulebooks in May 2025 (versions dated 19 May 2025) with a 30-day transition to 19 June 2025: Category 1 issuance expanded to include Asset-Referenced Virtual Assets, an Exempt VA category was added, USD or AED referenced VAs can count toward net liquid assets, and all VASPs must keep a wind-down plan. Federal Decree-Law No. 33 of 2025 (in force 1 January 2026) treats virtual assets as Financial Products under the federal Capital Markets Law; watch how CMA and VARA coordinate on licensing under the new framework.
Middle East · UAE · Federal
CMA UAE
Capital Market Authority (formerly Securities and Commodities Authority)
The CMA is the federal onshore securities, commodities and virtual asset regulator. Federal Decree-Law No. 32 of 2025 (Article 2) established the Capital Market Authority as the legal successor that replaces the Securities and Commodities Authority, in force from 1 January 2026, alongside the new Capital Markets Law (Federal Decree-Law No. 33 of 2025). Financial activities are licensed under the Rulebook (Board Decision No. 13/R.M of 2021, as amended) in categories: First (dealing in securities), Second (dealing in investment), Third (custody, clearing and registration), Fourth (credit rating), Fifth (arranging and advice), Sixth (crowdfunding) and Seventh (virtual asset service providers).
#25of 34
Balanced score
56 of 100
56 of 100
Scorecard
Credibility ×35%65Breadth ×15%57Entry threshold ×20%52Speed ×15%50Reach ×15%44
Categories11
Systems covered27 of 47
Typical timeline—market practice
Lowest capitalUSD 136 k
IOSCO MMoUA
Passportnational
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 1 k–3 k2 items · Paid once, when the application is filed
On grantUSD 20 k–123 k2 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 15 k–60 k2 items · Recurring fees and levies
OtherUSD 2721 item · Mandatory charges that arise in operation
The fee schedule for conventional licenses (First, Second, Third and Fifth Categories) was not located: Cabinet Resolution No. 21 of 2017 covers only joint-stock company and auditor services, so conventional license fees must be confirmed with the Authority. VASP fees under Resolution 83 of 2025 are among the highest in the UAE (AED 450,000 to issue a platform license).
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Application fee, Virtual Asset Platform OperatorCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. | AED 10,000≈ USD 3 k | Seventh Category – Virtual Assets Service Providers (Virtual asset platform operator) | Read in the rulebook |
| Application fee, Virtual Asset Custodian / BrokerCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. | AED 5,000≈ USD 1 k | Seventh Category – Virtual Assets Service Providers (Custody of virtual assets); Seventh Category – Virtual Assets Service Providers (Virtual assets broker) | Read in the rulebook |
| On grant | |||
| Licence issuance fee, Virtual Asset Platform OperatorCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. A platform operator that also carries on all VASP activities pays AED 525,000 on issuance. | AED 450,000 (AED 525,000 if also exercising all VASP activities)≈ USD 123 k | Seventh Category – Virtual Assets Service Providers (Virtual asset platform operator) | Read in the rulebook |
| Licence issuance fee, Virtual Asset Custodian / BrokerCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. | AED 75,000≈ USD 20 k | Seventh Category – Virtual Assets Service Providers (Custody of virtual assets); Seventh Category – Virtual Assets Service Providers (Virtual assets broker) | Read in the rulebook |
| Every year | |||
| Annual renewal fee, Virtual Asset Platform OperatorCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. | AED 220,000 (AED 275,000 if also exercising all VASP activities)≈ USD 60 k | Seventh Category – Virtual Assets Service Providers (Virtual asset platform operator) | Read in the rulebook |
| Annual renewal fee, Virtual Asset Custodian / BrokerCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. | AED 55,000≈ USD 15 k | Seventh Category – Virtual Assets Service Providers (Custody of virtual assets); Seventh Category – Virtual Assets Service Providers (Virtual assets broker) | Read in the rulebook |
| Other | |||
| Licence cancellation fee, VASPsCabinet Resolution No. 83 of 2025 on fees for services provided to VASPs (in force 27 June 2025), for VASPs licensed directly by the Authority. VASPs licensed by a local (emirate) authority instead register with the Authority: AED 3,000 registration, AED 1,500 annual renewal, AED 1,000 cancellation. | AED 10,000 (platform operator); AED 1,000 (custodian, broker)≈ USD 272 | Seventh Category – Virtual Assets Service Providers (Virtual asset platform operator); Seventh Category – Virtual Assets Service Providers (Custody of virtual assets); Seventh Category – Virtual Assets Service Providers (Virtual assets broker) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 943 k
Adviser / promoter / introducerFifth Category – Arranging and Advice
USD 136 k
Fund managerSecond Category – Dealing in Investment (Investment fund management)
USD 272 k
VA trading platformSeventh Category – Virtual Assets Service Providers (Virtual asset platform operator)
USD 272 k
VA brokerSeventh Category – Virtual Assets Service Providers (Virtual assets broker)
USD 545 k
Investment managerSecond Category – Dealing in Investment (Portfolio management)
USD 817 k
VA custodianSeventh Category – Virtual Assets Service Providers (Custody of virtual assets)
USD 1.09 m
Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market)
USD 8.17 m
Securities broker / dealerFirst Category – Dealing in Securities (trading broker, trading and clearing broker, international markets broker, financial products dealer)
USD 8.17 m
PSIA manager (Islamic)Second Category – Dealing in Investment (Managing a profit-sharing investment account)
USD 9.53 m
Custodian / clearing memberThird Category – Custody, Clearing and Registration
USD 13.61 m
100k1m10m100m
10 of 11 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
11 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Retail FX / CFD brokerFirst Category – Dealing in Securities (Trading Broker of OTC Derivatives, OTC Commodities contracts and Currencies in the Spot market)USD 8.17 mMinimum capital
- Permits
- Trading brokerage in OTC derivatives, OTC commodity contracts and spot foreign exchange (Forex) for clients.
- Minimum capital
- Paid-up capital not less than AED 30 million for the First Category (Rulebook Section 2, Annex No. 1). (≈USD 8.17 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Onshore license allowing business with UAE mainland clients, including retail. Where a licensee holds several categories, the highest capital suffices (Section 2, Chapter 4, Article 2); a guarantee may be required by the Authority. Retail leverage limits and client money rules apply under CMA conduct rules; specific leverage caps were not confirmed.
- Systems
- Retail BrokerageMulti-Asset BrokeragePrime-of-Prime
- Reading
- Read in the rulebook
- Sources
02Securities broker / dealerFirst Category – Dealing in Securities (trading broker, trading and clearing broker, international markets broker, financial products dealer)USD 8.17 mMinimum capital
- Permits
- Trading brokerage on UAE markets, trading and clearing brokerage, brokerage in international markets, and acting as a financial products dealer.
- Minimum capital
- Paid-up capital not less than AED 30 million (Rulebook Section 2, Annex No. 1). (≈USD 8.17 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Onshore license allowing business with UAE mainland clients, including retail. Where a licensee holds several categories, the highest capital suffices (Section 2, Chapter 4, Article 2); a guarantee may be required by the Authority. Exchange membership needed to trade on ADX or DFM.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrivate BrokerageStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
03Fund managerSecond Category – Dealing in Investment (Investment fund management)USD 272 kMinimum capital
- Permits
- Management of investment funds' investments.
- Minimum capital
- Paid-up capital not less than AED 1 million for this activity (Rulebook Section 2, Annex No. 1). Where several Second Category activities are held, the minimums are added together. (≈USD 272 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Public fund offerings to retail investors follow CMA fund rules. The 2022 amendment (Decision 18/R.M of 2022) replaced an earlier AED 50 million category figure with activity-specific minimums.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleMutual Fund & UCITSETF Platform
- Reading
- Read in the rulebook
- Sources
04Investment managerSecond Category – Dealing in Investment (Portfolio management)USD 817 kMinimum capital
- Permits
- Discretionary management of client portfolios.
- Minimum capital
- Paid-up capital not less than AED 3 million for portfolio management (Rulebook Section 2, Annex No. 1, as reported by two 2026 guides citing the annex). Where several Second Category activities are held, the minimums are added together. (≈USD 817 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- AED 3 million is given by exams.academy (citing the current annex) and Enterslice (October 2026). The official annex PDF's table extracts with scrambled cell order, so the pairing could not be read cleanly from the primary text; the 2022 amendment (Decision 18/R.M of 2022) set Second Category figures in an AED 1 million to 4 million range.
- Systems
- Asset Management CompanyWealth Management FirmMulti-Family OfficeQuantitative Trading DeskPension & Endowment Manager
- Reading
- From a secondary source
- Sources
05Family officeSecond Category – Dealing in Investment (Family business investment management – family office)No fixed figureMinimum capital
- Permits
- Investment management for a family business (family office).
- Minimum capital
- Not confirmed. The Rulebook annex's family office row sits next to a paid-up capital figure of AED 3 million, but the extracted table is scrambled and the AED 3 million may belong to portfolio management instead; no secondary source states a family office figure.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Must be wholly owned by family members whose wealth is at least AED 25 million (this condition is clear in the annex). Capital figure uncertain (AED 1 million or AED 3 million are the candidates); confirm with the CMA.
- Systems
- Single-Family Office
- Reading
- To be confirmed
- Sources
06PSIA manager (Islamic)Second Category – Dealing in Investment (Managing a profit-sharing investment account)USD 9.53 mMinimum capital
- Permits
- Managing a profit-sharing investment account on a Shari'a-compliant basis.
- Minimum capital
- Paid-up capital AED 35 million (Rulebook Section 2, Annex No. 1). In the annex text the 'AED 35 million' entry immediately precedes this activity, and a 2026 guide citing the annex gives the same figure; fund administration is separately listed at AED 1 million by that guide. (≈USD 9.53 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Limited to Shari'a-compliant entities wholly owned by the federal or a local government, government bodies, or companies wholly owned by them. Figure taken from the annex with a secondary source used to resolve the table layout.
- Systems
- Islamic Finance Structure
- Reading
- From a secondary source
- Sources
07Custodian / clearing memberThird Category – Custody, Clearing and RegistrationUSD 13.61 mMinimum capital
- Permits
- Safe custody, general clearing, issuing covered warrants, depository bank and depository bank agent for depository receipts, and registrar of private joint stock companies.
- Minimum capital
- Paid-up capital not less than AED 50 million (Rulebook Section 2, Annex No. 1). (≈USD 13.61 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Depository bank activities are limited to licensed banks or foreign bank branches; safe custody may be carried out by a company affiliated with a licensed bank.
- Systems
- Custody & Wallet InfrastructureStructured Products IssuerPrime Brokerage
- Reading
- Read in the rulebook
- Sources
08Adviser / promoter / introducerFifth Category – Arranging and AdviceUSD 136 kMinimum capital
- Permits
- Financial consulting, financial adviser (issuance manager), listing adviser, introducing and promotion.
- Minimum capital
- Paid-up capital AED 500,000 (Rulebook Section 2, Annex No. 1). (≈USD 136 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Open to free-zone and foreign firms to promote or introduce into the mainland. A 2022 amendment had set AED 2.5 million for this category; the June 2025 rulebook annex shows AED 500,000.
- Systems
- Investment Advisory FirmWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
09VA brokerSeventh Category – Virtual Assets Service Providers (Virtual assets broker)USD 545 kMinimum capital
- Permits
- Brokerage and dealing in virtual assets for clients onshore (outside Dubai's VARA perimeter and the financial free zones).
- Minimum capital
- Minimum capital AED 2 million (Rulebook Section 2, Annex No. 1). (≈USD 545 k)
- Fees
- Application fee, Virtual Asset Custodian / BrokerAED 5,000Licence issuance fee, Virtual Asset Custodian / BrokerAED 75,000Annual renewal fee, Virtual Asset Custodian / BrokerAED 55,000Licence cancellation fee, VASPsAED 10,000 (platform operator); AED 1,000 (custodian, broker)
- Clients
- Retail, with conditions
- Conditions
- Under Federal Decree-Law No. 33 of 2025, virtual assets are Financial Products and may only be traded if listed by a CMA-licensed platform and registered with the CMA. In Dubai, VA activity is licensed by VARA.
- Systems
- OTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
10VA custodianSeventh Category – Virtual Assets Service Providers (Custody of virtual assets)USD 1.09 mMinimum capital
- Permits
- Safekeeping of virtual assets for clients.
- Minimum capital
- AED 4 million plus the equivalent of 6 months of operating expenses (Rulebook Section 2, Annex No. 1). (≈USD 1.09 m)
- Fees
- Application fee, Virtual Asset Custodian / BrokerAED 5,000Licence issuance fee, Virtual Asset Custodian / BrokerAED 75,000Annual renewal fee, Virtual Asset Custodian / BrokerAED 55,000Licence cancellation fee, VASPsAED 10,000 (platform operator); AED 1,000 (custodian, broker)
- Clients
- Retail, with conditions
- Conditions
- Six-month operating expense reserve on top of the AED 4 million minimum.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
11VA trading platformSeventh Category – Virtual Assets Service Providers (Virtual asset platform operator)USD 272 kMinimum capital
- Permits
- Operating a virtual asset trading platform.
- Minimum capital
- AED 1 million plus 6 months of operating expenses if it only operates the platform; AED 5 million plus 6 months of operating expenses if it also carries out other virtual asset services (Rulebook Section 2, Annex No. 1). (≈USD 272 k)
- Fees
- Application fee, Virtual Asset Platform OperatorAED 10,000Licence issuance fee, Virtual Asset Platform OperatorAED 450,000 (AED 525,000 if also exercising all VASP activities)Annual renewal fee, Virtual Asset Platform OperatorAED 220,000 (AED 275,000 if also exercising all VASP activities)Licence cancellation fee, VASPsAED 10,000 (platform operator); AED 1,000 (custodian, broker)
- Clients
- Retail, with conditions
- Conditions
- Platform operators maintain the list of tradable virtual assets, which must be registered with the CMA under the 2025 Capital Markets Law.
- Systems
- Digital Asset Exchange
- Reading
- Read in the rulebook
- Sources
Reach
Nationwide onshore UAE reach. Does not cover activities conducted exclusively within DIFC or ADGM. Free-zone firms can obtain CMA licenses (commonly Category 5) to promote or introduce into the mainland. No foreign passport.
Passage
Market practice; no statutory decision deadline or service standard was located. Existing licensees must regularize under the 2025 decree-laws by 1 January 2027 (extendable by the CMA Board).
Licensed elsewhere
Banks, finance companies, exchange houses, payment and stored value services, payment tokens and insurance: CBUAE. Virtual asset firms in Dubai (outside DIFC): VARA. DIFC and ADGM activities: DFSA and FSRA. Proprietary trading on own capital, sovereign vehicles, physical commodity trading and mining are not CMA license categories. The Fourth Category (credit rating, AED 5 million) and Sixth Category (crowdfunding platform operator, AED 1 million) exist but do not map to the 47 systems.
Notes. Federal Decree-Law No. 32 of 2025 (issued 1 October 2025, in force 1 January 2026; Articles 2 and 30) created the Capital Market Authority to replace the SCA as its legal successor, substitutes the new name wherever the old one appears in legislation, and repealed Federal Law No. 4 of 2000 (Article 29); existing Cabinet and Authority resolutions, including the Rulebook, stay in force until replaced where consistent (Article 27(4)) (source: https://www.uaelegislation.gov.ae/en/legislations/4001/download). Under the companion Capital Markets Law (Federal Decree-Law No. 33 of 2025) virtual assets became Financial Products and existing licensees have until 1 January 2027 to regularize. Decision No. 11 of 2026 amended the capital-adequacy section (Tier 1 composition and a leverage requirement) per a secondary source. The Rulebook licensing section read here is the version dated 2 June 2025 (latest amendment cited: Decision 36/Chairman of 2024); its Annex No. 1 table extracts with scrambled cell order, which is why some Second Category pairings rely on secondary sources.
Middle East · UAE · Federal
CBUAE
Central Bank of the UAE
Tier 2Official site
The CBUAE licenses and supervises onshore banks, finance companies, exchange houses, payment and stored value providers, payment token issuers and, since the Insurance Authority was merged into it in 2020, insurers. Its legal basis is Federal Decree-Law No. 6 of 2025 regarding the Central Bank, Regulation of Financial Institutions and Activities, and Insurance Business, in force from 16 September 2025, which replaced Federal Decree-Law No. 14 of 2018 and the 2023 insurance decree-law. Banks and payment firms inside DIFC and ADGM are regulated by the DFSA and FSRA instead.
#33of 34
Balanced score
49 of 100
49 of 100
Scorecard
Credibility ×35%65Breadth ×15%32Entry threshold ×20%47Speed ×15%30Reach ×15%49
Categories14
Systems covered15 of 47
Typical timeline9–18 monthsmarket practice
Lowest capitalUSD 27 k
IOSCO MMoUN/A
Passportnational
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
No fee schedule could be read for this regulator. No published CBUAE fee schedule for bank, finance company, exchange house, SVF, retail payment or payment token licenses was located; the CBUAE quotes fees during the licensing process, so budget for them as unconfirmed. Capital, not fees, is the main cost driver for CBUAE licenses.
Threshold
Minimum capital, category by category
Middle halfMedian USD 6.81 m
Payment service providerRetail Payment Services license (Category I to IV, RPSCS Regulation)
USD 27 k
Payment token custodian / converterPayment Token Custody and Transfer / Conversion provider (Payment Token Services Regulation)
USD 408 k
Exchange house / remittanceExchange House – Category I, II or III (Exchange Business Regulation 2025)
USD 545 k
E-money / wallet issuerStored Value Facility (SVF) license
USD 4.08 m
Stablecoin / payment token issuerPayment Token Issuer (Payment Token Services Regulation, Circular No. 2/2024)
USD 4.08 m
Non-bank lenderFinance Company (Finance Companies Regulation)
USD 5.45 m
Digital-only remittance providerExchange House – Category IV (digital remittance, Exchange Business Regulation 2025)
USD 6.81 m
Foreign bank branchBranch of a foreign bank
USD 27.23 m
Insurer / reinsurer / takafulInsurance / Reinsurance Company license
USD 27.23 m
Specialized (low-risk) bankSpecialized Bank (Specialized Banks with Low Risk Regulation)
USD 81.69 m
Restricted (wholesale) bankRestricted Licence Bank
USD 272.29 m
Commercial bankLicensed Bank (conventional, incorporated in the UAE)
USD 544.59 m
Islamic bankLicensed Bank (Islamic, incorporated in the UAE)
USD 544.59 m
10k100k1m10m100m1bn
13 of 14 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
14 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Commercial bankLicensed Bank (conventional, incorporated in the UAE)USD 544.59 mMinimum capital
- Permits
- Full banking business onshore: taking deposits, lending, payments, trade finance, treasury and correspondent banking, card issuing and acquiring.
- Minimum capital
- Fully paid-up capital of at least AED 2,000,000,000 for banks incorporated in the UAE (Minimum Capital for Banks Regulation, Circular No. 12/2021 of 14 February 2021, Article 3.1). The CBUAE may impose a higher minimum at licensing (Article 6.1). Basel III capital ratios apply on top under the CBUAE capital adequacy regulations. (≈USD 544.59 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- The minimum must be met solely with fully paid-up capital (Article 4.1); existing banks had until 31 December 2023 to comply. New full bank licenses are rare. The regulation was issued under the 2018 law and is still published in the CBUAE Rulebook; check for any replacement under Federal Decree-Law No. 6 of 2025.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HouseCard Issuing ProgramMerchant Acquiring
- Reading
- Read in the rulebook
- Sources
02Islamic bankLicensed Bank (Islamic, incorporated in the UAE)USD 544.59 mMinimum capital
- Permits
- Banking business conducted wholly in compliance with Shari'a, under the Higher Shari'ah Authority framework.
- Minimum capital
- Same as other UAE-incorporated banks: fully paid-up capital of at least AED 2,000,000,000 (Minimum Capital for Banks Regulation, Circular No. 12/2021, Article 3.1, which applies to all banks incorporated in the UAE). Basel III capital ratios apply on top. (≈USD 544.59 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Internal Shari'a Supervisory Committee and Higher Shari'ah Authority standards apply. Conventional banks may run Islamic windows with CBUAE approval (conventional Specialized Banks may not).
- Systems
- Islamic Finance StructurePrivate BankDigital Bank
- Reading
- Read in the rulebook
- Sources
03Foreign bank branchBranch of a foreign bankUSD 27.23 mMinimum capital
- Permits
- Banking business onshore through a branch of a bank incorporated abroad, within the scope of its CBUAE license.
- Minimum capital
- Fully paid-up capital of at least AED 100,000,000 at branch level, and eligible capital of at least AED 2,000,000,000 (or equivalent) at the level of the foreign entity (Minimum Capital for Banks Regulation, Circular No. 12/2021, Articles 3.3.1 and 3.3.2). (≈USD 27.23 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Branch-level capital must meet the conditions in Article 4.2. A foreign branch licensed as a Restricted Licence Bank follows this same regulation rather than the AED 1 billion RLB figure.
- Systems
- Private BankInvestment BankCorrespondent Banking StructureTrade Finance HouseTreasury & Liquidity Desk
- Reading
- Read in the rulebook
- Sources
04Restricted (wholesale) bankRestricted Licence BankUSD 272.29 mMinimum capital
- Permits
- All Licensed Financial Activities, subject to restrictions: no business with natural persons (except CBUAE-approved high net worth individuals) and no banking relationship below AED 1 million (Restricted Licence Banks Regulation, Articles 3.1 to 3.4).
- Minimum capital
- Fully paid-up capital of at least AED 1,000,000,000 (Restricted Licence Banks Regulation, Circular No. 23/2022, Article 5.1). Foreign bank branches licensed as RLBs follow the Minimum Capital for Banks Regulation instead (Article 5.2). The CBUAE may set a higher figure (Article 5.3). (≈USD 272.29 m)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Retail banking is barred. Minimum initial deposit or credit facility of AED 1 million per customer relationship.
- Systems
- Investment BankPrivate BankCorrespondent Banking StructureTrade Finance HouseTreasury & Liquidity Desk
- Reading
- Read in the rulebook
- Sources
05Specialized (low-risk) bankSpecialized Bank (Specialized Banks with Low Risk Regulation)USD 81.69 mMinimum capital
- Permits
- Retail, mortgage and wholesale finance, cards, stored value and digital payment services, and deposit-taking from UAE residents in AED only, with individual balances capped at AED 5 million (Circular No. 21/2022, Articles 3.1 to 3.6).
- Minimum capital
- Fully paid-up capital of at least AED 300,000,000 for Specialized Banks incorporated in the UAE (Minimum Capital for Banks Regulation, Circular No. 12/2021, Article 3.2; cross-referenced by Article 4.3 of the Specialized Banks with Low Risk Regulation). (≈USD 81.69 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- UAE residents and AED only. Total consolidated assets capped at AED 25 billion; wholesale lending capped at 50% of lending, wholesale funding at 40%, foreign funding at 25%. Conventional Specialized Banks may not run Islamic windows. Conditions summarized from an aggregator copy of Circular No. 21/2022.
- Systems
- Digital Bank
- Reading
- Read in the rulebook
- Sources
06Non-bank lenderFinance Company (Finance Companies Regulation)USD 5.45 mMinimum capital
- Permits
- Retail finance (personal loans, credit cards, vehicle loans, short-term credit), mortgage finance, wholesale finance including leasing and SME lending, prepaid cards, and distribution of third-party products as agent (Finance Companies Regulation, Circular No. 3/2023, Article 10.1).
- Minimum capital
- Minimum paid-up capital AED 150,000,000 for a Finance Company, conventional or Islamic (Finance Companies Regulation, Circular No. 3/2023, Article 11.2). Restricted Licence Finance Companies (short-term credit only) must hold Aggregate Capital Funds of the higher of AED 20,000,000 or 5% of outstanding lending (Article 25.2). (≈USD 5.45 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- May take deposits only from legal persons (term of at least 30 days); deposits and loans from individuals are prohibited. Restricted Licence Finance Companies may not take deposits of any kind or use crowdfunding. Applicants must show at least AED 25 million of paid-up capital deposited at a UAE bank. Replaces the 1996 regime (Resolution 58/3/96, AED 35 million). Article 11.2 text read via an aggregator copy; Article 25 read on the CBUAE rulebook.
- Systems
- Trade Finance House
- Reading
- Read in the rulebook
- Sources
07Exchange house / remittanceExchange House – Category I, II or III (Exchange Business Regulation 2025)USD 545 kMinimum capital
- Permits
- Category III: currency exchange only. Category II: currency exchange and remittances. Category I: currency exchange, remittances and wage payments through WPS (Exchange Business Regulation, Circular No. 7/2025).
- Minimum capital
- Paid-up capital for a sole establishment or partnership: AED 2 million (Category III), AED 5 million (Category II), AED 10 million (Category I); AED 25 million for any category where the licensee is an LLC or similar company. Bank guarantee equal to the capital for sole establishments/partnerships and AED 50 million for LLCs (Exchange Business Regulation, Circular No. 7/2025, as summarized from the regulation text). (≈USD 545 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- The 2025 regulation (dated 16 June 2025) repealed Notice No. 1/2014 and replaced the old Categories A, B and C (AED 2 million, 5 million and 10 million, AED 50 million for an LLC, still shown in the Rulebook standards). Special products such as banknote shipment need separate no-objection letters and may carry higher capital. Heavy AML/CFT supervision. Figures read from an aggregator copy of the regulation text; the CBUAE Rulebook page for the new regulation was not reached.
- Systems
- Money Services Business
- Reading
- From a secondary source
- Sources
08Digital-only remittance providerExchange House – Category IV (digital remittance, Exchange Business Regulation 2025)USD 6.81 mMinimum capital
- Permits
- Remittances through digital channels only, with no physical outlets and no cash-in or cash-out activity.
- Minimum capital
- Paid-up capital AED 25 million and bank guarantee AED 25 million; must be an LLC (Exchange Business Regulation, Circular No. 7/2025). (≈USD 6.81 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- New category created in 2025; reported to allow up to 100% foreign ownership. Figures read from an aggregator copy of the regulation and consistent with the 'up to AED 25 million' reported by Pinsent Masons.
- Systems
- Money Services Business
- Reading
- From a secondary source
- Sources
09E-money / wallet issuerStored Value Facility (SVF) licenseUSD 4.08 mMinimum capital
- Permits
- Issuing stored value (prepaid wallets and e-money) onshore under the Stored Value Facilities Regulation.
- Minimum capital
- Paid-up capital of at least AED 15,000,000, plus Aggregate Capital Funds of at least 5% of the total Float received from customers (Stored Value Facilities Regulation, Circular No. 6/2020 of 30 September 2020, Article 7(4.1) and 7(4.2)). (≈USD 4.08 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Float must be safeguarded. Regulation effective 15 November 2020. Capital figure read in the Arabic rulebook text and confirmed by Simmons & Simmons.
- Systems
- Electronic Money InstitutionCard Issuing Program
- Reading
- Read in the rulebook
- Sources
10Payment service providerRetail Payment Services license (Category I to IV, RPSCS Regulation)USD 27 kMinimum capital
- Permits
- Category IV: payment initiation and account information. Category III: payment account issuance, payment instrument issuance, merchant acquiring, payment aggregation, domestic fund transfers. Category II: adds cross-border fund transfers. Category I: adds payment token services (now governed by the separate Payment Token Services Regulation).
- Minimum capital
- Initial capital (Retail Payment Services and Card Schemes Regulation, Circular No. 15/2021, Article 6): Category I AED 3 million where monthly average payment transactions are AED 10 million or more, otherwise AED 1.5 million; Category II AED 2 million / AED 1 million; Category III AED 1 million / AED 500,000; Category IV AED 100,000 regardless of volume. (≈USD 27 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- The monthly average is a three-month moving average (business plan figures at licensing). A provider exceeding AED 10 million a month for three consecutive months must notify the CBUAE and becomes subject to higher Aggregate Capital Funds (Article 7.3). Safeguarding of client funds required. Category activity mapping is from secondary summaries.
- Systems
- Payment Service ProviderMerchant AcquiringCard Issuing ProgramMoney Services Business
- Reading
- Read in the rulebook
- Sources
11Card scheme operatorCard Scheme license (RPSCS Regulation)No fixed figureMinimum capital
- Permits
- Operating a card scheme in the UAE.
- Minimum capital
- No capital figure located. The capital articles of the RPSCS Regulation read here (Articles 6 and 7) address Payment Service Providers only.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Single license granted under the Retail Payment Services and Card Schemes Regulation (in force 15 July 2021), with or without conditions. Capital, if any, is set case by case; not confirmed.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- To be confirmed
- Sources
12Stablecoin / payment token issuerPayment Token Issuer (Payment Token Services Regulation, Circular No. 2/2024)USD 4.08 mMinimum capital
- Permits
- Issuing Dirham Payment Tokens (fiat-backed stablecoins). Only companies incorporated in the UAE (including non-financial free zones, excluding DIFC and ADGM) may hold a Dirham Payment Token Issuer license; foreign issuers register as Foreign Payment Token Issuers.
- Minimum capital
- Initial and ongoing capital of AED 15 million, plus additional ongoing capital of 0.5% of the fiat face value of outstanding tokens (2% under the alternative reserve regime) (Payment Token Services Regulation, Article 13). An unconditional bank guarantee equal to the full paid-up capital is also required (Article 15.4). (≈USD 4.08 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Dirham tokens may be issued only to UAE residents. Foreign payment tokens may be transferred or accepted only to buy virtual assets or virtual asset derivatives. Reserve assets are governed by Article 22 (not read). Small issuers with reserves up to AED 500,000 and no more than 100 holders may be exempted. One-year transition from June 2024.
- Systems
- Stablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
13Payment token custodian / converterPayment Token Custody and Transfer / Conversion provider (Payment Token Services Regulation)USD 408 kMinimum capital
- Permits
- Custody and transfer of payment tokens, and conversion between payment tokens and fiat, onshore.
- Minimum capital
- Regulatory capital of AED 3 million where average monthly token transfer value is AED 10 million or more, otherwise AED 1.5 million (Payment Token Services Regulation, Article 14.1); the CBUAE may impose more (Article 15.1). Bank guarantee equal to paid-up capital (Article 15.4). (≈USD 408 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Covers payment tokens (stablecoins) only, not other virtual assets. Licensed VASPs, banks and exchange houses may instead seek a non-objection registration for certain custody and transfer activities.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
14Insurer / reinsurer / takafulInsurance / Reinsurance Company licenseUSD 27.23 mMinimum capital
- Permits
- Carrying on insurance or reinsurance business onshore (conventional or takaful). Insurers are licensed by the CBUAE under Federal Decree-Law No. 6 of 2025.
- Minimum capital
- Minimum subscribed and paid-up capital AED 100 million for an insurance company and AED 250 million for a reinsurance company (Insurance Authority Board Resolution No. 25 of 2014, Article 1, published in the CBUAE Rulebook). 2026 law-firm guides confirm the same figures remain current under the 2025 decree-law. (≈USD 27.23 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Figures are set by board resolution and the guides note they may be changed by the CBUAE Board. No separate takaful or foreign-branch figure was confirmed. Insurance in non-financial free zones now needs CBUAE authorization or a no-objection (DMCC transition ended 31 December 2025).
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
Nationwide onshore UAE reach. No foreign passport. Free-zone financial centers (DIFC, ADGM) are outside its licensing perimeter for financial services, although CBUAE monetary and AML powers apply nationally.
Passage
Market practice; no published service standard located. New bank licenses are granted rarely and on a long timeline.
Licensed elsewhere
Securities brokers, FX/CFD brokers, fund and portfolio managers, custodians of securities and onshore VASPs: CMA (formerly SCA). Virtual asset firms in Dubai: VARA. All financial services inside DIFC: DFSA; inside ADGM: FSRA. Asset management, hedge funds, private equity, venture capital, wealth management, digital asset exchanges and tokenization platforms are not CBUAE licenses.
Notes. Federal Decree-Law No. 6 of 2025 took effect on 16 September 2025 and replaced the previous central bank law (Federal Decree-Law No. 14 of 2018) and the 2023 insurance law; Article 184 gave existing persons one year to reconcile, so the deadline was 15 September 2026 (extendable by the Board; no general extension announced as of November 2026). Fines for unlicensed activity range from AED 50,000 to AED 500 million. The Exchange Business Regulation (Circular No. 7/2025) replaced the 2014 exchange house regime and its Categories A to C with Categories I to IV, including a digital-only remittance license. The Payment Token Services Regulation (Circular No. 2/2024) took payment token services out of the RPSCS framework. Bank capital figures come from the Minimum Capital for Banks Regulation (Circular No. 12/2021), still published in the Rulebook. The card scheme capital figure remains unconfirmed. ; https://www.tamimi.com/news/insurance-licensing-in-uae-what-has-changed-in-2026/
Middle East · Saudi Arabia
CMA Saudi
Capital Market Authority
The CMA regulates the Saudi securities market and licenses capital market institutions under the Capital Market Law (Royal Decree M/30 of 2003), the Securities Business Regulations and the Capital Market Institutions Regulations. Licenses are granted by activity: dealing, managing (managing investments, or managing investments and operating funds), arranging, advising and custody. Dealing, custody and managing licensees must be established in the Kingdom as a joint stock company, a subsidiary of a local bank or Saudi financial joint stock company, or a subsidiary of a foreign financial institution, with head office and management in Saudi Arabia.
#31of 34
Balanced score
51 of 100
51 of 100
Scorecard
Credibility ×35%65Breadth ×15%40Entry threshold ×20%32Speed ×15%50Reach ×15%57
Categories8
Systems covered19 of 47
Typical timeline—market practice
Lowest capitalUSD 5.33 m
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
No fee schedule could be read for this regulator. No CMA license application or annual fee schedule was located in this pass, so none is recorded; do not read this as zero. The binding cost is capital: SAR 50 million for dealing and custody, SAR 20 million or one year's operating expenses for asset management (per King & Spalding, Feb 2025).
Threshold
Minimum capital, category by category
Middle halfMedian USD 13.33 m
Asset and fund managerManaging investments and operating funds (CMIR Art. 6(g)(2))
USD 5.33 m
Dealing / brokerageDealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1))
USD 13.33 m
Securities custodianCustody (CMIR Art. 6(g)(1))
USD 13.33 m
1m10m100m
3 of 8 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
8 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Dealing / brokerageDealing (Securities Business Regulations; Capital Market Institutions Regulations Art. 6(g)(1))USD 13.33 mMinimum capital
- Permits
- Dealing in securities as principal or agent, including underwriting and executing transactions on a margin basis, in securities as defined by the CMA (shares, debt instruments, fund units, and securities-based derivatives).
- Minimum capital
- SAR 50 million minimum paid-up capital (CMIR Art. 6(g)(1), as amended by CMA Board Resolution 2-3-2026 dated 7 January 2026). A May 2026 CMA consultation proposes SAR 20 million for dealing as principal, underwriting and margin execution, and SAR 10 million for dealing as agent; not confirmed as adopted at October 2026. (≈USD 13.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Must be a Saudi joint stock company, a subsidiary of a local bank or of a Saudi financial-services joint stock company, or a subsidiary of a foreign financial institution licensed under the Banking Control Law (CMIR Art. 6(f)). Head office and management in Saudi Arabia (Art. 6(h)); registered persons must be resident unless exempted (Art. 24(b)). Ongoing capital under the CMA Prudential Rules. There is no CMA regime for retail OTC FX/CFD trading; the license covers securities as defined by the CMA.
- Systems
- Private BrokerageInstitutional BrokerageMulti-Asset BrokerageInvestment BankStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
02Asset and fund managerManaging investments and operating funds (CMIR Art. 6(g)(2))USD 5.33 mMinimum capital
- Permits
- Managing investments (discretionary portfolio management) and establishing, managing and operating public and private investment funds, including real estate funds and REITs.
- Minimum capital
- SAR 20 million minimum paid-up capital (CMIR Art. 6(g)(2)). (≈USD 5.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Same legal-form and Saudi head-office requirements as dealing (CMIR Art. 6(f), 6(h)). At least two portfolio managers required for investment management and fund operation business (CMIR Art. 20(g)). Robo-advisory permitted subject to conditions (Art. 10(f)). Funds are approved under the Investment Funds Regulations and the Real Estate Investment Funds Regulations.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleMutual Fund & UCITSETF PlatformWealth Management FirmMulti-Family OfficePension & Endowment ManagerIslamic Finance Structure
- Reading
- Read in the rulebook
- Sources
03Portfolio manager (no fund operation)Managing investments (CMIR Art. 6(g)(2))No fixed figureMinimum capital
- Permits
- Managing investments for clients on a discretionary basis, without operating investment funds.
- Minimum capital
- No fixed amount: paid-up capital must cover the expected expenses for one year (CMIR Art. 6(g)(2)).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Same legal-form and Saudi head-office requirements as dealing. A firm limited to managing investments can be exempted from parts of the Prudential Rules if owners' equity stays at least half of paid-up capital and it holds six months of working capital (per 2020 amendments reported by Argaam).
- Systems
- Wealth Management FirmMulti-Family OfficeAsset Management Company
- Reading
- Read in the rulebook
- Sources
04Arranger / corporate financeArranging (CMIR Art. 6(g)(3))No fixed figureMinimum capital
- Permits
- Arranging securities offerings and corporate finance transactions and introducing parties; also used for securities-based crowdfunding platforms.
- Minimum capital
- No fixed amount: paid-up capital must cover expected expenses for one year (CMIR Art. 6(g)(3); reduced in 2020 from SAR 2 million). A May 2026 consultation proposes SAR 2 million for securities crowdfunding that holds client funds.
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Any legal form established in the Kingdom (CMIR Art. 6(f)). May not hold client assets except as permitted for crowdfunding. Crowdfunding arrangers must register an IT officer (Art. 19(8)).
- Systems
- Investment Bank
- Reading
- Read in the rulebook
- Sources
05Investment adviserAdvising (CMIR Art. 6(g)(3))No fixed figureMinimum capital
- Permits
- Advising on the merits of dealing in securities, including financial planning and wealth management advice (scope expanded in the 2020 amendments).
- Minimum capital
- No fixed amount: paid-up capital must cover expected expenses for one year (CMIR Art. 6(g)(3); reduced in 2020 from SAR 400,000).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Any legal form established in the Kingdom. The May 2026 consultation would let advising-only firms carry on other businesses under conditions.
- Systems
- Investment Advisory FirmMulti-Family Office
- Reading
- Read in the rulebook
- Sources
06Securities custodianCustody (CMIR Art. 6(g)(1))USD 13.33 mMinimum capital
- Permits
- Safeguarding securities and administering them for clients, including acting as fund custodian.
- Minimum capital
- SAR 50 million minimum paid-up capital (CMIR Art. 6(g)(1)). The May 2026 consultation proposes reducing it to SAR 20 million; not confirmed as adopted at October 2026. (≈USD 13.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Same legal-form and Saudi head-office requirements as dealing. Covers securities only; the CMA has no digital-asset custody license.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
07FinTech Lab test permitFinTech Experimental Permit (FinTech ExPermit Instructions)No fixed figureMinimum capital
- Permits
- Live testing of an innovative product involving a securities activity in a controlled environment (used for crowdfunding, robo-advisory and fund distribution platforms).
- Minimum capital
- No fixed amount; the CMA may set capital requirements as a permit condition.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Valid for up to two years from start of business; extension only in exceptional cases on request at least three months before expiry. The CMA may cap the number and type of clients and transaction size. Not available for established products that already fit the rules. After testing, the firm must obtain a full license. Instructions last amended by Board Resolution 2-9-2021.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
08Fund and REIT product approvalPublic investment fund / REIT approval (Investment Funds Regulations; Real Estate Investment Funds Regulations)No fixed figureMinimum capital
- Permits
- CMA approval to offer a public fund (including ETFs) or a listed REIT, or notification of a private fund; the fund must be operated by a licensed manager.
- Minimum capital
- No capital requirement at fund level; the manager needs the managing investments and operating funds license (SAR 20 million).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Product approval, not an entity license. Minimum fund sizes and REIT listing conditions were not confirmed.
- Systems
- Mutual Fund & UCITSReal Estate Investment VehicleETF Platform
- Reading
- From a secondary source
- Sources
Reach
None. A CMA license covers Saudi Arabia only; there is no GCC passport for capital market institutions.
Passage
Statutory: under Capital Market Institutions Regulations Article 7(c), once the CMA has all required information it notifies the applicant and decides within 30 days of that notice. Licensing is two-stage (license, then authorization to commence business after conditions are met). Market practice: roughly 6 to 12 months end to end, driven by staffing, CMA qualification exams, incorporation and bank accounts.
Licensed elsewhere
Banks, digital banks, finance companies, payment institutions, e-money and money exchange/remittance: SAMA. Insurance and reinsurance: the Insurance Authority (took over insurance supervision from SAMA in 2023). Debt crowdfunding is a SAMA finance activity. The Saudi Exchange (Tadawul) is the only licensed exchange. No retail OTC FX/CFD regime exists, and no dedicated virtual-asset licensing regime was confirmed for exchanges, custodians or stablecoins. Sovereign vehicles (e.g. PIF) are created by statute. Mining/validation and commodities trading need no financial license.
Notes. CMIR was last amended by CMA Board Resolution 2-3-2026 (7 January 2026). On 18 May 2026 the CMA consulted (until 17 June 2026) on cutting capital: custody from SAR 50 million to SAR 20 million; dealing as principal, underwriting and margin execution grouped at SAR 20 million; dealing as agent SAR 10 million; securities crowdfunding holding client funds SAR 2 million. A February 2025 consultation would move the legal form and minimum capital of brokerage firms out of Capital Market Law Arts. 32-33 (fixed SAR 50 million) into implementing regulations. Neither change was confirmed as in force at October 2026; check before relying on SAR 50 million. Capital market institutions grew from 86 (2017) to 215 (Q4 2025). Certain roles must be filled by Saudi nationals (Saudization).
Middle East · Saudi Arabia
SAMA
Saudi Central Bank
Tier 2Official site
SAMA licenses and supervises banks (Banking Control Law), finance companies (Finance Companies Control Law), payment service providers and e-money institutions (Law of Payments and Payment Services and its Implementing Regulations) and money changers. Bank licenses are approved at government level on SAMA's recommendation; there is no fixed minimum capital in the licensing guidelines, which apply a case-by-case capital assessment. Insurance moved to the separate Insurance Authority in 2023.
#18of 34
Balanced score
62 of 100
62 of 100
Scorecard
Credibility ×35%65Breadth ×15%23Entry threshold ×20%60Speed ×15%100Reach ×15%55
Categories16
Systems covered11 of 47
Typical timeline3 monthsstatutory
Lowest capitalUSD 133 k
IOSCO MMoUN/A
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
Application—0 items · Paid once, when the application is filed
On grantUSD 3 k–53 k4 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every year—0 items · Recurring fees and levies
OtherUSD 13 k1 item · Mandatory charges that arise in operation
SAMA charges one-off issuance fees (SAR 20,000-50,000 for payment licenses; SAR 200,000 for finance companies under the pre-2026 rules) rather than income-based annual levies. No published license fee was located for banks or money changers.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| On grant | |||
| Payment license issuance fee, micro and open-banking licensesImplementing Regulations of the Law of Payments and Payment Services, Art. 23 (in force 13/6/2023): payable after approval and before the license is issued. No separate application or annual fee is stated in Art. 23. | SAR 20,000≈ USD 5 k | Micro Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(1), 44(1)(a)); Micro Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(1), 44(1)(c)); Payment Initiation Service provider (Art. 44(1)(e)); Payment Account Information Service provider (Art. 44(1)(f)) | Read in the rulebook |
| Payment license issuance fee, major licensesArt. 23 as above. Payment System Operator renewal fees are set by SAMA at its discretion. | SAR 50,000≈ USD 13 k | Major Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b)); Major Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(2), 44(1)(d)) | Read in the rulebook |
| Finance company license issuance feeImplementing Regulation of the Finance Companies Control Law, Art. 22(1)(a). SAMA issued an updated Implementing Regulation in January 2026 (Arabic only at publication); whether Art. 22 fees changed was not confirmed. | SAR 200,000≈ USD 53 k | Finance company - finance activities other than real estate (Implementing Regulation of the Finance Companies Control Law, Art. 8); Finance company - real estate finance (Implementing Regulation of the Finance Companies Control Law, Art. 8); Finance company - SME finance only (Implementing Regulation of the Finance Companies Control Law, Art. 8) | To be confirmed |
| Microfinance license issuance, renewal or amendment feeArt. 22(2) of the pre-2026 text. The January 2026 update repealed the separate microfinance regulations; the current fee was not confirmed. | SAR 10,000≈ USD 3 k | Finance company - microfinance only (Implementing Regulation of the Finance Companies Control Law, Art. 8) | To be confirmed |
| Other | |||
| Finance company license renewal and amendment feesArt. 22(1)(b)-(c) of the pre-2026 English translation; see note on the January 2026 update. | Renewal SAR 100,000; amendment SAR 50,000≈ USD 13 k | Finance company - finance activities other than real estate (Implementing Regulation of the Finance Companies Control Law, Art. 8); Finance company - real estate finance (Implementing Regulation of the Finance Companies Control Law, Art. 8); Finance company - SME finance only (Implementing Regulation of the Finance Companies Control Law, Art. 8) | To be confirmed |
Threshold
Minimum capital, category by category
Middle halfMedian USD 1.87 m
Account information (open banking)Payment Account Information Service provider (Art. 44(1)(f))
USD 133 k
Micro payment institutionMicro Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(1), 44(1)(a))
USD 267 k
Payment initiation (open banking)Payment Initiation Service provider (Art. 44(1)(e))
USD 267 k
Micro EMIMicro Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(1), 44(1)(c))
USD 533 k
Money changerMoney changer - currency exchange (Rules Regulating Money Changing Business)
USD 533 k
Major payment institutionMajor Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b))
USD 800 k
Money changer with cash import/exportMoney changer - import and export of cash (Rules Regulating Money Changing Business)
USD 1.87 m
Microfinance companyFinance company - microfinance only (Implementing Regulation of the Finance Companies Control Law, Art. 8)
USD 2.67 m
Major EMIMajor Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(2), 44(1)(d))
USD 2.67 m
Exchange house with remittanceMoney changer - money transfer inside and outside Saudi Arabia (Rules Regulating Money Changing Business)
USD 2.67 m
SME finance companyFinance company - SME finance only (Implementing Regulation of the Finance Companies Control Law, Art. 8)
USD 13.33 m
Finance companyFinance company - finance activities other than real estate (Implementing Regulation of the Finance Companies Control Law, Art. 8)
USD 26.67 m
Real estate finance companyFinance company - real estate finance (Implementing Regulation of the Finance Companies Control Law, Art. 8)
USD 53.33 m
100k1m10m100m
13 of 16 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
16 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Commercial bankLocally incorporated bank (Banking Control Law; SAMA Licensing Guidelines and Minimum Criteria for Banks, Dec 2018)No fixed figureMinimum capital
- Permits
- Full banking business: deposits, lending, payments, treasury, trade finance, card issuing and acquiring. Islamic banks are licensed under the same law.
- Minimum capital
- No fixed monetary minimum in the SAMA licensing guidelines; banks must maintain the capital adequacy ratio set by SAMA, which may be higher for new banks.
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Saudi joint stock company. Licenses are granted by government approval on SAMA's recommendation. Pre-application meeting with SAMA required. Saudization and governance rules apply. Securities business requires a separate CMA-licensed subsidiary.
- Systems
- Private BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HouseCard Issuing ProgramMerchant AcquiringIslamic Finance Structure
- Reading
- Read in the rulebook
- Sources
02Foreign bank branchForeign bank branch (SAMA Licensing Guidelines and Minimum Criteria for Banks)No fixed figureMinimum capital
- Permits
- Banking business through a branch of a foreign bank.
- Minimum capital
- Foreign bank branches are not required to maintain capital in Saudi Arabia; SAMA may set capital case by case for high-risk or specialized activities.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Scope set in the license. Parent supervision and financial strength are assessed.
- Systems
- Correspondent Banking StructureTreasury & Liquidity DeskTrade Finance House
- Reading
- Read in the rulebook
- Sources
03Digital bankDigital-only bank (Additional Licensing Guidelines and Criteria for Digital-Only Banks, Feb 2020)No fixed figureMinimum capital
- Permits
- Full banking business delivered through digital channels without a branch network.
- Minimum capital
- No fixed minimum; SAMA assesses capital adequacy case by case using the business plan, ICAAP and ILAAP. For reference, the D360 Bank license was approved with SAR 1.65 billion capital (Argaam).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Saudi joint stock company with a physical head office in Saudi Arabia. Exit plan required. SAMA may require an independent assessor for technology, cybersecurity and AML/CFT; SAMA must approve go-live. Same prudential rules as conventional banks.
- Systems
- Digital BankCard Issuing Program
- Reading
- Read in the rulebook
- Sources
04Finance companyFinance company - finance activities other than real estate (Implementing Regulation of the Finance Companies Control Law, Art. 8)USD 26.67 mMinimum capital
- Permits
- One or more non-real-estate finance activities licensed by SAMA, such as productive asset finance, SME finance, finance leasing, credit cards and consumer finance.
- Minimum capital
- SAR 100 million minimum paid-up capital (Art. 8, as amended by Governor decision 126/M SH T, 2023). (≈USD 26.67 m)
- Fees
- Finance company license issuance feeSAR 200,000Finance company license renewal and amendment feesRenewal SAR 100,000; amendment SAR 50,000
- Clients
- Retail permitted
- Conditions
- Saudi joint stock company. Cannot take deposits. SAMA may vary minimum capital by business model.
- Systems
- Card Issuing ProgramTrade Finance House
- Reading
- Read in the rulebook
- Sources
05Real estate finance companyFinance company - real estate finance (Implementing Regulation of the Finance Companies Control Law, Art. 8)USD 53.33 mMinimum capital
- Permits
- Real estate (mortgage) finance.
- Minimum capital
- SAR 200 million minimum paid-up capital (Art. 8, as amended 2023). (≈USD 53.33 m)
- Fees
- Finance company license issuance feeSAR 200,000Finance company license renewal and amendment feesRenewal SAR 100,000; amendment SAR 50,000
- Clients
- Retail permitted
- Conditions
- Saudi joint stock company; no deposit-taking.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
06SME finance companyFinance company - SME finance only (Implementing Regulation of the Finance Companies Control Law, Art. 8)USD 13.33 mMinimum capital
- Permits
- Finance to small and medium enterprises only.
- Minimum capital
- SAR 50 million minimum paid-up capital (Art. 8, as amended 2023). (≈USD 13.33 m)
- Fees
- Finance company license issuance feeSAR 200,000Finance company license renewal and amendment feesRenewal SAR 100,000; amendment SAR 50,000
- Clients
- Professional only
- Conditions
- Saudi joint stock company; no deposit-taking.
- Systems
- Trade Finance House
- Reading
- Read in the rulebook
- Sources
07Microfinance companyFinance company - microfinance only (Implementing Regulation of the Finance Companies Control Law, Art. 8)USD 2.67 mMinimum capital
- Permits
- Microfinance only.
- Minimum capital
- SAR 10 million minimum paid-up capital (Art. 8, as amended 2023). (≈USD 2.67 m)
- Fees
- Microfinance license issuance, renewal or amendment feeSAR 10,000
- Clients
- Retail permitted
- Conditions
- Subject to SAMA microfinance rules; no deposit-taking.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
08Micro payment institutionMicro Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(1), 44(1)(a))USD 267 kMinimum capital
- Permits
- One or more relevant payment services other than e-money issuance, with no cross-border services to persons outside the Kingdom and average monthly payments up to SAR 10 million.
- Minimum capital
- SAR 1,000,000 initial paid-up equity (Art. 44(1)(a)), maintained on an ongoing basis (Art. 45(2)). (≈USD 267 k)
- Fees
- Payment license issuance fee, micro and open-banking licensesSAR 20,000
- Clients
- Retail permitted
- Conditions
- Moves to Major PI once average monthly payment value exceeds SAR 10 million. In-principle approval first; full license required before operating.
- Systems
- Payment Service ProviderMerchant Acquiring
- Reading
- Read in the rulebook
- Sources
09Major payment institutionMajor Payment Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 42(2), 44(1)(b))USD 800 kMinimum capital
- Permits
- Relevant payment services other than e-money issuance with average monthly payments above SAR 10 million, including cross-border services such as money remittance.
- Minimum capital
- SAR 3,000,000 initial capital (Art. 44(1)(b)); ongoing, the higher of that amount or 1% of average monthly payment transaction value (Art. 45(3)). (≈USD 800 k)
- Fees
- Payment license issuance fee, major licensesSAR 50,000
- Clients
- Retail permitted
- Conditions
- Safeguarding of customer funds; SAMA decision within 90 days of receipt notice unless extended.
- Systems
- Payment Service ProviderMerchant AcquiringMoney Services BusinessCard Issuing Program
- Reading
- Read in the rulebook
- Sources
10Micro EMIMicro Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(1), 44(1)(c))USD 533 kMinimum capital
- Permits
- Issuing e-money and related payment services within caps of SAR 10 million in outstanding e-money and monthly payment value, and SAR 20,000 per user in holdings and monthly transactions.
- Minimum capital
- SAR 2,000,000 initial capital (Art. 44(1)(c)), maintained on an ongoing basis. (≈USD 533 k)
- Fees
- Payment license issuance fee, micro and open-banking licensesSAR 20,000
- Clients
- Retail permitted
- Conditions
- Must move to Major EMI if any cap is exceeded.
- Systems
- Electronic Money InstitutionPayment Service Provider
- Reading
- Read in the rulebook
- Sources
11Major EMIMajor Electronic Money Institution (Implementing Regulations of the Law of Payments and Payment Services, Arts. 43(2), 44(1)(d))USD 2.67 mMinimum capital
- Permits
- Issuing e-money and payment services above the Micro EMI limits, with per-user caps of SAR 100,000 in holdings and monthly transactions.
- Minimum capital
- SAR 10,000,000 initial capital (Art. 44(1)(d)); ongoing, the higher of that amount or 2% of average outstanding e-money (Art. 45(4)). (≈USD 2.67 m)
- Fees
- Payment license issuance fee, major licensesSAR 50,000
- Clients
- Retail permitted
- Conditions
- Safeguarding of e-money float; per-user limits apply.
- Systems
- Electronic Money InstitutionPayment Service ProviderCard Issuing Program
- Reading
- Read in the rulebook
- Sources
12Payment initiation (open banking)Payment Initiation Service provider (Art. 44(1)(e))USD 267 kMinimum capital
- Permits
- Payment initiation services, alone or with account information services.
- Minimum capital
- SAR 1,000,000 initial capital (Art. 44(1)(e)); professional indemnity insurance or equivalent guarantee required (Art. 46(1)). (≈USD 267 k)
- Fees
- Payment license issuance fee, micro and open-banking licensesSAR 20,000
- Clients
- Retail permitted
- Conditions
- Open banking participation under SAMA's open banking framework.
- Systems
- Payment Service Provider
- Reading
- Read in the rulebook
- Sources
13Account information (open banking)Payment Account Information Service provider (Art. 44(1)(f))USD 133 kMinimum capital
- Permits
- Payment account information services only.
- Minimum capital
- SAR 500,000 initial capital (Art. 44(1)(f)); professional indemnity insurance or equivalent guarantee required (Art. 46(1)). (≈USD 133 k)
- Fees
- Payment license issuance fee, micro and open-banking licensesSAR 20,000
- Clients
- Retail permitted
- Conditions
- No handling of funds.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
14Money changerMoney changer - currency exchange (Rules Regulating Money Changing Business)USD 533 kMinimum capital
- Permits
- Buying, selling and trading foreign currencies inside Saudi Arabia.
- Minimum capital
- SAR 2,000,000 minimum paid-up capital (SAMA Money Exchange FAQs). (≈USD 533 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Company must be established within six months of initial approval. Statutory reserve rules apply to exchange centers.
- Systems
- Money Services Business
- Reading
- Read in the rulebook
- Sources
15Money changer with cash import/exportMoney changer - import and export of cash (Rules Regulating Money Changing Business)USD 1.87 mMinimum capital
- Permits
- Currency exchange plus importing and exporting banknotes.
- Minimum capital
- SAR 7,000,000 minimum paid-up capital (SAMA Money Exchange FAQs). (≈USD 1.87 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- As for money changers.
- Systems
- Money Services Business
- Reading
- Read in the rulebook
- Sources
16Exchange house with remittanceMoney changer - money transfer inside and outside Saudi Arabia (Rules Regulating Money Changing Business)USD 2.67 mMinimum capital
- Permits
- Currency exchange plus domestic and cross-border money transfer.
- Minimum capital
- SAR 10,000,000 minimum paid-up capital (SAMA Money Exchange FAQs). (≈USD 2.67 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- As for money changers. Non-bank remittance can alternatively be licensed as a Major Payment Institution.
- Systems
- Money Services Business
- Reading
- Read in the rulebook
- Sources
Reach
None. Licenses are domestic; no GCC passport.
Passage
Regulator service standards: banks receive an acknowledgement within 15 business days, then are processed 'within reasonable time' with no fixed deadline (Licensing Guidelines and Minimum Criteria for Banks). Payment institutions: decision within 90 days of the Application Receipt Notice unless extended; incorporation within 180 days of in-principle approval. Money changers: decision within 60 days of a complete application; incorporation within six months of initial approval.
Licensed elsewhere
Securities dealing, asset and fund management, advisory, arranging and securities custody: CMA. Insurance and reinsurance: Insurance Authority (separate regulator since 2023; insurers must be licensed by it). No licensing regime for digital-asset exchanges, custodians or stablecoin issuers was confirmed. Investment banking is done through CMA-licensed subsidiaries. Sovereign vehicles (PIF) are statutory.
Notes. SAMA was re-established as the Saudi Central Bank under the 2020 SAMA Law. Finance company capital in Implementing Regulation Art. 8 was amended in 2023 (SME-only SAR 50 million and microfinance-only SAR 10 million tiers). Payment licensing now runs under the Law of Payments and Payment Services and its Implementing Regulations (Micro/Major PI, Micro/Major EMI, PIS, AIS). SAMA also runs a regulatory sandbox, and licenses finance support companies (aggregators SAR 2 million; debt collection SAR 10 million). Insurance is no longer licensed by SAMA; minimum insurer capital under the Insurance Authority was not confirmed.
Middle East · Bahrain
CBB
Central Bank of Bahrain
The CBB is Bahrain's single financial regulator under the CBB and Financial Institutions Law (2006), covering banks, investment firms, insurance, capital markets, specialized licensees (money changers, payment and ancillary service providers) and crypto-asset services. Its rules are set out by sector in the CBB Rulebook (Volumes 1-7). Conventional and Islamic banks are licensed separately (Volumes 1 and 2), each split into retail and wholesale licenses.
#20of 34
Balanced score
60 of 100
60 of 100
Scorecard
Credibility ×35%65Breadth ×15%79Entry threshold ×20%54Speed ×15%50Reach ×15%46
Categories24
Systems covered37 of 47
Typical timeline—market practice
Lowest capitalUSD 66 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 2703 items · Paid once, when the application is filed
On grantUSD 2 k–35 k2 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 3 k–5 k11 items · Recurring fees and levies
OtherUSD 3 k1 item · Mandatory charges that arise in operation
CBB fees are modest: a flat BHD 100 application fee and annual fees of 0.25% to 1% of operating expenses inside fixed floors and caps; the first year's floor is payable on grant. Insurance (Volume 3) fees were not retrieved in this pass.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| License application fee (Volumes 2, 4, 5 and 6)Non-refundable, paid on submission of the formal application (Vol 2 LR-4.1.1; Vol 4 AU-6.1.1 and C4-1.1.31; Vol 5 AU-5.1.1; Vol 6 CRA-1.5.1). | BHD 100≈ USD 270 | Islamic retail bank (Volume 2, LR-2.5.2A); Islamic wholesale bank (Volume 2, LR-2.5.2B); Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)); Category 2 investment firm (Volume 4; CA-1.2.7(b)) and 12 more | Read in the rulebook |
| License application fee, conventional banks (Volume 1 LR-4.1)LR-4.1 text was not retrieved; BHD 100 is the figure in the identical Volume 2 (Islamic banks) rule and in every other CBB volume checked. Verify LR-4.1.1 in Volume 1. | BHD 100 (expected)≈ USD 270 | Conventional retail bank (Volume 1, LR-2.5.2A); Conventional wholesale bank (Volume 1, LR-2.5.2B) | To be confirmed |
| Retail CIU authorization processing feeVol 7 CIU-1.2.2 (amended July 2023). Exempt CIUs file a notification (Form 2); no exempt-specific fee is stated. | BHD 100 per application≈ USD 270 | Collective Investment Undertakings (Volume 7) | Read in the rulebook |
| On grant | |||
| First annual license fee on grant, banksLR-4.2.11: payable when the license is issued; floor pro-rated by complete months left in the calendar year. Lowest figure shown is the wholesale floor before pro-rating. | Floor amount (retail BHD 30,000; wholesale BHD 13,000), pro-rated for complete months remaining≈ USD 35 k | Conventional retail bank (Volume 1, LR-2.5.2A); Conventional wholesale bank (Volume 1, LR-2.5.2B); Islamic retail bank (Volume 2, LR-2.5.2A); Islamic wholesale bank (Volume 2, LR-2.5.2B) | Read in the rulebook |
| First annual license fee on grant, investment firmsVol 4 AU-6.2.11 and C4-1.1.38: the first annual fee is payable on issue of the license at the category floor. | Category floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)≈ USD 2 k | Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)); Category 2 investment firm (Volume 4; CA-1.2.7(b)); Category 2 investment firm safeguarding financial instruments (CA-1.2.7(b)); Category 3 investment firm (Volume 4; CA-1.2.7(c)) and 2 more | Read in the rulebook |
| Every year | |||
| Annual license fee, retail banksVol 1 LR-4.2.2 and Vol 2 LR-4.2.2. Relevant operating expenses from latest audited accounts, excluding training, donations, CBB fees and NED pay. Due 1 December of the preceding year. | 1% of relevant operating expenses, floor BHD 30,000, cap BHD 240,000 | Conventional retail bank (Volume 1, LR-2.5.2A); Islamic retail bank (Volume 2, LR-2.5.2A) | Read in the rulebook |
| Annual license fee, Bahraini wholesale banksVol 1/Vol 2 LR-4.2.3. Wholesale branches of foreign banks pay 0.25% with the same BHD 13,000 floor and BHD 100,000 cap (LR-4.2.4). | 0.5% of relevant operating expenses, floor BHD 13,000, cap BHD 100,000 | Conventional wholesale bank (Volume 1, LR-2.5.2B); Islamic wholesale bank (Volume 2, LR-2.5.2B) | Read in the rulebook |
| Annual license fee, Category 1 investment firmVol 4 AU-6.2.3. First fee on grant is the floor (AU-6.2.11). Due 1 December of the preceding year. | 0.25% of relevant operating expenses, floor BHD 6,000, cap BHD 24,000 | Category 1 investment firm (Volume 4, AU-1; CA-1.2.7(a)) | Read in the rulebook |
| Annual license fee, Category 2 investment firmVol 4 AU-6.2.4. First fee on grant is the floor (AU-6.2.11). | 0.25% of relevant operating expenses, floor BHD 4,000, cap BHD 12,000 | Category 2 investment firm (Volume 4; CA-1.2.7(b)); Category 2 investment firm safeguarding financial instruments (CA-1.2.7(b)) | Read in the rulebook |
| Annual license fee, Category 3 investment firmVol 4 AU-6.2.5. First fee on grant is the floor (AU-6.2.11). | 0.25% of relevant operating expenses, floor BHD 1,000, cap BHD 4,000 | Category 3 investment firm (Volume 4; CA-1.2.7(c)) | Read in the rulebook |
| Annual license fee, Category 4 investment firmVol 4 C4-1.1.32. First fee on grant is the floor (C4-1.1.38). | 0.25% of relevant operating expenses; venture capital CIU operators floor BHD 750 / cap BHD 2,000; other CIU operators floor BHD 2,000 / cap BHD 6,000 | Category 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14); Category 4 investment firm - venture capital CIUs only (Volume 4, C4-1.1.14) | Read in the rulebook |
| Annual license fee, crypto-asset service licenseesVol 6 CRA-1.6.3. First fee on grant and for the first full year is the category floor (CRA-1.6.10-11). Due 1 December of the preceding year. | 0.25% of relevant operating expenses; Cat 1 BHD 2,000-6,000; Cat 2 BHD 3,000-8,000; Cat 3 BHD 4,000-10,000; Cat 4 BHD 5,000-12,000 | Crypto-asset service licensee Category 1 (Volume 6, Module CRA, CRA-1.1.9; CRA-3.1.2); Crypto-asset service licensee Category 2 (CRA-1.1.11; CRA-3.1.2); Crypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2); Crypto-asset service licensee Category 4 (CRA-1.1.15; CRA-3.1.2) | Read in the rulebook |
| Annual license fee, stablecoin issuerVol 6 SIO-2.4.3; first fee is the floor (SIO-2.4.10). No application fee is stated in SIO-2.4. | 0.25% of relevant operating expenses, floor BHD 5,000, cap BHD 12,000 | Stablecoin issuer license (Volume 6, Module SIO, SIO-4.1.1) | Read in the rulebook |
| Annual license fee, ancillary service providers (payments)Vol 5 Type 7 AU-5.2.2. Charged per regulated activity (AU-5.2.2A). First fee is the full fixed amount, payable on issue, not pro-rated (AU-5.2.3). | Fixed: card processing BHD 1,000; payment service provider BHD 2,000; PISP BHD 1,000; AISP BHD 1,000≈ USD 3 k | Ancillary service provider - card processing and payment service provider (Volume 5, AU-1.2.8; AU-2.5.4); Payment Initiation Services Provider (Volume 5, AU-2.5.6C); Account Information Services Provider (Volume 5, AU-2.5.6B) | Read in the rulebook |
| Annual license fee, money changersVol 5 Type 1 AU-5.2.3; first fee is the BHD 300 floor (AU-5.2.9). | 0.25% of relevant operating expenses, floor BHD 300, cap BHD 6,000 | Money changer licensee (Volume 5 Type 1; CA-1.2.2) | Read in the rulebook |
| Annual fee per Bahrain-domiciled retail CIUVol 7 CIU-1.2.2: payable before 31 March each year. Sub-fund charging per the archived CIU-1.1.13. | BHD 2,000 per CIU (and per sub-fund of an umbrella)≈ USD 5 k | Collective Investment Undertakings (Volume 7) | Read in the rulebook |
| Other | |||
| Annual fee per locally incorporated SPVVol 2 LR-4.2.9A and Vol 4 AU-6.2.9A: for each Bahrain SPV controlled by or performing functions for the licensee; not pro-rated; does not apply to SPVs of Bahrain-domiciled CIUs. | BHD 1,000 per SPV per year≈ USD 3 k | Conventional retail bank (Volume 1, LR-2.5.2A); Conventional wholesale bank (Volume 1, LR-2.5.2B); Islamic retail bank (Volume 2, LR-2.5.2A); Islamic wholesale bank (Volume 2, LR-2.5.2B) and 4 more | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 665 k
Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c))
USD 66 k
Venture capital fund managerCategory 4 investment firm - venture capital CIUs only (Volume 4, C4-1.1.14)
USD 66 k
Crypto RTO / adviserCrypto-asset service licensee Category 1 (Volume 6, Module CRA, CRA-1.1.9; CRA-3.1.2)
USD 66 k
Account information (open banking)Account Information Services Provider (Volume 5, AU-2.5.6B)
USD 66 k
Payment initiation (open banking)Payment Initiation Services Provider (Volume 5, AU-2.5.6C)
USD 80 k
Captive insurer (C1)Captive insurer Category C1 (Volume 3, CA-2.1.5(e))
USD 199 k
Private fund managerCategory 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14)
USD 266 k
Crypto agency broker / manager / custodianCrypto-asset service licensee Category 2 (CRA-1.1.11; CRA-3.1.2)
USD 266 k
Crypto principal dealerCrypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2)
USD 532 k
Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b))
USD 665 k
Stablecoin issuerStablecoin issuer license (Volume 6, Module SIO, SIO-4.1.1)
USD 665 k
Payment service providerAncillary service provider - card processing and payment service provider (Volume 5, AU-1.2.8; AU-2.5.4)
USD 665 k
Licensed crypto-asset exchangeCrypto-asset service licensee Category 4 (CRA-1.1.15; CRA-3.1.2)
USD 798 k
Captive insurer (C2)Captive insurer Category C2 (Volume 3, CA-2.1.5(f))
USD 798 k
Money changer / exchange houseMoney changer licensee (Volume 5 Type 1; CA-1.2.2)
USD 1.33 m
Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a))
USD 2.66 m
Category 2 with custodyCategory 2 investment firm safeguarding financial instruments (CA-1.2.7(b))
USD 2.66 m
InsurerBahraini insurance firm (Volume 3, CA-1.2.1)
USD 13.3 m
ReinsurerBahraini reinsurance firm (Volume 3, CA-1.2.1)
USD 26.6 m
Wholesale bankConventional wholesale bank (Volume 1, LR-2.5.2B)
USD 100 m
Islamic wholesale bankIslamic wholesale bank (Volume 2, LR-2.5.2B)
USD 100 m
Retail bankConventional retail bank (Volume 1, LR-2.5.2A)
USD 265.96 m
Islamic retail bankIslamic retail bank (Volume 2, LR-2.5.2A)
USD 265.96 m
10k100k1m10m100m1bn
23 of 24 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
24 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Retail bankConventional retail bank (Volume 1, LR-2.5.2A)USD 265.96 mMinimum capital
- Permits
- Full banking with residents and non-residents in Bahrain, including retail deposits, lending, payments, cards and trade finance.
- Minimum capital
- Minimum total shareholders' equity of BD 100 million (Volume 1 LR-2.5.2A, added April 2017, amended October 2018). (≈USD 265.96 m)
- Fees
- License application fee, conventional banks (Volume 1 LR-4.1)BHD 100 (expected)Annual license fee, retail banks1% of relevant operating expenses, floor BHD 30,000, cap BHD 240,000First annual license fee on grant, banksFloor amount (retail BHD 30,000; wholesale BHD 13,000), pro-rated for complete months remainingAnnual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail permitted
- Conditions
- Bahraini incorporation; head office in Bahrain. Branches of foreign banks have endowment capital set case by case (LR-2.5.7). Basel III capital adequacy applies.
- Systems
- Private BankDigital BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HouseCard Issuing ProgramMerchant Acquiring
- Reading
- Read in the rulebook
- Sources
02Wholesale bankConventional wholesale bank (Volume 1, LR-2.5.2B)USD 100 mMinimum capital
- Permits
- Banking business mainly with institutions, non-residents and high-value clients, including investment banking, treasury and trade finance.
- Minimum capital
- Minimum total shareholders' equity of USD 100 million (Volume 1 LR-2.5.2B, added April 2017, amended October 2018). (≈USD 100 m)
- Fees
- License application fee, conventional banks (Volume 1 LR-4.1)BHD 100 (expected)Annual license fee, Bahraini wholesale banks0.5% of relevant operating expenses, floor BHD 13,000, cap BHD 100,000First annual license fee on grant, banksFloor amount (retail BHD 30,000; wholesale BHD 13,000), pro-rated for complete months remainingAnnual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail, with conditions
- Conditions
- Restricted in dealing with Bahraini retail customers; the exact limits are in the license scope (LR-1), which was not reviewed in detail here.
- Systems
- Investment BankCorrespondent Banking StructureTreasury & Liquidity DeskTrade Finance HousePrivate Bank
- Reading
- Read in the rulebook
- Sources
03Islamic retail bankIslamic retail bank (Volume 2, LR-2.5.2A)USD 265.96 mMinimum capital
- Permits
- Full Shari'a-compliant retail banking.
- Minimum capital
- Minimum total shareholders' equity of BD 100 million (Volume 2 LR-2.5.2A, added April 2017, amended October 2018). (≈USD 265.96 m)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, retail banks1% of relevant operating expenses, floor BHD 30,000, cap BHD 240,000First annual license fee on grant, banksFloor amount (retail BHD 30,000; wholesale BHD 13,000), pro-rated for complete months remainingAnnual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail permitted
- Conditions
- Shari'a supervisory board and AAOIFI standards apply.
- Systems
- Islamic Finance StructurePrivate BankDigital BankTrade Finance HouseCard Issuing Program
- Reading
- Read in the rulebook
- Sources
04Islamic wholesale bankIslamic wholesale bank (Volume 2, LR-2.5.2B)USD 100 mMinimum capital
- Permits
- Shari'a-compliant wholesale banking and investment banking.
- Minimum capital
- Minimum total shareholders' equity of USD 100 million (Volume 2 LR-2.5.2B). (≈USD 100 m)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Bahraini wholesale banks0.5% of relevant operating expenses, floor BHD 13,000, cap BHD 100,000First annual license fee on grant, banksFloor amount (retail BHD 30,000; wholesale BHD 13,000), pro-rated for complete months remainingAnnual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail, with conditions
- Conditions
- Shari'a governance and AAOIFI standards; retail limits per license scope.
- Systems
- Islamic Finance StructureInvestment BankTreasury & Liquidity DeskTrade Finance House
- Reading
- Read in the rulebook
- Sources
05Full-scope investment firmCategory 1 investment firm (Volume 4, AU-1; CA-1.2.7(a))USD 2.66 mMinimum capital
- Permits
- Any regulated investment service: dealing in financial instruments as principal and as agent, arranging, managing, safeguarding (custody), advising, arranging and advising on credit, and operating a collective investment undertaking.
- Minimum capital
- BD 1,000,000 minimum capital (CA-1.2.7(a)); ongoing requirement is the higher of this and the risk-based capital requirement (CA-1.2.2). (≈USD 2.66 m)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Category 1 investment firm0.25% of relevant operating expenses, floor BHD 6,000, cap BHD 24,000First annual license fee on grant, investment firmsCategory floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)Annual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail permitted
- Conditions
- Must notify the CBB if capital falls below 110% of requirement. Head office in Bahrain. Can deal on own account, so it is the license for market-making brokers.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokeragePrime-of-PrimeStructured Products IssuerInvestment Bank
- Reading
- Read in the rulebook
- Sources
06Agency broker / asset managerCategory 2 investment firm (Volume 4; CA-1.2.7(b))USD 665 kMinimum capital
- Permits
- All regulated investment services except dealing in financial instruments as principal: agency dealing, arranging, managing, advising and operating CIUs.
- Minimum capital
- BD 250,000 minimum capital where not safeguarding client financial instruments (CA-1.2.7(b)); higher of this and risk-based requirement. (≈USD 665 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Category 2 investment firm0.25% of relevant operating expenses, floor BHD 4,000, cap BHD 12,000First annual license fee on grant, investment firmsCategory floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)Annual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail permitted
- Conditions
- No own-account trading. May hold client assets.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmPrivate Credit FundReal Estate Investment VehicleWealth Management FirmMulti-Family OfficePension & Endowment ManagerQuantitative Trading DeskPrivate BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
07Category 2 with custodyCategory 2 investment firm safeguarding financial instruments (CA-1.2.7(b))USD 2.66 mMinimum capital
- Permits
- Category 2 services plus safeguarding financial instruments (acting as custodian).
- Minimum capital
- BD 1,000,000 minimum capital where undertaking safeguarding (custodian) activity (CA-1.2.7(b)). (≈USD 2.66 m)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Category 2 investment firm0.25% of relevant operating expenses, floor BHD 4,000, cap BHD 12,000First annual license fee on grant, investment firmsCategory floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)Annual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail permitted
- Conditions
- No own-account trading.
- Systems
- Wealth Management FirmFund Management Company
- Reading
- Read in the rulebook
- Sources
08Adviser / arrangerCategory 3 investment firm (Volume 4; CA-1.2.7(c))USD 66 kMinimum capital
- Permits
- Arranging deals in financial instruments, advising on financial instruments, and arranging and advising on credit only.
- Minimum capital
- BD 25,000 minimum capital (CA-1.2.7(c), amended April 2023), plus liquid funds equal to 25% of prior-year operating expenses (CA-1.2.7A). (≈USD 66 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Category 3 investment firm0.25% of relevant operating expenses, floor BHD 1,000, cap BHD 4,000First annual license fee on grant, investment firmsCategory floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)Annual fee per locally incorporated SPVBHD 1,000 per SPV per year
- Clients
- Retail permitted
- Conditions
- May not hold client assets; must be independent, may not take fees or commissions from anyone other than the client, and may not act as a tied agent. Note: the Volume 4 Executive Summary (ES-1.8.3) still shows the older BD 125,000 figure; CA-1.2.7 is the operative rule.
- Systems
- Investment Advisory FirmMulti-Family Office
- Reading
- Read in the rulebook
- Sources
09Private fund managerCategory 4 investment firm - operator of exempt CIUs and PIUs (Volume 4, C4-1.1.14)USD 266 kMinimum capital
- Permits
- Operating collective investment undertakings open only to accredited investors: exempt CIUs and private investment undertakings (PIUs), as well as venture capital CIUs.
- Minimum capital
- BD 100,000 minimum (C4-1.1.14), plus liquid funds equal to 25% of prior-year operating expenses (C4-1.1.19); CBB may require more (C4-1.1.15). (≈USD 266 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Category 4 investment firm0.25% of relevant operating expenses; venture capital CIU operators floor BHD 750 / cap BHD 2,000; other CIU operators floor BHD 2,000 / cap BHD 6,000First annual license fee on grant, investment firmsCategory floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)
- Clients
- Professional only
- Conditions
- Bahraini joint stock company or Bahrain branch of an overseas CIU operator; head office in Bahrain. Accredited investors only. Introduced in 2021.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmPrivate Credit FundReal Estate Investment VehicleVenture Capital Firm
- Reading
- Read in the rulebook
- Sources
10Venture capital fund managerCategory 4 investment firm - venture capital CIUs only (Volume 4, C4-1.1.14)USD 66 kMinimum capital
- Permits
- Operating venture capital CIUs only, for accredited investors.
- Minimum capital
- BD 25,000 minimum (C4-1.1.14), plus 25% of prior-year operating expenses in liquid funds (C4-1.1.19). (≈USD 66 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, Category 4 investment firm0.25% of relevant operating expenses; venture capital CIU operators floor BHD 750 / cap BHD 2,000; other CIU operators floor BHD 2,000 / cap BHD 6,000First annual license fee on grant, investment firmsCategory floor: Cat 1 BHD 6,000; Cat 2 BHD 4,000; Cat 3 BHD 1,000; Cat 4 BHD 2,000 (VC operators BHD 750)
- Clients
- Professional only
- Conditions
- Accredited investors only.
- Systems
- Venture Capital Firm
- Reading
- Read in the rulebook
- Sources
11Bahrain-domiciled fundsCollective Investment Undertakings (Volume 7)No fixed figureMinimum capital
- Permits
- Authorization or registration of Bahrain-domiciled funds, including retail CIUs, expert CIUs, exempt CIUs, private investment undertakings, venture capital CIUs and REITs.
- Minimum capital
- No capital requirement at fund level; the operator must be a licensed investment firm (Category 1, 2 or 4) or bank.
- Fees
- Retail CIU authorization processing feeBHD 100 per applicationAnnual fee per Bahrain-domiciled retail CIUBHD 2,000 per CIU (and per sub-fund of an umbrella)
- Clients
- Retail, with conditions
- Conditions
- Only retail CIUs may be offered to the general public; other types are limited to expert or accredited investors. Fund-type details were not verified against Volume 7.
- Systems
- Mutual Fund & UCITSReal Estate Investment Vehicle
- Reading
- From a secondary source
- Sources
12Crypto RTO / adviserCrypto-asset service licensee Category 1 (Volume 6, Module CRA, CRA-1.1.9; CRA-3.1.2)USD 66 kMinimum capital
- Permits
- Reception and transmission of orders and investment advice on crypto-assets.
- Minimum capital
- BD 25,000 paid-up share capital (CRA-3.1.2). (≈USD 66 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, crypto-asset service licensees0.25% of relevant operating expenses; Cat 1 BHD 2,000-6,000; Cat 2 BHD 3,000-8,000; Cat 3 BHD 4,000-10,000; Cat 4 BHD 5,000-12,000
- Clients
- Retail permitted
- Conditions
- May not hold client assets or money; fees only from clients. Bahraini W.L.L. or B.S.C.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
13Crypto agency broker / manager / custodianCrypto-asset service licensee Category 2 (CRA-1.1.11; CRA-3.1.2)USD 266 kMinimum capital
- Permits
- Agency trading, portfolio management, custody and investment advice in crypto-assets.
- Minimum capital
- BD 100,000 paid-up share capital (CRA-3.1.2). (≈USD 266 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, crypto-asset service licensees0.25% of relevant operating expenses; Cat 1 BHD 2,000-6,000; Cat 2 BHD 3,000-8,000; Cat 3 BHD 4,000-10,000; Cat 4 BHD 5,000-12,000
- Clients
- Retail permitted
- Conditions
- No dealing as principal; may hold client assets. Bahraini W.L.L. or B.S.C.
- Systems
- Custody & Wallet InfrastructureOTC Digital Asset DeskDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
14Crypto principal dealerCrypto-asset service licensee Category 3 (CRA-1.1.13; CRA-3.1.2)USD 532 kMinimum capital
- Permits
- Agency and principal trading, portfolio management, custody, investment advice and digital token advisory.
- Minimum capital
- BD 200,000 paid-up share capital (CRA-3.1.2). (≈USD 532 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, crypto-asset service licensees0.25% of relevant operating expenses; Cat 1 BHD 2,000-6,000; Cat 2 BHD 3,000-8,000; Cat 3 BHD 4,000-10,000; Cat 4 BHD 5,000-12,000
- Clients
- Retail permitted
- Conditions
- May not operate a crypto-asset exchange. Bahraini W.L.L. or B.S.C.
- Systems
- OTC Digital Asset DeskCustody & Wallet InfrastructureDigital Asset FundTokenization Platform
- Reading
- Read in the rulebook
- Sources
15Licensed crypto-asset exchangeCrypto-asset service licensee Category 4 (CRA-1.1.15; CRA-3.1.2)USD 798 kMinimum capital
- Permits
- Operating a licensed crypto-asset exchange, custody and digital token advisory.
- Minimum capital
- BD 300,000 paid-up share capital (CRA-3.1.2). (≈USD 798 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, crypto-asset service licensees0.25% of relevant operating expenses; Cat 1 BHD 2,000-6,000; Cat 2 BHD 3,000-8,000; Cat 3 BHD 4,000-10,000; Cat 4 BHD 5,000-12,000
- Clients
- Retail permitted
- Conditions
- Must not execute client orders against proprietary capital or do matched principal trading (CRA-1.1.16). Must be a Bahraini joint stock company.
- Systems
- Digital Asset ExchangeCustody & Wallet InfrastructureTokenization Platform
- Reading
- Read in the rulebook
- Sources
16Stablecoin issuerStablecoin issuer license (Volume 6, Module SIO, SIO-4.1.1)USD 665 kMinimum capital
- Permits
- Issuing and offering stablecoins, controlling supply, minting and burning, and incidental reserve management and custody.
- Minimum capital
- BHD 250,000 minimum initial paid-up share capital (SIO-4.1.1, added July 2025), deposited with a Bahrain retail bank (SIO-4.1.2). (≈USD 665 k)
- Fees
- Annual license fee, stablecoin issuer0.25% of relevant operating expenses, floor BHD 5,000, cap BHD 12,000
- Clients
- Retail permitted
- Conditions
- Only single-currency stablecoins backed by reserve assets in BHD, USD or another CBB-approved fiat currency (SIO-1.2.1); reserves at least equal to par value of coins in circulation (SIO-1.2.2).
- Systems
- Stablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
17Payment service providerAncillary service provider - card processing and payment service provider (Volume 5, AU-1.2.8; AU-2.5.4)USD 665 kMinimum capital
- Permits
- Acting as intermediary for cash placement and withdrawal on client money accounts, settlement of direct debits, connecting access channels (ATM, POS, mobile, internet) and interfacing with switches and card schemes; card processing.
- Minimum capital
- BD 250,000 minimum core capital (AU-2.5.4). (≈USD 665 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, ancillary service providers (payments)Fixed: card processing BHD 1,000; payment service provider BHD 2,000; PISP BHD 1,000; AISP BHD 1,000
- Clients
- Retail permitted
- Conditions
- Volume 5 Type 7 (Ancillary Service Providers). There is no standalone EMI license today; a February 2026 consultation proposes a unified PSP license (see notes).
- Systems
- Payment Service ProviderMerchant Acquiring
- Reading
- Read in the rulebook
- Sources
18Payment initiation (open banking)Payment Initiation Services Provider (Volume 5, AU-2.5.6C)USD 80 kMinimum capital
- Permits
- Payment initiation services under the CBB open banking framework.
- Minimum capital
- BD 30,000 minimum core capital (AU-2.5.6C, added January 2019). (≈USD 80 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, ancillary service providers (payments)Fixed: card processing BHD 1,000; payment service provider BHD 2,000; PISP BHD 1,000; AISP BHD 1,000
- Clients
- Retail permitted
- Conditions
- Ancillary service provider license.
- Systems
- Payment Service Provider
- Reading
- Read in the rulebook
- Sources
19Account information (open banking)Account Information Services Provider (Volume 5, AU-2.5.6B)USD 66 kMinimum capital
- Permits
- Account information services.
- Minimum capital
- BD 25,000 minimum core capital (AU-2.5.6B, added January 2019). (≈USD 66 k)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, ancillary service providers (payments)Fixed: card processing BHD 1,000; payment service provider BHD 2,000; PISP BHD 1,000; AISP BHD 1,000
- Clients
- Retail permitted
- Conditions
- Ancillary service provider license; no handling of funds.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
20Money changer / exchange houseMoney changer licensee (Volume 5 Type 1; CA-1.2.2)USD 1.33 mMinimum capital
- Permits
- Sale, purchase and exchange of foreign currencies, currency transfers to and from Bahrain, travellers' cheques and dealing in precious metals within limits; wholesale banknote import/export only if specifically licensed.
- Minimum capital
- Paid-up capital not less than BD 500,000, plus BD 30,000 per branch and a bank guarantee of at least BD 50,000 (CA-1.2.2). Licensees authorized before 1 January 2011: BD 200,000 (CA-1.2.3). (≈USD 1.33 m)
- Fees
- License application fee (Volumes 2, 4, 5 and 6)BHD 100Annual license fee, money changers0.25% of relevant operating expenses, floor BHD 300, cap BHD 6,000
- Clients
- Retail permitted
- Conditions
- Must be a Bahraini B.S.C. (W.L.L. only if licensed before 1 October 2012). Head office in Bahrain. Core sponsoring shareholders normally hold at least 40% of initial capital in private placements.
- Systems
- Money Services Business
- Reading
- Read in the rulebook
- Sources
21InsurerBahraini insurance firm (Volume 3, CA-1.2.1)USD 13.3 mMinimum capital
- Permits
- Effecting and carrying out general (Category 1 or 2) or long-term (Category 3) insurance contracts.
- Minimum capital
- Minimum Tier 1 capital BD 5 million (CA-1.2.1), plus minimum fund by category: Category 1 BD 300,000; Category 2 BD 500,000; Category 3 BD 400,000 (CA-2.1.5). Capital must exceed the greater of required solvency margin and minimum fund. (≈USD 13.3 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Takaful firms follow CA-8 (figures not confirmed). Overseas insurance firms (branches) have no Tier 1 minimum.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
22ReinsurerBahraini reinsurance firm (Volume 3, CA-1.2.1)USD 26.6 mMinimum capital
- Permits
- Reinsurance business only.
- Minimum capital
- Minimum Tier 1 capital BD 10 million (CA-1.2.1). (≈USD 26.6 m)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Retakaful firms follow CA-8 (not confirmed here).
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
23Captive insurer (C1)Captive insurer Category C1 (Volume 3, CA-2.1.5(e))USD 199 kMinimum capital
- Permits
- Insuring risks of its parent group.
- Minimum capital
- No minimum Tier 1 capital for captives (CA-1.2.1); minimum fund BD 75,000 for Category C1 (CA-2.1.5(e)). (≈USD 199 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Module CI (Captive Insurance) applies.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
24Captive insurer (C2)Captive insurer Category C2 (Volume 3, CA-2.1.5(f))USD 798 kMinimum capital
- Permits
- Captive insurance with broader scope than C1 (including some third-party or related risks as defined in Module CI).
- Minimum capital
- Minimum fund BD 300,000 (CA-2.1.5(f)); no Tier 1 minimum. (≈USD 798 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Module CI applies. Exact C1/C2 scope distinction not verified here.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
None. A CBB license covers Bahrain only; no GCC passport.
Passage
Regulator rule: the CBB must decide within 60 calendar days of an application being deemed complete (e.g. Volume 4 AU-5.1.2); new licensees must start operations within six months of the license (AU-5.1.14). Market practice for a full process including pre-application is commonly several months.
Licensed elsewhere
The CBB licenses nearly all financial systems in Bahrain, including the Bahrain Bourse and other licensed exchanges (Volume 6), which were not researched for capital here. Prop trading on own capital and mining/validation are not separately licensed. Sovereign vehicles (Mumtalakat) are statutory. Physical commodities trading is a commercial registration matter (Ministry of Industry and Commerce).
Notes. Category 3 investment firm capital was cut to BD 25,000 in April 2023. Module CRA was amended in 2023 (digital token offerings, digital token advisory, custody). Module SIO (stablecoins) was added in July 2025. On 5 February 2026 the CBB consulted (until 5 March 2026) on a Payment Service Requirements Module (Module PS) creating a single PSP license covering payment accounts and instruments, domestic and cross-border transfers, merchant acquisition, crypto-asset based payments, e-money issuance, money-changing, payment initiation and account information, with risk-based capital tied to operating expenses; the final capital table and adoption status were not confirmed at October 2026. A secondary aggregator also reports a March 2026 consultation on initial capital for new licensees; scope unconfirmed. Financing companies, microfinance institutions and trust service providers are further Volume 5 license types not detailed here.
Middle East · Qatar · QFC
QFCRA
Qatar Financial Centre Regulatory Authority
The QFCRA authorizes and supervises firms conducting regulated activities in or from the Qatar Financial Centre, a common-law financial free zone in Doha. A firm first obtains a QFC Authority (QFCA) license and then QFCRA authorization for each regulated activity; prudential requirements are set by rulebook (BANK and IBANK for banking business, INMA for investment management and advisory, PINS for insurers, CAPI for captives, COLL/PRIV/PROF for funds). The QFCRA has not used numbered prudential categories since 2015.
#28of 34
Balanced score
52 of 100
52 of 100
Scorecard
Credibility ×35%65Breadth ×15%55Entry threshold ×20%45Speed ×15%50Reach ×15%32
Categories10
Systems covered26 of 47
Typical timeline—market practice
Lowest capitalUSD 148 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 10 k1 item · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 5 k1 item · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
QFC costs come from two bodies: the QFCRA (authorization) and the QFC Authority (licensing and annual fee). Only the QFCA USD 5,000 annual fee is confirmed; the QFCRA application fee range is from a 2020 law-firm note.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| QFCRA authorization fee on applicationInvoiced by the QFCRA on receipt of the application (Form Q02) per Addleshaw Goddard (2020). The figure was not verified against current QFCRA fee rules; the 2025 QFC application-fee cut (USD 5,000 to USD 500) covered non-regulated firms only. | USD 10,000 to USD 40,000, depending on the regulated activities sought | All categories | To be confirmed |
| Every year | |||
| QFC Authority annual license feePro-rated first year due within 21 days of grant; thereafter due by 1 January. Confirmed for QFC-licensed firms from a QFCA penalty notice; whether authorized (QFCRA-regulated) firms pay a different QFCA or QFCRA supervisory fee was not confirmed. | USD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4) | All categories | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 1.55 m
Captive insurerQFC captive insurer, Classes 1 to 4 (Captive Insurance Business Rules 2011, CAPI)
USD 148 k
Investment adviser / arrangerAdvisory and arranging firm (INMA 2014)
USD 250 k
Islamic bank (PSIA)Islamic financial institution operating a profit-sharing investment account (Islamic Banking Business Prudential Rules 2015, IBANK)
USD 9.62 m
Insurance and reinsuranceInsurer / reinsurer (Insurance Business Rules 2006, PINS)
USD 9.89 m
100k1m10m
4 of 10 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
10 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01QFC bankBanking business firm (Banking Business Prudential Rules 2014, BANK)No fixed figureMinimum capital
- Permits
- Accepting deposits, providing credit, dealing in investments as principal and related regulated activities; BANK applies to authorized firms that accept deposits, provide credit or deal in investments as principal.
- Minimum capital
- Base capital requirement is set in BANK; the QAR amount could not be read (the QFCRA rulebook host blocks automated access) and no reliable secondary source states it. Basel III risk-based capital, capital conservation buffer (BANK 3.3.2) and liquidity rules apply on top.
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- QFC banks serve mainly business, wholesale and high-net-worth clients; providing credit to retail clients is outside the QFC activity list and onshore retail banking is QCB-regulated. Draft BANK/IBANK (Market Risk and Miscellaneous) Amendments Rules 2025 would make the Basel simplified standardized approach the default for market risk (consultation, May 2025). Unclear: current base capital amount in QAR; confirm in BANK before relying on any figure.
- Systems
- Private BankInvestment BankTreasury & Liquidity DeskTrade Finance HouseCorrespondent Banking Structure
- Reading
- To be confirmed
- Sources
02Principal dealer / brokerInvestment firm dealing as principal (Banking Business Prudential Rules 2014, BANK)No fixed figureMinimum capital
- Permits
- Dealing in investments as principal and as agent, arranging deals in investments and related services.
- Minimum capital
- Prudentially regulated under BANK rather than INMA (QFCRA, December 2014); the base capital amount for a firm that deals as principal but does not take deposits was not found.
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- Retail access depends on client classification under QFCRA conduct rules; retail FX/CFD brokerage is not an established QFC model. Unclear: current base capital amount.
- Systems
- Institutional BrokeragePrivate BrokerageMulti-Asset BrokerageStructured Products Issuer
- Reading
- To be confirmed
- Sources
03Investment managerInvestment management firm (Investment Management and Advisory Rules 2014, INMA)No fixed figureMinimum capital
- Permits
- Managing investments, operating collective investment schemes and providing custody, as authorized (former prudential Category 3).
- Minimum capital
- Base capital is met through minimum paid-up share capital (INMA 3.3.3), plus an expenditure-based requirement of 13/52 of annual operating expenses. INMA (2015) kept the legacy nominal amounts but restated them in QAR rounded to the nearest thousand. Under the pre-2015 rules, Category 3 base capital was USD 500,000 (Mondaq, 2011); the current QAR figure in INMA 3.3.3 was not read.
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- INMA in force since 1 January 2015. Unclear: the exact current QAR base capital, whether the legacy USD 500,000 still applies unchanged, and whether custody or client money raises it. One law-firm guide (Al Tamimi) says CIS operators hold capital under BANK, which conflicts with INMA covering operators; confirm in the rulebook.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleWealth Management FirmMulti-Family OfficePension & Endowment Manager
- Reading
- To be confirmed
- Sources
04Investment adviser / arrangerAdvisory and arranging firm (INMA 2014)USD 250 kMinimum capital
- Permits
- Advising on investments and arranging deals in investments (former prudential Category 4).
- Minimum capital
- Former Category 4 base capital was USD 250,000; INMA kept that nominal amount, restated in QAR rounded to the nearest thousand and met through minimum paid-up share capital (INMA 3.3.3), plus 13/52 of annual operating expenses (Bloomberg Law and Lexology, 2015). (≈USD 250 k)
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- No holding of client money. Professional indemnity insurance required; a guarantee may substitute if the guarantor has net tangible assets above QR 35 million. The QFCRA consulted in December 2025 on new rules for wholesale advisory firms; check whether lower requirements now apply.
- Systems
- Investment Advisory FirmMulti-Family Office
- Reading
- From a secondary source
- Sources
05Insurance and reinsuranceInsurer / reinsurer (Insurance Business Rules 2006, PINS)USD 9.89 mMinimum capital
- Permits
- Effecting and carrying out contracts of insurance and reinsurance (general business categories 1 to 4, or long-term business). An insurer may not carry on both long-term and general business, except general business limited to categories 1 or 2 (PINS 1.5.1).
- Minimum capital
- Minimum capital requirement (MCR) is the higher of QAR 36 million and the insurer's risk-based capital requirement (PINS 3.3.1); eligible capital must at least equal the MCR (PINS 3.2.1), and the solvency reference requirement is 150% of the risk-based requirement (PINS 3.3.2A). (≈USD 9.89 m)
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- Own risk and solvency assessment and risk management policy required (PINS 2.1.2); annual, half-yearly and quarterly prudential returns. Captives are under a separate rulebook (CAPI). Insurance mediation (brokers, agents, captive managers) is a separate authorization under the Insurance Mediation Business Rules. Figure is from a law-firm chapter citing PINS; the PINS text itself was not read.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
06Captive insurerQFC captive insurer, Classes 1 to 4 (Captive Insurance Business Rules 2011, CAPI)USD 148 kMinimum capital
- Permits
- Class 1: single-owner captive insuring only its parent or affiliates. Class 2: captive with up to 20% of gross written premiums from third-party risks. Class 3: multi-owned captive insuring only its owners or affiliates. Class 4: other captive insurance. Protected cell companies are permitted.
- Minimum capital
- Base capital requirement (CAPI 2.2.2): Class 1 USD 150,000; Class 2 USD 400,000; Class 3 USD 250,000; Class 4 USD 1,000,000 (Classes 2 and 4 unless the QFCRA sets another amount), per the QFCRA captive guide. Al Tamimi states the current range as QAR 540,000 to QAR 3.6 million. Minimum capital is the higher of base capital and the premium and technical-provision risk components. A PCC needs non-cellular capital of at least USD 50,000 (QAR 180,000); cells carry only risk-based capital. (≈USD 148 k)
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Professional only
- Conditions
- Captive manager (Insurance Mediation Business Rules) needs USD 50,000 minimum paid-up share capital and net assets of at least 50% of that. The QFCRA's USD figures are from its own guide (regime commenced 1 July 2011); the current QAR amounts are from a law-firm guide; the CAPI text was not read.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
07Islamic bank (PSIA)Islamic financial institution operating a profit-sharing investment account (Islamic Banking Business Prudential Rules 2015, IBANK)USD 9.62 mMinimum capital
- Permits
- Islamic banking business, including accepting funds under profit-sharing investment accounts, providing Islamic financing and dealing as principal under Shari'a-compliant contracts.
- Minimum capital
- Base capital QAR 35 million for an Islamic financial institution operating a profit-sharing investment account scheme, with ongoing requirements depending on nature and scale (Al Tamimi, 2017 and 2019). Basel-aligned risk-based capital under IBANK applies. (≈USD 9.62 m)
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- Shari'a supervisory board required. Updates to the Islamic banking framework were proposed effective 1 July 2024. The figure is from a law-firm guide; the IBANK text was not read.
- Systems
- Islamic Finance StructurePrivate Bank
- Reading
- From a secondary source
- Sources
08Islamic windowIslamic window or Islamic financial business (QFCRA Islamic Finance Rules, ISFI)No fixed figureMinimum capital
- Permits
- Conducting other authorized activities (investment management, advisory, insurance as takaful) in a Shari'a-compliant manner through an Islamic window or as an Islamic firm.
- Minimum capital
- No separate figure found; capital appears to follow the rulebook for the underlying activity (INMA, PINS, CAPI). Not confirmed.
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- Shari'a supervisory board and QFCRA endorsement required. Unclear: whether ISFI adds any capital above the underlying activity's requirement.
- Systems
- Islamic Finance Structure
- Reading
- To be confirmed
- Sources
09QFC fundsQFC collective investment schemes (Collective Investment Schemes Rules 2010, COLL; Private Placement Schemes Rules, PRIV; Professional Investor Funds Rules 2022, PROF)No fixed figureMinimum capital
- Permits
- Establishment of QFC schemes: retail schemes (open to retail and qualified investors), qualified investor schemes, private placement schemes (qualified investors only, at most 100 unitholders) and professional investor funds under PROF. Fund types include equity, fixed income, REIT, hedge, ETF, Islamic and money market funds.
- Minimum capital
- No capital requirement at fund level; the operator must be QFCRA-authorised for operating a collective investment fund and meets the capital rules for that authorization.
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- Qualified investors include business customers with net assets or share capital of at least QAR 18 million (about USD 5 million) or turnover of at least QAR 30 million, and individuals with net assets of at least QAR 4 million (about USD 1.1 million) plus suitability assessment. Retail schemes may borrow up to 10% of scheme property; retail property funds up to 50% of gross assets; REITs distribute at least 80% of net income. PROF thresholds were not read. QFC managers have ESMA recognition for marketing to EU professional investors.
- Systems
- Mutual Fund & UCITSETF PlatformReal Estate Investment VehicleHedge FundPrivate Equity Firm
- Reading
- From a secondary source
- Sources
10Tokenization service providerToken services for investment tokens (QFC Digital Asset Regulations 2024; QFCRA Investment Token Rules 2024)No fixed figureMinimum capital
- Permits
- Token services: validation, token generation, token custody, operating a token exchange and token transfer. For investment tokens (tokenized securities, derivatives and Islamic contracts) the firm needs a QFCA license plus QFCRA authorization; for other permitted tokens or pure technology provision, only a QFCA token service provider license (Digital Asset Regulations 2024, Article 18) is required.
- Minimum capital
- No capital figure found in the sources read; the QFCRA rules for investment tokens were not read.
- Fees
- QFCRA authorization fee on applicationUSD 10,000 to USD 40,000, depending on the regulated activities soughtQFC Authority annual license feeUSD 5,000 standard annual fee (QFCA Rules, General Rule 10.5 and Schedule 4)
- Clients
- Retail, with conditions
- Conditions
- In force 1 September 2024. Tokens must represent a real right in property; cryptocurrencies and stablecoins are excluded, and the QFCRA confirmed on 2 September 2024 that its 2019 restrictions on virtual assets still apply. The QFCA may prohibit tokenization of certain underlying rights. Unclear: capital and custody requirements for QFCRA-authorised token service providers.
- Systems
- Tokenization PlatformCustody & Wallet Infrastructure
- Reading
- To be confirmed
- Sources
Reach
None. QFC authorization does not permit onshore Qatar business regulated by QCB or QFMA without their approval; no GCC passport.
Passage
Market practice: about 3 to 6 months for QFCA licensing plus QFCRA authorization; no statutory deadline confirmed.
Licensed elsewhere
Onshore Qatar banks, finance companies, payment service providers, e-money, exchange houses and onshore insurers: Qatar Central Bank (QCB). Onshore securities firms, brokers on the Qatar Stock Exchange, fund offerings to the public and onshore asset managers: Qatar Financial Markets Authority (QFMA). Crypto exchanges and crypto custody have no licensing route: QCB prohibits virtual-asset services onshore and the QFC framework excludes cryptocurrencies. Stablecoin issuance and retail FX/CFD brokerage are not available. Sovereign vehicles (QIA) are statutory.
Notes. Research gap: the QFCRA rulebook host (qfcra-en.thomsonreuters.com) and qfcra.com block automated access, so BANK, INMA, PINS and CAPI could not be read directly. Insurer, captive and Islamic bank figures come from law-firm guides and an older QFCRA guide (secondary); bank, principal dealer and investment manager base capital remain unconfirmed. QFC regulated activities: accepting deposits, providing credit (except to retail), dealing in investments, arranging deals, arranging credit, advising, managing investments, operating a collective investment fund, providing and arranging custody, effecting and carrying out insurance, insurance mediation, plus token services for investment tokens (2024). Insurance mediation is not mapped to any of the 47 systems. The QFC Digital Assets Framework took effect 1 September 2024. The 2014-2015 overhaul repealed the Investment and Banking Business Rules 2005 and replaced numbered prudential categories with BANK and INMA. QAR is pegged at 3.64 per USD; USD conversions use that rate.
Americas · United States
SEC
US Securities and Exchange Commission
Federal regulator for securities markets under the Securities Act of 1933, the Securities Exchange Act of 1934, the Investment Company Act of 1940 and the Investment Advisers Act of 1940. Broker-dealers register with the SEC on Form BD and must also join a self-regulatory organization, in practice FINRA, which runs the new-member review and day-to-day examination. Investment advisers below USD 100 million in regulatory assets generally register with their state securities regulator, not the SEC.
#13of 34
Balanced score
74 of 100
74 of 100
Scorecard
Credibility ×35%100Breadth ×15%62Entry threshold ×20%73Speed ×15%60Reach ×15%42
Categories15
Systems covered29 of 47
Typical timeline6–12 monthsmarket practice
Lowest capitalUSD 5 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 40–8 k4 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 40–1 k7 items · Recurring fees and levies
OtherUSD 1252 items · Mandatory charges that arise in operation
The SEC charges almost nothing to register; the real costs are FINRA (NMA fee up to USD 55,000, revenue-based Gross Income Assessment, per-person and per-branch fees, frozen at 2026 rates through 2028) and SIPC at 0.15% of net operating revenues. State registration and notice-filing fees are extra.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| FINRA new member application (NMA) feeOne-time FINRA fee under By-Laws Schedule A s.4. Tiers: small USD 7,500-20,000; medium USD 25,000-30,000; large USD 35,000-55,000, set by number of registered representatives. Form BD itself is filed through FINRA's CRD; registration is not effective for business until FINRA membership is approved. Capital acquisition brokers also go through the NMA process; the fee tier applicable to them was not separately confirmed. | USD 7,500 to USD 55,000 by applicant size | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)); Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)); Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)); Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) and 1 more | Read in the rulebook |
| FINRA NMA surcharge for clearing and carrying firmsAdded to the NMA fee for new members that intend to clear or carry customer accounts. | USD 5,000 | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)) | Read in the rulebook |
| Form ADV initial filing fee (IARD)Paid through the IARD Flex-Funding Account. State notice-filing fees are separate and set by each state. Fees unchanged since Release IA-3126 (2010). | USD 40 (RAUM under USD 25m), USD 150 (USD 25-100m), USD 225 (USD 100m or more) | Registered investment adviser (Advisers Act s.203; Form ADV) | Read in the rulebook |
| Exempt reporting adviser initial report fee (IARD)Release IA-3305. State notice-filing fees may apply separately. | USD 150 | Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1); Exempt reporting adviser: venture capital fund adviser exemption (Advisers Act s.203(l); Rule 203(l)-1) | Read in the rulebook |
| Every year | |||
| FINRA Gross Income Assessment2026 rates under Schedule A s.1(c); SR-FINRA-2026-020 (filed 15 September 2026) froze them at 2026 levels through 31 December 2028, with increases resuming 2029-2031. FINRA also levies a Personnel Assessment per registered person (tier amounts not confirmed). | USD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn) | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)); Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)); Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)); Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) and 2 more | Read in the rulebook |
| FINRA branch office fees2026 renewal fee falls with branch count: USD 245 (1-250 branches), 210 (251-500), 175 (501-1,000), 140 (1,001-2,000), 105 (2,001+). One branch per firm is waived, so a single-office firm pays nothing here. | USD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processing | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)); Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)); Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)); Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) and 2 more | Read in the rulebook |
| FINRA Trading Activity FeeTransaction-based, charged on member sales; 2026 rates held through 2028 by SR-FINRA-2026-020. | USD 0.000195 per share on covered equity sales (max USD 9.79 per trade); USD 0.00329 per options contract; USD 0.00124 per bond (max USD 1.24) for TRACE-eligible and municipal securities | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)); Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)); Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)); Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) and 1 more | Read in the rulebook |
| SIPC assessmentRate confirmed by the SIPC Board on 18 September 2025 for 2026. SIPC membership is mandatory for registered broker-dealers save statutory exclusions (e.g. business conducted outside the US, or exclusively in mutual funds, variable annuities or insurance). A statutory minimum assessment applies (not confirmed on the SIPC page). | 0.15% (0.0015) of net operating revenues from the securities business | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)); Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)); Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)); Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) and 1 more | Read in the rulebook |
| Form ADV annual updating amendment fee (IARD)No fee for other-than-annual amendments, ADV-W or ADV-E. | USD 40 / 150 / 225 by RAUM tier, same tiers as initial filing | Registered investment adviser (Advisers Act s.203; Form ADV) | Read in the rulebook |
| Exempt reporting adviser annual updating amendment fee (IARD)No fee for other amendments or final reports. | USD 150 | Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1); Exempt reporting adviser: venture capital fund adviser exemption (Advisers Act s.203(l); Rule 203(l)-1) | Read in the rulebook |
| Exchange Act Section 31 transaction feePaid by national securities exchanges (and FINRA for OTC trades) and passed on to members. The rate was USD 0.00 per million for charge dates through 3 April 2026. It is reset each fiscal year, so check for an FY2027 advisory. | USD 20.60 per USD 1 million of covered sales (from 4 April 2026); USD 0.0042 per round turn on security futures | National securities exchange (Exchange Act s.6; Form 1) | Read in the rulebook |
| Other | |||
| FINRA registration fees per registered person (Form U4)Annual system processing fee per approved individual (2026): USD 70 (1-5 regulators), 95 (6-20), 110 (21-40), 125 (41+). Disclosure processing fee USD 155 per filing with new or amended disclosure. Qualification exam fees (Series 7, 24, 27 etc.) and state registration fees are extra. FINRA's 2024 phased fee increases were deferred by SR-FINRA-2026-020: 2026 rates stay in force through 31 December 2028 (U4 fee rises to USD 175 from 2030). | USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing fee | Broker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i)); Dealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii)); Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv)); Broker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi)) and 2 more | Read in the rulebook |
| Securities Act s.6(b) registration fee on fund sharesChanged 1 October 2026 (FY2027 rate, Release 33-11436). Open-end funds, ETFs and interval funds register an indefinite amount and pay annually on net sales under Rule 24f-2 at this rate; closed-end funds and BDCs pay on the amount registered. The link to Rule 24f-2 is from general knowledge, not confirmed in the sources fetched. | USD 87.00 per USD 1 million of securities registered (from 1 October 2026; was USD 138.10 in FY2026) | Registered open-end management investment company (Investment Company Act of 1940; Form N-1A); Registered closed-end fund, interval fund (Rule 23c-3) or business development company (Investment Company Act; Form N-2); Exchange-traded fund under Rule 6c-11 (Investment Company Act) | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 100 k
Non-receiving broker-dealerBroker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi))
USD 5 k
Capital acquisition brokerFINRA Capital Acquisition Broker (CAB Rules); statutory M&A broker exemption (Exchange Act s.15(b)(13))
USD 5 k
Alternative trading systemAlternative trading system (Regulation ATS, Rules 300-304; Form ATS or Form ATS-N)
USD 5 k
Introducing broker-dealer (receiving)Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv))
USD 50 k
Dealer / non-carrying principal broker-dealerDealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii))
USD 100 k
Registered mutual fundRegistered open-end management investment company (Investment Company Act of 1940; Form N-1A)
USD 100 k
Closed-end fund, interval fund or BDCRegistered closed-end fund, interval fund (Rule 23c-3) or business development company (Investment Company Act; Form N-2)
USD 100 k
ETF (1940 Act)Exchange-traded fund under Rule 6c-11 (Investment Company Act)
USD 100 k
Carrying / clearing broker-dealerBroker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i))
USD 250 k
1k10k100k1m
9 of 15 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
15 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Carrying / clearing broker-dealerBroker-dealer carrying customer accounts (Exchange Act s.15(b); Rule 15c3-1(a)(2)(i))USD 250 kMinimum capital
- Permits
- Effecting transactions in securities for customers and carrying customer or broker-dealer accounts, including receiving and holding customer funds and securities, clearing and margin lending.
- Minimum capital
- Net capital of not less than USD 250,000 for a broker-dealer that carries customer or broker or dealer accounts and receives or holds their funds or securities (Rule 15c3-1(a)(2)(i)), or the higher ratio-based amount under the aggregate indebtedness or alternative standard. Market makers add USD 2,500 per security (USD 1,000 for securities priced at USD 5 or less), capped at USD 1,000,000 for that component (Rule 15c3-1(a)(4)). (≈USD 250 k)
- Fees
- FINRA new member application (NMA) feeUSD 7,500 to USD 55,000 by applicant sizeFINRA NMA surcharge for clearing and carrying firmsUSD 5,000FINRA registration fees per registered person (Form U4)USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing feeFINRA Gross Income AssessmentUSD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn)FINRA branch office feesUSD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processingFINRA Trading Activity FeeUSD 0.000195 per share on covered equity sales (max USD 9.79 per trade); USD 0.00329 per options contract; USD 0.00124 per bond (max USD 1.24) for TRACE-eligible and municipal securitiesSIPC assessment0.15% (0.0015) of net operating revenues from the securities business
- Clients
- Retail permitted
- Conditions
- FINRA membership, SIPC membership, Customer Protection Rule 15c3-3 (reserve account and possession or control), Regulation Best Interest and Form CRS for retail, net capital early-warning notices under Rule 17a-11, annual PCAOB-audited financials. Crypto asset securities can now be custodied inside an ordinary broker-dealer under Rule 15c3-3: SEC staff FAQs (15 May 2025) made the 2020 special purpose broker-dealer statement optional, and a 17 December 2025 staff statement explained when a broker-dealer is deemed to have physical possession of crypto asset securities. SIPC protection does not cover non-security crypto assets.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrime BrokerageInvestment BankCustody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
02Dealer / non-carrying principal broker-dealerDealer (Rule 15c3-1(a)(2)(iii)); also (k)(2)(i)-exempt broker-dealer (Rule 15c3-1(a)(2)(ii))USD 100 kMinimum capital
- Permits
- Buying and selling securities for the firm's own account as part of a regular business (including more than ten own-account transactions a year, or writing or endorsing OTC options), underwriting, and market making, without carrying customer accounts.
- Minimum capital
- Net capital of not less than USD 100,000 for a dealer (Rule 15c3-1(a)(2)(iii)) and for a broker-dealer exempt from Rule 15c3-3 under paragraph (k)(2)(i) (Rule 15c3-1(a)(2)(ii)). Market makers: USD 2,500 per security (USD 1,000 if priced at USD 5 or less), component capped at USD 1,000,000 (Rule 15c3-1(a)(4)). (≈USD 100 k)
- Fees
- FINRA new member application (NMA) feeUSD 7,500 to USD 55,000 by applicant sizeFINRA registration fees per registered person (Form U4)USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing feeFINRA Gross Income AssessmentUSD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn)FINRA branch office feesUSD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processingFINRA Trading Activity FeeUSD 0.000195 per share on covered equity sales (max USD 9.79 per trade); USD 0.00329 per options contract; USD 0.00124 per bond (max USD 1.24) for TRACE-eligible and municipal securitiesSIPC assessment0.15% (0.0015) of net operating revenues from the securities business
- Clients
- Retail permitted
- Conditions
- FINRA membership is required. A firm trading only its own capital may fall within the trader exception and need no registration, but a firm that wants direct exchange membership, sponsored access or market making generally registers. Market Access Rule 15c3-5 applies to firms with exchange or ATS access. Underwriting adds FINRA Rule 5110 corporate financing review.
- Systems
- Proprietary Trading FirmQuantitative Trading DeskInvestment BankStructured Products IssuerTreasury & Liquidity Desk
- Reading
- Read in the rulebook
- Sources
03Introducing broker-dealer (receiving)Introducing broker-dealer receiving but not holding customer funds or securities (Rule 15c3-1(a)(2)(iv))USD 50 kMinimum capital
- Permits
- Introducing customer transactions and accounts to a clearing broker-dealer on a fully disclosed basis, where the firm receives customer securities or checks but promptly forwards them and does not hold them.
- Minimum capital
- Net capital of not less than USD 50,000 (Rule 15c3-1(a)(2)(iv)). (≈USD 50 k)
- Fees
- FINRA new member application (NMA) feeUSD 7,500 to USD 55,000 by applicant sizeFINRA registration fees per registered person (Form U4)USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing feeFINRA Gross Income AssessmentUSD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn)FINRA branch office feesUSD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processingFINRA Trading Activity FeeUSD 0.000195 per share on covered equity sales (max USD 9.79 per trade); USD 0.00329 per options contract; USD 0.00124 per bond (max USD 1.24) for TRACE-eligible and municipal securitiesSIPC assessment0.15% (0.0015) of net operating revenues from the securities business
- Clients
- Retail permitted
- Conditions
- Requires a fully disclosed clearing agreement with a carrying broker-dealer, FINRA membership, Regulation Best Interest and Form CRS for retail customers. This is the usual structure for a branded brokerage that relies on another firm's clearing and custody infrastructure.
- Systems
- Private BrokerageWhite-Label BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
04Non-receiving broker-dealerBroker-dealer that does not receive, hold or owe customer funds or securities (Rule 15c3-1(a)(2)(vi))USD 5 kMinimum capital
- Permits
- Brokerage activity where the firm never receives or holds customer funds or securities, for example introducing with all funds sent directly to the clearing firm, private placements, and M&A or capital-raising advisory.
- Minimum capital
- Net capital of not less than USD 5,000 (Rule 15c3-1(a)(2)(vi)). A separate USD 25,000 tier applies to firms that only sell investment company shares or insurance separate-account interests directly with the issuer (Rule 15c3-1(a)(2)(v)). (≈USD 5 k)
- Fees
- FINRA new member application (NMA) feeUSD 7,500 to USD 55,000 by applicant sizeFINRA registration fees per registered person (Form U4)USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing feeFINRA Gross Income AssessmentUSD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn)FINRA branch office feesUSD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processingFINRA Trading Activity FeeUSD 0.000195 per share on covered equity sales (max USD 9.79 per trade); USD 0.00329 per options contract; USD 0.00124 per bond (max USD 1.24) for TRACE-eligible and municipal securitiesSIPC assessment0.15% (0.0015) of net operating revenues from the securities business
- Clients
- Retail permitted
- Conditions
- FINRA membership is required. The firm must not take possession of customer assets at any time. Some private placement and M&A firms can instead use the Capital Acquisition Broker rules or the statutory M&A broker exemption.
- Systems
- Private BrokerageWhite-Label BrokerageInvestment Bank
- Reading
- Read in the rulebook
- Sources
05Capital acquisition brokerFINRA Capital Acquisition Broker (CAB Rules); statutory M&A broker exemption (Exchange Act s.15(b)(13))USD 5 kMinimum capital
- Permits
- A limited FINRA membership for firms that act as placement agent or finder in private offerings to institutional investors, advise on M&A of privately held companies, and (since the amendments effective 25 March 2026) act in exempt secondary transactions between institutional investors. CABs may not hold customer accounts, funds or securities, or trade for their own account. Under s.15(b)(13), M&A brokers that meet the statutory conditions need no SEC registration at all.
- Minimum capital
- No separate CAB capital rule. CABs remain registered broker-dealers subject to Rule 15c3-1; because they cannot hold customer funds or securities, they normally fall in the USD 5,000 tier of Rule 15c3-1(a)(2)(vi). (≈USD 5 k)
- Fees
- FINRA registration fees per registered person (Form U4)USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing feeFINRA Gross Income AssessmentUSD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn)FINRA branch office feesUSD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processing
- Clients
- Professional only
- Conditions
- Clients are limited to institutional investors as defined in the CAB rules (widened in 2026 to include certain eligible employees of an issuer). FINRA Regulatory Notice 26-04 (23 February 2026) amended the CAB rules: CABs may represent both buyer and seller in a change of control with written consent, receive securities as compensation from private issuers (new CAB Rule 511), and rely directly on the statutory M&A broker exemption after the SEC withdrew its 2014 M&A brokers no-action letter.
- Systems
- Investment Bank
- Reading
- From a secondary source
- Sources
06Alternative trading systemAlternative trading system (Regulation ATS, Rules 300-304; Form ATS or Form ATS-N)USD 5 kMinimum capital
- Permits
- Operating a marketplace that brings together orders of multiple buyers and sellers of securities using established non-discretionary methods, without registering as a national securities exchange. ATSs trading NMS stocks file Form ATS-N; others file Form ATS.
- Minimum capital
- No ATS-specific capital rule. The operator must be a registered broker-dealer and meet Rule 15c3-1 for its activity: USD 5,000 if it never receives or holds customer funds or securities, rising to USD 100,000 (dealer) or USD 250,000 (carrying). (≈USD 5 k)
- Fees
- FINRA new member application (NMA) feeUSD 7,500 to USD 55,000 by applicant sizeFINRA registration fees per registered person (Form U4)USD 125 initial Form U4 fee plus USD 70 annual system processing fee (1-5 regulators); USD 155 disclosure processing feeFINRA Gross Income AssessmentUSD 1,200 on the first USD 1 million of annual gross revenue, then tiered percentages (0.1827% on USD 1-25m, 0.3909% on USD 25-50m, 0.0779% on USD 50-100m, 0.0549% on USD 100m-5bn, 0.0597% on USD 5-25bn, 0.1286% above USD 25bn)FINRA branch office feesUSD 245 annual branch renewal registration plus USD 75 annual branch processing fee per branch (one branch waived); initial branch registration USD 105 plus USD 75 processingFINRA Trading Activity FeeUSD 0.000195 per share on covered equity sales (max USD 9.79 per trade); USD 0.00329 per options contract; USD 0.00124 per bond (max USD 1.24) for TRACE-eligible and municipal securitiesSIPC assessment0.15% (0.0015) of net operating revenues from the securities business
- Clients
- Retail, with conditions
- Conditions
- Subscribers are typically broker-dealers or institutions; retail access usually comes through a subscriber broker-dealer. Fair access and capacity, integrity and security obligations (Regulation SCI where applicable) apply above volume thresholds. An ATS that trades crypto asset securities or tokenized securities must also solve custody and settlement under Rule 15c3-3. Above certain volumes the SEC can require exchange registration.
- Systems
- ECN & DMA VenueTokenization PlatformDigital Asset Exchange
- Reading
- From a secondary source
- Sources
07Registered securities exchangeNational securities exchange (Exchange Act s.6; Form 1)No fixed figureMinimum capital
- Permits
- Operating a registered exchange for securities, with self-regulatory organization status, its own member rules and listing standards.
- Minimum capital
- No fixed statutory minimum. The SEC assesses financial and operational capacity in the Form 1 review; as a self-regulatory organization the exchange must be able to enforce its rules and surveil its market.
- Fees
- Exchange Act Section 31 transaction feeUSD 20.60 per USD 1 million of covered sales (from 4 April 2026); USD 0.0042 per round turn on security futures
- Clients
- Retail, with conditions
- Conditions
- Retail investors reach the exchange only through member broker-dealers. Rule changes require SEC filings under Rule 19b-4. Regulation SCI applies. This route is rarely practical for a new entrant compared with an ATS.
- Systems
- ECN & DMA Venue
- Reading
- From a secondary source
- Sources
08Transfer agentRegistered transfer agent (Exchange Act s.17A(c); Form TA-1; Rules 17Ac2-1 and 17Ad-1 to 17Ad-27)No fixed figureMinimum capital
- Permits
- Maintaining the official record of security holders, registering transfers, and issuing and cancelling securities on behalf of issuers. Several tokenization platforms register as transfer agents so that a blockchain record can serve as the master securityholder file.
- Minimum capital
- No SEC minimum capital for non-bank transfer agents. Bank transfer agents register with their bank regulator instead.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Serves issuers, not investors directly. Turnaround, recordkeeping and safeguarding rules apply. The SEC has listed transfer-agent modernization, including blockchain records, on its 2026 agenda; no final rule was confirmed for this record.
- Systems
- Tokenization Platform
- Reading
- From a secondary source
- Sources
09SEC-registered investment adviserRegistered investment adviser (Advisers Act s.203; Form ADV)No fixed figureMinimum capital
- Permits
- Providing investment advice for compensation, including discretionary portfolio management, managing private funds and managing registered funds.
- Minimum capital
- No federal minimum capital. Registration with the SEC is permitted from USD 100 million and required from USD 110 million of regulatory assets under management; an adviser must generally withdraw below USD 90 million. Advisers under USD 100 million generally register with their state (state net worth or bonding rules may apply there).
- Fees
- Form ADV initial filing fee (IARD)USD 40 (RAUM under USD 25m), USD 150 (USD 25-100m), USD 225 (USD 100m or more)Form ADV annual updating amendment fee (IARD)USD 40 / 150 / 225 by RAUM tier, same tiers as initial filing
- Clients
- Retail permitted
- Conditions
- Fiduciary duty; custody rule 206(4)-2 (client assets with a qualified custodian such as a bank, broker-dealer or state trust company, plus surprise examination or audited fund financials); marketing rule; code of ethics; chief compliance officer; Form CRS for retail clients; Form PF for private fund advisers. The 2023 private fund adviser rules were vacated by the Fifth Circuit in June 2024.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmPrivate Credit FundReal Estate Investment VehicleWealth Management FirmMulti-Family OfficeInvestment Advisory FirmPension & Endowment ManagerDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
10Exempt reporting adviser (private funds under USD 150m)Exempt reporting adviser: private fund adviser exemption (Advisers Act s.203(m); Rule 203(m)-1)No fixed figureMinimum capital
- Permits
- Advising solely qualifying private funds with less than USD 150 million in private fund assets under management in the United States, without full SEC registration.
- Minimum capital
- No minimum capital. Threshold: less than USD 150 million private fund AUM (for a non-US adviser, only assets managed from a US place of business count).
- Fees
- Exempt reporting adviser initial report fee (IARD)USD 150Exempt reporting adviser annual updating amendment fee (IARD)USD 150
- Clients
- Professional only
- Conditions
- Files a short Form ADV as an exempt reporting adviser and is subject to SEC examination and anti-fraud rules. Fund investors are limited by the fund's own exemption (accredited investors under Regulation D; qualified purchasers for s.3(c)(7) funds). State registration or notice may still apply. Once private fund AUM reaches USD 150 million, the adviser must register.
- Systems
- Hedge FundPrivate Equity FirmPrivate Credit FundReal Estate Investment VehicleFund Management CompanyDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
11Exempt reporting adviser (venture capital)Exempt reporting adviser: venture capital fund adviser exemption (Advisers Act s.203(l); Rule 203(l)-1)No fixed figureMinimum capital
- Permits
- Advising solely venture capital funds, as defined in Rule 203(l)-1, with no AUM ceiling.
- Minimum capital
- No minimum capital and no AUM limit.
- Fees
- Exempt reporting adviser initial report fee (IARD)USD 150Exempt reporting adviser annual updating amendment fee (IARD)USD 150
- Clients
- Professional only
- Conditions
- Each fund must meet the venture capital fund definition (mainly qualifying investments in private operating companies, with only a limited basket of non-qualifying investments and limited fund-level leverage, and no redemption rights except in extraordinary circumstances). Files a short Form ADV as an exempt reporting adviser.
- Systems
- Venture Capital Firm
- Reading
- Read in the rulebook
- Sources
12Excluded single-family officeFamily office exclusion (Advisers Act s.202(a)(11)(G); Rule 202(a)(11)(G)-1)No fixed figureMinimum capital
- Permits
- A family office that advises only family clients is excluded from the definition of investment adviser and needs no SEC registration or filing.
- Minimum capital
- None. This is an exclusion, not a license.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Must have only family clients, be wholly owned by family clients and exclusively controlled by family members or family entities, and must not hold itself out to the public as an investment adviser. A multi-family office serving unrelated families does not qualify and generally must register as an investment adviser.
- Systems
- Single-Family Office
- Reading
- Read in the rulebook
- Sources
13Registered mutual fundRegistered open-end management investment company (Investment Company Act of 1940; Form N-1A)USD 100 kMinimum capital
- Permits
- Publicly offering redeemable shares of a pooled investment fund to retail investors.
- Minimum capital
- The fund must have a net worth of at least USD 100,000 before making a public offering (Investment Company Act s.14(a)), normally met with sponsor seed capital. (≈USD 100 k)
- Fees
- Securities Act s.6(b) registration fee on fund sharesUSD 87.00 per USD 1 million of securities registered (from 1 October 2026; was USD 138.10 in FY2026)
- Clients
- Retail permitted
- Conditions
- Requires an SEC-registered investment adviser, an independent board, a qualified custodian, limits on leverage (Rule 18f-4 derivatives risk management) and illiquid holdings (Rule 22e-4, 15% cap), daily NAV, and distribution through registered broker-dealers.
- Systems
- Mutual Fund & UCITS
- Reading
- From a secondary source
- Sources
14Closed-end fund, interval fund or BDCRegistered closed-end fund, interval fund (Rule 23c-3) or business development company (Investment Company Act; Form N-2)USD 100 kMinimum capital
- Permits
- Publicly offering a pooled fund that does not offer daily redemption, suited to less liquid assets such as private credit and real estate debt. A BDC invests mainly in US private or small public operating companies.
- Minimum capital
- USD 100,000 minimum net worth before a public offering (Investment Company Act s.14(a); applied to BDCs through s.59). (≈USD 100 k)
- Fees
- Securities Act s.6(b) registration fee on fund sharesUSD 87.00 per USD 1 million of securities registered (from 1 October 2026; was USD 138.10 in FY2026)
- Clients
- Retail permitted
- Conditions
- Requires an SEC-registered adviser and an independent board. Interval funds must offer periodic repurchases of 5% to 25% of shares. BDCs have asset coverage limits on leverage (150% if elected). Many are sold only to accredited investors in practice, though retail sale is permitted.
- Systems
- Private Credit FundReal Estate Investment Vehicle
- Reading
- From a secondary source
- Sources
15ETF (1940 Act)Exchange-traded fund under Rule 6c-11 (Investment Company Act)USD 100 kMinimum capital
- Permits
- Operating an open-end ETF that meets Rule 6c-11 conditions without obtaining an individual exemptive order. Spot commodity and crypto exchange-traded products are not 1940 Act funds: they are registered under the Securities Act only and listed under exchange rules.
- Minimum capital
- USD 100,000 seed net worth before the public offering (Investment Company Act s.14(a)). Rule 6c-11 adds no capital figure. (≈USD 100 k)
- Fees
- Securities Act s.6(b) registration fee on fund sharesUSD 87.00 per USD 1 million of securities registered (from 1 October 2026; was USD 138.10 in FY2026)
- Clients
- Retail permitted
- Conditions
- Daily portfolio transparency, written custom-basket policies, website disclosure of premiums and discounts and bid-ask spreads. Leveraged or inverse ETFs must also comply with Rule 18f-4. Requires an authorized participant network and an exchange listing.
- Systems
- ETF Platform
- Reading
- From a secondary source
- Sources
Reach
None. SEC registration is US-only and there is no mutual recognition. Non-US broker-dealers can deal with US institutional investors only within the Rule 15a-6 exemption (chaperoning through a US broker-dealer). Non-US advisers can use the foreign private adviser exemption (Advisers Act s.203(b)(3): fewer than 15 US clients and investors and less than USD 25 million attributable to them) or file as exempt reporting advisers.
Passage
Broker-dealer: the SEC must grant registration or start proceedings within 45 days of filing Form BD (Exchange Act s.15(b)(1)), but a firm cannot operate until FINRA approves its membership; FINRA must process a substantially complete new member application within 180 calendar days (FINRA Rule 1000 Series), and 6 to 12 months in total is market practice. Investment adviser: 45 days from filing Form ADV (Advisers Act s.203(c)(2)). Form ATS-N for NMS-stock ATSs: 120-day review, extendable by up to 90 days (Rule 304). Transfer agent Form TA-1: effective 30 days after filing (Exchange Act s.17A(c)(2)). Fund registration statements have no fixed review deadline (market practice several months).
Licensed elsewhere
Banks and trust companies: chartered by the OCC (national banks and national trust banks) or by state banking departments such as NYDFS, with FDIC deposit insurance and Federal Reserve oversight of holding companies. Money transmission, e-money-like stored value, payments and remittance: state money transmitter licenses (often through NMLS) plus FinCEN MSB registration. Retail FX, futures, commodity pools and swaps: CFTC with NFA membership. Insurance and reinsurance: state insurance departments. Payment stablecoins: GENIUS Act (signed July 2025) issuers are supervised by the OCC or a state regulator, not the SEC. Spot trading and custody of crypto assets that are not securities: state licenses (for example the NY BitLicense) and, for listed spot products, CFTC-registered DCMs. Investment advisers under USD 100 million: state securities regulators. REITs: no license (a public REIT registers its offering under the Securities Act). Sovereign vehicles: not licensed.
Notes. Crypto policy changed sharply in 2025-2026. The SEC issued an interpretive release on how securities laws apply to certain crypto assets (Release 33-11412, 17 March 2026, effective 23 March 2026), and the SEC and CFTC published joint guidance defining 'digital commodity' in March 2026. The SEC proposed 'Regulation Crypto Assets' on 18 August 2026 (an offering framework for covered investment contracts and a safe harbor separating a crypto asset from its investment contract); it is not final. An innovation exemption for on-chain tokenized securities and DeFi was announced but not adopted at the time of writing. The Digital Asset Market Clarity Act (H.R. 3633), which would split crypto oversight between the SEC and CFTC, failed a Senate cloture vote 49-50 on 15 September 2026 and is not law. The 2019 joint SEC-FINRA statement on broker-dealer custody of digital assets was withdrawn on 15 May 2025. Security-based swap dealers and clearing agencies also register with the SEC but are outside the 47 systems.
Americas · United States
CFTC · NFA
Commodity Futures Trading Commission
Federal regulator of futures, options on futures, swaps and retail off-exchange forex under the Commodity Exchange Act. Intermediaries (FCMs, RFEDs, IBs, CPOs, CTAs, swap dealers) register through, and must join, the National Futures Association, which acts as the frontline self-regulatory organization and sets additional capital and conduct rules. Exchanges (DCMs, SEFs) and clearing houses (DCOs) are designated or registered by the CFTC directly.
#15of 34
Balanced score
68 of 100
68 of 100
Scorecard
Credibility ×35%100Breadth ×15%32Entry threshold ×20%50Speed ×15%77Reach ×15%46
Categories11
Systems covered15 of 47
Typical timeline1–12 monthsmarket practice
Lowest capitalUSD 45 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 200–15 k5 items · Paid once, when the application is filed
On grantUSD 750–282 k4 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 750–282 k5 items · Recurring fees and levies
OtherUSD 851 item · Mandatory charges that arise in operation
The CFTC charges no registration or application fee; costs come from NFA. Registration fees are small, but RFED and forex dealer dues start at USD 125,000 a year and rise to USD 1,000,000 with revenue, and swap dealer dues reach USD 1.465 million a year (USD 1.6 million from July 2027).
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| NFA registration fee, Form 7-R (FCM)NFA Registration Rule 203(a)(2). Non-refundable. The CFTC itself charges no registration fee; NFA processes registration on its behalf. | USD 500 | Futures commission merchant (CEA s.4d; Regulation 1.17); FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | Read in the rulebook |
| NFA registration fee, Form 7-R (RFED)NFA Registration Rule 203(a)(15). Non-refundable. | USD 500 | Retail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) | Read in the rulebook |
| NFA registration fee, Form 7-R (IB)NFA Registration Rule 203(a)(3). Non-refundable. | USD 200 | Introducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)); Introducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED) | Read in the rulebook |
| NFA registration fee, Form 7-R (CPO or CTA)NFA Registration Rule 203(a)(4). | USD 200 | Commodity pool operator (CEA s.1a(11); Part 4); Commodity trading advisor (CEA s.1a(12); Part 4) | Read in the rulebook |
| NFA registration fee, Form 7-R (swap dealer)NFA Registration Rule 203(a)(16). | USD 15,000 | Swap dealer (CEA s.4s; Regulations 23.100-23.106) | Read in the rulebook |
| On grant | |||
| NFA membership dues on admission (FCM)Initial dues equal annual dues. Non-refundable. | USD 5,625 (NFA as DSRO); USD 1,500 (exchange as DSRO); USD 7,375 (swaps FCM, NFA as DSRO) | Futures commission merchant (CEA s.4d; Regulation 1.17) | Read in the rulebook |
| NFA membership dues on admission (RFED or forex dealer member FCM)Applies to RFEDs and to FCMs acting as counterparty to retail forex (Forex Dealer Members). | USD 125,000 (NFA as DSRO); USD 25,000 for an FDM whose exchange DSRO examines its forex activities | FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1); Retail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) | Read in the rulebook |
| NFA membership dues on admission (IB, CPO, CTA)Initial dues equal annual dues. | USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firms | Introducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)); Introducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED); Commodity pool operator (CEA s.1a(11); Part 4); Commodity trading advisor (CEA s.1a(12); Part 4) | Read in the rulebook |
| NFA membership dues on admission (swap dealer)Rising from 1 July 2027 to USD 1,600,000 (Tier 1), USD 395,000 (Tier 2) and USD 395,000 (affiliate). Major swap participants pay USD 200,000. | USD 1,465,000 (Tier 1); USD 365,000 (Tier 2); USD 282,500 (affiliate of a Tier 1 or Tier 2 SD) | Swap dealer (CEA s.4s; Regulations 23.100-23.106) | Read in the rulebook |
| Every year | |||
| NFA annual membership dues (FCM)A late payment fee of USD 25 per month applies. Non-payment within 30 days is treated as a request to withdraw (Bylaw 1303). | USD 5,625 (NFA as DSRO); USD 1,500 (exchange as DSRO); USD 7,375 (swaps FCM, NFA as DSRO) | Futures commission merchant (CEA s.4d; Regulation 1.17) | Read in the rulebook |
| NFA annual membership dues (RFED or forex dealer member FCM)Tiers: up to USD 5m revenue USD 125,000; USD 5-10m USD 250,000; USD 10-25m USD 500,000; USD 25-50m USD 750,000; above USD 50m USD 1,000,000. An FDM whose exchange DSRO examines its forex activities pays USD 25,000. | USD 125,000 to USD 1,000,000 by gross annual revenue | FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1); Retail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7) | Read in the rulebook |
| NFA annual membership dues (IB, CPO, CTA) | USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firms | Introducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)); Introducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED); Commodity pool operator (CEA s.1a(11); Part 4); Commodity trading advisor (CEA s.1a(12); Part 4) | Read in the rulebook |
| NFA annual membership dues (swap dealer)These are annual amounts, invoiced and payable quarterly. From 1 July 2027: USD 1,600,000 (Tier 1), USD 395,000 (Tier 2 and affiliates). | USD 1,465,000 (Tier 1); USD 365,000 (Tier 2); USD 282,500 (affiliate) | Swap dealer (CEA s.4s; Regulations 23.100-23.106) | Read in the rulebook |
| NFA assessment fee on futures and optionsCollected by FCMs from customers and remitted monthly to NFA. Current from 1 July 2026; rises to USD 0.02 per side from 1 July 2027. Forex and swap transaction assessments were not confirmed. | USD 0.01 per side on futures, exchange-traded options and security futures | Futures commission merchant (CEA s.4d; Regulation 1.17); FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1) | Read in the rulebook |
| Other | |||
| Form 8-R fee per principal and associated personNFA Registration Rule 203(a)(1) and (8); USD 65 for filings under Rule 209. Waived for individuals already registered with the CFTC or listed as a principal of a current registrant. Swap dealer APs are not registered, but SD principals file Form 8-R. Proficiency exams (Series 3, Series 34 for forex) are extra. | USD 85 per individual | Futures commission merchant (CEA s.4d; Regulation 1.17); FCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1); Retail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7); Introducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii)) and 4 more | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 20 m
Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii))
USD 45 k
FCMFutures commission merchant (CEA s.4d; Regulation 1.17)
USD 1 m
FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1)
USD 20 m
RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7)
USD 20 m
Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106)
USD 20 m
10k100k1m10m100m
5 of 11 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
11 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01FCMFutures commission merchant (CEA s.4d; Regulation 1.17)USD 1 mMinimum capital
- Permits
- Soliciting or accepting orders for futures, options on futures and cleared swaps, and accepting customer money or property to margin those trades; clearing membership at DCOs.
- Minimum capital
- Adjusted net capital of the greatest of USD 1,000,000; 8% of customer and non-customer risk margin; the NFA requirement; or the SEC amount if also a broker-dealer (Regulation 1.17(a)(1)(i); NFA Financial Requirements s.1). An FCM that is also a swap dealer: USD 20,000,000 (USD 100,000,000 if using approved capital models). (≈USD 1 m)
- Fees
- NFA registration fee, Form 7-R (FCM)USD 500Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (FCM)USD 5,625 (NFA as DSRO); USD 1,500 (exchange as DSRO); USD 7,375 (swaps FCM, NFA as DSRO)NFA annual membership dues (FCM)USD 5,625 (NFA as DSRO); USD 1,500 (exchange as DSRO); USD 7,375 (swaps FCM, NFA as DSRO)NFA assessment fee on futures and optionsUSD 0.01 per side on futures, exchange-traded options and security futures
- Clients
- Retail permitted
- Conditions
- Customer segregation (s.4d accounts, 30.7 secured accounts, cleared swaps accounts), daily segregation reporting, residual interest, risk management program under Regulation 1.11, chief compliance officer, NFA membership. Since a December 2025 staff no-action letter and pilot, FCMs may accept certain payment stablecoins and non-security digital assets (initially BTC, ETH and USDC) as customer margin, with weekly reporting.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrime Brokerage
- Reading
- Read in the rulebook
- Sources
02FCM offering retail forexFCM acting as counterparty to retail forex transactions (Regulation 5.7(a)(1); NFA Financial Requirements s.1)USD 20 mMinimum capital
- Permits
- Acting as counterparty to retail off-exchange forex transactions with non-eligible contract participants, in addition to ordinary FCM business.
- Minimum capital
- Adjusted net capital of at least USD 20,000,000, plus 5% of total retail forex obligations above USD 10,000,000 (Regulation 5.7; NFA Financial Requirements s.1 and s.11). (≈USD 20 m)
- Fees
- NFA registration fee, Form 7-R (FCM)USD 500Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (RFED or forex dealer member FCM)USD 125,000 (NFA as DSRO); USD 25,000 for an FDM whose exchange DSRO examines its forex activitiesNFA annual membership dues (RFED or forex dealer member FCM)USD 125,000 to USD 1,000,000 by gross annual revenueNFA assessment fee on futures and optionsUSD 0.01 per side on futures, exchange-traded options and security futures
- Clients
- Retail permitted
- Conditions
- Minimum retail security deposits (leverage caps): 2% of notional for major currencies (about 50:1) and 5% for all others (about 20:1) under Regulation 5.9 and NFA Financial Requirements s.12. NFA's major currency list is GBP, CHF, CAD, JPY, EUR, AUD, NZD, SEK, NOK and DKK. No CFDs on other underlyings may be offered to US retail clients. Risk disclosure, quarterly profitability disclosure and trade practice rules under NFA Compliance Rule 2-43 apply.
- Systems
- Retail BrokerageMulti-Asset Brokerage
- Reading
- Read in the rulebook
- Sources
03RFEDRetail foreign exchange dealer (CEA s.2(c)(2)(B); Regulations 5.3 and 5.7)USD 20 mMinimum capital
- Permits
- Acting as, or offering to act as, counterparty to retail off-exchange forex transactions, without FCM futures business.
- Minimum capital
- Adjusted net capital of at least USD 20,000,000, plus 5% of retail forex obligations above USD 10,000,000 (Regulation 5.7(a)(1)); NFA adds 10% of liabilities to affiliates and eligible contract participant dealer counterparties (NFA Financial Requirements s.11). (≈USD 20 m)
- Fees
- NFA registration fee, Form 7-R (RFED)USD 500Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (RFED or forex dealer member FCM)USD 125,000 (NFA as DSRO); USD 25,000 for an FDM whose exchange DSRO examines its forex activitiesNFA annual membership dues (RFED or forex dealer member FCM)USD 125,000 to USD 1,000,000 by gross annual revenue
- Clients
- Retail permitted
- Conditions
- Same 2% (about 50:1) and 5% (about 20:1) minimum security deposits as for FCMs (Regulation 5.9; NFA Financial Requirements s.12). NFA Forex Dealer Member status. Few firms hold this registration because of the capital level; most offshore FX/CFD brands do not accept US residents.
- Systems
- Retail Brokerage
- Reading
- Read in the rulebook
- Sources
04Independent IBIntroducing broker, independent (CEA s.1a(31); Regulation 1.17(a)(1)(iii))USD 45 kMinimum capital
- Permits
- Soliciting or accepting futures, options, swap or retail forex orders without accepting customer money, and passing them to an FCM or RFED.
- Minimum capital
- Adjusted net capital of the greatest of USD 45,000; for IBs with less than USD 1,000,000 adjusted net capital, USD 6,000 per office and USD 3,000 per associated person; or the SEC amount if also a broker-dealer (Regulation 1.17(a)(1)(iii); NFA Financial Requirements s.5). (≈USD 45 k)
- Fees
- NFA registration fee, Form 7-R (IB)USD 200Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firmsNFA annual membership dues (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firms
- Clients
- Retail permitted
- Conditions
- May not hold customer funds. NFA membership, Series 3 for associated persons, AML program. An IB that introduces retail forex accounts may instead operate under a guarantee agreement with an FCM or RFED.
- Systems
- Private BrokerageWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
05Guaranteed IBIntroducing broker, guaranteed (Regulation 1.10(j); guarantee agreement with an FCM or RFED)No fixed figureMinimum capital
- Permits
- Same activities as an independent IB, but the guarantor FCM or RFED is jointly liable for the IB's obligations under the CEA, so the IB has no capital requirement and introduces only to that guarantor.
- Minimum capital
- No minimum adjusted net capital while the guarantee agreement is in force (Regulation 1.17(a)(2)(ii)); the guarantor carries the responsibility.
- Fees
- NFA registration fee, Form 7-R (IB)USD 200Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firmsNFA annual membership dues (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firms
- Clients
- Retail permitted
- Conditions
- Can introduce only to its guarantor. This is the closest US equivalent of a white-label arrangement under another firm's license.
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
06CPOCommodity pool operator (CEA s.1a(11); Part 4)No fixed figureMinimum capital
- Permits
- Operating a collective investment vehicle that trades futures, options on futures, swaps or retail forex, and soliciting or accepting funds for it.
- Minimum capital
- No CFTC or NFA minimum capital.
- Fees
- NFA registration fee, Form 7-R (CPO or CTA)USD 200Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firmsNFA annual membership dues (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firms
- Clients
- Retail, with conditions
- Conditions
- Registration can be avoided under Regulation 4.13(a)(3) where commodity interest trading stays within de minimis limits (initial margin and premiums no more than 5% of liquidation value, or net notional no more than 100%) and investors are accredited or similar. Regulation 4.7 gives disclosure and reporting relief to registered CPOs whose pools are sold only to qualified eligible persons. Registered funds can use the Regulation 4.5 exclusion within the same limits. Pools open to the public need a CFTC-compliant disclosure document and NFA review.
- Systems
- Hedge FundFund Management CompanyDigital Asset FundQuantitative Trading Desk
- Reading
- Read in the rulebook
- Sources
07CTACommodity trading advisor (CEA s.1a(12); Part 4)No fixed figureMinimum capital
- Permits
- Advising others for compensation on trading futures, options on futures, swaps or retail forex, including managing discretionary accounts.
- Minimum capital
- No CFTC or NFA minimum capital.
- Fees
- NFA registration fee, Form 7-R (CPO or CTA)USD 200Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firmsNFA annual membership dues (IB, CPO, CTA)USD 750; USD 2,500 for IB, CPO or CTA forex or swaps firms
- Clients
- Retail permitted
- Conditions
- Exemptions include Regulation 4.14(a)(8) for advisers whose commodity advice is incidental to securities advice to exempt pools, and Regulation 4.14(a)(10) for advisers with no more than 15 clients in the past 12 months who do not hold themselves out to the public as a CTA. Registered CTAs file disclosure documents with NFA.
- Systems
- Quantitative Trading DeskInvestment Advisory Firm
- Reading
- Read in the rulebook
- Sources
08Swap dealerSwap dealer (CEA s.4s; Regulations 23.100-23.106)USD 20 mMinimum capital
- Permits
- Dealing in swaps as a business: holding out as a dealer, making a market or regularly entering into swaps with counterparties, above the de minimis threshold in Regulation 1.3.
- Minimum capital
- Non-bank swap dealers: the greatest of USD 20,000,000 or a percentage of margin, under one of three approaches (Regulation 23.101): bank-based (common equity tier 1 of at least USD 20,000,000 plus 8% of risk-weighted assets and 8% of uncleared initial margin), net liquid assets (net capital of at least USD 20,000,000 and 2% of uncleared initial margin), or tangible net worth for predominantly commercial groups (USD 20,000,000 plus market and credit risk charges and 8% of uncleared initial margin). Bank swap dealers follow their prudential regulator. (≈USD 20 m)
- Fees
- NFA registration fee, Form 7-R (swap dealer)USD 15,000Form 8-R fee per principal and associated personUSD 85 per individualNFA membership dues on admission (swap dealer)USD 1,465,000 (Tier 1); USD 365,000 (Tier 2); USD 282,500 (affiliate of a Tier 1 or Tier 2 SD)NFA annual membership dues (swap dealer)USD 1,465,000 (Tier 1); USD 365,000 (Tier 2); USD 282,500 (affiliate)
- Clients
- Professional only
- Conditions
- Counterparties must be eligible contract participants. Uncleared margin rules, business conduct standards, swap data reporting, chief compliance officer and NFA membership. Capital rules have applied since 6 October 2021.
- Systems
- Structured Products IssuerCommodities Trading House
- Reading
- Read in the rulebook
- Sources
09DCM (futures exchange)Designated contract market (CEA s.5; Part 38)No fixed figureMinimum capital
- Permits
- Operating a board of trade that lists futures, options on futures and swaps, open to retail participants through FCMs; since December 2025 also listed leveraged spot crypto, and since May 2026 crypto perpetual contracts approved under Regulation 40.3.
- Minimum capital
- No fixed dollar minimum. Financial resources at least equal to one year of projected operating costs on a rolling basis, with at least six months covered by unencumbered liquid assets (Regulation 38.1101(a) and (e)).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- 23 core principles, including market surveillance, position limits and an independent regulatory function. Contracts are self-certified (Regulation 40.2) or submitted for approval (40.3). The CFTC said in December 2025 that DCMs may list leveraged spot crypto, approved the first US bitcoin perpetual on 29 May 2026, and issued a 24/7 trading staff advisory (Staff Letter 26-16).
- Systems
- ECN & DMA VenueDigital Asset Exchange
- Reading
- Read in the rulebook
- Sources
10SEFSwap execution facility (CEA s.5h; Part 37)No fixed figureMinimum capital
- Permits
- Operating a multiple-to-multiple trading facility for swaps, including the required order book and request-for-quote functionality for swaps subject to the trade execution requirement.
- Minimum capital
- No fixed dollar minimum. Financial resources covering one year of operating costs, with at least six months in liquid assets (Regulations 37.1301-37.1307).
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Participants must be eligible contract participants. Impartial access, compliance and surveillance obligations.
- Systems
- ECN & DMA Venue
- Reading
- From a secondary source
- Sources
11DCO (clearing house)Derivatives clearing organization (CEA s.5b; Part 39)No fixed figureMinimum capital
- Permits
- Clearing and settling futures, options and swaps as a central counterparty. Vertically integrated crypto derivatives venues often pair a DCM with their own DCO.
- Minimum capital
- No fixed dollar minimum. Financial resources to cover a default by the clearing member creating the largest financial exposure in extreme but plausible conditions, plus one year of operating costs (Regulation 39.11).
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Clearing members are normally FCMs. Some DCOs clear fully collateralized contracts directly for retail participants. Risk management, default management and system safeguards core principles apply. Since December 2025 staff relief covers DCOs accepting certain digital assets as margin. A founder building an exchange applies as a designated contract market (DCM); a DCO is added only for a vertically integrated venue that clears its own contracts.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- From a secondary source
- Sources
Reach
None. Non-US firms dealing with US customers in foreign futures can get relief under Part 30 (Rule 30.10 comparability orders). Foreign swap dealers can use substituted compliance where the CFTC has issued a comparability determination. Foreign venues can register as a foreign board of trade (FBOT), and foreign clearing houses can seek DCO exemption.
Passage
Intermediary registration through NFA has no statutory deadline; market practice is 6 to 12 months for an FCM or RFED and a few weeks to a few months for an IB, CPO or CTA once principals and Series 3 associated persons are approved. DCM designation, SEF registration and DCO registration each have a 180-day review period under CFTC rules (Regulations 38.3, 37.3, 39.3), which the CFTC can extend or toll.
Licensed elsewhere
Securities brokerage, investment advisers and registered funds: SEC and FINRA (and state securities regulators). Banks, digital banks and correspondent banking: OCC, Federal Reserve, FDIC and state banking departments. Money transmission, payments and e-money-like products: state money transmitter licenses plus FinCEN MSB registration. Spot crypto exchanges, OTC desks and custody outside DCMs: state regimes such as the NY BitLicense or trust charters. Stablecoins: GENIUS Act issuers under the OCC or state regulators. Insurance: state insurance departments. Proprietary trading of futures with the firm's own money needs no CFTC registration, though exchange membership rules apply.
Notes. Leverage caps for US retail forex are set as minimum security deposits: 2% for major currencies (about 50:1) and 5% for other currencies (about 20:1), under Regulation 5.9 and NFA Financial Requirements s.12. NFA can raise them in volatile markets. CFDs are not permitted for US retail. Recent changes: December 2025 tokenized collateral guidance and a digital asset collateral pilot for FCMs (BTC, ETH, USDC), with withdrawal of the earlier staff advisory on virtual currency collateral; listed leveraged spot crypto on DCMs (first launched December 2025); first US bitcoin perpetual approved 29 May 2026, with Staff Letter 26-17 allowing certain digital commodity perpetuals to be treated as foreign futures; SEC-CFTC joint guidance defining 'digital commodity' (March 2026). Michael Selig chairs the CFTC. The CLARITY Act, which would have created CFTC registration for digital commodity exchanges, brokers and dealers, failed Senate cloture 49-50 on 15 September 2026 and is not law. Funded-trader or evaluation programs that let US retail customers trade forex or futures exposure can trigger RFED, CPO or CTA registration depending on structure; take advice before launching one.
Americas · United States · New York
NYDFS
New York State Department of Financial Services
Tier 1Official site
State regulator for New York-chartered banks and trust companies, foreign bank branches and agencies, money transmitters, virtual currency businesses (BitLicense, 23 NYCRR Part 200) and insurers, under the New York Banking Law, Insurance Law and Financial Services Law. A New York license covers New York only; firms operating nationally need licenses in other states as well. NYDFS also enforces its own cybersecurity rule (23 NYCRR Part 500) and AML rules (3 NYCRR Parts 115, 116, 416, 417, 504) on licensees.
#23of 34
Balanced score
58 of 100
58 of 100
Scorecard
Credibility ×35%100Breadth ×15%34Entry threshold ×20%50Speed ×15%0Reach ×15%51
Categories8
Systems covered16 of 47
Typical timeline12–24 monthsmarket practice
Lowest capitalUSD 150 k
IOSCO MMoUN/A
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 3 k–12 k4 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guaranteesUSD 2 m3 items · Held or lodged, beyond the minimum capital
Every yearFormula2 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
Application fees are modest (USD 3,000-12,500), but DFS bills ongoing supervision costs back to licensees through assessments, and bonds and asset pledges (a USD 2 million minimum for a foreign branch) tie up capital. Licences in the other 49 states are separate costs.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| BitLicense application fee23 NYCRR 200.5. A conditional BitLicense is an application under the same Part 200; the fee was assumed to be the same, not separately confirmed. | USD 5,000 | Virtual currency business activity license (BitLicense, 23 NYCRR Part 200); Conditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c)) | Read in the rulebook |
| Bank or trust company charter application feeBanking Law s.23 organization application. Covers limited purpose trust companies. | USD 12,500 | Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100); New York state-chartered commercial bank or trust company with general powers (Banking Law Article III) | Read in the rulebook |
| Foreign bank branch, agency or representative office license applicationBanking Law s.26. | USD 7,500 | Foreign bank branch, agency or representative office (Banking Law Article V) | Read in the rulebook |
| Money transmitter original license feeBanking Law s.641(3). | USD 3,000 | Money transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406) | Read in the rulebook |
| Deposits & guarantees | |||
| Foreign bank asset pledge (asset maintenance deposit)3 NYCRR 322.1(a). For well-rated banks the requirement is tiered (1% of the first USD 1bn, 0.75% of the next 4bn, 0.5% of the next 5bn, 0.25% above) and capped at USD 100 million (322.1(f)). Not required where branch deposits are FDIC-insured. A first branch bases it on projected first-year liabilities. | Greater of 1% of average total third-party liabilities or USD 2,000,000 | Foreign bank branch, agency or representative office (Banking Law Article V) | Read in the rulebook |
| Money transmitter surety bondBanking Law s.643 requires a bond. DFS does not publish a fixed sum, and surety providers report USD 500,000 as the common baseline, with more for high-volume licensees. Not confirmed in DFS's own text. | Amount set by DFS during licensing; USD 500,000 commonly cited as baseline | Money transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406) | To be confirmed |
| BitLicense surety bond or trust accountA surety-bond vendor states a USD 500,000 minimum, which was not confirmed in the regulation text. DFS will not issue the license until the bond or trust account is in place. | Amount acceptable to the Superintendent (23 NYCRR 200.9); USD 500,000 commonly cited | Virtual currency business activity license (BitLicense, 23 NYCRR Part 200); Conditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c)) | To be confirmed |
| Every year | |||
| DFS virtual currency licensee assessment23 NYCRR Part 102 under Financial Services Law s.206(a), as amended 30 June 2022. Billed in four quarterly instalments plus a year-end true-up, separately for each license. Licensees are tiered small, medium and large. | Supervisory component (transaction-value and custody bases) plus regulatory component (remaining DFS virtual currency operating costs divided by number of licensees) | Virtual currency business activity license (BitLicense, 23 NYCRR Part 200); Conditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c)) | Read in the rulebook |
| DFS assessment on banking organizationsLimited purpose trust companies and banking organizations, including those doing virtual currency business, are assessed under Part 101. Money transmitters, as Banking Law licensees, are within s.206's assessment of Banking Law-regulated persons. The Part 101 formula was not reviewed. | Allocation of DFS operating expenses under Financial Services Law s.206 (23 NYCRR Part 101) | Limited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100); New York state-chartered commercial bank or trust company with general powers (Banking Law Article III); Foreign bank branch, agency or representative office (Banking Law Article V); Money transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406) | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 194 k
Domestic insurance companyDomestic insurer license (New York Insurance Law; capital and surplus under ss.4103 and 4202)
USD 150 k
Captive insurerCaptive insurance company (New York Insurance Law Article 70)
USD 250 k
100k1m
2 of 8 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
8 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BitLicenseVirtual currency business activity license (BitLicense, 23 NYCRR Part 200)No fixed figureMinimum capital
- Permits
- Virtual currency business activity involving New York or a New York resident: transmitting virtual currency, storing or holding it for others (custody), buying and selling it as a customer business, performing exchange services, and controlling, administering or issuing a virtual currency (23 NYCRR 200.2(q)).
- Minimum capital
- No fixed minimum. Capital is set case by case by the superintendent based on business model and risk (23 NYCRR 200.8). Licensees must also hold a surety bond or trust account for customer protection (23 NYCRR 200.9); DFS states the generally applicable minimum is USD 500,000.
- Fees
- BitLicense application feeUSD 5,000BitLicense surety bond or trust accountAmount acceptable to the Superintendent (23 NYCRR 200.9); USD 500,000 commonly citedDFS virtual currency licensee assessmentSupervisory component (transaction-value and custody bases) plus regulatory component (remaining DFS virtual currency operating costs divided by number of licensees)
- Clients
- Retail permitted
- Conditions
- Application through NMLS; USD 5,000 application fee plus annual assessments. Coin listing must follow DFS listing guidance (November 2023): licensees with an approved policy can self-certify coins, and Greenlisted coins need 10 days' notice. Custody must follow DFS custody guidance updated 30 September 2025. Compliance officer, AML program, Part 500 cybersecurity, and prior approval for new products and changes of control. A BitLicensee that also transmits fiat needs a separate New York money transmitter license.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureStablecoin Issuance StructureTokenization Platform
- Reading
- Read in the rulebook
- Sources
02Conditional BitLicenseConditional BitLicense (framework proposed by DFS in June 2020 under 23 NYCRR 200.4(c))No fixed figureMinimum capital
- Permits
- Virtual currency business activity within the scope of a supervisory agreement, carried out in partnership with an existing BitLicensee or New York limited purpose trust company that provides support such as structure, capital, systems and personnel.
- Minimum capital
- No fixed minimum. Capital support and responsibilities are allocated between the applicant and its sponsoring licensee in the service agreement and the DFS supervisory agreement.
- Fees
- BitLicense application feeUSD 5,000BitLicense surety bond or trust accountAmount acceptable to the Superintendent (23 NYCRR 200.9); USD 500,000 commonly citedDFS virtual currency licensee assessmentSupervisory component (transaction-value and custody bases) plus regulatory component (remaining DFS virtual currency operating costs divided by number of licensees)
- Clients
- Retail permitted
- Conditions
- Designed as a temporary route for start-ups and firms new to New York, with the expectation that the firm later applies for a full BitLicense. The applicant files a draft service-level agreement with the sponsoring licensee, then signs a supervisory agreement with DFS. The current DFS virtual currency page lists only the 2020 request for comments, so confirm the framework's current terms with DFS before relying on it.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
03Limited purpose trust companyLimited purpose trust company (New York Banking Law Article III; fiduciary powers under s.100)No fixed figureMinimum capital
- Permits
- Fiduciary business without general deposit-taking or lending: personal, corporate and employee benefit trust, custody, transfer agency, securities clearance and investment management. With DFS approval it can also conduct virtual currency business (custody, exchange, stablecoin issuance) without a BitLicense, and money transmission without a separate money transmitter license.
- Minimum capital
- No fixed minimum. Capital is set by the superintendent at an amount and in a form sufficient for financial integrity and ongoing operations; at least one-third of capital must be capital stock. Also required: a fidelity bond with at least USD 1,000,000 primary coverage and a surety bond in an amount set by DFS.
- Fees
- Bank or trust company charter application feeUSD 12,500DFS assessment on banking organizationsAllocation of DFS operating expenses under Financial Services Law s.206 (23 NYCRR Part 101)
- Clients
- Retail permitted
- Conditions
- Deposits and loans are limited to those arising directly from fiduciary activity; FDIC insurance is not available, so the company must obtain an exemption under Banking Law s.32. Requires a pre-application meeting, Certificate of Merit, background checks on incorporators, directors and 10% shareholders, three-year projections, a wind-down analysis, BSA/AML and Part 500 compliance, and a supervisory agreement. Current DFS-issued US dollar stablecoins are issued through trust companies. DFS proposed a GENIUS Act-aligned stablecoin regulation on 9 June 2026.
- Systems
- Custody & Wallet InfrastructureStablecoin Issuance StructureDigital Asset ExchangeOTC Digital Asset DeskTokenization PlatformMulti-Family Office
- Reading
- Read in the rulebook
- Sources
04Money transmitterMoney transmitter license (New York Banking Law Article 13-B, ss.640-652-b; 3 NYCRR Part 406)No fixed figureMinimum capital
- Permits
- Receiving money for transmission, transmitting money within the US or abroad, and selling or issuing payment instruments or stored value in or from New York.
- Minimum capital
- No fixed net worth minimum in the statute; financial condition is assessed case by case (Banking Law s.642(1)). A surety bond of at least USD 500,000 for New York instruments (Banking Law s.643(1)), and at least USD 750,000 for traveler's checks, increased at the superintendent's discretion. Permissible investments must at least equal outstanding payment instruments (s.651).
- Fees
- Money transmitter original license feeUSD 3,000Money transmitter surety bondAmount set by DFS during licensing; USD 500,000 commonly cited as baselineDFS assessment on banking organizationsAllocation of DFS operating expenses under Financial Services Law s.206 (23 NYCRR Part 101)
- Clients
- Retail permitted
- Conditions
- USD 3,000 investigation fee (s.641(3)), NMLS filing, AML program under 3 NYCRR Part 416, agent oversight, Part 500 cybersecurity, and FinCEN MSB registration. Licensing in other states is needed for national coverage.
- Systems
- Money Services BusinessPayment Service ProviderElectronic Money Institution
- Reading
- From a secondary source
- Sources
05State-chartered bankNew York state-chartered commercial bank or trust company with general powers (Banking Law Article III)No fixed figureMinimum capital
- Permits
- Full banking business: taking deposits, lending, payments, card issuing, trade finance, correspondent banking and fiduciary services.
- Minimum capital
- No fixed figure published by DFS for de novo banks; capital is set by the superintendent in the charter review and, in practice, by the FDIC as a condition of deposit insurance (FDIC policy expects de novo banks to keep a Tier 1 leverage ratio of at least 8% for their first three years).
- Fees
- Bank or trust company charter application feeUSD 12,500DFS assessment on banking organizationsAllocation of DFS operating expenses under Financial Services Law s.206 (23 NYCRR Part 101)
- Clients
- Retail permitted
- Conditions
- Requires FDIC deposit insurance; Federal Reserve membership is optional, and a holding company is supervised by the Federal Reserve. Fit-and-proper review of organizers, business plan, CRA plan, BSA/AML, Part 500 cybersecurity. De novo approvals are slow and capital-heavy.
- Systems
- Private BankDigital BankCorrespondent Banking StructureTrade Finance HouseCard Issuing ProgramTreasury & Liquidity Desk
- Reading
- To be confirmed
- Sources
06Foreign bank branch or agencyForeign bank branch, agency or representative office (Banking Law Article V)No fixed figureMinimum capital
- Permits
- A branch can conduct a broad banking business, mainly wholesale; an agency can lend and pay out but cannot accept deposits from US citizens or residents (it can hold credit balances); a representative office can only market and liaise.
- Minimum capital
- No capital is held in the branch itself. The branch or agency must maintain an asset pledge with an approved New York depository bank under Banking Law s.202-b and 3 NYCRR Part 322; the exact sizing formula was not confirmed for this record.
- Fees
- Foreign bank branch, agency or representative office license applicationUSD 7,500Foreign bank asset pledge (asset maintenance deposit)Greater of 1% of average total third-party liabilities or USD 2,000,000DFS assessment on banking organizationsAllocation of DFS operating expenses under Financial Services Law s.206 (23 NYCRR Part 101)
- Clients
- Retail, with conditions
- Conditions
- The parent bank must be supervised on a consolidated basis in its home country and the Federal Reserve must also approve the office. Branches established after 1991 generally cannot accept FDIC-insured retail deposits. Asset maintenance, AML and Part 500 apply. The asset pledge amount should be confirmed with DFS.
- Systems
- Correspondent Banking StructureTrade Finance HouseTreasury & Liquidity DeskPrivate Bank
- Reading
- To be confirmed
- Sources
07Domestic insurance companyDomestic insurer license (New York Insurance Law; capital and surplus under ss.4103 and 4202)USD 150 kMinimum capital
- Permits
- Writing property/casualty, life, health and other kinds of insurance or reinsurance as a New York domestic insurer, licensed by kind of insurance under Insurance Law s.1113.
- Minimum capital
- Stock property/casualty insurers: paid-in capital and surplus by kind of insurance under Table One of Insurance Law s.4103(a)(1), from USD 100,000 capital plus USD 50,000 surplus (single minor kinds) up to USD 2,000,000 capital plus USD 1,000,000 surplus; a company writing several kinds needs at least USD 1,000,000 capital (s.4103(a)(2)-(3)). Stock life insurers: USD 2,000,000 capital plus surplus of the greater of USD 4,000,000 or 200% of capital (s.4202(a)). (≈USD 150 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Risk-based capital, reserve and investment rules, NAIC filings, holding company approval for 10% control, Part 500 cybersecurity. Capital_min_usd shows the smallest P&C capital-plus-surplus combination; real-world new insurers need far more.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
08Captive insurerCaptive insurance company (New York Insurance Law Article 70)USD 250 kMinimum capital
- Permits
- Insuring or reinsuring the risks of a parent company and its affiliates (pure captive) or of a group of members (group captive).
- Minimum capital
- Pure captive: total surplus to policyholders of at least USD 250,000, including USD 100,000 paid-in capital for a stock insurer. Group captive: at least USD 500,000, including USD 200,000 paid-in capital for a stock insurer (Insurance Law s.7004). (≈USD 250 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Insures only the parent, affiliates or group members. Business plan and actuarial review by DFS; annual reporting and examinations.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
None. Licenses and charters are New York-specific. A New York trust company can conduct money transmission without a separate New York money transmitter license, and can carry out fiduciary business in other states subject to their law. Under the federal GENIUS Act, a New York-supervised stablecoin issuer can qualify as a state-qualified issuer if the New York regime is certified as substantially similar to the federal one.
Passage
BitLicense: DFS must approve or deny within 90 days after an application is deemed complete (23 NYCRR 200.6(a)), but completeness review usually takes much longer; DFS gives no fixed processing time and 12 to 24 months is market practice. Money transmitter: 90 days from filing, extendable with the applicant's consent (Banking Law s.642(2)); 12 to 24 months is market practice. Bank and trust charters: no statutory deadline; market practice 12 to 24 months including pre-application meetings.
Licensed elsewhere
Securities brokerage, investment advisers, funds, ETFs and trading venues: SEC and FINRA (New York-based advisers below the SEC threshold register with the New York Attorney General's Investor Protection Bureau). Futures, retail forex and swaps: CFTC and NFA. National banks and national trust banks: OCC. Federal stablecoin issuers: OCC under the GENIUS Act. Card network and acquiring activities are not licensed as such; acquirers are banks or work through sponsor banks, and payment facilitators may need money transmitter licenses depending on structure. Mining and validation: no NYDFS license (New York has a 2022 moratorium on new fossil-fuel proof-of-work mining permits, administered by the Department of Environmental Conservation).
Notes. Kaitlin Asrow is Acting Superintendent (2026). On 9 June 2026 DFS proposed a stablecoin regulation to align its regime with the federal GENIUS Act (signed July 2025), adding reserve and custodian concentration limits; a 60-day comment period follows State Register publication. DFS issued updated custody guidance on 30 September 2025 (replacing January 2023 guidance), a January 2025 notice on sentiment-based coins, and recent BitLicenses or charters to firms including Fireblocks, Bullish US, MoonPay, Anchorage Digital NY and Circle Internet Trust Company. Several licensees surrendered BitLicenses in 2024-2025 (for example Bakkt in April 2025). The capital figures for new bank charters, foreign branch asset pledges and the conditional BitLicense terms should be confirmed with DFS before planning.
Americas · Cayman Islands
CIMA
Cayman Islands Monetary Authority
Cayman's single regulator for banks and trust companies, insurers, investment funds (Mutual Funds Act and Private Funds Act), securities investment business (SIBA), virtual asset service providers and money services businesses. Most investment managers serving sophisticated or high-net-worth clients are 'registered persons' under SIBA rather than licensees. Cayman is a British Overseas Territory with no passport into the EU or US.
#29of 34
Balanced score
52 of 100
52 of 100
Scorecard
Credibility ×35%35Breadth ×15%68Entry threshold ×20%72Speed ×15%77Reach ×15%27
Categories22
Systems covered32 of 47
Typical timeline1–12 monthsmarket practice
Lowest capitalUSD 18 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 1 k–7 k5 items · Paid once, when the application is filed
On grantUSD 6 k–37 k3 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 3 k–37 k8 items · Recurring fees and levies
OtherUSD 6401 item · Mandatory charges that arise in operation
CIMA fees are modest per license but stack per fund, sub-fund and license type, all payable by 15 January with monthly late surcharges. From 2026 fund fees are consolidated and higher, and bank fees scale with total assets.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| SIBA license application feeSIBA (Licence Applications and Fees) (Amendment) Regulations 2024 (SL 76 of 2024), Schedule 2; amounts in CI$. CIMA published a consolidated fee schedule updated 20 October 2026 that could not be read in this pass, so check it for later changes. A broker-dealer that is a broker member pays CI$500. | CI$1,000≈ USD 1 k | SIBA license - broker-dealer, market maker or securities manager; SIBA license - arranging deals or advising | Read in the rulebook |
| SIBA registered person registration feeCollas Crill (updated May 2026). Conyers (February 2024) gave CI$5,000 (USD 6,100) before the 2024 fee amendments. | USD 7,317.07 (CI$6,000)≈ USD 7 k | SIBA registered person (s. 5(4) and Schedule 4) | From a secondary source |
| Banking license application feeBanks and Trust Companies (Licence Applications and Fees) (Amendment) Regulations 2024 (SL 66 of 2024), Schedule item 16. Applying the "B license" figure to restricted Class B is an inference. | Class A CI$10,000; Class B CI$4,000≈ USD 5 k | Class A banking license; Class B banking license (unrestricted); Restricted Class B banking license | Read in the rulebook |
| VASP registration application feeBase KY$1,000 plus: issuance KY$1,500 (revenue under KY$1m) or KY$3,500; other services including exchange KY$1,500 (revenue under KY$5m) or KY$5,000. amount_local is the lowest total. Registered VASPs pay the same amount each year. Virtual Asset (Service Providers) (Amendment) Regulations 2025; Bedell Cristin labels the figures guidance only. | KY$1,000 base plus KY$1,500 to KY$5,000 by service and revenue≈ USD 3 k | VASP registration (Virtual Asset (Service Providers) Act) | From a secondary source |
| VASP license application fee (custody or trading platform)Virtual Asset (Service Providers) (Amendment) Regulations 2025. | KY$5,000≈ USD 6 k | VASP license (Virtual Asset (Service Providers) Act, as amended 2024) | From a secondary source |
| On grant | |||
| SIBA license fee on first grant, broker-dealer, market maker or securities managerSIBA (Licence Applications and Fees) (Amendment) Regulations 2024 (SL 76 of 2024), Schedule 2; amounts in CI$. CIMA published a consolidated fee schedule updated 20 October 2026 that could not be read in this pass, so check it for later changes. Each additional license type CI$4,000; restricted license CI$5,000. | CI$10,000≈ USD 12 k | SIBA license - broker-dealer, market maker or securities manager | Read in the rulebook |
| SIBA license fee on first grant, securities arranger or adviserSIBA (Licence Applications and Fees) (Amendment) Regulations 2024 (SL 76 of 2024), Schedule 2; amounts in CI$. CIMA published a consolidated fee schedule updated 20 October 2026 that could not be read in this pass, so check it for later changes. | Securities arranger CI$5,000; securities adviser CI$10,000≈ USD 6 k | SIBA license - arranging deals or advising | Read in the rulebook |
| VASP license grant feeLocally registered VASPs pay lower fees (KY$3,000 custody, KY$10,000 trading platform per the source, fee type not stated). | Custody KY$30,000; trading platform KY$100,000≈ USD 37 k | VASP license (Virtual Asset (Service Providers) Act, as amended 2024) | From a secondary source |
| Every year | |||
| Annual fee, registered mutual fund (consolidated, includes fund annual return fee)Changed 1 January 2026 (Mutual Funds (Fees) (Amendment) Regulations 2025): the separate annual return (FAR) fee was folded into one annual fee; previously KY$3,675 in total. Master funds KY$3,075 (USD 3,750). Payable by 15 January. Whether s. 4(4), administered and licensed funds pay the same figure was not verified. | KY$4,125 (USD 5,030) from 1 January 2026≈ USD 5 k | Registered mutual fund (Mutual Funds Act s. 4(3)) | From a secondary source |
| Annual fee, private fund (consolidated)Carey Olsen (March 2026) and Harneys give one "registered funds" figure and split only the sub-fund fees by fund type, so applying it to private funds is likely but not confirmed in the regulations (Private Funds (Fees) (Amendment) Regulations 2025). | KY$4,125 (USD 5,030) reported for registered funds from 1 January 2026≈ USD 5 k | Private fund (Private Funds Act 2020) | To be confirmed |
| SIBA annual license renewal fee, broker-dealer, market maker or securities managerSIBA (Licence Applications and Fees) (Amendment) Regulations 2024 (SL 76 of 2024), Schedule 2; amounts in CI$. CIMA published a consolidated fee schedule updated 20 October 2026 that could not be read in this pass, so check it for later changes. Payable by 15 January. | CI$10,000≈ USD 12 k | SIBA license - broker-dealer, market maker or securities manager | Read in the rulebook |
| SIBA annual license renewal fee, securities arranger or adviserSIBA (Licence Applications and Fees) (Amendment) Regulations 2024 (SL 76 of 2024), Schedule 2; amounts in CI$. CIMA published a consolidated fee schedule updated 20 October 2026 that could not be read in this pass, so check it for later changes. | Securities arranger CI$5,000; securities adviser CI$10,000≈ USD 6 k | SIBA license - arranging deals or advising | Read in the rulebook |
| SIBA registered person annual feeCollas Crill (May 2026) gives both USD 7,317.07 and USD 6,100 in different places; confirm against the CIMA fee schedule. | CI$5,000 to CI$6,000 (USD 6,100 to USD 7,317)≈ USD 6 k | SIBA registered person (s. 5(4) and Schedule 4) | To be confirmed |
| Banking license annual feeIntroduced by the Banks and Trust Companies (Licence Applications and Fees) (Amendment) Regulations 2025, effective 1 January 2026. Before that, first-grant fees for some bank licenses were raised in 2024 (for example CI$600,000 to CI$750,000) but the class mapping was not in the amending text. | Tiered by total assets from 2026, phased in 2026-2028; amounts not verified | Class A banking license; Class B banking license (unrestricted); Restricted Class B banking license | To be confirmed |
| VASP registration annual feeSee the registration application entry. | Equal to the amount paid at registration (KY$2,500 to KY$6,000)≈ USD 3 k | VASP registration (Virtual Asset (Service Providers) Act) | From a secondary source |
| VASP license annual feeRevenue-banded. | Custody KY$30,000 to KY$200,000; trading platform KY$50,000 to KY$100,000, by revenue≈ USD 37 k | VASP license (Virtual Asset (Service Providers) Act, as amended 2024) | From a secondary source |
| Other | |||
| Annual fee per sub-fund or alternative investment vehicleFrom 1 January 2026; previously KY$300 each. | Mutual fund sub-fund KY$750 (USD 915); private fund sub-fund or AIV KY$525 (USD 640)≈ USD 640 | Registered mutual fund (Mutual Funds Act s. 4(3)); Private fund (Private Funds Act 2020) | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 173 k
Licensed arranger / adviserSIBA license - arranging deals or advising
USD 18 k
In-house / family bankRestricted Class B banking license
USD 24 k
Money services businessMoney services business license (Money Services Act)
USD 37 k
Pure captiveClass B(i) insurer license
USD 100 k
Licensed securities firmSIBA license - broker-dealer, market maker or securities manager
USD 122 k
Captive with significant third-party businessClass B(ii) insurer license
USD 150 k
Commercial / open-market captiveClass B(iii) insurer license
USD 200 k
Domestic insurerClass A insurer license
USD 366 k
Fund administrator (full)Mutual fund administrator license (full, MFAL), Mutual Funds Act
USD 488 k
Domestic and offshore bankClass A banking license
USD 488 k
Offshore bankClass B banking license (unrestricted)
USD 488 k
Open-market reinsurerClass D insurer license
USD 50 m
10k100k1m10m100m
12 of 22 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
22 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Registered open-ended fundRegistered mutual fund (Mutual Funds Act s. 4(3))No fixed figureMinimum capital
- Permits
- Open-ended fund whose minimum aggregate equity interest purchasable by a prospective investor is CI$80,000 (USD 100,000), or whose interests are listed on a CIMA-approved stock exchange. Master funds follow the same test.
- Minimum capital
- No capital requirement for the fund. Minimum investment per investor CI$80,000 (USD 100,000).
- Fees
- Annual fee, registered mutual fund (consolidated, includes fund annual return fee)KY$4,125 (USD 5,030) from 1 January 2026Annual fee per sub-fund or alternative investment vehicleMutual fund sub-fund KY$750 (USD 915); private fund sub-fund or AIV KY$525 (USD 640)
- Clients
- Professional only
- Conditions
- Annual audit by a CIMA-approved local auditor, fund annual return, at least two directors registered under the Directors Registration and Licensing Act. This is the standard hedge fund vehicle.
- Systems
- Hedge FundDigital Asset FundPrivate Credit Fund
- Reading
- Read in the rulebook
- Sources
02Administered fundAdministered mutual fund (Mutual Funds Act s. 4(1)(b))No fixed figureMinimum capital
- Permits
- Open-ended fund with more than 15 investors, not licensed or registered, whose principal office is provided by a CIMA-licensed mutual fund administrator.
- Minimum capital
- No capital requirement for the fund.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- The licensed administrator must be satisfied about the promoters and the fund's business. No minimum investment.
- Systems
- Hedge FundDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
03Licensed fundLicensed mutual fund (Mutual Funds Act s. 4(1)(a))No fixed figureMinimum capital
- Permits
- Open-ended fund licensed directly by CIMA, typically used by large well-known institutions that will not appoint a Cayman administrator; no minimum investment.
- Minimum capital
- No capital requirement for the fund.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- CIMA reviews the promoters' reputation and the offering documents. The usual Cayman route for a fund without a minimum subscription.
- Systems
- Mutual Fund & UCITSHedge Fund
- Reading
- Read in the rulebook
- Sources
04Limited investor fundLimited investor fund (Mutual Funds Act s. 4(4))No fixed figureMinimum capital
- Permits
- Open-ended fund with 15 or fewer investors, a majority of whom can appoint or remove the operators (directors or general partner). Formerly exempt; registration required since the Mutual Funds (Amendment) Law 2020.
- Minimum capital
- No capital requirement and no minimum investment.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Annual audit by a CIMA-approved auditor, fund annual return within six months of year-end, at least two directors.
- Systems
- Hedge FundDigital Asset FundSingle-Family Office
- Reading
- Read in the rulebook
- Sources
05Closed-ended fundPrivate fund (Private Funds Act 2020)No fixed figureMinimum capital
- Permits
- Closed-ended fund (private equity, venture, credit, real estate) that must register with CIMA.
- Minimum capital
- No capital requirement for the fund.
- Fees
- Annual fee, private fund (consolidated)KY$4,125 (USD 5,030) reported for registered funds from 1 January 2026Annual fee per sub-fund or alternative investment vehicleMutual fund sub-fund KY$750 (USD 915); private fund sub-fund or AIV KY$525 (USD 640)
- Clients
- Professional only
- Conditions
- Annual audit, valuation policy, custody (or title verification) of assets, cash monitoring and securities identification requirements. Not reviewed against a minimum investment.
- Systems
- Private Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- From a secondary source
- Sources
06Licensed securities firmSIBA license - broker-dealer, market maker or securities managerUSD 122 kMinimum capital
- Permits
- Dealing in securities, market making, or managing securities with discretion, for clients who do not all qualify for registration.
- Minimum capital
- Base financial resource requirement CI$100,000 (CIMA securities FAQ). Professional indemnity insurance of at least CI$1,000,000 per claim and CI$1,500,000 aggregate. (≈USD 122 k)
- Fees
- SIBA license application feeCI$1,000SIBA license fee on first grant, broker-dealer, market maker or securities managerCI$10,000SIBA annual license renewal fee, broker-dealer, market maker or securities managerCI$10,000
- Clients
- Retail permitted
- Conditions
- Fit and proper, business plan, systems and controls, local auditor. Broker-dealers file monthly financial statements; others quarterly. Retail FX/CFD brokers use this license.
- Systems
- Retail BrokerageMulti-Asset BrokerageInstitutional BrokeragePrime-of-PrimeAsset Management CompanyWealth Management FirmProprietary Trading Firm
- Reading
- Read in the rulebook
- Sources
07Licensed arranger / adviserSIBA license - arranging deals or advisingUSD 18 kMinimum capital
- Permits
- Arranging deals in securities or advising on securities.
- Minimum capital
- Base financial resource requirement CI$15,000 (CIMA securities FAQ), plus the same professional indemnity insurance as other licensees. (≈USD 18 k)
- Fees
- SIBA license application feeCI$1,000SIBA license fee on first grant, securities arranger or adviserSecurities arranger CI$5,000; securities adviser CI$10,000SIBA annual license renewal fee, securities arranger or adviserSecurities arranger CI$5,000; securities adviser CI$10,000
- Clients
- Retail permitted
- Conditions
- Same governance and reporting framework as other SIBA licensees.
- Systems
- Investment Advisory FirmWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
08Registered investment manager / adviserSIBA registered person (s. 5(4) and Schedule 4)No fixed figureMinimum capital
- Permits
- Securities investment business carried on exclusively for sophisticated persons or high-net-worth persons (individuals with USD 1 million net worth or entities with USD 5 million total assets), for group companies only, or by firms regulated by a recognized overseas regulator.
- Minimum capital
- No capital requirement stated for registered persons.
- Fees
- SIBA registered person registration feeUSD 7,317.07 (CI$6,000)SIBA registered person annual feeCI$5,000 to CI$6,000 (USD 6,100 to USD 7,317)
- Clients
- Professional only
- Conditions
- Registered office serviced by a licensed provider, at least two directors registered under the Directors Registration and Licensing Act, AML officers, annual declaration and fee by 15 January. The standard route for Cayman fund managers and general partners.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundWealth Management FirmMulti-Family OfficeInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
09Fund administrator (full)Mutual fund administrator license (full, MFAL), Mutual Funds ActUSD 488 kMinimum capital
- Permits
- Providing administration, including the principal office, to any number of mutual funds and other investment funds.
- Minimum capital
- Net worth of at least CI$400,000 (stated as '$400,000' in CIMA's Regulatory Policy: Licensing Mutual Fund Administrators, September 2018, para. 5.5.2); CIMA may waive or vary it having regard to the shareholders' financial capacity. (≈USD 488 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Professional indemnity insurance at the level set in CIMA's Statement of Guidance on professional indemnity insurance (para. 5.7.4). Required to act as administrator providing the principal office of administered funds.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
10Fund administrator (restricted)Restricted mutual fund administrator license (RMFAL), Mutual Funds ActNo fixed figureMinimum capital
- Permits
- Administering only the regulated mutual funds and other investment funds named in the license (para. 4.3); CIMA approves the number of funds case by case (para. 6.5.3).
- Minimum capital
- No prescribed net worth; CIMA sets the required net worth according to the nature, scale and complexity of the business (Regulatory Policy: Licensing Mutual Fund Administrators, September 2018, para. 5.5.3).
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Professional indemnity insurance as for the full license (para. 5.7.4). Typically used by a sponsor administering its own funds.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
11Domestic and offshore bankClass A banking licenseUSD 488 kMinimum capital
- Permits
- Banking business both within and outside the Cayman Islands. A restricted Class A license limits domestic business (for example to private banking for high-net-worth residents or principal-office services).
- Minimum capital
- CI$400,000 (about USD 500,000) minimum paid-up capital for a new unrestricted license; CIMA may require more depending on scope. (≈USD 488 k)
- Fees
- Banking license application feeClass A CI$10,000; Class B CI$4,000Banking license annual feeTiered by total assets from 2026, phased in 2026-2028; amounts not verified
- Clients
- Retail permitted
- Conditions
- Usually granted only to branches or affiliates of major international banks. Fully staffed Cayman office. Statutory minimum risk-weighted capital ratio 10%; CIMA expects 12% for subsidiaries under consolidated supervision and 15% otherwise.
- Systems
- Private BankCorrespondent Banking StructureTrade Finance HouseDigital Bank
- Reading
- From a secondary source
- Sources
12Offshore bankClass B banking license (unrestricted)USD 488 kMinimum capital
- Permits
- Offshore banking with non-Cayman-resident clients; may not take deposits from or hold most claims on Cayman residents.
- Minimum capital
- CI$400,000 (about USD 500,000) minimum paid-up capital; CIMA may require more. (≈USD 488 k)
- Fees
- Banking license application feeClass A CI$10,000; Class B CI$4,000Banking license annual feeTiered by total assets from 2026, phased in 2026-2028; amounts not verified
- Clients
- Retail, with conditions
- Conditions
- Physical presence, or registered office at a Class A bank with two Cayman-resident authorized agents. Capital ratio expectations as for Class A.
- Systems
- Private BankTreasury & Liquidity DeskCorrespondent Banking StructureTrade Finance House
- Reading
- From a secondary source
- Sources
13In-house / family bankRestricted Class B banking licenseUSD 24 kMinimum capital
- Permits
- Banking limited to a small set of named, approved non-resident clients (generally related parties, about 20 at most), used for intra-group treasury or family banking.
- Minimum capital
- CI$20,000 (about USD 25,000) minimum paid-up capital; CIMA may require more. (≈USD 24 k)
- Fees
- Banking license application feeClass A CI$10,000; Class B CI$4,000Banking license annual feeTiered by total assets from 2026, phased in 2026-2028; amounts not verified
- Clients
- Professional only
- Conditions
- Clients must be approved by CIMA.
- Systems
- Treasury & Liquidity DeskSingle-Family Office
- Reading
- From a secondary source
- Sources
14Domestic insurerClass A insurer licenseUSD 366 kMinimum capital
- Permits
- Insurance business with Cayman-resident policyholders (domestic insurers and reinsurers).
- Minimum capital
- Insurance (Capital and Solvency) (Class A Insurers) Regulations 2012: a local insurer's minimum capital requirement is the greater of $300,000 or a risk-based square-root formula (reg. 6(2)); an approved external insurer's MCR is the greater of $1,000,000 or its policy liabilities (reg. 5(2)). Prescribed capital is 125% of MCR for local insurers and 150% for external insurers (reg. 2), and external insurers must hold assets in trust at least equal to it (reg. 5(1)). (≈USD 366 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Local presence required. The Regulations state amounts in 'dollars' without naming the currency; under Cayman interpretation rules this is read as Cayman Islands dollars, so CI$300,000 is about USD 365,850. CIMA may set an enhanced prescribed capital requirement (reg. 6(4)). Later amendments to the 2012 Regulations were not checked.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
15Pure captiveClass B(i) insurer licenseUSD 100 kMinimum capital
- Permits
- Captive insurer where at least 95% of net premiums come from related business.
- Minimum capital
- Minimum capital requirement USD 100,000 general, USD 200,000 long-term, USD 300,000 composite; prescribed capital equals the MCR (Insurance (Capital and Solvency) (Classes B, C and D Insurers) Regulations, Schedule 1). (≈USD 100 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Must appoint a licensed Cayman insurance manager. Additional capital may be required by the business plan.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
16Captive with significant third-party businessClass B(ii) insurer licenseUSD 150 kMinimum capital
- Permits
- Insurer where more than 50% of net premiums come from related business.
- Minimum capital
- Minimum capital requirement USD 150,000 general, USD 300,000 long-term, USD 450,000 composite. Prescribed capital for general business: 10% of net earned premium up to USD 5 million, 5% of the next tranche up to USD 20 million, 2.5% above. (≈USD 150 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Must appoint a licensed Cayman insurance manager.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
17Commercial / open-market captiveClass B(iii) insurer licenseUSD 200 kMinimum capital
- Permits
- Insurer where 50% or less of net premiums come from related business.
- Minimum capital
- Minimum capital requirement USD 200,000 general, USD 400,000 long-term, USD 600,000 composite. Prescribed capital for general business: 15%, 7.5% and 5% of net earned premium in the same bands. (≈USD 200 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Must appoint a licensed Cayman insurance manager.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
18Collateralized reinsurer / ILS vehicleClass C insurer licenseUSD 500 (nominal)Minimum capital
- Permits
- Fully collateralized reinsurance, typically insurance-linked securities, sidecars and catastrophe bond vehicles.
- Minimum capital
- Minimum capital requirement USD 500; prescribed capital equals the MCR. (≈USD 500)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Obligations must be fully funded by collateral.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
19Open-market reinsurerClass D insurer licenseUSD 50 mMinimum capital
- Permits
- Reinsurance business on the open market.
- Minimum capital
- Minimum capital requirement USD 50,000,000; CIMA may prescribe a reduced MCR for an applicant (Regulation 7(2A)). Prescribed capital is risk-based. (≈USD 50 m)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Physical presence and substance expected.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
20Registered VASPVASP registration (Virtual Asset (Service Providers) Act)No fixed figureMinimum capital
- Permits
- Virtual asset services other than custody and trading platforms: exchange between virtual assets and fiat or other virtual assets, transfers, and virtual asset issuance.
- Minimum capital
- No fixed capital figure found in CIMA's VASP guidance; business plans must include two years of standalone financial statements and projections.
- Fees
- VASP registration application feeKY$1,000 base plus KY$1,500 to KY$5,000 by service and revenueVASP registration annual feeEqual to the amount paid at registration (KY$2,500 to KY$6,000)
- Clients
- Retail, with conditions
- Conditions
- Travel Rule (AML Regulations Part XA). Supervised persons licensed under other regulatory laws notify CIMA or apply for a waiver.
- Systems
- OTC Digital Asset DeskTokenization PlatformStablecoin Issuance Structure
- Reading
- To be confirmed
- Sources
21Licensed VASP (custody / trading platform)VASP license (Virtual Asset (Service Providers) Act, as amended 2024)No fixed figureMinimum capital
- Permits
- Virtual asset custody and operating a virtual asset trading platform; licensing regime in force since 1 April 2025.
- Minimum capital
- No fixed capital figure found in CIMA's VASP guidance; fees are in Schedule 2 of the VASP (Amendment) Regulations 2025.
- Fees
- VASP license application fee (custody or trading platform)KY$5,000VASP license grant feeCustody KY$30,000; trading platform KY$100,000VASP license annual feeCustody KY$30,000 to KY$200,000; trading platform KY$50,000 to KY$100,000, by revenue
- Clients
- Retail, with conditions
- Conditions
- Existing registered custody and trading-platform providers had 90 days from 1 April 2025 to apply. Licensees and registered persons pay annual renewal fees by 15 January.
- Systems
- Digital Asset ExchangeCustody & Wallet Infrastructure
- Reading
- To be confirmed
- Sources
22Money services businessMoney services business license (Money Services Act)USD 37 kMinimum capital
- Permits
- Money transmission, currency exchange, cheque cashing and similar money services business.
- Minimum capital
- Minimum net worth CI$30,000, evidenced by an auditor's confirmation of paid-up capital. (≈USD 37 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Application under the Money Services Businesses Regulations; AML/CFT obligations.
- Systems
- Money Services BusinessPayment Service Provider
- Reading
- Read in the rulebook
- Sources
Reach
None. Cayman funds and managers access investors through private placement and the target country's rules (for example AIFMD national private placement in the EU, US exemptions).
Passage
No statutory deadlines found. Fund registrations take effect on the date CIMA receives a complete application (CIMA FAQ). Licences (SIBA, banks, insurers, VASP) are market practice: several weeks for straightforward captives and SIBA licenses to many months for banks and VASP licenses.
Licensed elsewhere
Single-family offices serving only their group can register under SIBA (group exemption) or need nothing. Trust companies and corporate services providers are also CIMA-licensed but outside these categories. No dedicated regime for EMIs, card issuing or merchant acquiring (payment businesses use the money services license or a bank). Not licensed: sovereign vehicles, mining and validation, physical commodity trading, and Islamic finance as a separate regime. The Cayman Islands Stock Exchange lists securities but is not one of these license categories.
Notes. VASP Act Phase 2 licensing for custody and trading platforms commenced 1 April 2025. Mutual Funds (Amendment) Law 2020 brought s. 4(4) funds into registration, and the Private Funds Act 2020 requires closed-ended funds to register. SIBA 'excluded persons' had to become registered persons or licensees by 15 January 2020. USD conversions use CI$1 = USD 1.2195.
Americas · British Virgin Islands
BVI FSC
British Virgin Islands Financial Services Commission
The BVI's single regulator for investment business and funds (Securities and Investment Business Act 2010, SIBA), banking and trust business (Banks and Trust Companies Act 1990), insurance (Insurance Act 2008), financing and money services (Financing and Money Services Act 2009) and virtual asset service providers (VASP Act 2022). SIBA licenses are issued by category of investment business (Categories 1 to 7) with no fixed minimum capital; the FSC sets capital case by case under the Regulatory Code. Funds are recognized or registered as private, professional, public, incubator, approved or private investment funds, and small managers can use the approved manager regime.
#34of 34
Balanced score
44 of 100
44 of 100
Scorecard
Credibility ×35%10Breadth ×15%68Entry threshold ×20%72Speed ×15%77Reach ×15%28
Categories23
Systems covered32 of 47
Typical timeline1–12 monthsmarket practice
Lowest capitalUSD 10 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 850–25 k9 items · Paid once, when the application is filed
On grantUSD 1 k–150 k4 items · Paid once, when the license is granted
Deposits & guaranteesUSD 500 k1 item · Held or lodged, beyond the minimum capital
Every yearUSD 1 k–150 k7 items · Recurring fees and levies
OtherUSD 5001 item · Mandatory charges that arise in operation
BVI regulator fees are low for SIBA licenses and funds but very high for banks (license fees in six figures plus a USD 500,000 deposit). Fees are charged per SIBA category or sub-category held and were raised by S.I. No. 4 of 2025. The June 2025 FATF grey-listing raises banking and correspondent costs more than the fees themselves.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| SIBA license application fee, dealing, arranging or custodyFinancial Services (Fees) Regulations 2010 as amended, most recently by S.I. No. 4 of 2025 (per Harneys, August 2026). The FSC-hosted Revised 2020 text shows lower pre-2025 figures (application USD 1,000; license USD 1,500, custody USD 2,500). | USD 2,200 per category or sub-category | SIBA Category 1, sub-category (a): Dealing in investments as agent; SIBA Category 1, sub-category (b): Dealing in investments as principal; SIBA Category 2: Arranging deals in investments; SIBA Category 5: Custody of investments | From a secondary source |
| SIBA license application fee, management, advice or administrationFinancial Services (Fees) Regulations 2010 as amended, most recently by S.I. No. 4 of 2025 (per Harneys, August 2026). The FSC-hosted Revised 2020 text shows lower pre-2025 figures (application USD 1,000; license USD 1,500, custody USD 2,500). | USD 1,200 per category or sub-category | SIBA Category 3: Investment management; SIBA Category 4: Investment advice; SIBA Category 6: Administration of investments | From a secondary source |
| SIBA license application fee, investment exchangeFinancial Services (Fees) Regulations 2010 as amended, most recently by S.I. No. 4 of 2025 (per Harneys, August 2026). The FSC-hosted Revised 2020 text shows lower pre-2025 figures (application USD 1,000; license USD 1,500, custody USD 2,500). | USD 3,000 | SIBA Category 7: Operating an investment exchange | From a secondary source |
| Approved manager application feeHarneys (August 2026); was USD 1,000 in the Revised 2020 text. | USD 1,200 | Approved manager (Investment Business (Approved Managers) Regulations 2012) | From a secondary source |
| Fund recognition application fee, private, professional and private investment fundsWas USD 700 in the Revised 2020 text. | USD 850 | Private fund (SIBA; Mutual Funds Regulations 2010); Professional fund (SIBA; Mutual Funds Regulations 2010); Private investment fund (closed-ended; SIBA as amended 2019) | From a secondary source |
| Public fund registration application feeRegistration fee USD 1,800 and annual renewal USD 1,800 per Carey Olsen (2025); was USD 1,000 / 1,500 / 1,500 in the Revised 2020 text. | USD 1,800, plus USD 300 prospectus fee | Public fund (SIBA; Public Funds Code 2010) | From a secondary source |
| Incubator and approved fund application feeTravers Thorp Alberga (April 2026). | USD 1,800, plus USD 200 for a certificate of status | Incubator fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015); Approved fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015) | From a secondary source |
| Banking license application feeRevised 2020 text; S.I. No. 4 of 2025 raised other FSC fees and may have changed these, so the 2026 figure is not confirmed. | General USD 50,000; restricted Class I or II USD 25,000 | General banking license (Banks and Trust Companies Act 1990); Restricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990) | To be confirmed |
| VASP registration application feeFee Regulations under the VASP Act 2022, per Harneys (August 2026). | General VASP USD 5,000; custody USD 10,000; exchange USD 10,000 | VASP registration (Virtual Assets Service Providers Act 2022) | From a secondary source |
| On grant | |||
| SIBA initial license feeFinancial Services (Fees) Regulations 2010 as amended, most recently by S.I. No. 4 of 2025 (per Harneys, August 2026). The FSC-hosted Revised 2020 text shows lower pre-2025 figures (application USD 1,000; license USD 1,500, custody USD 2,500). The 2020 text halved the initial fee for licenses granted after 30 June; whether that survives the 2025 amendment was not confirmed. | Dealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000 | SIBA Category 1, sub-category (a): Dealing in investments as agent; SIBA Category 1, sub-category (b): Dealing in investments as principal; SIBA Category 2: Arranging deals in investments; SIBA Category 3: Investment management and 4 more | From a secondary source |
| Fund recognition fee, private and professional fundsWas USD 1,000 (USD 500 after 30 June) in the Revised 2020 text. | USD 1,200 on recognition | Private fund (SIBA; Mutual Funds Regulations 2010); Professional fund (SIBA; Mutual Funds Regulations 2010) | From a secondary source |
| Banking license issue feeRevised 2020 text; may have changed in 2025. | General USD 250,000; restricted USD 150,000 (halved if issued after 30 June) | General banking license (Banks and Trust Companies Act 1990); Restricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990) | To be confirmed |
| VASP initial registration feePer Harneys (August 2026). | General VASP USD 7,500; custody USD 15,000; exchange USD 25,000 | VASP registration (Virtual Assets Service Providers Act 2022) | From a secondary source |
| Deposits & guarantees | |||
| Bank deposit or investment with the FSCRequired in addition to paid-up capital (USD 2m general, USD 1m restricted), in the form the FSC prescribes (Banks and Trust Companies Act 1990). | USD 500,000 | General banking license (Banks and Trust Companies Act 1990); Restricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990) | From a secondary source |
| Every year | |||
| SIBA annual license feeFinancial Services (Fees) Regulations 2010 as amended, most recently by S.I. No. 4 of 2025 (per Harneys, August 2026). The FSC-hosted Revised 2020 text shows lower pre-2025 figures (application USD 1,000; license USD 1,500, custody USD 2,500). Per category or sub-category held; due by 31 March. | Dealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000 | SIBA Category 1, sub-category (a): Dealing in investments as agent; SIBA Category 1, sub-category (b): Dealing in investments as principal; SIBA Category 2: Arranging deals in investments; SIBA Category 3: Investment management and 4 more | From a secondary source |
| Approved manager approval and annual renewal feeHarneys (August 2026); was USD 1,500. | USD 1,800 | Approved manager (Investment Business (Approved Managers) Regulations 2012) | From a secondary source |
| Fund annual renewal fee, private, professional and private investment fundsPrivate investment fund renewal was USD 500 in the Revised 2020 text; Maples (June 2025) and Carey Olsen (2025) give USD 1,200. | USD 1,200 | Private fund (SIBA; Mutual Funds Regulations 2010); Professional fund (SIBA; Mutual Funds Regulations 2010); Private investment fund (closed-ended; SIBA as amended 2019) | From a secondary source |
| Public fund annual renewal feeCarey Olsen (2025). | USD 1,800 | Public fund (SIBA; Public Funds Code 2010) | From a secondary source |
| Incubator and approved fund annual feeSources disagree: Travers Thorp Alberga (April 2026) says USD 1,800, Carey Olsen (2025) USD 1,200. | USD 1,200 to USD 1,800 | Incubator fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015); Approved fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015) | To be confirmed |
| Banking license annual renewal feeRevised 2020 text; may have changed in 2025. | General USD 250,000; restricted USD 150,000 | General banking license (Banks and Trust Companies Act 1990); Restricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990) | To be confirmed |
| VASP annual renewal feePer Harneys (August 2026). | General VASP USD 7,500; custody USD 15,000; exchange USD 25,000 | VASP registration (Virtual Assets Service Providers Act 2022) | From a secondary source |
| Other | |||
| Director or senior officer approvalChange of control (significant interest) approval USD 800; approval of a branch or subsidiary outside the BVI USD 1,200. | USD 200 application plus USD 300 on approval, per individual | SIBA Category 1, sub-category (a): Dealing in investments as agent; SIBA Category 1, sub-category (b): Dealing in investments as principal; SIBA Category 2: Arranging deals in investments; SIBA Category 3: Investment management and 4 more | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 250 k
Money services businessMoney services business license, Class A or Class B (Financing and Money Services Act 2009)
USD 10 k
Insurer / captiveInsurer license (Insurance Act 2008), domestic or captive
USD 100 k
Trust companyGeneral trust license (Banks and Trust Companies Act 1990)
USD 250 k
Restricted bankRestricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990)
USD 1 m
BankGeneral banking license (Banks and Trust Companies Act 1990)
USD 2 m
10k100k1m10m
5 of 23 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
23 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Agency brokerSIBA Category 1, sub-category (a): Dealing in investments as agentNo fixed figureMinimum capital
- Permits
- Buying, selling, subscribing for or underwriting investments as agent for clients.
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, dealing, arranging or custodyUSD 2,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Retail, with conditions
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4). No BVI-specific retail leverage cap was found; firms serving retail clients abroad must meet host-country rules. Retail FX/CFD brokers in the BVI usually hold Category 1 licenses.
- Systems
- Retail BrokerageMulti-Asset BrokerageInstitutional BrokeragePrivate BrokerageWhite-Label Brokerage
- Reading
- From a secondary source
- Sources
02Principal dealer / market makerSIBA Category 1, sub-category (b): Dealing in investments as principalNo fixed figureMinimum capital
- Permits
- Dealing in investments as principal, including taking the other side of client trades.
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, dealing, arranging or custodyUSD 2,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Retail, with conditions
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4). Expect the FSC to require more capital for principal dealing than for agency business, given the s. 181 risk-based test.
- Systems
- Retail BrokerageMulti-Asset BrokeragePrime-of-Prime
- Reading
- From a secondary source
- Sources
03Arranger / introducing brokerSIBA Category 2: Arranging deals in investmentsNo fixed figureMinimum capital
- Permits
- Arranging deals in investments for others, including introducing clients to dealers.
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, dealing, arranging or custodyUSD 2,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Retail, with conditions
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4).
- Systems
- White-Label Brokerage
- Reading
- From a secondary source
- Sources
04Investment managerSIBA Category 3: Investment managementNo fixed figureMinimum capital
- Permits
- Managing segregated portfolios, mutual funds, pension schemes, insurance products or other investments (sub-categories by what is managed).
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, management, advice or administrationUSD 1,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Retail, with conditions
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4). Managers of only private, professional, incubator, approved or private investment funds within the AUM caps can use the lighter approved manager route instead.
- Systems
- Asset Management CompanyWealth Management FirmFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundMulti-Family OfficePension & Endowment ManagerDigital Asset Fund
- Reading
- From a secondary source
- Sources
05Investment adviserSIBA Category 4: Investment adviceNo fixed figureMinimum capital
- Permits
- Giving investment advice (sub-categories for advice to mutual funds and to others).
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, management, advice or administrationUSD 1,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Retail, with conditions
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4). Advisers to qualifying funds can use the approved manager route.
- Systems
- Investment Advisory Firm
- Reading
- From a secondary source
- Sources
06CustodianSIBA Category 5: Custody of investmentsNo fixed figureMinimum capital
- Permits
- Acting as custodian or depositary of investments of another person (sub-categories for mutual funds and others).
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, dealing, arranging or custodyUSD 2,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Professional only
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4). SIBA has no excluded activities for custody (Mourant). Custody of virtual assets is registered under the VASP Act 2022 instead.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- From a secondary source
- Sources
07Fund administratorSIBA Category 6: Administration of investmentsNo fixed figureMinimum capital
- Permits
- Administering, or arranging the administration of, investments of another person, including acting as administrator of mutual funds.
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, management, advice or administrationUSD 1,200 per category or sub-categorySIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Professional only
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4).
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- From a secondary source
- Sources
08Investment exchangeSIBA Category 7: Operating an investment exchangeNo fixed figureMinimum capital
- Permits
- Providing a facility, electronic or otherwise, for the orderly trading of investments.
- Minimum capital
- No fixed minimum capital is prescribed for this category. SIBA s. 7 and Regulatory Code s. 181 require financial resources adequate to the nature, size, complexity and risk of the business; the FSC sets the amount case by case and can impose it as a license condition. Advisers commonly budget about USD 1 million for a dealing license (Harneys, Aug 2026), but that is a planning figure, not a rule.
- Fees
- SIBA license application fee, investment exchangeUSD 3,000SIBA initial license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000SIBA annual license feeDealing or arranging USD 3,300; management, advice or administration USD 1,800; custody USD 4,500; investment exchange USD 10,000Director or senior officer approvalUSD 200 application plus USD 300 on approval, per individual
- Clients
- Retail, with conditions
- Conditions
- Applications go through an authorized intermediary. Minimum two directors and professional indemnity insurance (or an FSC exemption); an authorized representative in the BVI unless there is significant management presence there. Annual review of capital adequacy under Regulatory Code s. 181(4). A venue trading virtual assets is registered as a virtual assets exchange under the VASP Act 2022, not under this category.
- Systems
- ECN & DMA Venue
- Reading
- From a secondary source
- Sources
09Approved managerApproved manager (Investment Business (Approved Managers) Regulations 2012)No fixed figureMinimum capital
- Permits
- Lighter-touch approval to act as manager or adviser to private, professional, incubator, approved and private investment funds (BVI funds, and in practice some Cayman funds).
- Minimum capital
- No minimum capital is prescribed for approved managers in the sources reviewed.
- Fees
- Approved manager application feeUSD 1,200Approved manager approval and annual renewal feeUSD 1,800
- Clients
- Professional only
- Conditions
- AUM caps of USD 400 million for open-ended funds and USD 1 billion of capital commitments for closed-ended funds; above these the manager needs a full SIBA Category 3 license. May start business 7 days after a complete application if the FSC raises no questions. No requirement for personnel in the BVI; must appoint an AML officer and file an annual return and financial statements (unaudited).
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
10Private fundPrivate fund (SIBA; Mutual Funds Regulations 2010)No fixed figureMinimum capital
- Permits
- Open-ended fund limited to 50 investors or offered only on a private basis; must be recognized by the FSC before it starts business.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Fund recognition application fee, private, professional and private investment fundsUSD 850Fund recognition fee, private and professional fundsUSD 1,200 on recognitionFund annual renewal fee, private, professional and private investment fundsUSD 1,200
- Clients
- Professional only
- Conditions
- No minimum investment. Must appoint a manager, administrator, custodian (exemption possible) and auditor. Annual audited financial statements within six months of year end. Recognition usually issued within 14 business days.
- Systems
- Hedge FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
11Professional fundProfessional fund (SIBA; Mutual Funds Regulations 2010)No fixed figureMinimum capital
- Permits
- Open-ended fund whose interests are issued only to professional or exempted investors; no limit on investor numbers.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Fund recognition application fee, private, professional and private investment fundsUSD 850Fund recognition fee, private and professional fundsUSD 1,200 on recognitionFund annual renewal fee, private, professional and private investment fundsUSD 1,200
- Clients
- Professional only
- Conditions
- Minimum initial investment USD 100,000 for professional investors (none for exempted investors). Professional investor: ordinary business in the same kind of property, or net worth over USD 1 million alone or with spouse. Manager, administrator, custodian (exemption possible) and auditor required; annual audit. May start up to 21 days before recognition if the application is filed within 14 days of launch.
- Systems
- Hedge FundDigital Asset FundPrivate Credit Fund
- Reading
- From a secondary source
- Sources
12Public (retail) fundPublic fund (SIBA; Public Funds Code 2010)No fixed figureMinimum capital
- Permits
- Open-ended fund offered to the public with no restriction on investor type or number; must be registered by the FSC before it starts business.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Public fund registration application feeUSD 1,800, plus USD 300 prospectus feePublic fund annual renewal feeUSD 1,800
- Clients
- Retail permitted
- Conditions
- Prospectus complying with the Public Funds Code. Manager, administrator, custodian and auditor required; annual audited statements with directors' certificate and report to investors. Registration usually within about six weeks.
- Systems
- Mutual Fund & UCITSReal Estate Investment Vehicle
- Reading
- From a secondary source
- Sources
13Incubator fundIncubator fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015)No fixed figureMinimum capital
- Permits
- Start-up open-ended fund for sophisticated private investors, with a lighter regime for a limited period.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Incubator and approved fund application feeUSD 1,800, plus USD 200 for a certificate of statusIncubator and approved fund annual feeUSD 1,200 to USD 1,800
- Clients
- Professional only
- Conditions
- Maximum 20 investors; minimum investment USD 20,000 each; net assets capped at USD 20 million. Two years, extendable by one year; must convert or wind down when a limit is exceeded or time runs out. No mandatory manager, administrator, custodian or audit; unaudited semi-annual financial statements. May start two business days after applying.
- Systems
- Hedge FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
14Approved fundApproved fund (Securities and Investment Business (Incubator and Approved Funds) Regulations 2015)No fixed figureMinimum capital
- Permits
- Small open-ended fund for friends-and-family or smaller strategies, with no time limit.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Incubator and approved fund application feeUSD 1,800, plus USD 200 for a certificate of statusIncubator and approved fund annual feeUSD 1,200 to USD 1,800
- Clients
- Professional only
- Conditions
- Maximum 20 investors; net assets capped at USD 100 million; no minimum investment. Administrator required; manager and custodian not required; annual unaudited financial statements. May start two days after applying.
- Systems
- Hedge FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
15Closed-ended private investment fundPrivate investment fund (closed-ended; SIBA as amended 2019)No fixed figureMinimum capital
- Permits
- Closed-ended fund (BVI business company or limited partnership) recognized by the FSC.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Fund recognition application fee, private, professional and private investment fundsUSD 850Fund annual renewal fee, private, professional and private investment fundsUSD 1,200
- Clients
- Professional only
- Conditions
- Constitutional documents must specify one of: no more than 50 investors; private-basis offers only; or professional/exempted investors only with USD 100,000 minimum for professional investors. Must appoint a person responsible for management, valuation and safekeeping; auditor required; annual audit within six months. May operate for 21 days after applying.
- Systems
- Private Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- From a secondary source
- Sources
16BankGeneral banking license (Banks and Trust Companies Act 1990)USD 2 mMinimum capital
- Permits
- Banking business within and outside the BVI, including taking deposits from BVI residents.
- Minimum capital
- Minimum fully paid-up capital USD 2,000,000, plus a deposit or investment of USD 500,000 in the form the FSC prescribes (FSC FAQ; Banks and Trust Companies Act 1990). Risk-weighted capital adequacy under Regulatory Code s. 83. (≈USD 2 m)
- Fees
- Banking license application feeGeneral USD 50,000; restricted Class I or II USD 25,000Banking license issue feeGeneral USD 250,000; restricted USD 150,000 (halved if issued after 30 June)Banking license annual renewal feeGeneral USD 250,000; restricted USD 150,000Bank deposit or investment with the FSCUSD 500,000
- Clients
- Retail permitted
- Conditions
- The FSC FAQ says the FSC follows Basel standards with an 8% floor on risk-weighted assets; Walkers (Dec 2024) reports a 12% minimum risk-weighted capital adequacy ratio under the Regulatory Code. Confirm the ratio with the FSC. The FSC aims to decide a complete application within ten weeks.
- Systems
- Private BankDigital BankCorrespondent Banking StructureTrade Finance House
- Reading
- Read in the rulebook
- Sources
17Restricted bankRestricted Class I and Restricted Class II banking license (Banks and Trust Companies Act 1990)USD 1 mMinimum capital
- Permits
- Banking business that may not take deposits from BVI residents other than other licensees; Class II is further limited to the persons named in the license.
- Minimum capital
- Minimum fully paid-up capital USD 1,000,000, plus a deposit or investment of USD 500,000 (FSC FAQ; Banks and Trust Companies Act 1990). (≈USD 1 m)
- Fees
- Banking license application feeGeneral USD 50,000; restricted Class I or II USD 25,000Banking license issue feeGeneral USD 250,000; restricted USD 150,000 (halved if issued after 30 June)Banking license annual renewal feeGeneral USD 250,000; restricted USD 150,000Bank deposit or investment with the FSCUSD 500,000
- Clients
- Professional only
- Conditions
- Cannot invest in certain claims on BVI residents or carry on other business without FSC approval. Same capital adequacy ratio question as the general license (8% per FSC FAQ, 12% per Walkers).
- Systems
- Private BankTreasury & Liquidity Desk
- Reading
- Read in the rulebook
- Sources
18Insurer / captiveInsurer license (Insurance Act 2008), domestic or captiveUSD 100 kMinimum capital
- Permits
- Insurance business from or within the BVI, including captive insurance (licensed by category under the Act).
- Minimum capital
- Captives: USD 100,000 for general insurers and USD 200,000 for long-term insurers (FSC FAQ). By line of business under the Regulatory Code: USD 100,000 property and casualty, USD 200,000 life and health, USD 300,000 for both, or more if the FSC directs (Conyers 2021). Minimum solvency margin: USD 250,000 for life and health; for property and casualty USD 100,000 where net written premium is under USD 500,000, 20% of premium up to USD 5 million, then USD 1 million plus 10% of the excess. (≈USD 100 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- The FSC aims to decide a complete insurer application within 6 weeks; incomplete applications can take up to 6 months. Captive figures confirmed on the FSC website; domestic-insurer figures from Conyers (Nov 2021).
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
19Registered VASPVASP registration (Virtual Assets Service Providers Act 2022)No fixed figureMinimum capital
- Permits
- Virtual asset services, in three FSC application categories: operating a virtual assets exchange, providing virtual assets custody services, and other virtual assets services (exchange between virtual assets and fiat, transfer, safekeeping and similar).
- Minimum capital
- No fixed minimum in the Act. The FSC expects capital and liquidity commensurate with the nature, size, complexity and risk of the business; in some recent registrations it imposed a minimum capital condition of USD 1,000,000 (Ogier, July 2026).
- Fees
- VASP registration application feeGeneral VASP USD 5,000; custody USD 10,000; exchange USD 10,000VASP initial registration feeGeneral VASP USD 7,500; custody USD 15,000; exchange USD 25,000VASP annual renewal feeGeneral VASP USD 7,500; custody USD 15,000; exchange USD 25,000
- Clients
- Retail, with conditions
- Conditions
- Application fee USD 10,000 for exchange or custody, USD 5,000 for other services. Corporate directors not permitted; fit-and-proper directors and senior officers; compliance officer and MLRO required. FSC service standard: initial comments within six weeks of a complete application, process concluded within six months. Travel rule and CDD threshold of USD 1,000 for one-off virtual asset transactions.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- From a secondary source
- Sources
20Financing companyFinancing business license, Class C (Financing and Money Services Act 2009)No fixed figureMinimum capital
- Permits
- Non-bank lending (financing business). Class D covers financing leases; Class F (international P2P lending) cannot be issued until regulations are adopted.
- Minimum capital
- None prescribed: the Regulatory Code does not apply to holders of a financing license (Regulatory Code s. 6, explanatory notes).
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Consumer finance loans of USD 5,000 to USD 35,000 were brought into scope by the 2019 amendments.
- Systems
- Trade Finance House
- Reading
- Read in the rulebook
- Sources
21Money services businessMoney services business license, Class A or Class B (Financing and Money Services Act 2009)USD 10 kMinimum capital
- Permits
- Class A: transmitting money in any form, including electronic and mobile payments. Class B: issuing, selling or redeeming money orders or traveller's cheques, cheque cashing and currency exchange.
- Minimum capital
- Minimum capital resources USD 10,000 cash in hand or on deposit, or USD 5,000 cash plus a USD 5,000 standby letter of credit or guarantee (Regulatory Code s. 169). BVI money services businesses make no regulatory deposit; a foreign money services business deposits USD 10,000 (Regulatory Code s. 171). (≈USD 10 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- There is no separate e-money or payment institution class; transmission of electronic money falls under Class A. Figures come from Mourant's 2019 summary of the Regulatory Code and were not read in the Code itself.
- Systems
- Money Services BusinessPayment Service Provider
- Reading
- From a secondary source
- Sources
22Trust companyGeneral trust license (Banks and Trust Companies Act 1990)USD 250 kMinimum capital
- Permits
- Trust business for the public, including acting as trustee and providing fiduciary services to families.
- Minimum capital
- Minimum paid-up capital USD 250,000, plus a deposit or investment set by the FSC of up to USD 100,000 (USD 20,000 or USD 40,000 depending on how many registered agent companies are served) (FSC FAQ). (≈USD 250 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Proven trust experience, fit-and-proper criteria and physical presence in the BVI.
- Systems
- Multi-Family Office
- Reading
- Read in the rulebook
- Sources
23Restricted trust companyRestricted trust license (Banks and Trust Companies Act 1990)No fixed figureMinimum capital
- Permits
- Trust business restricted to the persons or class of persons specified in the license.
- Minimum capital
- No minimum capital requirement (FSC FAQ).
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Used for trust business serving a defined group such as one family. Private trust companies serving a single family may instead rely on the private trust company exemption, which was not verified in this pass.
- Systems
- Single-Family Office
- Reading
- Read in the rulebook
- Sources
Reach
None. BVI entities access other markets under the host country's private placement or licensing rules.
Passage
FSC service standards: insurer license up to 6 weeks for a complete application (FSC FAQ); banks within ten weeks of a complete application (per Walkers, Dec 2024); VASP registration initial comments within six weeks and conclusion within six months (per Ogier, July 2026). Funds: private fund recognition usually within 14 business days and public fund registration about six weeks; incubator and approved funds may start two days after applying; approved managers may start 7 days after a complete application. SIBA licenses: market practice 2 to 4 weeks for simple applications, several months (up to 9 to 12) for complex ones (Harneys, Aug 2026).
Licensed elsewhere
No dedicated EMI, card-issuing, merchant-acquiring or stablecoin regime: e-money transmission falls under the money services Class A license, and stablecoin issuers would be assessed under the VASP Act and SIBA case by case. Company managers are FSC-licensed (USD 25,000 paid-up capital) but are not one of the 47 systems. Not licensed: sovereign vehicles, mining and validation, physical commodity trading, and Islamic finance as a separate regime. Private trust companies serving a single family are a common single-family-office route outside the trust license (exemption not verified in this pass).
Notes. Revised Oct 2026 against FSC pages and law-firm guides. Primary figures: bank capital (USD 2m general, USD 1m restricted, plus USD 500k deposit), captive insurer capital (USD 100k general, USD 200k long-term), trust license capital (USD 250k general, none restricted), and the non-application of the Regulatory Code to financing licensees. Secondary: SIBA has no fixed minimum capital (Harneys Aug 2026, Zitadelle Oct 2025; Regulatory Code s. 181 adequacy test), fund thresholds (Carey Olsen Jan 2025), approved manager caps (Conyers Aug 2024, Harneys 2026), money services capital (Mourant 2019), VASP practice (Ogier July 2026). The full Regulatory Code (Revised 2020, amended by S.I. 69/2019) could not be read past the early sections, so section-level capital text was not checked. Open point: bank capital adequacy ratio is 8% per the FSC FAQ but 12% per Walkers. Known changes: VASP Act 2022 in force from February 2023; private investment fund regime from the 2019 SIBA amendments; incubator and approved funds from 2015; Financing and Money Services Act license classes A to G from March 2019.
Americas · Bermuda
BMA
Bermuda Monetary Authority
The BMA is Bermuda's integrated regulator for banks and deposit companies, insurance and reinsurance, investment business, investment funds and fund administrators, trust business and digital asset business. Bermuda is a leading reinsurance and insurance-linked securities center, and its Digital Asset Business Act 2018 (DABA) is one of the earliest full licensing regimes for digital-asset firms, with Class T, M and F licenses.
#27of 34
Balanced score
53 of 100
53 of 100
Scorecard
Credibility ×35%35Breadth ×15%62Entry threshold ×20%96Speed ×15%50Reach ×15%30
Categories25
Systems covered29 of 47
Typical timeline—market practice
Lowest capitalUSD 10 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 800–50 k7 items · Paid once, when the application is filed
On grantUSD 2 k2 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 850–25 k8 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
Bermuda digital asset fees scale with client receipts (0.075%, floors up to BMD 150,000, cap BMD 450,000) and bank fees with gross assets (over BMD 425,000 a year at the smallest band). Figures come from the 2025 schedule because the 2026 schedule could not be parsed.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| DABA application fee, Class F or Class MDigital Asset Business Act 2018. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 2,266≈ USD 2 k | DABA Class M license (Digital Asset Business Act 2018); DABA Class F license (Digital Asset Business Act 2018) | Read in the rulebook |
| DABA application fee, Class TFigure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 1,000≈ USD 1 k | DABA Class T license (Digital Asset Business Act 2018) | Read in the rulebook |
| Investment business license application (s.16(1))A retail leveraged CFD license application is BMD 25,000. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 2,840≈ USD 3 k | Investment business standard license: investment provider acting as principal (Investment Business Act 2003); Investment business standard license: investment provider acting as agent (Investment Business Act 2003); Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | Read in the rulebook |
| Registered person application (s.13A / s.13B)Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 2,840≈ USD 3 k | Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | Read in the rulebook |
| Investment fund authorization or registration feePrivate fund filing BMD 1,325; professional Class B BMD 1,250. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | Authorization BMD 1,040; registered-fund initial filing BMD 950 (overseas) to BMD 1,870 (professional Class A / closed)≈ USD 950 | Investment funds (Investment Funds Act 2006): authorized and registered funds | Read in the rulebook |
| Bank or deposit company license application (BDCA 1999 s.13(1))The schedule has no separate restricted-bank line; applying the s.13(1) fee to restricted banks is an inference. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 50,000≈ USD 50 k | Bank license (Banks and Deposit Companies Act 1999); Restricted bank license (Banks and Deposit Companies Act 1999); Deposit company license (Banks and Deposit Companies Act 1999) | Read in the rulebook |
| Insurer application fee (Insurance Act s.4(1))Payable in addition to the class registration fee. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 800≈ USD 800 | Insurance Class 1 (Insurance Act 1978); Insurance Class 2 (Insurance Act 1978); Insurance Class 3 (Insurance Act 1978); Insurance Class 3A (Insurance Act 1978) and 10 more | To be confirmed |
| On grant | |||
| DABA license grant fee, Class F or Class MBased on estimated client receipts at grant. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | Higher of the activity floor or 0.00075 x estimated client receipts, capped at BMD 450,000; floors BMD 15,000 (general activities), BMD 100,000 (certain exchange/vendor activities without custody), BMD 150,000 (with custody of client private keys) | DABA Class M license (Digital Asset Business Act 2018); DABA Class F license (Digital Asset Business Act 2018) | Read in the rulebook |
| Insurer registration fee by classAnnual business fees equal the registration fee for these classes, banded by gross premium written (Class 3, 3A, 3B, 4) or collateral. Long-term Classes C, D and E are asset-banded and range from BMD 25,000 to BMD 430,000+. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. The 2026 changes could not be mapped to classes, so confidence is uncertain. | Class 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000≈ USD 2 k | Insurance Class 1 (Insurance Act 1978); Insurance Class 2 (Insurance Act 1978); Insurance Class 3 (Insurance Act 1978); Insurance Class 3A (Insurance Act 1978) and 6 more | To be confirmed |
| Every year | |||
| DABA annual fee, Class F or Class MCustody of client private keys carries the BMD 150,000 floor. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | Higher of the activity floor or 0.00075 x prior-year client receipts, capped at BMD 450,000; floors BMD 15,000 to BMD 150,000 by activity | DABA Class M license (Digital Asset Business Act 2018); DABA Class F license (Digital Asset Business Act 2018) | Read in the rulebook |
| DABA annual fee, Class TFigure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 1,000 flat≈ USD 1 k | DABA Class T license (Digital Asset Business Act 2018) | Read in the rulebook |
| Investment business annual fee, licensed providersGroup consolidated supervision adds BMD 78,330 (net assets up to USD 500m) or BMD 313,240. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 2,710 to BMD 13,560 by scope: BMD 2,710 (other activities), BMD 6,780 (not holding client assets), BMD 13,560 (holding client assets); retail leveraged CFD BMD 100,000≈ USD 3 k | Investment business standard license: investment provider acting as principal (Investment Business Act 2003); Investment business standard license: investment provider acting as agent (Investment Business Act 2003); Investment business standard license: investment provider neither agent nor principal (Investment Business Act 2003) | Read in the rulebook |
| Registered person annual fee, Class A or Class BFigure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 850≈ USD 850 | Class A and Class B Registered Persons (Investment Business Act 2003, as amended 2022) | Read in the rulebook |
| Investment fund annual feeDue 31 March. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 1,170 to BMD 1,870 per fund by type (standard BMD 1,860; administered/institutional BMD 1,170; professional Class A/closed BMD 1,870; Class B BMD 1,250; private BMD 1,325; overseas BMD 1,270)≈ USD 1 k | Investment funds (Investment Funds Act 2006): authorized and registered funds | Read in the rulebook |
| Bank annual fees (BDCA 1999 s.16 plus Banks and Deposit Companies (Fees) Act 1975)Banded by consolidated gross assets; s.16 fee due 31 March, Fees Act fee due 31 January. Lowest combined bank cost is about BMD 425,750 a year. Restricted-bank treatment not stated. Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | s.16 fee BMD 25,180 (assets up to USD 1bn) to BMD 400,130 (over USD 10bn); plus Fees Act 1975 fee BMD 400,570 (up to USD 1bn) to BMD 1,987,330 (over USD 10bn)≈ USD 25 k | Bank license (Banks and Deposit Companies Act 1999) | Read in the rulebook |
| Deposit company annual feesFigure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | BMD 20,000 (Fees Act 1975) plus BDCA s.16 fee from BMD 25,180≈ USD 20 k | Deposit company license (Banks and Deposit Companies Act 1999) | Read in the rulebook |
| Insurer annual business fee by classFrom 2026 the Head of an IAIG pays BMD 545,900 plus 0.002% of GWP, capped at BMD 1,249,000 (BMA Amendment Act 2025). Figure from the BMA fee schedule effective 1 January 2025; the 2026 schedule (published 15 January 2026) could not be read. The BMA Amendment Act 2025 (operative 1 January 2026) changed insurance fees only. | Class 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000≈ USD 2 k | Insurance Class 1 (Insurance Act 1978); Insurance Class 2 (Insurance Act 1978); Insurance Class 3 (Insurance Act 1978); Insurance Class 3A (Insurance Act 1978) and 6 more | To be confirmed |
Threshold
Minimum capital, category by category
Middle halfMedian USD 250 k
Digital asset test licenseDABA Class T license (Digital Asset Business Act 2018)
USD 10 k
Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003)
USD 12 k
Digital asset modified licenseDABA Class M license (Digital Asset Business Act 2018)
USD 100 k
Digital asset full licenseDABA Class F license (Digital Asset Business Act 2018)
USD 100 k
Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003)
USD 100 k
Pure captiveInsurance Class 1 (Insurance Act 1978)
USD 120 k
Long-term pure captiveLong-term insurance Class A (Insurance Act 1978)
USD 120 k
Innovative (sandbox) insurerInnovative insurer classes IIGB and IILT (Insurance Act 1978, Insurance Regulatory Sandbox)
USD 120 k
Multi-owner / limited third-party captiveInsurance Class 2 (Insurance Act 1978)
USD 250 k
Long-term multi-owner captiveLong-term insurance Class B (Insurance Act 1978)
USD 250 k
Collateralized reinsurance vehicleCollateralized Insurer (Insurance Act 1978)
USD 250 k
Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003)
USD 250 k
Small commercial life insurerLong-term insurance Class C (Insurance Act 1978)
USD 500 k
Small commercial / captive with third-party businessInsurance Class 3 (Insurance Act 1978)
USD 1 m
Small commercial insurerInsurance Class 3A (Insurance Act 1978)
USD 1 m
Large commercial insurerInsurance Class 3B (Insurance Act 1978)
USD 1 m
Deposit companyDeposit company license (Banks and Deposit Companies Act 1999)
USD 1 m
Mid-size commercial life insurerLong-term insurance Class D (Insurance Act 1978)
USD 4 m
Restricted (fintech) bankRestricted bank license (Banks and Deposit Companies Act 1999)
USD 5 m
Large commercial life insurerLong-term insurance Class E (Insurance Act 1978)
USD 8 m
Bermuda bankBank license (Banks and Deposit Companies Act 1999)
USD 10 m
Large commercial insurer/reinsurerInsurance Class 4 (Insurance Act 1978)
USD 100 m
10k100k1m10m100m
22 of 25 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
25 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Digital asset test licenseDABA Class T license (Digital Asset Business Act 2018)USD 10 kMinimum capital
- Permits
- Pilot or beta testing of a digital asset business activity for a limited period.
- Minimum capital
- Minimum net assets USD 10,000 (BMA DAB FAQs); the BMA may require more. (≈USD 10 k)
- Fees
- DABA application fee, Class TBMD 1,000DABA annual fee, Class TBMD 1,000 flat
- Clients
- Retail, with conditions
- Conditions
- Duration of 3 to 12 months, extendable. Restrictions on scale and clients set by the BMA. Must keep client and proprietary transaction records for five years (2024 amendments).
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureTokenization PlatformStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
02Digital asset modified licenseDABA Class M license (Digital Asset Business Act 2018)USD 100 kMinimum capital
- Permits
- Carrying on digital asset business for a limited period while scaling operations, under modified requirements.
- Minimum capital
- Minimum net assets USD 100,000 (BMA DAB FAQs); the BMA may require more based on nature, scale and complexity. (≈USD 100 k)
- Fees
- DABA application fee, Class F or Class MBMD 2,266DABA license grant fee, Class F or Class MHigher of the activity floor or 0.00075 x estimated client receipts, capped at BMD 450,000; floors BMD 15,000 (general activities), BMD 100,000 (certain exchange/vendor activities without custody), BMD 150,000 (with custody of client private keys)DABA annual fee, Class F or Class MHigher of the activity floor or 0.00075 x prior-year client receipts, capped at BMD 450,000; floors BMD 15,000 to BMD 150,000 by activity
- Clients
- Retail permitted
- Conditions
- Typically 12 months (up to 24), extendable. Bermuda economic substance required. Application fee USD 2,266 (BMA FAQs).
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureTokenization PlatformStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
03Digital asset full licenseDABA Class F license (Digital Asset Business Act 2018)USD 100 kMinimum capital
- Permits
- Any DABA activity without a time limit: issuing, selling or redeeming digital assets; payment services using digital assets; operating a digital asset exchange or derivatives exchange; custodial wallet services; digital asset trust services; benchmark administration; and digital asset lending or repo (added 2024).
- Minimum capital
- Minimum net assets USD 100,000 (BMA DAB FAQs); the BMA may require more. Ongoing prudential returns under the Digital Asset Business (Prudential Standards) (Annual Return) Rules 2018. (≈USD 100 k)
- Fees
- DABA application fee, Class F or Class MBMD 2,266DABA license grant fee, Class F or Class MHigher of the activity floor or 0.00075 x estimated client receipts, capped at BMD 450,000; floors BMD 15,000 (general activities), BMD 100,000 (certain exchange/vendor activities without custody), BMD 150,000 (with custody of client private keys)DABA annual fee, Class F or Class MHigher of the activity floor or 0.00075 x prior-year client receipts, capped at BMD 450,000; floors BMD 15,000 to BMD 150,000 by activity
- Clients
- Retail permitted
- Conditions
- Economic substance in Bermuda. Digital Asset Business (Custody of Client Assets) Rules 2025 require segregation and reconciliation. Operational Resilience and Outsourcing Code finalized September 2025, implementation by 31 March 2028. Annual fee up to USD 450,000 depending on activity and client receipts (secondary source).
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureTokenization PlatformStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
04Pure captiveInsurance Class 1 (Insurance Act 1978)USD 120 kMinimum capital
- Permits
- Single-parent captive underwriting only the risks of its owners and their affiliates.
- Minimum capital
- Minimum capital and surplus USD 120,000 (BMA). Minimum margin of solvency is the greatest of USD 120,000, a premium test (20% of net premiums up to USD 6 million, then USD 1.2 million plus 10% of the excess) and 10% of loss reserves (Insurance Returns and Solvency Regulations 1980, reg. 10 and Schedule I). (≈USD 120 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Limited-purpose insurer; files annual audited financial return.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
05Multi-owner / limited third-party captiveInsurance Class 2 (Insurance Act 1978)USD 250 kMinimum capital
- Permits
- Multi-owner captive insuring only its owners' and affiliates' risks, or a single- or multi-owner captive with no more than 20% of net premiums from unrelated risks.
- Minimum capital
- Minimum capital and surplus USD 250,000 (BMA). Minimum margin of solvency is the greatest of USD 250,000, the Schedule I premium test and 10% of loss reserves (IRSR 1980, reg. 10). (≈USD 250 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Actuarial certification of loss reserves every three years.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
06Small commercial / captive with third-party businessInsurance Class 3 (Insurance Act 1978)USD 1 mMinimum capital
- Permits
- Catch-all for insurers and reinsurers not in Classes 1, 2, 3A, 3B or 4, including structured reinsurers writing third-party business and captives with more than 20% but less than 50% unrelated business.
- Minimum capital
- Minimum capital and surplus USD 1,000,000 (BMA). Minimum margin of solvency is the greatest of USD 1,000,000, the Schedule I premium test (15% above USD 6 million) and 15% of loss reserves (IRSR 1980, reg. 10). (≈USD 1 m)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Retail, with conditions
- Conditions
- Annual actuarial certification of loss reserves.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
07Small commercial insurerInsurance Class 3A (Insurance Act 1978)USD 1 mMinimum capital
- Permits
- Commercial insurer where unrelated business is 50% or more of net premiums or loss reserves and unrelated net premiums are under USD 50 million.
- Minimum capital
- Minimum capital and surplus USD 1,000,000 (BMA). As a commercial insurer it must also hold capital against the Enhanced Capital Requirement (ECR) under the BSCR model; minimum margin of solvency is set under the Insurance Account Rules 2016 (Skadden cites USD 1 million or 25% of ECR). (≈USD 1 m)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Retail, with conditions
- Conditions
- Commercial insurer under the Bermuda Solvency Capital Requirement (BSCR); Solvency II-equivalent regime.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
08Large commercial insurerInsurance Class 3B (Insurance Act 1978)USD 1 mMinimum capital
- Permits
- Commercial insurer meeting the 3A unrelated-business test with unrelated net premiums above USD 50 million.
- Minimum capital
- Minimum capital and surplus USD 1,000,000 (BMA), plus capital against the BSCR Enhanced Capital Requirement; MSM under the Insurance Account Rules 2016. (≈USD 1 m)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Retail, with conditions
- Conditions
- Commercial insurer under BSCR.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
09Large commercial insurer/reinsurerInsurance Class 4 (Insurance Act 1978)USD 100 mMinimum capital
- Permits
- Insurers and reinsurers writing direct excess liability and/or property catastrophe reinsurance.
- Minimum capital
- Minimum capital and surplus USD 100,000,000. Minimum solvency margin is the greatest of USD 100 million, 15% of net loss reserves and 50% of net premiums written (BMA), plus the BSCR Enhanced Capital Requirement. (≈USD 100 m)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Commercial insurer under BSCR; annual actuarial certification of loss reserves.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
10Long-term pure captiveLong-term insurance Class A (Insurance Act 1978)USD 120 kMinimum capital
- Permits
- Single-parent long-term captive underwriting only its owners' and affiliates' long-term risks.
- Minimum capital
- Minimum capital and surplus USD 120,000 (BMA); minimum margin of solvency the greater of USD 120,000 or 0.5% of assets (IRSR 1980, reg. 12 and Schedule II). (≈USD 120 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Limited-purpose long-term insurer.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
11Long-term multi-owner captiveLong-term insurance Class B (Insurance Act 1978)USD 250 kMinimum capital
- Permits
- Multi-owner long-term captive, or a long-term captive with no more than 20% unrelated net premiums.
- Minimum capital
- Minimum capital and surplus USD 250,000 (BMA); minimum margin of solvency the greater of USD 250,000 or 1% of assets (IRSR 1980, reg. 12 and Schedule II). (≈USD 250 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Limited-purpose long-term insurer.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
12Small commercial life insurerLong-term insurance Class C (Insurance Act 1978)USD 500 kMinimum capital
- Permits
- Long-term insurers and reinsurers with total assets under USD 250 million not registrable as Class A or B.
- Minimum capital
- Minimum capital and surplus USD 500,000 (BMA). MSM is the greatest of USD 500,000, 1.5% of assets and 25% of ECR (Insurance (Prudential Standards) (Class C, Class D and Class E Solvency Requirement) Rules 2011, per Skadden). (≈USD 500 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800
- Clients
- Retail, with conditions
- Conditions
- Commercial long-term insurer under BSCR.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
13Mid-size commercial life insurerLong-term insurance Class D (Insurance Act 1978)USD 4 mMinimum capital
- Permits
- Long-term insurers and reinsurers with total assets of USD 250 million to under USD 500 million not registrable as Class A or B.
- Minimum capital
- Minimum capital and surplus USD 4,000,000 (BMA). MSM is the greatest of USD 4 million, 2% of the first USD 250 million of assets plus 1.5% of the excess, and 25% of ECR (Class C, D and E Solvency Requirement Rules 2011, per Skadden). (≈USD 4 m)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800
- Clients
- Retail, with conditions
- Conditions
- Commercial long-term insurer under BSCR.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
14Large commercial life insurerLong-term insurance Class E (Insurance Act 1978)USD 8 mMinimum capital
- Permits
- Long-term insurers and reinsurers with total assets of USD 500 million or more not registrable as Class A or B.
- Minimum capital
- MSM is the greatest of USD 8 million, 2% of the first USD 500 million of assets plus 1.5% of the excess, and 25% of ECR (Insurance (Prudential Standards) (Class C, Class D and Class E Solvency Requirement) Rules 2011, per Skadden). The BMA licensing page lists this tier but its figure was not shown. (≈USD 8 m)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800
- Clients
- Retail, with conditions
- Conditions
- Commercial long-term insurer under BSCR. Figure from a law-firm chapter; not read in the Rules.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
15ILS / fully collateralized vehicleSpecial Purpose Insurer (SPI) (Insurance Act 1978)USD 1 (nominal)Minimum capital
- Permits
- Transfers insurance risk to the capital markets; business must be fully collateralized with cash or cash equivalents held for the cedant. Restricted (approved insureds) or unrestricted.
- Minimum capital
- Minimum solvency capital requirement USD 1: special purpose business assets must exceed related liabilities by at least USD 1 (BMA; Skadden). (≈USD 1)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Used for catastrophe bonds and sidecars; fast-track registration is common market practice.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
16Collateralized reinsurance vehicleCollateralized Insurer (Insurance Act 1978)USD 250 kMinimum capital
- Permits
- Special purpose business with broader collateralization criteria, written openly to cedants, supervised under the Collateralized BSCR model.
- Minimum capital
- Minimum margin of solvency USD 250,000; paid-up share capital of at least USD 120,000; ECR under the Collateralized BSCR with a USD 250,000 floor (Skadden). The BMA licensing page states no fixed figure. (≈USD 250 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800Insurer registration fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 from BMD 17,800; Class 3A from BMD 24,550; Class 3B and Class 4 from BMD 253,000; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised insurer from BMD 15,000Insurer annual business fee by classClass 1 BMD 2,250; Class 2 BMD 4,375; Class 3 BMD 17,800-30,000; Class 3A BMD 24,550-44,500; Class 3B and 4 BMD 253,000-446,800; Class A/B BMD 13,570; SPI BMD 10,000-15,000; collateralised BMD 15,000-50,000
- Clients
- Professional only
- Conditions
- Figures from a law-firm chapter; the BMA page confirms the class but not the amounts.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
17Innovative (sandbox) insurerInnovative insurer classes IIGB and IILT (Insurance Act 1978, Insurance Regulatory Sandbox)USD 120 kMinimum capital
- Permits
- General (IIGB) or long-term (IILT) insurance business carried on in an innovative manner, typically insurtech models, under the BMA's insurance regulatory sandbox.
- Minimum capital
- IIGB: paid-up share capital USD 120,000 plus available capital and surplus equal to the ECR under the BSCR-IIGB model (BMA). IILT: minimum margin of solvency the greater of USD 120,000 or 0.5% of assets (IRSR 1980, Schedule II). (≈USD 120 k)
- Fees
- Insurer application fee (Insurance Act s.4(1))BMD 800
- Clients
- Retail, with conditions
- Conditions
- Time-limited, with conditions set by the BMA; firms are expected to graduate to a standard class.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
18Investment dealer (principal)Investment business standard license: investment provider acting as principal (Investment Business Act 2003)USD 250 kMinimum capital
- Permits
- Dealing in investments as principal, together with any other investment activity under the Act (arranging, managing, advising, safeguarding and administering).
- Minimum capital
- Minimum net assets USD 250,000 (Investment Business (Prudential Standards) (Standard Licences, Test Licences, and Class A Registered Persons) (Capital, Net Assets and Liquidity) Rules 2022, rule 3); where the BMA requires additional capital, 8% of risk-weighted assets and not less than USD 250,000. Liquid assets equal to three months of annual expenditure (rule 7). (≈USD 250 k)
- Fees
- Investment business license application (s.16(1))BMD 2,840Investment business annual fee, licensed providersBMD 2,710 to BMD 13,560 by scope: BMD 2,710 (other activities), BMD 6,780 (not holding client assets), BMD 13,560 (holding client assets); retail leveraged CFD BMD 100,000
- Clients
- Retail, with conditions
- Conditions
- Standard license (any investment activity) or test license (activities agreed with the BMA, for a defined period); the same net asset minimums apply to both. Which bucket a firm falls in (principal, agent, or neither) depends on how it deals and handles client assets; confirm with the BMA. Bermuda has no dedicated retail FX/CFD conduct regime (no leverage caps found); client money under the Investment Business (Client Money) Regulations 2004.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokeragePrime-of-PrimeStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
19Investment broker (agent)Investment business standard license: investment provider acting as agent (Investment Business Act 2003)USD 100 kMinimum capital
- Permits
- Dealing in investments as agent and arranging deals, together with related investment activities.
- Minimum capital
- Minimum net assets USD 100,000 (Capital, Net Assets and Liquidity Rules 2022, rule 3). Liquid assets equal to three months of annual expenditure (rule 7). (≈USD 100 k)
- Fees
- Investment business license application (s.16(1))BMD 2,840Investment business annual fee, licensed providersBMD 2,710 to BMD 13,560 by scope: BMD 2,710 (other activities), BMD 6,780 (not holding client assets), BMD 13,560 (holding client assets); retail leveraged CFD BMD 100,000
- Clients
- Retail, with conditions
- Conditions
- Standard license (any investment activity) or test license (activities agreed with the BMA, for a defined period); the same net asset minimums apply to both. Which bucket a firm falls in (principal, agent, or neither) depends on how it deals and handles client assets; confirm with the BMA. Client money regulations apply where client funds are held.
- Systems
- Private BrokerageInstitutional BrokerageWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
20Investment manager / adviserInvestment business standard license: investment provider neither agent nor principal (Investment Business Act 2003)USD 12 kMinimum capital
- Permits
- Managing investments, investment advice and arranging, where the firm does not deal as principal or agent.
- Minimum capital
- Minimum net assets USD 12,000 (Capital, Net Assets and Liquidity Rules 2022, rule 3). Liquid assets of at least one month of annual expenditure (rule 7). The BMA may require more. (≈USD 12 k)
- Fees
- Investment business license application (s.16(1))BMD 2,840Investment business annual fee, licensed providersBMD 2,710 to BMD 13,560 by scope: BMD 2,710 (other activities), BMD 6,780 (not holding client assets), BMD 13,560 (holding client assets); retail leveraged CFD BMD 100,000
- Clients
- Retail, with conditions
- Conditions
- Standard license (any investment activity) or test license (activities agreed with the BMA, for a defined period); the same net asset minimums apply to both. Which bucket a firm falls in (principal, agent, or neither) depends on how it deals and handles client assets; confirm with the BMA. Managers serving only sophisticated or institutional clients may qualify as Class B registered persons instead.
- Systems
- Asset Management CompanyFund Management CompanyWealth Management FirmInvestment Advisory FirmMulti-Family OfficeHedge FundPrivate Equity Firm
- Reading
- Read in the rulebook
- Sources
21Registered investment firmClass A and Class B Registered Persons (Investment Business Act 2003, as amended 2022)No fixed figureMinimum capital
- Permits
- Class A: Bermuda-formed firm regulated by a recognized foreign regulator with no place of business in Bermuda. Class B: firms (other than market intermediaries) dealing exclusively with specified investors, such as high-net-worth or sophisticated private investors, investment funds and entities with total assets of at least USD 5 million, or with fewer than 20 persons without public solicitation.
- Minimum capital
- No fixed minimum net assets for Class B. Class A follows its home regulator's capital requirements or, absent those, requirements set by the BMA.
- Fees
- Registered person application (s.13A / s.13B)BMD 2,840Registered person annual fee, Class A or Class BBMD 850
- Clients
- Professional only
- Conditions
- Class A must appoint a BMA-approved senior representative with an office in Bermuda. Registration rather than a license; framework effective 27 July 2022.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundMulti-Family Office
- Reading
- From a secondary source
- Sources
22Bermuda investment fundInvestment funds (Investment Funds Act 2006): authorized and registered fundsNo fixed figureMinimum capital
- Permits
- Authorized funds: institutional (qualified participants or minimum investment USD 100,000), administered (licensed administrator plus USD 50,000 minimum investment or a recognized listing), specified jurisdiction and standard (may have a larger retail element). Registered funds: private (no more than 20 participants, no public marketing) and professional Class A and Class B (qualified participants only).
- Minimum capital
- No capital requirement at fund level. Fund administrators licensed under Part III of the Act must secure minimum net assets of USD 50,000 (BMA). Investment managers are subject to the Investment Business Act categories above.
- Fees
- Investment fund authorization or registration feeAuthorization BMD 1,040; registered-fund initial filing BMD 950 (overseas) to BMD 1,870 (professional Class A / closed)Investment fund annual feeBMD 1,170 to BMD 1,870 per fund by type (standard BMD 1,860; administered/institutional BMD 1,170; professional Class A/closed BMD 1,870; Class B BMD 1,250; private BMD 1,325; overseas BMD 1,270)
- Clients
- Retail, with conditions
- Conditions
- Professional Class A funds need an investment manager licensed under the Investment Business Act, authorized by a recognized foreign regulator, or with at least USD 100 million gross assets under management (or in a group meeting that threshold). Registered funds must appoint manager, administrator, registrar, auditor and custodian or prime broker, and file AML/ATF policies.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundDigital Asset FundReal Estate Investment VehicleMutual Fund & UCITS
- Reading
- Read in the rulebook
- Sources
23Bermuda bankBank license (Banks and Deposit Companies Act 1999)USD 10 mMinimum capital
- Permits
- Banking business including deposit-taking; full banks must provide core banking services (Bermuda-dollar current and savings accounts, loans, foreign exchange and card facilities).
- Minimum capital
- Minimum net assets of USD 10 million at licensing (BDCA 1999, Second Schedule, paragraph 7, as substituted by BR 74/2024); ongoing Basel III capital and liquidity requirements (Guidance Notes - Basel III for Bermuda Banks, 2024). (≈USD 10 m)
- Fees
- Bank or deposit company license application (BDCA 1999 s.13(1))BMD 50,000Bank annual fees (BDCA 1999 s.16 plus Banks and Deposit Companies (Fees) Act 1975)s.16 fee BMD 25,180 (assets up to USD 1bn) to BMD 400,130 (over USD 10bn); plus Fees Act 1975 fee BMD 400,570 (up to USD 1bn) to BMD 1,987,330 (over USD 10bn)
- Clients
- Retail permitted
- Conditions
- Only four banks are licensed (HSBC Bank Bermuda, Butterfield, Clarien, Bermuda Commercial Bank). Large exposure framework (December 2024) applies. The BMA is consulting on new wholesale bank models, including digital asset banks (Walkers, September 2026). Bermuda dollar is pegged 1:1 to USD.
- Systems
- Private BankDigital BankCorrespondent Banking Structure
- Reading
- Read in the rulebook
- Sources
24Restricted (fintech) bankRestricted bank license (Banks and Deposit Companies Act 1999)USD 5 mMinimum capital
- Permits
- Banking business with fewer required core banking services; may serve a wider client group, including digital asset businesses, casinos and non-resident entities.
- Minimum capital
- Minimum net assets of USD 5 million at licensing (BDCA 1999, Second Schedule, paragraph 7, as substituted by BR 74/2024, operative 26 July 2024). (≈USD 5 m)
- Fees
- Bank or deposit company license application (BDCA 1999 s.13(1))BMD 50,000
- Clients
- Retail, with conditions
- Conditions
- Created to support fintech and digital-asset-focused banks; no restricted bank was operating as of September 2026 (Jewel Bank holds a DABA Class F license but no banking license). Basel III requirements apply.
- Systems
- Digital BankPrivate Bank
- Reading
- Read in the rulebook
- Sources
25Deposit companyDeposit company license (Banks and Deposit Companies Act 1999)USD 1 mMinimum capital
- Permits
- Narrower deposit-taking business than a bank.
- Minimum capital
- Minimum net assets of USD 1 million at licensing (BDCA 1999, Second Schedule, paragraph 7, as substituted by BR 74/2024). (≈USD 1 m)
- Fees
- Bank or deposit company license application (BDCA 1999 s.13(1))BMD 50,000Deposit company annual feesBMD 20,000 (Fees Act 1975) plus BDCA s.16 fee from BMD 25,180
- Clients
- Retail, with conditions
- Conditions
- Not a full bank; scope of permitted deposit-taking is set in the license.
- Systems
- Trade Finance House
- Reading
- Read in the rulebook
- Sources
Reach
No passport. Bermuda's commercial insurance regime has EU Solvency II equivalence and is recognized under the US-EU-Bermuda covered agreement framework, which eases cross-border reinsurance; investment, banking and digital asset licenses carry no cross-border rights.
Passage
DABA service standards (BMA guidance, not statutory): acknowledgement in 2 business days, completeness check in 3 business days, preliminary review in 10 business days and final decision in about 20 business days. Investment business: no statutory deadline; the BMA generally would not expect an application to remain outstanding beyond 3 months (Conyers, 2025). Insurance: market practice of several weeks for captives and simple structures; longer for commercial insurers and banks.
Licensed elsewhere
Bermuda has no retail FX/CFD regime of note; a forex broker would need an Investment Business license. Payment services (non-digital-asset) and e-money: a Payment Services Act was proposed, with license classes planned for 2026 (BMA 2026 Business Plan); until enacted there is no dedicated PSP/EMI license. Token offerings (ICOs) are authorized under the Digital Asset Issuance Act 2020. Independent miners and node validators are generally outside DABA. Sovereign vehicles: none relevant.
Notes. Digital Asset Business Amendment Act 2024 added lending and repo services and shifted custody rules to functional control; the Digital Asset Business (Custody of Client Assets) Rules 2025 and Operational Resilience and Outsourcing Code (final September 2025, implementation by 31 March 2028) followed. Banks and Deposit Companies (Restricted Banks) Amendment Order 2024 (BR 74/2024, operative 26 July 2024) set initial net assets at USD 10 million for banks, USD 5 million for restricted banks and USD 1 million for deposit companies. Investment business capital, net assets and liquidity rules took effect with the 2022 framework (27 July 2022). Bermuda corporate income tax of 15% applies from 1 January 2025 to Bermuda entities of multinational groups with revenue of EUR 750 million or more. Insurance Class E, Collateralized Insurer and commercial-insurer MSM details come from a law-firm chapter; other insurance figures were read on bma.bm and in the Insurance Returns and Solvency Regulations 1980. Bermuda dollar is pegged 1:1 to USD.
Americas · The Bahamas
SCB Bahamas
Securities Commission of The Bahamas
Regulator of securities and capital markets business, investment funds and their managers and administrators, digital asset businesses, and financial and corporate service providers in The Bahamas. Its main statutes are the Securities Industry Act, 2024 and the Digital Assets and Registered Exchanges (DARE) Act, 2024 (both in force 29 July 2024), the Investment Funds Act, 2019 and the Financial and Corporate Service Providers Act, 2020. Banks, trust companies and payment providers are licensed by the Central Bank of The Bahamas, not the SCB.
#21of 34
Balanced score
59 of 100
59 of 100
Scorecard
Credibility ×35%35Breadth ×15%62Entry threshold ×20%85Speed ×15%90Reach ×15%48
Categories17
Systems covered29 of 47
Typical timeline3–6 monthsmarket practice
Lowest capitalUSD 25 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 500–6 k6 items · Paid once, when the application is filed
On grantUSD 800–20 k8 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 800–45 k6 items · Recurring fees and levies
OtherUSD 475–6252 items · Mandatory charges that arise in operation
New fee rules (SIA, Investment Funds and DARE) are proposed to take effect on 1 January 2027, sharply raising CFD fees (annual BSD 45,000 to 75,000) and digital asset fees. First-year annual fees are pro-rated to 31 December.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Registered firm application fee (dealing, arranging, managing or advising)Securities Industry (Fees) Rules, 2024. Firms applying for more than one activity pay BSD 3,125. The draft 2026 Fees Rules (in force 1 January 2027 if adopted) keep BSD 1,500. BSD is pegged 1:1 to USD. | BSD 1,500≈ USD 2 k | Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2); Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024); Registered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024); Registered firm: managing capital markets instruments (Securities Industry Act, 2024) and 1 more | Read in the rulebook |
| CFD firm application feeThe 2024 Rules' column order was inferred from the schedule layout. The draft Securities Industry (Fees) Rules, 2026 (consultation closed 25 September 2026) would raise it to BSD 20,000 from 1 January 2027. CFD firms pay CFD fees in place of the other capital markets fees. | BSD 5,000 (current); BSD 20,000 proposed from 1 January 2027≈ USD 5 k | Registered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | Read in the rulebook |
| Investment fund license application feeInvestment Funds (Fees) Rules, 2024. Non-refundable. Draft Investment Funds Fees Rules 2026 are under consultation for 1 January 2027; amounts not reviewed. | BSD 2,000 (BSD 4,000 fast-tracked professional or SMART fund)≈ USD 2 k | Standard fund (Investment Funds Act, 2019); Professional fund (Investment Funds Act, 2019); SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | Read in the rulebook |
| Investment fund manager application fee (per fund)A manager already registered under the Securities Industries Act pays only this fee. | BSD 500≈ USD 500 | Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | Read in the rulebook |
| Fund administrator license application feeBands are 0-24, 25-49 and 50+ funds. | BSD 6,250 to 13,750 (restricted); BSD 13,750 to 20,000 (unrestricted), by number of funds administered≈ USD 6 k | Unrestricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D); Restricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D) | Read in the rulebook |
| Digital asset business application feeDigital Assets and Registered Exchanges (Fees) Rules, 2024. Draft 2026 Rules would set BSD 7,500 (exchange) and BSD 5,000 (other) from 1 January 2027. | BSD 6,250 (exchange); BSD 3,750 (other digital asset business); BSD 7,500 or 5,000 for an additional activity≈ USD 4 k | Digital asset business registration (DARE Act, 2024, Part III, s.6(1)); Digital asset exchange registration (DARE Act, 2024, ss.21-24; Form 5) | Read in the rulebook |
| On grant | |||
| Registration fee, dealing in capital markets instrumentsApplies to both principal-and-agent and agent-only dealers (the Fees Rules have one dealing category). First-year annual fee is pro-rated by month of approval. Unchanged in the 2027 draft. | BSD 15,000≈ USD 15 k | Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2); Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024) | Read in the rulebook |
| Registration fee, managing capital markets instrumentsUnchanged in the 2027 draft. | BSD 12,500≈ USD 12 k | Registered firm: managing capital markets instruments (Securities Industry Act, 2024) | Read in the rulebook |
| Registration fee, advising on capital markets instrumentsUnchanged in the 2027 draft. | BSD 8,500≈ USD 8 k | Registered firm: advising on capital markets instruments (Securities Industry Act, 2024) | Read in the rulebook |
| Registration fee, arranging deals in capital markets instrumentsUnchanged in the 2027 draft. | BSD 6,250≈ USD 6 k | Registered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024) | Read in the rulebook |
| CFD firm registration feeDraft 2026 Rules would raise it to BSD 75,000. | BSD 20,000 (current); BSD 75,000 proposed from 1 January 2027≈ USD 20 k | Registered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | Read in the rulebook |
| Investment fund manager initial registration fee (per fund)Not payable by managers registered under the Securities Industries Act. | BSD 800≈ USD 800 | Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | Read in the rulebook |
| Fund administrator initial licensing feeBy number of funds administered. | BSD 12,000 to 20,000 (restricted); BSD 20,000 to 26,250 (unrestricted)≈ USD 12 k | Unrestricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D); Restricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D) | Read in the rulebook |
| Digital asset business registration feeDraft 2026 Rules: BSD 23,500 (exchange) and BSD 15,625 (other) from 1 January 2027. | BSD 18,750 (exchange); BSD 12,500 (other digital asset business)≈ USD 12 k | Digital asset business registration (DARE Act, 2024, Part III, s.6(1)); Digital asset exchange registration (DARE Act, 2024, ss.21-24; Form 5) | Read in the rulebook |
| Every year | |||
| Annual fee, registered firmMulti-activity firms pay the highest fee plus BSD 6,250 per extra activity (and BSD 4,000 per extra activity on registration). The first year is pro-rated monthly to 31 December. The same amounts appear in the 2027 draft. | BSD 16,500 (dealing); BSD 15,000 (managing); BSD 11,000 (advising); BSD 8,500 (arranging)≈ USD 8 k | Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2); Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024); Registered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024); Registered firm: managing capital markets instruments (Securities Industry Act, 2024) and 1 more | Read in the rulebook |
| CFD firm annual fee and quarterly activity feeThe quarterly activity fee amount was not found. A CFD supervisory officer pays BSD 1,250 application, 3,750 registration and 6,250 annual. | BSD 45,000 annual (current); BSD 75,000 proposed from 1 January 2027; plus a quarterly activity fee under SCB published policy≈ USD 45 k | Registered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020) | Read in the rulebook |
| Investment fund annual feeFirst year pro-rated to 31 December. | BSD 2,750 (with administrator); BSD 3,125 (self-administered professional or SMART fund)≈ USD 3 k | Standard fund (Investment Funds Act, 2019); Professional fund (Investment Funds Act, 2019); SMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007) | Read in the rulebook |
| Investment fund manager annual fee (per fund)Not payable by managers registered under the Securities Industries Act. | BSD 800≈ USD 800 | Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B) | Read in the rulebook |
| Fund administrator annual feeBy number of funds administered. | BSD 16,875 to 35,625 (restricted); BSD 27,500 to 46,000 (unrestricted)≈ USD 17 k | Unrestricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D); Restricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D) | Read in the rulebook |
| Digital asset business annual feeFirst year pro-rated. Draft 2026 Rules: BSD 23,500 or 15,625, plus BSD 6,250 per extra activity, payable by 31 January. | BSD 18,750 (exchange); BSD 12,500 (other digital asset business); additional activity BSD 6,250 or 3,750≈ USD 12 k | Digital asset business registration (DARE Act, 2024, Part III, s.6(1)); Digital asset exchange registration (DARE Act, 2024, ss.21-24; Form 5) | Read in the rulebook |
| Other | |||
| Approved individuals: CEO, compliance officer, registered representativesSecurities Industry (Fees) Rules, 2024, Part VII. | BSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)≈ USD 475 | Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2); Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024); Registered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024); Registered firm: managing capital markets instruments (Securities Industry Act, 2024) and 2 more | From a secondary source |
| Investment funds administrative feesInvestment Funds (Fees) Rules, 2024, Table F. | BSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator≈ USD 625 | Investment fund manager registration (Investment Funds Act, 2019, Part II; Form B); Unrestricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D); Restricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D); Standard fund (Investment Funds Act, 2019) and 2 more | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 25 k
Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024)
USD 25 k
Portfolio managementRegistered firm: managing capital markets instruments (Securities Industry Act, 2024)
USD 25 k
Investment adviceRegistered firm: advising on capital markets instruments (Securities Industry Act, 2024)
USD 25 k
Securities dealer (agent only)Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024)
USD 120 k
Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2)
USD 300 k
10k100k1m
5 of 17 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
17 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Securities dealer (principal and agent)Registered firm: dealing in capital markets instruments as principal and agent (Securities Industry Act, 2024, First Schedule Part 2)USD 300 kMinimum capital
- Permits
- Dealing in securities and derivatives (capital markets instruments) as principal or agent. Only firms registered for dealing may hold client cash and other client assets.
- Minimum capital
- Fixed floor of USD 300,000, applied as the greater of the floor or 25% of annual expenditure, plus counterparty and position risk requirements (SCB financial resources presentation, 27 April 2021, 'current' column). The 2021 draft rules would set USD 325,000; not adopted as of October 2026. (≈USD 300 k)
- Fees
- Registered firm application fee (dealing, arranging, managing or advising)BSD 1,500Registration fee, dealing in capital markets instrumentsBSD 15,000Annual fee, registered firmBSD 16,500 (dealing); BSD 15,000 (managing); BSD 11,000 (advising); BSD 8,500 (arranging)Approved individuals: CEO, compliance officer, registered representativesBSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)
- Clients
- Retail permitted
- Conditions
- Status as of October 2026: the draft Securities Industry (Financial Resources) Rules, 2021 (consulted 12 March to 7 May 2021) were never made; the SCB's published list of rules contains no Financial Resources Rules, and its March 2026 update still lists them as pending. The current floors therefore rest on the older capital formula, which were not read in the Regulations themselves; the figures come from the SCB's 2021 presentation describing the floors then in force. Some secondary sources quote different class structures. Physical presence rules, a resident compliance officer, indemnity insurance (reg. 43), quarterly financials within 30 days and audited financials within 120 days apply. Bahamian dollar is pegged 1:1 to the USD.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrivate BrokeragePrime-of-PrimeInvestment BankStructured Products Issuer
- Reading
- To be confirmed
- Sources
02Securities dealer (agent only)Registered firm: dealing in capital markets instruments as agent only (Securities Industry Act, 2024)USD 120 kMinimum capital
- Permits
- Executing transactions in securities and derivatives for clients as agent, without dealing as principal.
- Minimum capital
- Fixed floor of USD 120,000, applied as the greater of the floor or 25% of annual expenditure, plus counterparty and position risk requirements (SCB financial resources presentation, 27 April 2021, 'current' column). The 2021 draft rules would set USD 175,000; not adopted as of October 2026. (≈USD 120 k)
- Fees
- Registered firm application fee (dealing, arranging, managing or advising)BSD 1,500Registration fee, dealing in capital markets instrumentsBSD 15,000Annual fee, registered firmBSD 16,500 (dealing); BSD 15,000 (managing); BSD 11,000 (advising); BSD 8,500 (arranging)Approved individuals: CEO, compliance officer, registered representativesBSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)
- Clients
- Retail permitted
- Conditions
- Status as of October 2026: the draft Securities Industry (Financial Resources) Rules, 2021 (consulted 12 March to 7 May 2021) were never made; the SCB's published list of rules contains no Financial Resources Rules, and its March 2026 update still lists them as pending. The current floors therefore rest on the older capital formula, which were not read in the Regulations themselves; the figures come from the SCB's 2021 presentation describing the floors then in force. Same governance, insurance and reporting duties as other registered firms.
- Systems
- Private BrokerageInstitutional BrokerageWhite-Label Brokerage
- Reading
- To be confirmed
- Sources
03Arranging dealsRegistered firm: arranging deals in capital markets instruments (Securities Industry Act, 2024)USD 25 kMinimum capital
- Permits
- Making arrangements for others to buy, sell, subscribe for or underwrite securities, such as introducing clients to a dealer or arranging placements, without dealing.
- Minimum capital
- Fixed floor of USD 25,000, applied as the greater of the floor or 25% of annual expenditure, plus counterparty and position risk requirements (SCB financial resources presentation, 27 April 2021, 'current' column). The 2021 draft rules would set USD 50,000; not adopted as of October 2026. (≈USD 25 k)
- Fees
- Registered firm application fee (dealing, arranging, managing or advising)BSD 1,500Registration fee, arranging deals in capital markets instrumentsBSD 6,250Annual fee, registered firmBSD 16,500 (dealing); BSD 15,000 (managing); BSD 11,000 (advising); BSD 8,500 (arranging)Approved individuals: CEO, compliance officer, registered representativesBSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)
- Clients
- Retail permitted
- Conditions
- Status as of October 2026: the draft Securities Industry (Financial Resources) Rules, 2021 (consulted 12 March to 7 May 2021) were never made; the SCB's published list of rules contains no Financial Resources Rules, and its March 2026 update still lists them as pending. The current floors therefore rest on the older capital formula, which were not read in the Regulations themselves; the figures come from the SCB's 2021 presentation describing the floors then in force. May not hold client assets. One secondary source quotes USD 120,000 for arranging, which conflicts with the SCB document.
- Systems
- White-Label BrokerageInvestment Bank
- Reading
- To be confirmed
- Sources
04Portfolio managementRegistered firm: managing capital markets instruments (Securities Industry Act, 2024)USD 25 kMinimum capital
- Permits
- Managing securities and derivatives belonging to others on a discretionary basis.
- Minimum capital
- Fixed floor of USD 25,000, applied as the greater of the floor or 25% of annual expenditure, plus counterparty and position risk requirements (SCB financial resources presentation, 27 April 2021, 'current' column). The 2021 draft rules would set USD 50,000; not adopted as of October 2026. (≈USD 25 k)
- Fees
- Registered firm application fee (dealing, arranging, managing or advising)BSD 1,500Registration fee, managing capital markets instrumentsBSD 12,500Annual fee, registered firmBSD 16,500 (dealing); BSD 15,000 (managing); BSD 11,000 (advising); BSD 8,500 (arranging)Approved individuals: CEO, compliance officer, registered representativesBSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)
- Clients
- Retail permitted
- Conditions
- Status as of October 2026: the draft Securities Industry (Financial Resources) Rules, 2021 (consulted 12 March to 7 May 2021) were never made; the SCB's published list of rules contains no Financial Resources Rules, and its March 2026 update still lists them as pending. The current floors therefore rest on the older capital formula, which were not read in the Regulations themselves; the figures come from the SCB's 2021 presentation describing the floors then in force. Client assets must sit with a registered dealer or custodian. A manager of investment funds also registers as an investment fund manager under the Investment Funds Act.
- Systems
- Asset Management CompanyWealth Management FirmMulti-Family OfficePension & Endowment Manager
- Reading
- To be confirmed
- Sources
05Investment adviceRegistered firm: advising on capital markets instruments (Securities Industry Act, 2024)USD 25 kMinimum capital
- Permits
- Giving investors advice on buying, selling or exercising rights in securities and derivatives.
- Minimum capital
- Fixed floor of USD 25,000, applied as the greater of the floor or 25% of annual expenditure, plus counterparty and position risk requirements (SCB financial resources presentation, 27 April 2021, 'current' column). The 2021 draft rules would set USD 25,000 (unchanged); not adopted as of October 2026. (≈USD 25 k)
- Fees
- Registered firm application fee (dealing, arranging, managing or advising)BSD 1,500Registration fee, advising on capital markets instrumentsBSD 8,500Annual fee, registered firmBSD 16,500 (dealing); BSD 15,000 (managing); BSD 11,000 (advising); BSD 8,500 (arranging)Approved individuals: CEO, compliance officer, registered representativesBSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)
- Clients
- Retail permitted
- Conditions
- Status as of October 2026: the draft Securities Industry (Financial Resources) Rules, 2021 (consulted 12 March to 7 May 2021) were never made; the SCB's published list of rules contains no Financial Resources Rules, and its March 2026 update still lists them as pending. The current floors therefore rest on the older capital formula, which were not read in the Regulations themselves; the figures come from the SCB's 2021 presentation describing the floors then in force. May not hold client assets.
- Systems
- Investment Advisory FirmMulti-Family Office
- Reading
- To be confirmed
- Sources
06CFD dealerRegistered firm: dealing in contracts for differences (Securities Industry (Contracts for Differences) Rules, 2020)No fixed figureMinimum capital
- Permits
- Dealing in, providing or marketing CFDs (including FX and digital asset CFDs) in or from The Bahamas, either as a firm also registered for dealing or as a CFD-only firm.
- Minimum capital
- In force: a capital formula prescribed by Commission rules (CFD Rules 2020, r.13), with no CFD-specific dollar figure. Proposed: the draft Securities Industry (Contracts for Differences) (Amendment) Rules, 2026 would require at least USD 1,000,000 held on deposit with a Bahamian licensed bank, or a higher amount under future Financial Resources Rules. Consultation ran 28 August to 25 September 2026; as of late October 2026 the SCB still lists it as a draft and no final rules have been published.
- Fees
- CFD firm application feeBSD 5,000 (current); BSD 20,000 proposed from 1 January 2027CFD firm registration feeBSD 20,000 (current); BSD 75,000 proposed from 1 January 2027CFD firm annual fee and quarterly activity feeBSD 45,000 annual (current); BSD 75,000 proposed from 1 January 2027; plus a quarterly activity fee under SCB published policyApproved individuals: CEO, compliance officer, registered representativesBSD 575 application plus BSD 800 registration and BSD 800 annual (CEO and compliance officer); BSD 475 plus 725 and 725 (registered representative)
- Clients
- Retail permitted
- Conditions
- Retail minimum margin of 0.5% of exposure (about 200:1) for most CFDs and 5% (about 20:1) for digital asset CFDs (r.23); margin close-out at 50% of required margin (r.27-28); negative balance protection (r.29); cash-only retail margin, segregated (r.22, r.26); no binary options for retail (r.32); a CFD Supervisory Officer resident in The Bahamas (r.8). The 2026 draft would replace fixed margins with an SCB-approved margin policy. Fees: USD 5,000 application, USD 20,000 registration, USD 45,000 annual, plus a quarterly activity fee.
- Systems
- Retail BrokerageMulti-Asset BrokeragePrime-of-Prime
- Reading
- Read in the rulebook
- Sources
07MarketplaceMarketplace, clearing facility or ancillary facility (Securities Industry Act, 2024)No fixed figureMinimum capital
- Permits
- Operating a securities exchange or other marketplace for capital markets instruments, a clearing facility, or an ancillary facility.
- Minimum capital
- No fixed figure published; the Commission can require whatever minimum capital it considers necessary (Securities Industry Regulations, 2012, reg. 4(2) and 22).
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Fees: marketplace USD 15,000 application, USD 21,000 registration and annual; clearing facility USD 5,500 and USD 15,625. Rulebook, surveillance and systems approval by the SCB.
- Systems
- ECN & DMA Venue
- Reading
- From a secondary source
- Sources
08Investment fund managerInvestment fund manager registration (Investment Funds Act, 2019, Part II; Form B)No fixed figureMinimum capital
- Permits
- Managing investment funds licensed or registered under the Investment Funds Act. The SCB also licenses alternative investment fund managers (AIFMs) under Part II.
- Minimum capital
- The Investment Funds Act, 2019 leaves the amount to the Commission: a licensed manager 'shall have an initial capital as prescribed by the Commission' (s.63(1)) and own funds or professional indemnity insurance to cover negligence risk (s.63(2)). No prescribed dollar figure was found in the Act, the SCB's published rules list, its forms or its guidance.
- Fees
- Investment fund manager application fee (per fund)BSD 500Investment fund manager initial registration fee (per fund)BSD 800Investment fund manager annual fee (per fund)BSD 800Investment funds administrative feesBSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator
- Clients
- Retail, with conditions
- Conditions
- Fees per fund: USD 500 application and USD 800 registration and annual (no registration fee if the manager is already registered under the Securities Industry Act). Delegation requires prior notice (s.65). The SCB's registration checklist asks for 'confirmation of regulatory capital (where applicable)'. Capital: uncertain; ask the SCB for the prescribed amount. Section numbers are from the 2019 Bill text and the SCB's own references.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- To be confirmed
- Sources
09Unrestricted fund administratorUnrestricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D)No fixed figureMinimum capital
- Permits
- Providing administration services (registrar, transfer agency, NAV calculation, compliance) to any number of investment funds.
- Minimum capital
- No published dollar figure was found. The Investment Funds Act, 2019 requires 'prescribed financial requirements' at licensing (s.36(1)(h)) and lets the Commission direct an administrator whose shareholders' equity falls below 'any amount prescribed by the Commission' to increase it (s.58). The SCB lists an ongoing capital requirement under s.58 without stating the amount; Form D asks only for authorized share capital and shareholders' equity.
- Fees
- Fund administrator license application feeBSD 6,250 to 13,750 (restricted); BSD 13,750 to 20,000 (unrestricted), by number of funds administeredFund administrator initial licensing feeBSD 12,000 to 20,000 (restricted); BSD 20,000 to 26,250 (unrestricted)Fund administrator annual feeBSD 16,875 to 35,625 (restricted); BSD 27,500 to 46,000 (unrestricted)Investment funds administrative feesBSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator
- Clients
- Retail, with conditions
- Conditions
- Indemnity insurance (s.58); audited financials within 120 days; six-monthly statistics on administered funds. Fees scale with the number of funds: USD 13,750 to 20,000 application, USD 20,000 to 26,250 licensing, USD 27,500 to 46,000 annual. Capital: uncertain; ask the SCB for the prescribed shareholders' equity.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- To be confirmed
- Sources
10Restricted fund administratorRestricted investment fund administrator license (Investment Funds Act, 2019, Part II; Form D)No fixed figureMinimum capital
- Permits
- Administering only the specific funds named in the license, typically a sponsor's own funds.
- Minimum capital
- No published dollar figure was found. The Investment Funds Act, 2019 requires 'prescribed financial requirements' at licensing (s.36(1)(h)) and lets the Commission direct an administrator whose shareholders' equity falls below 'any amount prescribed by the Commission' to increase it (s.58). The SCB lists an ongoing capital requirement under s.58 without stating the amount; Form D asks only for authorized share capital and shareholders' equity.
- Fees
- Fund administrator license application feeBSD 6,250 to 13,750 (restricted); BSD 13,750 to 20,000 (unrestricted), by number of funds administeredFund administrator initial licensing feeBSD 12,000 to 20,000 (restricted); BSD 20,000 to 26,250 (unrestricted)Fund administrator annual feeBSD 16,875 to 35,625 (restricted); BSD 27,500 to 46,000 (unrestricted)Investment funds administrative feesBSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator
- Clients
- Retail, with conditions
- Conditions
- Same insurance and reporting duties as unrestricted administrators. Fees: USD 6,250 to 13,750 application, USD 12,000 to 20,000 licensing, USD 16,875 to 35,625 annual, depending on the number of funds. Capital: uncertain; ask the SCB for the prescribed shareholders' equity.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- To be confirmed
- Sources
11Standard fundStandard fund (Investment Funds Act, 2019)No fixed figureMinimum capital
- Permits
- A licensed investment fund that may be offered to the general public, including retail investors.
- Minimum capital
- No fund-level minimum capital found in SCB materials. Fees: USD 2,000 application, USD 2,750 annual.
- Fees
- Investment fund license application feeBSD 2,000 (BSD 4,000 fast-tracked professional or SMART fund)Investment fund annual feeBSD 2,750 (with administrator); BSD 3,125 (self-administered professional or SMART fund)Investment funds administrative feesBSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator
- Clients
- Retail permitted
- Conditions
- Requires a licensed fund administrator, an offering document meeting the Act's content requirements, and audited financial statements within 180 days of year-end. The SCB has listed an overhaul of the Investment Funds Act as a 2026 initiative.
- Systems
- Mutual Fund & UCITSReal Estate Investment Vehicle
- Reading
- From a secondary source
- Sources
12Professional fundProfessional fund (Investment Funds Act, 2019)No fixed figureMinimum capital
- Permits
- An investment fund offered only to eligible (sophisticated or high-net-worth) investors as defined under the Act and regulations; may be administered by a licensed administrator or self-administered, with a fast-track option.
- Minimum capital
- No fund-level minimum capital found in SCB materials. Fees: USD 2,000 application (USD 4,000 fast-tracked), USD 2,750 annual (USD 3,125 if self-administered).
- Fees
- Investment fund license application feeBSD 2,000 (BSD 4,000 fast-tracked professional or SMART fund)Investment fund annual feeBSD 2,750 (with administrator); BSD 3,125 (self-administered professional or SMART fund)Investment funds administrative feesBSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator
- Clients
- Professional only
- Conditions
- Investor eligibility thresholds are set in the Act and regulations and were not confirmed for this record. Audited financials within 180 days.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset Fund
- Reading
- From a secondary source
- Sources
13SMART fundSMART fund (Specific Mandate Alternative Regulatory Test; Investment Funds Act, 2019 and SMART Fund Rules, SFM 001-007)No fixed figureMinimum capital
- Permits
- A fund built on an SCB-approved template (SMART Fund Model) with conditions on investor numbers and type set by that template; commonly used for small closed-circle and private vehicles. May be administered or self-administered, with a fast-track option.
- Minimum capital
- No fund-level minimum capital found in SCB materials. Fees: USD 2,000 application (USD 4,000 fast-tracked), USD 2,750 annual (USD 3,125 if self-administered).
- Fees
- Investment fund license application feeBSD 2,000 (BSD 4,000 fast-tracked professional or SMART fund)Investment fund annual feeBSD 2,750 (with administrator); BSD 3,125 (self-administered professional or SMART fund)Investment funds administrative feesBSD 625 approval of a director, operator or CEO change; BSD 1,000 compliance officer or MLRO approval; BSD 625 share transfer approval for an administrator
- Clients
- Retail, with conditions
- Conditions
- Each SMART Fund Model (SFM 001 to 007) sets its own investor limits and requirements; check the specific model rules.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundDigital Asset Fund
- Reading
- From a secondary source
- Sources
14Digital asset businessDigital asset business registration (DARE Act, 2024, Part III, s.6(1))No fixed figureMinimum capital
- Permits
- Registrable activities include exchanging digital assets for fiat or other digital assets, digital asset payment services, order execution and transmission, issuing stablecoins, placing digital assets, transfer services, custody, advice, portfolio management, DLT node services, digital asset derivatives and staking services.
- Minimum capital
- No fixed dollar minimum in the Act. The Commission sets financial requirements by risk (s.15(1)-(2)) and registrants must keep liquid capital at or above the prescribed level, with monthly liquid capital returns (s.15(5)).
- Fees
- Digital asset business application feeBSD 6,250 (exchange); BSD 3,750 (other digital asset business); BSD 7,500 or 5,000 for an additional activityDigital asset business registration feeBSD 18,750 (exchange); BSD 12,500 (other digital asset business)Digital asset business annual feeBSD 18,750 (exchange); BSD 12,500 (other digital asset business); additional activity BSD 6,250 or 3,750
- Clients
- Retail permitted
- Conditions
- Client assets segregated on separate addresses, omnibus only with consent, quarterly position statements, annual independent custody review (s.18). Staking needs detailed disclosure and risk warnings (s.20). Stablecoins must be fully reserved, with algorithmic stablecoins prohibited (s.49), quarterly proof-of-reserve reports (s.51) and 1:1 redemption (s.53). Commercial mining is prohibited unless ancillary to a registered business or for the miner's own account (s.8). Fees: USD 3,750 application and USD 12,500 registration and annual, plus fees per additional activity.
- Systems
- OTC Digital Asset DeskCustody & Wallet InfrastructureStablecoin Issuance StructureDigital Asset FundMining & Validation OperationTokenization Platform
- Reading
- Read in the rulebook
- Sources
15Digital asset exchangeDigital asset exchange registration (DARE Act, 2024, ss.21-24; Form 5)No fixed figureMinimum capital
- Permits
- Operating a platform for trading digital assets, with optional custody and other registered activities.
- Minimum capital
- No fixed dollar minimum. The exchange must hold assets in The Bahamas at least equal to twelve months of operating expenses (s.23(1)(a)), in addition to the general liquid capital requirement (s.15).
- Fees
- Digital asset business application feeBSD 6,250 (exchange); BSD 3,750 (other digital asset business); BSD 7,500 or 5,000 for an additional activityDigital asset business registration feeBSD 18,750 (exchange); BSD 12,500 (other digital asset business)Digital asset business annual feeBSD 18,750 (exchange); BSD 12,500 (other digital asset business); additional activity BSD 6,250 or 3,750
- Clients
- Retail permitted
- Conditions
- Listing rules, transaction monitoring, settlement and business continuity controls (s.22); custody rules if it holds client assets (s.24); must begin operations within 12 months of registration. Fees: USD 6,250 application and USD 18,750 registration and annual.
- Systems
- Digital Asset Exchange
- Reading
- Read in the rulebook
- Sources
16Token offeringInitial token offering registration (DARE Act, 2024, Part IV, ss.36-55)No fixed figureMinimum capital
- Permits
- Offering digital tokens, including stablecoins and tokenized assets, to the public in or from The Bahamas with a registered offering memorandum.
- Minimum capital
- No fixed figure; the Commission may impose minimum capital and liquid capital requirements on issuers (s.36(8)).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Offering memorandum filed at least 45 days before the offer period (s.42(1)); 72-hour purchaser withdrawal right (s.55). Exemptions for offers to fewer than 150 persons, qualified purchasers only, and certain employee schemes (s.36(4)). Privacy tokens may not be offered (s.38). Filing fee USD 6,000.
- Systems
- Tokenization PlatformStablecoin Issuance StructureStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
17FCSP (financial services)Financial and corporate service provider license, financial services (Financial and Corporate Service Providers Act, 2020)No fixed figureMinimum capital
- Permits
- Financial services outside the securities and banking regimes, including trading in commodities and other financial instruments, financial intermediation, advisory or consultancy, money lending, money broking and financial leasing. A separate corporate services license covers company formation, registered agent and trustee services for ICONs and PTCs.
- Minimum capital
- No fixed figure; licensees must maintain adequate financial resources and solvency (s.20) and indemnity insurance (s.21). Fees for trading in commodities and other financial instruments: USD 11,875 application, USD 31,250 annual.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Activities that amount to dealing in securities or derivatives need Securities Industry Act registration instead; check the boundary with the SCB.
- Systems
- Commodities Trading House
- Reading
- From a secondary source
- Sources
Reach
None. Registration covers business carried on in or from The Bahamas; there is no EU or other passport. Firms serving clients abroad must check the host country's rules. The Bahamas left the FATF grey list in December 2020; its CFATF fifth-round mutual evaluation was scheduled for October 2026.
Passage
No statutory decision deadline was found for registered firms, fund licenses or DARE registrations. Market practice: about 3 to 6 months for a securities firm or digital asset business from a complete application (secondary sources). DARE token offerings must be filed at least 45 days before the offer period begins (DARE Act s.42(1)).
Licensed elsewhere
Banks and trust companies (private bank, digital bank, correspondent banking, trade finance, treasury), private trust companies, payment service providers, e-money, card issuing, acquiring and money transmission businesses: Central Bank of The Bahamas (Banks and Trust Companies Regulation Act, 2020; Payment Systems Act, 2012 and Payment Instruments (Oversight) Regulations, 2017), which also runs exchange control. Insurance and reinsurance, including captives and external insurers: Insurance Commission of The Bahamas. Retail FX and CFDs are licensed by the SCB (CFD category). Single-family offices usually use a private trust company registered under Central Bank rules or an exempt SMART fund rather than an SCB license. Sovereign vehicles: not licensed by the SCB.
Notes. The Securities Industry Act, 2024 and the DARE Act, 2024 came into force on 29 July 2024, replacing the 2011 Act and the DARE Act, 2020. Capital rules for securities firms are in flux: the 2021 draft Financial Resources Rules were never made, and the SCB's March 2026 update lists new Financial Resources Rules and the finalization of Securities Industry Regulations as pending, along with an overhaul of the Investment Funds Act. In August-September 2026 it consulted on CFD amendments (USD 1,000,000 bank-deposit capital floor, approved retail margin policies) and new 2026 fee rules for all four statutes; none was final by late October 2026. New AML/CFT/CPF rules for 2026 were issued under each statute. A Decentralised Autonomous Organisations Act, 2026 is also administered by the SCB. All amounts are in USD; the Bahamian dollar is pegged 1:1. Fund administrator and fund manager capital is left by the Investment Funds Act to amounts prescribed by the Commission, and no published figure was found.
Asia-Pacific · Singapore
MAS
Monetary Authority of Singapore
MAS is Singapore's central bank and single integrated regulator for banking, insurance, capital markets and payments. Capital markets firms are licensed under the Securities and Futures Act 2001 (Capital Markets Services license, one license with activity-by-activity base capital in the SF(FMR)R), payment firms under the Payment Services Act 2019, and banks under the Banking Act 1970. Where a firm holds several CMS activities, the highest applicable base capital applies.
#8of 34
Balanced score
78 of 100
78 of 100
Scorecard
Credibility ×35%100Breadth ×15%89Entry threshold ×20%68Speed ×15%60Reach ×15%44
Categories27
Systems covered42 of 47
Typical timeline6–12 monthsservice standard
Lowest capitalUSD 39 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 385–15 k6 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guaranteesUSD 77 k1 item · Held or lodged, beyond the minimum capital
Every yearUSD 1 k–96 k11 items · Recurring fees and levies
OtherUSD 1541 item · Mandatory charges that arise in operation
Direct MAS fees are modest (a few thousand SGD a year for CMS and PSA licenses); banks pay SGD 100,000 to 125,000 a year. The real costs are base capital, the MPI security deposit and local staffing.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| CMS license application fee (Form 1)Non-refundable, prescribed under reg. 6 of the SF(LCB)R. MAS lists no separate per-activity application fee. Adding a regulated activity to an existing license (Form 5): SGD 500. | SGD 1,000≈ USD 770 | CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives); CMS license: Dealing in capital markets products (OTC derivatives); CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading); CMS license: Dealing in capital markets products (specified commodity futures) and 7 more | Read in the rulebook |
| Approved exchange or recognized market operator application feeNon-refundable. Annual fee is set in the Schedule to the Securities and Futures (Organised Markets) Regulations 2018; amount not confirmed this session. | SGD 4,000≈ USD 3 k | Approved Exchange (AE) under Part 2 of the SFA; Recognised Market Operator (RMO) under Part 2 of the SFA | Read in the rulebook |
| PSA license application fee, money-changing | SGD 500≈ USD 385 | Payment Services Act: Money-changing license | From a secondary source |
| PSA license application fee, standard payment institutionPer-service application fee SGD 1,000 for domestic or cross-border money transfer, merchant acquisition, e-money issuance and digital payment token service; account issuance nil; money-changing SGD 500. | SGD 1,000 (higher of SGD 1,000 or sum of per-service fees)≈ USD 770 | Payment Services Act: Standard Payment Institution (SPI) license | From a secondary source |
| PSA license application fee, major payment institutionPer-service application fee SGD 1,500 for each of domestic or cross-border money transfer, merchant acquisition, e-money issuance and digital payment token service; account issuance nil; money-changing SGD 500. | SGD 1,500 (higher of SGD 1,500 or sum of per-service fees)≈ USD 1 k | Payment Services Act: Major Payment Institution (MPI) license | From a secondary source |
| Bank license application feeNon-refundable. Banking (Fees) Notification s.4. Digital full and digital wholesale banks are licensed as full and wholesale banks under the Banking Act; applying the same fee to them is an inference. | SGD 20,000≈ USD 15 k | Banking Act: Full bank license (including qualifying full bank); Banking Act: Wholesale bank license; Banking Act: Digital full bank (DFB) license; Banking Act: Digital wholesale bank (DWB) license and 1 more | Read in the rulebook |
| Deposits & guarantees | |||
| MPI security (cash deposit with MAS or bank guarantee)SGD 100,000 where average monthly payment transactions for every payment service do not exceed SGD 6 million in the calendar year; SGD 200,000 otherwise. Not required for SPIs or money-changers. | SGD 100,000 or SGD 200,000≈ USD 77 k | Payment Services Act: Major Payment Institution (MPI) license | Read in the rulebook |
| Every year | |||
| Annual license fee, dealing in capital markets productsFixed fee depends on products dealt and on approved exchange or clearing house membership; a broker-dealer in securities that is not an SGX securities trading member pays SGD 4,000. Variable fee of SGD 5 per representative from the 101st, counted at 1 January. | SGD 2,000 to 8,000 per year, plus SGD 5 per representative from the 101st≈ USD 2 k | CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives); CMS license: Dealing in capital markets products (OTC derivatives); CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading); CMS license: Dealing in capital markets products (specified commodity futures) | Read in the rulebook |
| Annual license fee, fund management (LFMC, retail or A/I)Representative count taken at 1 January each year. | SGD 4,000 per year, plus SGD 5 per representative from the 101st≈ USD 3 k | CMS license: Fund management (Retail LFMC); CMS license: Fund management (Accredited/Institutional LFMC) | Read in the rulebook |
| Annual license fee, venture capital fund manager (VCFM) | SGD 4,000 per year≈ USD 3 k | CMS license: Fund management (Venture Capital Fund Manager, VCFM regime) | Read in the rulebook |
| Annual license fee, advising on corporate finance or REIT managementMAS lists SGD 4,000 for corporate finance advisory and SGD 4,000 for REIT management. | SGD 4,000 per year (each activity)≈ USD 3 k | CMS license: Advising on corporate finance; CMS license: Real estate investment trust management | Read in the rulebook |
| Annual license fee, product financing or custodial servicesMAS lists SGD 2,000 for product financing and SGD 2,000 for providing custodial services. | SGD 2,000 per year (each activity)≈ USD 2 k | CMS license: Providing custodial services; CMS license: Product financing | Read in the rulebook |
| PSA annual license fee, money-changing | SGD 1,500 per year≈ USD 1 k | Payment Services Act: Money-changing license | From a secondary source |
| PSA annual license fee, standard payment institutionPer-service annual fee SGD 5,000 for each money transfer, acquiring, e-money or DPT service; account issuance nil; money-changing SGD 1,500. | SGD 5,000 per year (higher of SGD 5,000 or sum of per-service fees)≈ USD 4 k | Payment Services Act: Standard Payment Institution (SPI) license | From a secondary source |
| PSA annual license fee, major payment institutionPer-service annual fee SGD 10,000 for each money transfer, acquiring, e-money or DPT service; account issuance nil; money-changing SGD 1,500. | SGD 10,000 per year (higher of SGD 10,000 or sum of per-service fees)≈ USD 8 k | Payment Services Act: Major Payment Institution (MPI) license | From a secondary source |
| Annual license fee, full bankPlus SGD 10,000 per additional Singapore branch and SGD 1,000 per limited-purpose branch. Banking (Fees) Notification s.3, text current at 26 March 2026 as reproduced by a third party. Digital full bank treated as a full bank license (inference). | SGD 125,000 per year for the head or main office≈ USD 96 k | Banking Act: Full bank license (including qualifying full bank); Banking Act: Digital full bank (DFB) license | From a secondary source |
| Annual license fee, wholesale bankPlus SGD 1,000 per limited-purpose branch. Digital wholesale bank treated as a wholesale bank license (inference). | SGD 100,000 per year for the head or main office≈ USD 77 k | Banking Act: Wholesale bank license; Banking Act: Digital wholesale bank (DWB) license | From a secondary source |
| Annual license fee, merchant bankBanking (Fees) Notification s.3. | SGD 35,000 per year≈ USD 27 k | Banking Act: Merchant bank license | From a secondary source |
| Other | |||
| Representative lodgement and annual representative fee (CMS)Annual representative fee is SGD 700 or SGD 200 depending on the CMS activities conducted, charged on a highest-of basis regardless of number of activities; pro-rated in the first year for provisional representatives. | SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative≈ USD 154 | CMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives); CMS license: Dealing in capital markets products (OTC derivatives); CMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading); CMS license: Dealing in capital markets products (specified commodity futures) and 7 more | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 552 k
Securities and exchange-traded derivatives dealerCMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives)
USD 39 k
Standard payment institutionPayment Services Act: Standard Payment Institution (SPI) license
USD 78 k
Commodity futures brokerCMS license: Dealing in capital markets products (specified commodity futures)
USD 195 k
Corporate finance adviserCMS license: Advising on corporate finance
USD 195 k
A/I licensed fund managerCMS license: Fund management (Accredited/Institutional LFMC)
USD 195 k
Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFA
USD 195 k
Major payment institutionPayment Services Act: Major Payment Institution (MPI) license
USD 195 k
DTSP (overseas-only digital token services)Digital Token Service Provider (DTSP) license under Part 9 of the Financial Services and Markets Act 2022
USD 195 k
Licensed financial adviserFinancial Advisers Act: Financial adviser's license
USD 195 k
OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives)
USD 390 k
Retail licensed fund managerCMS license: Fund management (Retail LFMC)
USD 390 k
Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading)
USD 780 k
REIT managerCMS license: Real estate investment trust management
USD 780 k
CustodianCMS license: Providing custodial services
USD 780 k
Margin / product financierCMS license: Product financing
USD 780 k
Direct insurer / reinsurerInsurance Act 1966: Licensed direct insurer or reinsurer
USD 3.9 m
Approved exchangeApproved Exchange (AE) under Part 2 of the SFA
USD 7.8 m
Digital full bankBanking Act: Digital full bank (DFB) license
USD 11.7 m
Merchant bankBanking Act: Merchant bank license
USD 11.7 m
Wholesale bankBanking Act: Wholesale bank license
USD 78 m
Digital wholesale bankBanking Act: Digital wholesale bank (DWB) license
USD 78 m
Full bankBanking Act: Full bank license (including qualifying full bank)
USD 156 m
10k100k1m10m100m1bn
22 of 27 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
27 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Securities and exchange-traded derivatives dealerCMS license: Dealing in capital markets products (securities, CIS units, exchange-traded derivatives)USD 39 kMinimum capital
- Permits
- Dealing in capital markets products that are securities, units in collective investment schemes and exchange-traded derivatives, as principal or agent.
- Minimum capital
- Base capital (SFA04-G01 Annex 1, Table AA; SF(FMR)R First Schedule): S$5 million clearing member; S$1 million trading member of an approved exchange or non-member; S$500,000 introducing broker; S$50,000 where it deals only with accredited, expert or institutional investors. Financial resources must also exceed the total risk requirement (Notice SFA 04-N13). (≈USD 39 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, dealing in capital markets productsSGD 2,000 to 8,000 per year, plus SGD 5 per representative from the 101stRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- Highest base capital applies where several activities are held. Fit and proper, Singapore office, professional indemnity insurance, representatives notified on the Public Register. The S$50,000 tier applies only if no retail clients are served. Retail investors are protected by customer-asset segregation rules and product-specific requirements (e.g. Specified Investment Product rules).
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrivate BrokeragePrime BrokerageWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
02OTC derivatives / CFD dealerCMS license: Dealing in capital markets products (OTC derivatives)USD 390 kMinimum capital
- Permits
- Dealing in over-the-counter derivatives contracts, including CFDs, as principal or agent.
- Minimum capital
- Base capital (SFA04-G01 Annex 1, Table AB): S$5 million for a clearing member or a non-clearing member with retail clients; S$1 million for a non-clearing member with only non-retail clients; S$500,000 for others. (≈USD 390 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, dealing in capital markets productsSGD 2,000 to 8,000 per year, plus SGD 5 per representative from the 101stRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- A CFD broker serving retail clients needs S$5 million base capital. Margin requirements for leveraged retail products under the SF(FMR)R. Risk-based capital (Notice SFA 04-N13). OTC derivatives reporting and margining rules apply to larger dealers.
- Systems
- Retail BrokerageInstitutional BrokeragePrivate BrokeragePrime-of-PrimeMulti-Asset BrokerageStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
03Leveraged FX dealerCMS license: Dealing in capital markets products (spot FX for leveraged foreign exchange trading)USD 780 kMinimum capital
- Permits
- Dealing in spot foreign exchange contracts for the purposes of leveraged foreign exchange trading.
- Minimum capital
- Base capital (SFA04-G01 Annex 1, Table E): S$5 million where it deals with any customer who is not an accredited, institutional or expert investor; S$1 million where it deals only with accredited, institutional or expert investors. (≈USD 780 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, dealing in capital markets productsSGD 2,000 to 8,000 per year, plus SGD 5 per representative from the 101stRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- Retail leveraged FX requires S$5 million base capital and compliance with MAS minimum margin rules for retail customers under the SF(FMR)R (leverage limits apply; confirm current ratios in the regulations). Financial resources above 120% of total risk requirement expected in practice.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokeragePrime-of-Prime
- Reading
- Read in the rulebook
- Sources
04Commodity futures brokerCMS license: Dealing in capital markets products (specified commodity futures)USD 195 kMinimum capital
- Permits
- Dealing in specified commodity futures contracts.
- Minimum capital
- Base capital (SFA04-G01 Annex 1, Table C): S$1 million clearing member; S$500,000 non-clearing member or non-member; S$250,000 introducing broker or restricted broker. (≈USD 195 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, dealing in capital markets productsSGD 2,000 to 8,000 per year, plus SGD 5 per representative from the 101stRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- A license is needed to deal in commodity futures for clients. Physical commodity trading on own account does not need a CMS license.
- Systems
- Institutional BrokerageMulti-Asset Brokerage
- Reading
- Read in the rulebook
- Sources
05Corporate finance adviserCMS license: Advising on corporate financeUSD 195 kMinimum capital
- Permits
- Advising on corporate finance, including capital raising, listings, takeovers and restructurings.
- Minimum capital
- Base capital S$250,000; S$1 million if it is also a non-clearing or trading member dealing in certain products (MAS CMS license page). (≈USD 195 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, advising on corporate finance or REIT managementSGD 4,000 per year (each activity)Representative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail, with conditions
- Conditions
- Usually combined with dealing in capital markets products for underwriting. Investment banking in Singapore is done either through this CMS route or through a bank or merchant bank license.
- Systems
- Investment Bank
- Reading
- Read in the rulebook
- Sources
06Retail licensed fund managerCMS license: Fund management (Retail LFMC)USD 390 kMinimum capital
- Permits
- Fund management, including managing collective investment schemes offered to retail investors and discretionary portfolios for retail customers.
- Minimum capital
- Base capital (SFA04-G05 para 3.13, Table 2): S$1 million where it manages a CIS offered to non-accredited/non-institutional investors; S$500,000 where it serves non-accredited/non-institutional customers but not through a CIS; S$250,000 otherwise. Financial resources at least 120% of total risk requirement (para 3.14). (≈USD 390 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, fund management (LFMC, retail or A/I)SGD 4,000 per year, plus SGD 5 per representative from the 101stRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- Minimum of 2 directors (one executive with 5 years' experience), CEO resident in Singapore, at least 3 relevant professionals and 3 representatives resident in Singapore (check Table A1-1), independent custody and valuation, annual audit, professional indemnity insurance. Retail CIS must also be authorized or recognized by MAS.
- Systems
- Asset Management CompanyFund Management CompanyMutual Fund & UCITSETF PlatformWealth Management FirmPension & Endowment ManagerReal Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
07A/I licensed fund managerCMS license: Fund management (Accredited/Institutional LFMC)USD 195 kMinimum capital
- Permits
- Fund management for accredited and institutional investors only, through funds or segregated mandates.
- Minimum capital
- Base capital S$250,000 (SFA04-G05 para 3.13, Table 2), plus financial resources above the total risk requirement. (≈USD 195 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, fund management (LFMC, retail or A/I)SGD 4,000 per year, plus SGD 5 per representative from the 101stRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Professional only
- Conditions
- May serve only qualifying investors and must not use structures to reach retail (SFA04-G05 para 2.1–2.2). At least 2 directors, 2 relevant professionals and 2 representatives resident in Singapore (check Table A1-1). Independent custody and independent valuation required. No AUM cap.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmPrivate Credit FundReal Estate Investment VehicleWealth Management FirmMulti-Family OfficeQuantitative Trading DeskDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
08Venture capital fund managerCMS license: Fund management (Venture Capital Fund Manager, VCFM regime)No fixed figureMinimum capital
- Permits
- Fund management limited to venture capital funds that invest in unlisted start-ups and are offered only to accredited and institutional investors.
- Minimum capital
- No minimum base capital: VCFMs are exempt from Part III of the SF(FMR)R (SFA04-G05 para 5.2).
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, venture capital fund manager (VCFM)SGD 4,000 per yearRepresentative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Professional only
- Conditions
- Funds must meet VC fund eligibility conditions (para 5.1). At least 2 directors (one full-time and resident in Singapore) and at least 2 full-time professionals or representatives resident in Singapore.
- Systems
- Venture Capital Firm
- Reading
- Read in the rulebook
- Sources
09REIT managerCMS license: Real estate investment trust managementUSD 780 kMinimum capital
- Permits
- Managing a REIT whose units are listed or to be listed on an approved exchange.
- Minimum capital
- Base capital S$1 million; financial resources above the total risk requirement (MAS CMS license page). (≈USD 780 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, advising on corporate finance or REIT managementSGD 4,000 per year (each activity)Representative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- REITs must comply with the Code on Collective Investment Schemes, Appendix 6 (Property Funds), including gearing limits. Unlisted real estate funds are run under a fund management license instead.
- Systems
- Real Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
10CustodianCMS license: Providing custodial servicesUSD 780 kMinimum capital
- Permits
- Providing custodial services for capital markets products (securities, CIS units, derivatives and tokenized capital markets products) for customers.
- Minimum capital
- Base capital S$1 million (SFA04-G01 Annex 1, Table E). (≈USD 780 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, product financing or custodial servicesSGD 2,000 per year (each activity)Representative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- Customer asset segregation and custody rules under the SFA and Securities and Futures (Licensing and Conduct of Business) Regulations. Custody of digital payment tokens is licensed under the PSA instead.
- Systems
- Custody & Wallet InfrastructurePrime Brokerage
- Reading
- Read in the rulebook
- Sources
11Margin / product financierCMS license: Product financingUSD 780 kMinimum capital
- Permits
- Lending to customers to finance purchases of capital markets products (margin financing).
- Minimum capital
- Base capital S$1 million (SFA04-G01 Annex 1, Table E). (≈USD 780 k)
- Fees
- CMS license application fee (Form 1)SGD 1,000Annual license fee, product financing or custodial servicesSGD 2,000 per year (each activity)Representative lodgement and annual representative fee (CMS)SGD 200 per new lodgement; annual SGD 700 or SGD 200 per representative
- Clients
- Retail permitted
- Conditions
- Margin requirements for product financing under the SF(FMR)R (revised margin rules recently brought into force). Banks are exempt from this license.
- Systems
- Prime Brokerage
- Reading
- Read in the rulebook
- Sources
12Variable Capital CompanyVariable Capital Company (VCC Act 2018) – fund vehicle, not a licenseNo fixed figureMinimum capital
- Permits
- A corporate fund structure, standalone or umbrella with segregated sub-funds, registered with ACRA and supervised by MAS for AML/CFT.
- Minimum capital
- No minimum capital set for the VCC itself. Capital requirements fall on its manager, which must be a permissible fund manager (an LFMC or an exempt financial institution such as a bank).
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- At least one director resident in Singapore and at least one director who is a director of the fund manager or a qualified representative; three directors (one independent) if the VCC runs MAS-authorized retail schemes. Independent custodian required. AML/CFT under MAS Notice VCC-N01. Retail offering only if the sub-fund is an authorized scheme.
- Systems
- Fund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundSingle-Family Office
- Reading
- From a secondary source
- Sources
13Single family officeSingle family office – class exemption from CMS licensing; tax incentives under sections 13O, 13OA and 13U of the Income Tax ActNo fixed figureMinimum capital
- Permits
- Managing assets of one family, typically through a fund vehicle, without a fund management license. Tax-exempt fund status is granted by MAS under 13O/13OA or 13U.
- Minimum capital
- No base capital (not licensed). Tax incentive minimum fund size: S$20 million AUM in designated investments for 13O/13OA; S$50 million for 13U (MAS family office scheme page).
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- 13O/13OA: 2 investment professionals (one non-family); 13U: 3 investment professionals (one non-family), each earning over S$3,500 a month and resident in Singapore. Local business spending S$200,000 (AUM < S$250m), S$500,000 (S$250m–S$2bn) or S$1 million (≥ S$2bn). Capital deployment of the lower of 10% of AUM or S$10 million in qualifying Singapore investments. Managing third-party or unrelated money requires a license.
- Systems
- Single-Family Office
- Reading
- Read in the rulebook
- Sources
14Approved exchangeApproved Exchange (AE) under Part 2 of the SFAUSD 7.8 mMinimum capital
- Permits
- Operating an organized market of systemic importance, including listings and exchange-traded derivatives (e.g. SGX).
- Minimum capital
- Minimum base capital S$10,000,000 (MAS AE/RMO license page). (≈USD 7.8 m)
- Fees
- Approved exchange or recognized market operator application feeSGD 4,000
- Clients
- Retail permitted
- Conditions
- Corporation only. Admission criteria cover market structure, track record, financial soundness, risk management, business plans and governance. Approval is granted rarely.
- Systems
- ECN & DMA Venue
- Reading
- Read in the rulebook
- Sources
15Recognised market operatorRecognised Market Operator (RMO) under Part 2 of the SFAUSD 195 kMinimum capital
- Permits
- Operating an organized market such as a multilateral trading venue, an institutional matching platform or a security-token exchange. Local and foreign RMOs are possible.
- Minimum capital
- A Singapore-incorporated ("specified") RMO must hold eligible capital of at least the higher of S$250,000 or 25% of annual operating expenses, and liquid assets of at least 25% of annual operating expenses (MAS Notice SFA 02-N04, in force 28 March 2022, as summarized by Allen & Gledhill). Foreign RMOs rely on home-country requirements. (≈USD 195 k)
- Fees
- Approved exchange or recognized market operator application feeSGD 4,000
- Clients
- Retail, with conditions
- Conditions
- Corporation only; Form 1A (Singapore-incorporated) or Form 1B (foreign RMO). Processing about 9 months. Many tokenization and digital securities platforms in Singapore operate as RMOs together with CMS licenses. This session did not read the Notice itself or confirm whether every Singapore-incorporated RMO is a "specified RMO".
- Systems
- ECN & DMA VenueTokenization PlatformDigital Asset Exchange
- Reading
- From a secondary source
- Sources
16Money changerPayment Services Act: Money-changing licenseNo fixed figureMinimum capital
- Permits
- Buying or selling physical foreign currency notes (money-changing service).
- Minimum capital
- No base capital requirement stated (MAS licensing page).
- Fees
- PSA license application fee, money-changingSGD 500PSA annual license fee, money-changingSGD 1,500 per year
- Clients
- Retail permitted
- Conditions
- Strict ownership tests: Singapore Citizen sole proprietor, majority Singaporean partnership, or a company more than 50% owned and controlled by Singapore Citizens. Foreign-owned money changers must belong to large, well-supervised groups. Remittance requires an SPI or MPI license.
- Systems
- Money Services Business
- Reading
- Read in the rulebook
- Sources
17Standard payment institutionPayment Services Act: Standard Payment Institution (SPI) licenseUSD 78 kMinimum capital
- Permits
- Any of the PSA payment services (account issuance, domestic money transfer, cross-border money transfer, merchant acquisition, e-money issuance, digital payment token service, money-changing) below the size thresholds.
- Minimum capital
- Base capital S$100,000 plus a capital buffer (MAS SPI page). No security deposit. (≈USD 78 k)
- Fees
- PSA license application fee, standard payment institutionSGD 1,000 (higher of SGD 1,000 or sum of per-service fees)PSA annual license fee, standard payment institutionSGD 5,000 per year (higher of SGD 5,000 or sum of per-service fees)
- Clients
- Retail permitted
- Conditions
- Must stay below S$3 million monthly transactions for any one service, S$6 million for two or more services, and S$5 million daily outstanding e-money; above that an MPI license is required. Singapore company or branch; one executive director who is a Singapore Citizen or PR (or an EP holder plus a Citizen/PR director). DPT services carry additional AML/CFT, consumer-protection and technology-risk requirements.
- Systems
- Payment Service ProviderElectronic Money InstitutionMoney Services BusinessMerchant AcquiringCard Issuing ProgramOTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
18Major payment institutionPayment Services Act: Major Payment Institution (MPI) licenseUSD 195 kMinimum capital
- Permits
- All PSA payment services without the SPI thresholds, including digital payment token services (dealing, exchange, custody and transfer of DPTs).
- Minimum capital
- Base capital S$250,000 plus a capital buffer; security deposit with MAS of S$100,000 where average monthly transactions do not exceed S$6 million for any service, otherwise S$200,000 (MAS MPI page). (≈USD 195 k)
- Fees
- PSA license application fee, major payment institutionSGD 1,500 (higher of SGD 1,500 or sum of per-service fees)PSA annual license fee, major payment institutionSGD 10,000 per year (higher of SGD 10,000 or sum of per-service fees)MPI security (cash deposit with MAS or bank guarantee)SGD 100,000 or SGD 200,000
- Clients
- Retail permitted
- Conditions
- Safeguarding of customer money for e-money and transfer services. DPT providers must segregate customer tokens and hold them on trust, with retail-access restrictions (no incentives, risk-awareness assessment, no retail lending or staking with retail funds). Non-bank issuers of MAS-regulated single-currency stablecoins with more than S$5 million in circulation fall under the MPI route (see notes).
- Systems
- Payment Service ProviderElectronic Money InstitutionMoney Services BusinessMerchant AcquiringCard Issuing ProgramDigital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
19DTSP (overseas-only digital token services)Digital Token Service Provider (DTSP) license under Part 9 of the Financial Services and Markets Act 2022USD 195 kMinimum capital
- Permits
- Digital token services provided from Singapore solely to customers outside Singapore, by Singapore-incorporated entities or persons with a place of business in Singapore.
- Minimum capital
- Base capital S$250,000 (reported by Bird & Bird; annual fee S$10,000). Not confirmed in the regulations this session. (≈USD 195 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- In force 30 June 2025 with no transition. MAS has said it will grant DTSP licenses only in extremely limited circumstances. Firms already licensed under the PSA or SFA for the same activities generally rely on those licenses.
- Systems
- Digital Asset ExchangeOTC Digital Asset Desk
- Reading
- From a secondary source
- Sources
20Full bankBanking Act: Full bank license (including qualifying full bank)USD 156 mMinimum capital
- Permits
- Full range of banking business, including retail deposits in Singapore dollars, lending, payments, treasury and private banking.
- Minimum capital
- Banking Act 1970 s 9: paid-up capital of at least S$1,500 million for a bank incorporated in Singapore; head office capital funds of at least the equivalent of S$200 million for a foreign bank branch. (≈USD 156 m)
- Fees
- Bank license application feeSGD 20,000Annual license fee, full bankSGD 125,000 per year for the head or main office
- Clients
- Retail permitted
- Conditions
- Granted only rarely to foreign banks (QFB privileges are by invitation). Capital adequacy under MAS Notice 637, liquidity rules, deposit insurance membership for retail deposits.
- Systems
- Private BankCorrespondent Banking StructureTrade Finance HouseTreasury & Liquidity DeskCard Issuing ProgramMerchant AcquiringInvestment Bank
- Reading
- From a secondary source
- Sources
21Wholesale bankBanking Act: Wholesale bank licenseUSD 78 mMinimum capital
- Permits
- Banking business other than Singapore-dollar retail banking; most foreign private banks and investment banks in Singapore operate under it.
- Minimum capital
- S$100 million minimum paid-up capital for a Singapore-incorporated wholesale bank (WongPartnership 2023). Foreign bank branches: head office capital funds at least the equivalent of S$200 million (Banking Act s 9(1)(b)). (≈USD 78 m)
- Fees
- Bank license application feeSGD 20,000Annual license fee, wholesale bankSGD 100,000 per year for the head or main office
- Clients
- Retail, with conditions
- Conditions
- Restrictions on Singapore-dollar retail deposits (e.g. fixed deposits from individuals subject to minimum amounts). Branches are subject to home-regulator consolidated supervision.
- Systems
- Private BankInvestment BankCorrespondent Banking StructureTrade Finance HouseTreasury & Liquidity DeskPrime BrokerageStructured Products Issuer
- Reading
- From a secondary source
- Sources
22Digital full bankBanking Act: Digital full bank (DFB) licenseUSD 11.7 mMinimum capital
- Permits
- Retail and corporate banking through digital channels, starting in a restricted phase.
- Minimum capital
- Restricted DFB may start with S$15 million paid-up capital and must progressively reach S$1.5 billion when fully functioning (MAS digital bank eligibility criteria). (≈USD 11.7 m)
- Fees
- Bank license application feeSGD 20,000Annual license fee, full bankSGD 125,000 per year for the head or main office
- Clients
- Retail permitted
- Conditions
- Restricted phase: aggregate deposit cap S$50 million and S$75,000 per individual. Must be anchored in Singapore, controlled by Singaporeans and headquartered in Singapore. Licences issued in 2020 windows; MAS does not run open-ended application rounds.
- Systems
- Digital Bank
- Reading
- Read in the rulebook
- Sources
23Digital wholesale bankBanking Act: Digital wholesale bank (DWB) licenseUSD 78 mMinimum capital
- Permits
- Digital banking for SMEs and non-retail segments.
- Minimum capital
- Minimum paid-up capital S$100 million (MAS digital bank eligibility criteria). (≈USD 78 m)
- Fees
- Bank license application feeSGD 20,000Annual license fee, wholesale bankSGD 100,000 per year for the head or main office
- Clients
- Retail, with conditions
- Conditions
- May offer Singapore-dollar current accounts for business use; may not grant unsecured credit to retail individuals. Retail deposit-taking restricted per the wholesale bank guidelines.
- Systems
- Digital BankTrade Finance House
- Reading
- Read in the rulebook
- Sources
24Merchant bankBanking Act: Merchant bank licenseUSD 11.7 mMinimum capital
- Permits
- Corporate finance, underwriting, treasury and wholesale lending; no retail deposits.
- Minimum capital
- Minimum paid-up capital S$15 million for a Singapore-incorporated merchant bank (WongPartnership 2023). (≈USD 11.7 m)
- Fees
- Bank license application feeSGD 20,000Annual license fee, merchant bankSGD 35,000 per year
- Clients
- Professional only
- Conditions
- Also needs SFA licenses or exemptions for capital markets activities. No Singapore-dollar retail deposit-taking.
- Systems
- Investment BankStructured Products IssuerTreasury & Liquidity Desk
- Reading
- From a secondary source
- Sources
25Licensed financial adviserFinancial Advisers Act: Financial adviser's licenseUSD 195 kMinimum capital
- Permits
- Advising others on investment products, issuing research and arranging life insurance.
- Minimum capital
- Base capital: S$250,000 for research-only advisers; S$500,000 for other financial advisory activities, or S$300,000 if the firm also holds an additional S$500,000 of professional indemnity insurance. Financial resources: at least the higher of 1/4 of relevant annual expenditure for the preceding financial year or S$150,000. PII limits: S$500,000 (research only); S$1 million where revenue is up to S$5 million; otherwise the lower of 20% of gross revenue or S$10 million (MAS financial adviser's license page, under the FAA). (≈USD 195 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Needed for investment advisory businesses that do not manage portfolios on a discretionary basis. Fund managers and banks are exempt for advice incidental to their licensed business. The S$150,000 figure often cited as base capital is the financial resources floor.
- Systems
- Investment Advisory FirmWealth Management Firm
- Reading
- Read in the rulebook
- Sources
26Direct insurer / reinsurerInsurance Act 1966: Licensed direct insurer or reinsurerUSD 3.9 mMinimum capital
- Permits
- Writing life, general or composite direct insurance, or reinsurance (including special purpose reinsurance vehicles).
- Minimum capital
- Minimum paid-up ordinary share capital: S$5 million for a direct insurer limited to a prescribed restricted line of business; S$10 million for other direct insurers; S$25 million for a reinsurer (Legal 500 Singapore insurance guide, WongPartnership). Insurance Act s 11(3)(b) and (9) require licensed insurers to meet prescribed financial requirements, and the RBC 2 total risk requirement applies under the Insurance (Valuation and Capital) Regulations 2004 (as amended in force 31 March 2020). (≈USD 3.9 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Risk-based capital framework RBC 2 with two supervisory intervention levels. Authorized reinsurers and Lloyd's Asia scheme are alternative routes. The paid-up capital amounts come from a law firm guide; this session did not read the regulation that prescribes them.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- From a secondary source
- Sources
27Captive insurerInsurance Act 1966: Captive insurer licenseNo fixed figureMinimum capital
- Permits
- Insuring principally the risks of related companies.
- Minimum capital
- Not confirmed. Insurance Act s 11 leaves the amount to prescribed financial requirements, and neither MAS's captive license page nor its captive compliance toolkit states a figure. Secondary sources conflict: S$400,000 (Captive International, 2019) and S$1 million (Willis fact sheet, 1996, outdated).
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Business must consist principally of the risks of related companies. MAS processing up to 3 months after a complete application. Captives are exempted from some provisions by the Insurance (General Provisions and Exemptions for Captive Insurers) Regulations 2018.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- To be confirmed
- Sources
Reach
No license passport. Cross-border fund distribution is possible through the ASEAN CIS Framework (Singapore, Malaysia, Thailand) and bilateral mutual recognition of funds; a Singapore license does not by itself permit dealing with clients in other countries.
Passage
CMS license: MAS service standard of up to 6 months for complete applications from applicants that meet all admission criteria, then up to 6 months (extendable by 3) after in-principle approval to meet licensing conditions (MAS CMS license page). RMO: about 9 months (MAS AE/RMO page). Captive insurer: up to 3 months after a complete application (MAS captive insurer page). PSA licenses and bank licenses: no published service standard; market practice is 6–12+ months for PSA (longer for digital payment tokens) and much longer for banks.
Licensed elsewhere
Physical commodity trading houses need no MAS license (Enterprise Singapore runs the Global Trader Programme incentive). Mining and validation are not licensed activities. Sovereign vehicles (GIC, Temasek) are statutory or exempt entities. Islamic finance has no separate MAS license; Islamic products are offered under the ordinary bank, CMS and insurance licenses. White-label brokerage under another firm's license has no dedicated pathway: brands must be licensed themselves or act as representatives or introducing brokers of the licensee. Proprietary trading on own capital with no clients generally needs no license. Pension schemes are mainly the CPF Board (statutory). Company and VCC registration is with ACRA.
Notes. 2024: PSA amendments widened digital payment token services to include custody and transfer of DPTs, with new consumer-protection rules. 30 June 2025: FSMA Part 9 DTSP regime took effect with no transition; MAS has said licenses will be granted in extremely limited circumstances. Stablecoins: MAS finalized its single-currency stablecoin framework in August 2023 (base capital the higher of S$1 million or 50% of annual operating expenses; reserves; par redemption within 5 business days), to be implemented by amending the PSA. The framework is not yet in force: on 1 September 2026 MAS published a consultation on the Payment Services Act amendments to implement it (capital, redemption at par, disclosure, a ban on interest, stress testing, recovery and wind-down plans, recognition of some foreign-issued stablecoins), with comments due by 16 October 2026 and no commencement date announced. Fund managers: the RFMC regime (max 30 qualified investors, S$250 million AUM) is closed to new applicants per Withers; the A/I LFMC is now the entry route. SF(FMR)R product-financing margin changes took effect recently (Allen & Gledhill). The guideline used for base capital, SFA04-G01, was last revised 21 January 2025. FX conversions use SGD 1 = USD 0.78.
Asia-Pacific · Hong Kong
SFC
Securities and Futures Commission
The SFC licenses corporations carrying on regulated activities under the Securities and Futures Ordinance (Cap. 571) and virtual asset trading platforms under the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615). Capital is set per regulated activity by the Securities and Futures (Financial Resources) Rules (FRR) as minimum paid-up share capital plus minimum liquid capital; where several types are held, the highest applies. Banks are licensed by the HKMA and become SFC 'registered institutions' for securities business.
#3of 34
Balanced score
80 of 100
80 of 100
Scorecard
Credibility ×35%100Breadth ×15%60Entry threshold ×20%80Speed ×15%87Reach ×15%50
Categories17
Systems covered28 of 47
Typical timeline4–6 monthsservice standard
Lowest capitalUSD 13 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 609–17 k3 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 609–17 k2 items · Recurring fees and levies
OtherUSD 3791 item · Mandatory charges that arise in operation
SFC fees are per regulated activity and per individual, so they scale with each RA and each RO and representative; Type 3 (leveraged FX) costs about 27 times more than other RAs. Annual licensing fees are being charged again from April 2025.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)Securities and Futures (Fees) Rules, Schedule 3. Charltons lists Types 1, 2 and 4 to 10; the same per-RA fee is assumed for Types 12 and 13. | HKD 4,740 per regulated activity≈ USD 609 | Type 1 – Dealing in securities (general case); Type 1 – Dealing in securities (approved introducing agent or trader); Type 2 – Dealing in futures contracts (general case); Type 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer) and 10 more | From a secondary source |
| Licensed corporation application fee, Type 3 (leveraged FX)Source does not separate approved introducing agents; the general Type 3 fee is applied to both. | HKD 129,730≈ USD 17 k | Type 3 – Leveraged foreign exchange trading (general case); Type 3 – Leveraged foreign exchange trading (approved introducing agent) | From a secondary source |
| VATP (AMLO licensed VASP) application feesVATPs normally also hold SFO Types 1 and 7, which carry their own application and annual fees. AMLO annual fee not confirmed this session. | HKD 4,740 (license); HKD 2,950 per responsible officer; HKD 1,790 per licensed representative≈ USD 609 | Virtual Asset Trading Platform (VATP) license (AMLO Part 5B), usually held with Types 1 and 7 under the SFO | Read in the rulebook |
| Every year | |||
| Annual licensing fee, licensed corporation, per regulated activitySecurities and Futures (Fees) Rules Sch. 3 item 18; due within one month after each license anniversary, surcharge for late payment. Collection resumed 1 April 2025 after a long waiver. Type 7 fee waived where incidental to Type 1 or 2. | HKD 4,740 per regulated activity per year≈ USD 609 | Type 1 – Dealing in securities (general case); Type 1 – Dealing in securities (approved introducing agent or trader); Type 2 – Dealing in futures contracts (general case); Type 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer) and 10 more | From a secondary source |
| Annual licensing fee, licensed corporation, Type 3Collection resumed 1 April 2025. | HKD 129,730 per year≈ USD 17 k | Type 3 – Leveraged foreign exchange trading (general case); Type 3 – Leveraged foreign exchange trading (approved introducing agent) | From a secondary source |
| Other | |||
| Responsible officer approval and annual feesEach RA needs at least two responsible officers. Licensed representatives: application HKD 1,790 per RA (Type 3 HKD 2,420), annual HKD 1,790 per RA (Type 3 HKD 2,420). | Application HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)≈ USD 379 | Type 1 – Dealing in securities (general case); Type 1 – Dealing in securities (approved introducing agent or trader); Type 2 – Dealing in futures contracts (general case); Type 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer) and 12 more | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 643 k
Securities adviserType 4 – Advising on securities (no client assets)
USD 13 k
Futures adviserType 5 – Advising on futures contracts
USD 13 k
Corporate finance adviser / sponsorType 6 – Advising on corporate finance
USD 13 k
Asset manager (non-custodial)Type 9 – Asset management (no client assets)
USD 13 k
Credit rating agencyType 10 – Providing credit rating services
USD 13 k
Securities introducing agent / traderType 1 – Dealing in securities (approved introducing agent or trader)
USD 64 k
Futures introducing agent / non-clearing dealerType 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer)
USD 64 k
Securities dealerType 1 – Dealing in securities (general case)
USD 642 k
Futures dealerType 2 – Dealing in futures contracts (general case)
USD 642 k
Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent)
USD 642 k
Automated trading venueType 7 – Providing automated trading services
USD 642 k
Asset manager (holding client assets)Type 9 – Asset management (holds client assets)
USD 642 k
Virtual asset trading platformVirtual Asset Trading Platform (VATP) license (AMLO Part 5B), usually held with Types 1 and 7 under the SFO
USD 642 k
Securities margin financierType 8 – Securities margin financing
USD 1.28 m
Depositary of SFC-authorized fundsType 13 – Providing depositary services for relevant collective investment schemes
USD 1.28 m
Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case)
USD 3.85 m
10k100k1m10m
16 of 17 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
17 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Securities dealerType 1 – Dealing in securities (general case)USD 642 kMinimum capital
- Permits
- Buying and selling securities, or offering to, for clients; includes stock broking, securities placement and dealing in fund units and security tokens.
- Minimum capital
- FRR: minimum paid-up share capital HK$5,000,000 and minimum liquid capital HK$3,000,000. If it provides securities margin financing or acts as custodian of a private OFC: HK$10,000,000 paid-up and HK$3,000,000 liquid (SFC licensing page summary of the FRR). A firm licensed for several types must meet the highest requirement among them. (≈USD 642 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- At least two responsible officers (one executive director) approved by the SFC, with at least one always available in Hong Kong. Client securities and client money rules. Investor Compensation Fund coverage for exchange-traded products.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrivate BrokeragePrime BrokerageWhite-Label BrokerageStructured Products IssuerTokenization Platform
- Reading
- Read in the rulebook
- Sources
02Securities introducing agent / traderType 1 – Dealing in securities (approved introducing agent or trader)USD 64 kMinimum capital
- Permits
- Type 1 business that only introduces clients to another licensed corporation, or deals as an exchange trader without holding client assets.
- Minimum capital
- FRR: no paid-up capital requirement; minimum liquid capital HK$500,000 (SFC licensing page summary of the FRR). (≈USD 64 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- May not hold client assets. Typical route for introducing brokers and white-label style arrangements with an executing broker.
- Systems
- White-Label BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
03Futures dealerType 2 – Dealing in futures contracts (general case)USD 642 kMinimum capital
- Permits
- Dealing in exchange-traded futures and options contracts for clients.
- Minimum capital
- FRR: minimum paid-up share capital HK$5,000,000 and minimum liquid capital HK$3,000,000 (SFC licensing page summary of the FRR). (≈USD 642 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- Two responsible officers; client money segregation; exchange participantship for direct market access.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrime Brokerage
- Reading
- Read in the rulebook
- Sources
04Futures introducing agent / non-clearing dealerType 2 – Dealing in futures contracts (approved introducing agent, trader or futures non-clearing dealer)USD 64 kMinimum capital
- Permits
- Futures business as introducing agent, exchange trader or non-clearing dealer.
- Minimum capital
- FRR: no paid-up capital requirement; minimum liquid capital HK$500,000 (SFC licensing page summary of the FRR). (≈USD 64 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- No holding of client assets for the introducing agent and trader cases.
- Systems
- Institutional BrokerageWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
05Leveraged FX dealerType 3 – Leveraged foreign exchange trading (general case)USD 3.85 mMinimum capital
- Permits
- Entering into or offering leveraged foreign exchange contracts with clients.
- Minimum capital
- FRR: minimum paid-up share capital HK$30,000,000 and minimum liquid capital HK$15,000,000 (SFC licensing page summary of the FRR). (≈USD 3.85 m)
- Fees
- Licensed corporation application fee, Type 3 (leveraged FX)HKD 129,730Annual licensing fee, licensed corporation, Type 3HKD 129,730 per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- Highest capital of any SFC type. Leveraged FX margin and conduct rules under the Securities and Futures (Leveraged Foreign Exchange Trading) rules. Very few new Type 3 licenses are granted. CFDs on securities are dealt with under Type 1.
- Systems
- Retail BrokeragePrivate BrokeragePrime-of-Prime
- Reading
- Read in the rulebook
- Sources
06Leveraged FX introducing agentType 3 – Leveraged foreign exchange trading (approved introducing agent)USD 642 kMinimum capital
- Permits
- Introducing clients to a Type 3 licensed corporation for leveraged FX.
- Minimum capital
- FRR: minimum paid-up share capital HK$5,000,000 and minimum liquid capital HK$3,000,000 (SFC licensing page summary of the FRR). (≈USD 642 k)
- Fees
- Licensed corporation application fee, Type 3 (leveraged FX)HKD 129,730Annual licensing fee, licensed corporation, Type 3HKD 129,730 per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- May not carry client positions on its own books.
- Systems
- White-Label Brokerage
- Reading
- Read in the rulebook
- Sources
07Securities adviserType 4 – Advising on securities (no client assets)USD 13 kMinimum capital
- Permits
- Giving advice or issuing research on securities, without holding client assets.
- Minimum capital
- FRR: with a licensing condition not to hold client assets, no paid-up capital requirement and minimum liquid capital HK$100,000; otherwise HK$5,000,000 paid-up and HK$3,000,000 liquid (SFC licensing page summary of the FRR). (≈USD 13 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- Two responsible officers. Suitability and research disclosure obligations.
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family Office
- Reading
- Read in the rulebook
- Sources
08Futures adviserType 5 – Advising on futures contractsUSD 13 kMinimum capital
- Permits
- Giving advice or issuing research on futures contracts.
- Minimum capital
- FRR: with a licensing condition not to hold client assets, no paid-up capital requirement and minimum liquid capital HK$100,000; otherwise HK$5,000,000 paid-up and HK$3,000,000 liquid (SFC licensing page summary of the FRR). (≈USD 13 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- Usually held alongside Type 2 or Type 9.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
09Corporate finance adviser / sponsorType 6 – Advising on corporate financeUSD 13 kMinimum capital
- Permits
- Advising on listings, takeovers, the Listing Rules and capital raising; sponsor work for IPOs.
- Minimum capital
- FRR: sponsor holding client assets HK$10,000,000 paid-up / HK$3,000,000 liquid; sponsor not holding client assets HK$10,000,000 paid-up / HK$100,000 liquid; non-sponsor holding client assets HK$5,000,000 / HK$3,000,000; non-sponsor not holding client assets no paid-up requirement / HK$100,000 liquid (SFC licensing page summary of the FRR). (≈USD 13 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail, with conditions
- Conditions
- Sponsors need additional principal and staffing requirements under the Code of Conduct. Combined with Type 1 for underwriting.
- Systems
- Investment Bank
- Reading
- Read in the rulebook
- Sources
10Automated trading venueType 7 – Providing automated trading servicesUSD 642 kMinimum capital
- Permits
- Operating an electronic system for trading securities or futures, such as an alternative trading system or dark pool, or a platform for security tokens.
- Minimum capital
- FRR: minimum paid-up share capital HK$5,000,000 and minimum liquid capital HK$3,000,000 (SFC licensing page summary of the FRR). (≈USD 642 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail, with conditions
- Conditions
- Licensed corporations operating ATS venues are subject to SFC ATS guidelines. Overseas exchanges offering access in Hong Kong are instead authorized under Part III of the SFO. VATPs offering security tokens also need Types 1 and 7.
- Systems
- ECN & DMA VenueTokenization PlatformDigital Asset Exchange
- Reading
- Read in the rulebook
- Sources
11Securities margin financierType 8 – Securities margin financingUSD 1.28 mMinimum capital
- Permits
- Providing financial accommodation to facilitate acquisition or holding of securities.
- Minimum capital
- FRR: minimum paid-up share capital HK$10,000,000 and minimum liquid capital HK$3,000,000 (SFC licensing page summary of the FRR). (≈USD 1.28 m)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- SFC guidelines on margin lending (concentration, haircut and stress-testing controls).
- Systems
- Prime BrokerageMulti-Asset Brokerage
- Reading
- Read in the rulebook
- Sources
12Asset manager (non-custodial)Type 9 – Asset management (no client assets)USD 13 kMinimum capital
- Permits
- Real estate investment scheme management or securities/futures portfolio management for others, where the manager does not hold client assets.
- Minimum capital
- FRR: with a licensing condition not to hold client assets, no paid-up capital requirement and minimum liquid capital HK$100,000 (SFC licensing page summary of the FRR). (≈USD 13 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail, with conditions
- Conditions
- Two responsible officers. Fund Manager Code of Conduct. Retail funds must be SFC-authorized. Managers of portfolios investing in virtual assets are subject to SFC standard terms and conditions. Hong Kong OFC and LPF fund vehicles require a Type 9 manager.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundWealth Management FirmMulti-Family OfficeQuantitative Trading DeskDigital Asset FundReal Estate Investment VehiclePension & Endowment Manager
- Reading
- Read in the rulebook
- Sources
13Asset manager (holding client assets)Type 9 – Asset management (holds client assets)USD 642 kMinimum capital
- Permits
- Type 9 business where the manager holds client money or assets.
- Minimum capital
- FRR: minimum paid-up share capital HK$5,000,000 and minimum liquid capital HK$3,000,000 (SFC licensing page summary of the FRR). (≈USD 642 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- Rare in practice: most managers use third-party custodians to stay in the lower capital tier. Managers of SFC-authorized retail funds and ETFs often fall here.
- Systems
- Mutual Fund & UCITSETF PlatformAsset Management CompanyFund Management Company
- Reading
- Read in the rulebook
- Sources
14Credit rating agencyType 10 – Providing credit rating servicesUSD 13 kMinimum capital
- Permits
- Preparing credit ratings for dissemination.
- Minimum capital
- FRR: with a licensing condition not to hold client assets, no paid-up capital requirement and minimum liquid capital HK$100,000; otherwise HK$5,000,000 paid-up and HK$3,000,000 liquid (SFC licensing page summary of the FRR). (≈USD 13 k)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Professional only
- Conditions
- Code of Conduct for Persons Providing Credit Rating Services. Not mapped to any of the 47 systems.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
15OTC derivatives client clearerType 12 – Providing client clearing services for OTC derivative transactionsNo fixed figureMinimum capital
- Permits
- Providing client clearing services for OTC derivative transactions.
- Minimum capital
- Not confirmed. This session could not confirm that Type 12 has commenced or that its FRR requirements have been finalized.
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Professional only
- Conditions
- Part of the Hong Kong OTC derivatives regime. Type 11 and Type 12 commencement depends on FRR amendments; check status with the SFC before relying on this route.
- Systems
- Prime Brokerage
- Reading
- To be confirmed
- Sources
16Depositary of SFC-authorized fundsType 13 – Providing depositary services for relevant collective investment schemesUSD 1.28 mMinimum capital
- Permits
- Acting as trustee or custodian (top-level depositary) of SFC-authorized collective investment schemes, including unit trusts, OFCs and REITs.
- Minimum capital
- FRR: minimum paid-up share capital HK$10,000,000 and minimum liquid capital HK$3,000,000 (SFC licensing page summary of the FRR). (≈USD 1.28 m)
- Fees
- Licensed corporation application fee, per regulated activity (Types 1, 2, 4 to 10, 12, 13)HKD 4,740 per regulated activityAnnual licensing fee, licensed corporation, per regulated activityHKD 4,740 per regulated activity per yearResponsible officer approval and annual feesApplication HKD 2,950 per RA; annual HKD 4,740 per RA (Type 3: HKD 5,370)
- Clients
- Retail permitted
- Conditions
- In force since 2 October 2024. Sub-custodians and pure MPF trustees are outside the regime. Banks register with the SFC instead of being licensed.
- Systems
- Custody & Wallet InfrastructureMutual Fund & UCITSETF Platform
- Reading
- Read in the rulebook
- Sources
17Virtual asset trading platformVirtual Asset Trading Platform (VATP) license (AMLO Part 5B), usually held with Types 1 and 7 under the SFOUSD 642 kMinimum capital
- Permits
- Operating a centralized virtual asset exchange in Hong Kong, including for retail investors. The licensed operator's associated entity holds client virtual assets.
- Minimum capital
- Minimum paid-up share capital HK$5,000,000 at all times; liquid capital above the required liquid capital under the applicable financial resources rules; and liquid assets held in Hong Kong (excluding virtual assets) of at least 12 months of actual operating expenses on a rolling basis (SFC VATP Guidelines, as summarized by Tanner De Witt and Forvis Mazars). For the Type 1 and Type 7 licenses usually held alongside, the SFC sets minimum liquid capital of HK$3,000,000. (≈USD 642 k)
- Fees
- VATP (AMLO licensed VASP) application feesHKD 4,740 (license); HKD 2,950 per responsible officer; HKD 1,790 per licensed representative
- Clients
- Retail permitted
- Conditions
- 98% of client virtual assets in cold storage. SFC-approved compensation arrangement covering 50% of cold-storage assets and 100% of hot-storage assets. Token admission rules and retail suitability tests. New platforms may not operate or market to Hong Kong investors until licensed.
- Systems
- Digital Asset ExchangeCustody & Wallet InfrastructureTokenization Platform
- Reading
- From a secondary source
- Sources
Reach
No passport. Fund distribution through Mutual Recognition of Funds arrangements (Mainland China and several other jurisdictions) and Stock/Bond Connect; otherwise foreign firms need their own license to actively market to Hong Kong investors.
Passage
SFC performance pledge of 15 weeks for a corporate license application (8 weeks for representatives, 10 weeks for responsible officers), counted from a complete application (Charltons). VATP applications have taken considerably longer in practice.
Licensed elsewhere
Banks: the HKMA authorizes licensed banks, restricted license banks, deposit-taking companies and virtual banks, and supervises banks' SFC-registered securities business. Stored value facilities (e-money, wallets): HKMA SVF license. Fiat-referenced stablecoin issuers: HKMA license under the Stablecoins Ordinance (in force 1 August 2025; minimum paid-up capital HK$25 million unless the issuer is an authorized institution). Money service operators (remittance and money-changing): Customs and Excise Department. Insurance: Insurance Authority. Pension (MPF): MPFA. Payment systems: HKMA. Card issuing and merchant acquiring: banks or SVF licensees (HKMA). Commodity trading houses and mining need no SFC license. No dedicated Islamic finance license; sukuk are issued under ordinary rules with tax-neutral treatment.
Notes. Type 13 commenced 2 October 2024. HKMA stablecoin issuer regime commenced 1 August 2025; HKMA indicated the first licenses would be granted in early 2026. VA dealing (OTC) and VA custodian licensing regimes: FSTB/SFC consultation conclusions in December 2025; a bill amending the AMLO was planned for the Legislative Council in 2026, with a hard commencement date and no deeming arrangement. A further consultation on VA advisory and VA management services (aligned to Types 4 and 9) closed in January 2026. This session did not confirm the bill's status as of October 2026. Single family offices managing only family assets generally fall outside Type 9; a profits tax concession for eligible family-owned investment holding vehicles exists (FIHV regime). FX conversions use HKD 1 = USD 0.1285; capital_min_usd uses paid-up capital where it applies, otherwise liquid capital.
Asia-Pacific · Australia
ASIC
Australian Securities and Investments Commission
ASIC is Australia's conduct and markets regulator. It grants Australian financial services licenses (AFSL) under Chapter 7 of the Corporations Act 2001 with specific authorizations by product and service, and supervises licensed markets and clearing facilities. Australia runs a twin-peaks model: APRA prudentially licenses banks (ADIs), insurers and superannuation trustees, while AUSTRAC registers remitters and virtual asset service providers for AML/CTF. Financial requirements are set in RG 166 and ASIC legislative instruments.
#6of 34
Balanced score
79 of 100
79 of 100
Scorecard
Credibility ×35%100Breadth ×15%68Entry threshold ×20%64Speed ×15%77Reach ×15%65
Categories10
Systems covered32 of 47
Typical timeline5–8 monthsservice standard
Lowest capitalUSD 105 k
IOSCO MMoUA
Passportregional
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 1 k–2 k2 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 836–83 k8 items · Recurring fees and levies
OtherUSD 2 k1 item · Mandatory charges that arise in operation
Application fees are small; the material recurring cost is the ASIC industry funding levy, invoiced after each financial year and set by subsector metrics (retail CFD issuers about AUD 128,000 each for 2025-26). Retail licensees also pay AFCA membership, and advice and securities dealing subsectors pay the CSLR levy.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| New AFS license application, body corporate, retail clients (online)Paper lodgement AUD 5,582 to 11,305. Fees for service effective 1 July 2024 and not indexed annually; check for any 2026 update. Retail OTC derivatives, responsible entity and DAP applications are likely high complexity. | AUD 3,721 (low complexity) to AUD 7,537 (high complexity)≈ USD 2 k | AFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients); AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator); AFSL – provide custodial or depository services (non-incidental); AFSL – personal advice and managed discretionary account (MDA) services and 2 more | Read in the rulebook |
| New AFS license application, body corporate, wholesale clients only (online)Paper lodgement AUD 3,349 to 7,537. Effective 1 July 2024, not indexed. | AUD 2,233 (low complexity) to AUD 5,025 (high complexity)≈ USD 1 k | AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities); AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | Read in the rulebook |
| Every year | |||
| ASIC industry funding levy, retail OTC derivatives issuersPro-rated by days authorized; no minimum or threshold. 2024-25 actual was AUD 166,679. Levies are invoiced after year end. | AUD 128,388 per issuer (2025-26 estimate)≈ USD 83 k | AFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients) | Read in the rulebook |
| ASIC industry funding levy, OTC traders (wholesale)2024-25 actual: AUD 1,000 plus AUD 5,351 per FTE. Securities dealers: minimum AUD 1,000 plus AUD 31.13 per AUD 1 million of turnover (2025-26 estimate). | Minimum AUD 1,000 plus AUD 4,150 per FTE in OTC trading (2025-26 estimate) | AFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities) | Read in the rulebook |
| ASIC industry funding levy, responsible entities | Minimum AUD 7,000 plus AUD 14.35 per AUD 1 million of assets above AUD 10 million (2024-25 actual) | AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator) | Read in the rulebook |
| ASIC industry funding levy, wholesale trustees | Minimum AUD 1,000 plus AUD 4.74 per AUD 1 million of adjusted total assets (2024-25 actual) | AFSL – wholesale fund manager / trustee of unregistered managed investment schemes | Read in the rulebook |
| ASIC industry funding levy, custodiansFlat levy. | AUD 1,286 (2024-25 actual)≈ USD 836 | AFSL – provide custodial or depository services (non-incidental) | Read in the rulebook |
| ASIC industry funding levy, personal advice to retail clients on relevant financial productsAdvice licensees also fall within the Compensation Scheme of Last Resort levy. | Minimum AUD 1,500 plus AUD 2,398 per adviser (2024-25 actual) | AFSL – personal advice and managed discretionary account (MDA) services | Read in the rulebook |
| ASIC industry funding levy, payment product providers | Minimum AUD 2,000 plus AUD 6.92 per AUD 10,000 of payment product revenue (2024-25 actual) | AFSL – issue and deal in non-cash payment facilities | Read in the rulebook |
| ASIC industry funding levy, market operatorsPer exchange, pro-rated by days operated. Self-listing-only small securities exchange AUD 19,669; large securities exchange operators AUD 1.91 per AUD 1 million of transactions. No digital asset market subsector in the 2025-26 CRIS. | Small securities exchange operator AUD 352,795; small futures exchange operator AUD 5,997 (2025-26 estimates)≈ USD 4 k | Australian market license (Corporations Act Part 7.2) | Read in the rulebook |
| Other | |||
| AFS license variation, body corporate (online)Paper AUD 3,704. Used when adding authorizations to an existing license. | AUD 2,470≈ USD 2 k | All categories | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 700 k
Responsible entity (retail fund operator)AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator)
USD 105 k
Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients)
USD 700 k
CustodianAFSL – provide custodial or depository services (non-incidental)
USD 7 m
100k1m10m
3 of 10 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
10 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Retail CFD/FX market makerAFSL – issuer of retail OTC derivatives (deal and make a market in derivatives and foreign exchange contracts for retail clients)USD 700 kMinimum capital
- Permits
- Issuing and making a market in OTC derivatives (CFDs, margin FX) to retail clients.
- Minimum capital
- NTA of the greater of AUD 1,000,000 or 10% of average revenue, with 50% held in cash or cash equivalents and 50% in liquid assets; quarterly 12-month cash flow projections (ASIC Corporations (Financial Requirements for Issuers of Retail OTC Derivatives) Instrument 2022/705; RG 166). (≈USD 700 k)
- Fees
- New AFS license application, body corporate, retail clients (online)AUD 3,721 (low complexity) to AUD 7,537 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, retail OTC derivatives issuersAUD 128,388 per issuer (2025-26 estimate)
- Clients
- Retail permitted
- Conditions
- ASIC product intervention order for retail CFDs: leverage limits (30:1 major FX pairs down to 2:1 crypto assets), margin close-out, negative balance protection, no inducements (check the order's current expiry). Design and distribution obligations (target market determinations). Client money rules (ASIC Client Money Reporting Rules 2017). Responsible managers with relevant experience.
- Systems
- Retail BrokerageMulti-Asset BrokeragePrivate Brokerage
- Reading
- Read in the rulebook
- Sources
02Wholesale-only AFSLAFSL – wholesale clients only (dealing, market making, advice in derivatives, FX and securities)No fixed figureMinimum capital
- Permits
- Financial services provided only to wholesale clients (s 761G Corporations Act), such as institutional dealing, market making and wholesale advice.
- Minimum capital
- No fixed capital minimum. RG 166 base level requirements: solvency and positive net assets, cash needs requirement and audit. If client money or property held exceeds AUD 100,000, at least AUD 50,000 in surplus liquid funds (RG 166.69).
- Fees
- New AFS license application, body corporate, wholesale clients only (online)AUD 2,233 (low complexity) to AUD 5,025 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, OTC traders (wholesale)Minimum AUD 1,000 plus AUD 4,150 per FTE in OTC trading (2025-26 estimate)
- Clients
- Professional only
- Conditions
- No retail client protections such as PDS or DDO, but conduct, AML/CTF (AUSTRAC) and breach reporting duties apply. Common route for institutional brokers, prime-of-prime and liquidity providers.
- Systems
- Institutional BrokeragePrivate BrokeragePrime-of-PrimeQuantitative Trading DeskInvestment BankStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
03Wholesale fund managerAFSL – wholesale fund manager / trustee of unregistered managed investment schemesNo fixed figureMinimum capital
- Permits
- Operating, dealing in and advising on interests in unregistered (wholesale) managed investment schemes and managing their portfolios.
- Minimum capital
- RG 166 base level requirements (solvency, positive net assets, cash needs, audit); AUD 50,000 surplus liquid funds if client money or property exceeds AUD 100,000. A trustee that holds scheme assets itself may also be a custodial provider subject to NTA (see custodial category).
- Fees
- New AFS license application, body corporate, wholesale clients only (online)AUD 2,233 (low complexity) to AUD 5,025 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, wholesale trusteesMinimum AUD 1,000 plus AUD 4.74 per AUD 1 million of adjusted total assets (2024-25 actual)
- Clients
- Professional only
- Conditions
- Wholesale investors only (s 761G). Most managers appoint an external custodian. The same financial requirements apply to AFSL holders running hedge funds, PE, VC, private credit and real estate funds for wholesale clients.
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleDigital Asset FundMulti-Family Office
- Reading
- From a secondary source
- Sources
04Responsible entity (retail fund operator)AFSL – responsible entity of a registered managed investment scheme (including corporate director of a retail CCIV and IDPS operator)USD 105 kMinimum capital
- Permits
- Operating registered managed investment schemes and retail CCIVs offered to retail investors, including listed and unlisted retail funds and ETFs.
- Minimum capital
- Concessional NTA (where an eligible custodian is used or assets qualify): greater of AUD 150,000, 0.5% of average value of scheme property (capped at AUD 5 million) or 10% of average RE revenue. Non-concessional: greater of AUD 10 million or 10% of average revenue. At least 50% of the NTA requirement in cash or cash equivalents (minimum AUD 150,000) and 100% in liquid assets (ASIC Instrument 2023/647; RG 166). From 1 July 2027 (Instrument 2026/708): AUD 200,000 / AUD 700,000 / cap AUD 7 million / AUD 14 million, indexed annually to CPI. (≈USD 105 k)
- Fees
- New AFS license application, body corporate, retail clients (online)AUD 3,721 (low complexity) to AUD 7,537 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, responsible entitiesMinimum AUD 7,000 plus AUD 14.35 per AUD 1 million of assets above AUD 10 million (2024-25 actual)
- Clients
- Retail permitted
- Conditions
- Public company with a compliance plan and compliance committee (or majority-external board). Constitution lodged with ASIC. Product disclosure and design and distribution obligations.
- Systems
- Fund Management CompanyAsset Management CompanyMutual Fund & UCITSETF PlatformReal Estate Investment VehicleDigital Asset FundWealth Management Firm
- Reading
- From a secondary source
- Sources
05CustodianAFSL – provide custodial or depository services (non-incidental)USD 7 mMinimum capital
- Permits
- Holding financial products or beneficial interests in them on trust for, or on behalf of, clients as a custody business.
- Minimum capital
- NTA of the greater of AUD 10 million or 10% of average revenue. Providers whose custody is only incidental to other services: greater of AUD 150,000 or 10% of average revenue (ASIC 13-154MR; RG 166 Appendix 4). (≈USD 7 m)
- Fees
- New AFS license application, body corporate, retail clients (online)AUD 3,721 (low complexity) to AUD 7,537 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, custodiansAUD 1,286 (2024-25 actual)
- Clients
- Retail permitted
- Conditions
- Requirements in force since 1 July 2013 (transition to 1 July 2014). Asset-holding standards in RG 133. Custody of digital assets that are financial products will move to the tokenized custody platform regime (see notes).
- Systems
- Custody & Wallet InfrastructurePrime Brokerage
- Reading
- Read in the rulebook
- Sources
06Adviser / MDA providerAFSL – personal advice and managed discretionary account (MDA) servicesNo fixed figureMinimum capital
- Permits
- Giving personal and general financial product advice, and operating managed discretionary accounts for retail or wholesale clients.
- Minimum capital
- RG 166 base level requirements (solvency, positive net assets, cash needs, audit) plus AUD 50,000 surplus liquid funds if client money or property exceeds AUD 100,000. MDA providers that hold client assets themselves may face custodial NTA requirements; this session did not confirm the exact MDA tier.
- Fees
- New AFS license application, body corporate, retail clients (online)AUD 3,721 (low complexity) to AUD 7,537 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, personal advice to retail clients on relevant financial productsMinimum AUD 1,500 plus AUD 2,398 per adviser (2024-25 actual)
- Clients
- Retail permitted
- Conditions
- Relevant providers must be registered and meet education and exam standards for retail advice. Best-interests duty (s 961B). MDA providers must comply with ASIC Instrument 2016/968 and RG 179.
- Systems
- Wealth Management FirmInvestment Advisory FirmMulti-Family Office
- Reading
- From a secondary source
- Sources
07Non-cash payment facility providerAFSL – issue and deal in non-cash payment facilitiesNo fixed figureMinimum capital
- Permits
- Issuing or arranging non-cash payment products such as prepaid cards, digital wallets and certain stablecoins that are payment products.
- Minimum capital
- RG 166 base level requirements; no fixed capital minimum. Stored value in a widely available purchased payment facility needs separate APRA authorization.
- Fees
- New AFS license application, body corporate, retail clients (online)AUD 3,721 (low complexity) to AUD 7,537 (high complexity)AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, payment product providersMinimum AUD 2,000 plus AUD 6.92 per AUD 10,000 of payment product revenue (2024-25 actual)
- Clients
- Retail permitted
- Conditions
- Many low-value facilities rely on ASIC relief instruments. A payments licensing reform bill moving stored-value and payment services into a dedicated AFSL framework has been announced; this session did not confirm its status. Distributors of certain stablecoins have class relief under ASIC instruments.
- Systems
- Electronic Money InstitutionPayment Service ProviderCard Issuing ProgramStablecoin Issuance Structure
- Reading
- To be confirmed
- Sources
08Authorized representative modelCorporate authorized representative (CAR) of an AFS licenseeNo fixed figureMinimum capital
- Permits
- Providing financial services under another firm's AFSL as its authorized representative (Corporations Act s 916A).
- Minimum capital
- No capital requirement for the CAR; the licensee's financial requirements and liability apply.
- Fees
- AFS license variation, body corporate (online)AUD 2,470
- Clients
- Retail, with conditions
- Conditions
- The licensee is responsible for the CAR's conduct and must supervise it. ASIC has scrutinized CAR use in OTC derivatives and managed funds. A CAR cannot issue products in its own right.
- Systems
- White-Label BrokerageInvestment Advisory FirmWealth Management Firm
- Reading
- From a secondary source
- Sources
09Licensed market operatorAustralian market license (Corporations Act Part 7.2)No fixed figureMinimum capital
- Permits
- Operating a financial market, such as an exchange, alternative trading venue or security-token market.
- Minimum capital
- No fixed capital minimum. The operator must have sufficient financial, technological and human resources (s 792A). This session did not confirm the figure ASIC expects.
- Fees
- AFS license variation, body corporate (online)AUD 2,470ASIC industry funding levy, market operatorsSmall securities exchange operator AUD 352,795; small futures exchange operator AUD 5,997 (2025-26 estimates)
- Clients
- Retail, with conditions
- Conditions
- Tiered market licensing. Market Integrity Rules and ASIC supervision apply. Clearing and settlement facilities need a separate CS facility license. Some venues operate under exemptions.
- Systems
- ECN & DMA VenueTokenization PlatformDigital Asset Exchange
- Reading
- From a secondary source
- Sources
10Digital asset platform / tokenized custodyAFSL – digital asset platform (DAP) and tokenized custody platform (TCP) authorizations (Corporations Amendment (Digital Assets Framework) Act 2026)No fixed figureMinimum capital
- Permits
- Operating a platform that holds digital tokens for clients and facilitates their exchange, or a tokenized custody platform.
- Minimum capital
- Financial requirements not confirmed this session. ASIC is expected to set them in RG 166 or an instrument.
- Fees
- New AFS license application, body corporate, retail clients (online)AUD 3,721 (low complexity) to AUD 7,537 (high complexity)AFS license variation, body corporate (online)AUD 2,470
- Clients
- Retail permitted
- Conditions
- The Act received Royal Assent on 8 April 2026 and commences on 9 April 2027; the transition period ends in October 2027. Net tangible assets and liquidity requirements have not been finalized by ASIC. The Act exempts platforms with annual transaction volume below AUD 10 million. Until commencement, tokens that are already financial products need an existing AFSL (ASIC INFO 225), and exchanges need AUSTRAC registration.
- Systems
- Digital Asset ExchangeCustody & Wallet InfrastructureOTC Digital Asset DeskTokenization Platform
- Reading
- To be confirmed
- Sources
Reach
No passport. Asia Region Funds Passport (with Japan, Korea, New Zealand and Thailand) for qualifying retail funds, and the Trans-Tasman mutual recognition arrangement with New Zealand for retail fund offers. Foreign providers serving wholesale clients may rely on ASIC foreign financial service provider relief where available (check current conditions).
Passage
ASIC service charter: decide 70% of complete AFSL applications (new or variation) within 150 days and 90% within 240 days. No service standard is published for market licenses.
Licensed elsewhere
Banks and digital banks (ADIs), insurers and reinsurers, superannuation trustees and providers of widely available purchased payment facilities: APRA. Remittance (registered remittance providers) and digital currency exchange / virtual asset service providers: AUSTRAC registration under the AML/CTF Act (VASP regime expanded from 31 March 2026). Card issuing and merchant acquiring are done by ADIs or scheme members, with the RBA overseeing payment systems. Proprietary trading on own capital generally needs no AFSL. A single family office managing only its own family's wealth generally needs no AFSL. Sovereign vehicles (Future Fund) are statutory. Physical commodity trading, mining and validation are not licensed by ASIC. There is no dedicated Islamic finance license.
Notes. NTA increase for responsible entities, IDPS operators and retail CCIV corporate directors takes effect 1 July 2027 (Instrument 2026/708, made October 2026; RG 166 reissued 21 October 2026). ASIC is consulting (closing 8 September 2026) on extending the retail OTC derivatives financial requirements instrument 2022/705 from its 1 October 2027 sunset to 1 October 2032 without changes. Digital Assets Framework Bill passed Parliament in April 2026 and commences 12 months after Royal Assent. ASIC's sector-wide no-action position for digital asset businesses applying for licenses ran to 30 June 2026. AUSTRAC AML/CTF reforms (tranche 2 and VASP expansion) commenced 31 March 2026, with the travel rule from 1 July 2026. FX conversions use AUD 1 = USD 0.70.
Asia-Pacific · Japan
FSA Japan
Financial Services Agency
The FSA is Japan's integrated financial regulator for banks, insurers, securities firms, asset managers, payment firms and crypto-asset exchanges. Most registrations are filed with and supervised by the regional Local Finance Bureaus under FSA delegation. Securities and asset management firms register under the Financial Instruments and Exchange Act (FIEA); crypto-asset exchanges, electronic payment instruments (stablecoin) intermediaries and funds transfer providers under the Payment Services Act; banks under the Banking Act. Founders should expect long pre-consultation, Japanese-language filings and a local representative and staff.
#4of 34
Balanced score
80 of 100
80 of 100
Scorecard
Credibility ×35%100Breadth ×15%85Entry threshold ×20%62Speed ×15%60Reach ×15%72
Categories15
Systems covered40 of 47
Typical timeline6–12 monthsmarket practice
Lowest capitalUSD 67 k
IOSCO MMoUA
Passportregional
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
Application—0 items · Paid once, when the application is filed
On grantUSD 1 k2 items · Paid once, when the license is granted
Deposits & guaranteesUSD 33 k1 item · Held or lodged, beyond the minimum capital
Every year—0 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
The FSA charges no application fee; the government cost is the registration and license tax, but mandatory self-regulatory memberships (JSDA, FFAJ, JVCEA, JPEA), Japan Investor Protection Fund contributions for Type I firms and deposit insurance premiums for banks add recurring costs. Funds transfer providers must secure outstanding customer transfer obligations by deposit, guarantee or trust (amounts not captured here).
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| On grant | |||
| Registration and license tax, Type II financial instruments business registrationNational tax paid on registration under the Registration and License Tax Act. | JPY 150,000≈ USD 1 k | Type II Financial Instruments Business (FIEA Art. 28(2)) | From a secondary source |
| Registration and license tax, other FIEA registrations (Type I, investment management, investment advisory)Same per-registration tax is understood to apply to all FIEA registrations, but only the Type II figure was confirmed in a source this session. Verify against the Registration and License Tax Act appended table. | JPY 150,000 per registration (not confirmed this session)≈ USD 1 k | Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29); Investment Management Business (FIEA Art. 28(4)) – discretionary investment management; Investment Management Business for Qualified Investors (FIEA Art. 29-5); Investment Advisory and Agency Business (FIEA Art. 28(3)) | To be confirmed |
| Deposits & guarantees | |||
| Operating security deposit, investment advisory and agency businessDeposited with the Legal Affairs Bureau in cash or securities and kept while the business operates (FIEA Art. 31-2). | JPY 5,000,000≈ USD 33 k | Investment Advisory and Agency Business (FIEA Art. 28(3)) | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 335 k
Type II FIBOType II Financial Instruments Business (FIEA Art. 28(2))
USD 67 k
Pro investment managerInvestment Management Business for Qualified Investors (FIEA Art. 29-5)
USD 67 k
Crypto-asset exchangeCrypto-Asset Exchange Service Provider registration (Payment Services Act Art. 63-2)
USD 67 k
Stablecoin intermediaryElectronic Payment Instruments Exchange Service Provider registration (Payment Services Act, in force June 2023)
USD 67 k
Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29)
USD 335 k
Investment managerInvestment Management Business (FIEA Art. 28(4)) – discretionary investment management
USD 335 k
Trust companyTrust company license or registration (Trust Business Act)
USD 335 k
Proprietary trading system (PTS)PTS operation authorization (FIEA Art. 30) for a Type I firm
USD 2.01 m
InsurerInsurance business license (Insurance Business Act)
USD 6.7 m
BankBank license (Banking Act Art. 4)
USD 13.4 m
10k100k1m10m100m
10 of 15 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
15 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Securities firm (Type I FIBO)Type I Financial Instruments Business (FIEA Art. 28(1), registration under Art. 29)USD 335 kMinimum capital
- Permits
- Dealing and brokerage in highly liquid securities (listed shares, bonds), OTC derivatives including retail FX and CFDs, crypto-asset derivatives, underwriting and custody of securities.
- Minimum capital
- Stated capital of at least JPY 50 million and net assets of at least JPY 50 million (FIEA Art. 29-4(1)(iv)-(v)), and a capital adequacy ratio of at least 120% (Art. 29-4(1)(vi)), per the FSA Financial Market Entry guidebook. Underwriting raises the minimum to JPY 3 billion for principal (lead) underwriting and JPY 500 million for other underwriting (general press source; the Enforcement Order text was not read). PTS operation: see the PTS category. (≈USD 335 k)
- Fees
- Registration and license tax, other FIEA registrations (Type I, investment management, investment advisory)JPY 150,000 per registration (not confirmed this session)
- Clients
- Retail permitted
- Conditions
- Must be a stock company (kabushiki kaisha) with a board of directors. Retail FX leverage limited to 25:1 and crypto-asset derivatives to 2:1. Membership of a self-regulatory organization (JSDA or FFAJ) is effectively required, and securities firms join the Investor Protection Fund. Client asset segregation and trust requirements. A firm registered only for the specially permitted intermediary service for unlisted securities needs JPY 10 million of capital and net assets and no capital adequacy ratio (FSA guidebook); that narrow variant is not reflected in capital_min_usd. The underwriting figures are secondary.
- Systems
- Retail BrokerageMulti-Asset BrokerageInstitutional BrokeragePrivate BrokeragePrime BrokeragePrime-of-PrimeStructured Products IssuerTokenization Platform
- Reading
- Read in the rulebook
- Sources
02Type II FIBOType II Financial Instruments Business (FIEA Art. 28(2))USD 67 kMinimum capital
- Permits
- Public offering and private placement of fund interests (collective investment scheme interests, e.g. LPS and TK interests), trust beneficiary interests and dealing in less liquid securities and certain market derivatives.
- Minimum capital
- Stated capital of at least JPY 10 million for a corporation (FIEA Art. 29-4(1)(iv)); no net assets or capital adequacy requirement. An individual registrant instead lodges a business security deposit of JPY 10 million (FIEA Art. 31-2). Source: FSA Financial Market Entry guidebook. (≈USD 67 k)
- Fees
- Registration and license tax, Type II financial instruments business registrationJPY 150,000
- Clients
- Retail permitted
- Conditions
- Commonly held by fund sponsors to self-offer their own fund interests. Type II Financial Instruments Firms Association membership optional but expected for smaller firms.
- Systems
- Private Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleHedge FundFund Management Company
- Reading
- Read in the rulebook
- Sources
03Investment managerInvestment Management Business (FIEA Art. 28(4)) – discretionary investment managementUSD 335 kMinimum capital
- Permits
- Managing investment trusts, investment corporations (J-REITs), discretionary investment contracts and fund assets (self-managed funds).
- Minimum capital
- Stated capital of at least JPY 50 million and net assets of at least JPY 50 million (FIEA Art. 29-4(1)(iv)-(v); FSA Financial Market Entry guidebook). The reduced JPY 10 million threshold applies only to the separate Investment Management Business for Qualified Investors. No capital adequacy ratio. (≈USD 335 k)
- Fees
- Registration and license tax, other FIEA registrations (Type I, investment management, investment advisory)JPY 150,000 per registration (not confirmed this session)
- Clients
- Retail permitted
- Conditions
- Stock company with a board of directors and statutory auditors or committees. Investment trust managers also need Investment Trusts Association membership. J-REIT asset managers also need a real estate brokerage license and a discretionary transaction agent approval under the Building Lots and Buildings Transaction Business Act (MLIT).
- Systems
- Asset Management CompanyFund Management CompanyMutual Fund & UCITSETF PlatformReal Estate Investment VehicleWealth Management FirmPension & Endowment ManagerHedge FundQuantitative Trading Desk
- Reading
- Read in the rulebook
- Sources
04Pro investment managerInvestment Management Business for Qualified Investors (FIEA Art. 29-5)USD 67 kMinimum capital
- Permits
- Investment management of funds whose investors are only qualified investors, with a lighter registration.
- Minimum capital
- Stated capital of at least JPY 10 million and net assets of at least JPY 10 million (FIEA Art. 29-5; FSA Financial Market Entry guidebook), compared with JPY 50 million for general investment management. (≈USD 67 k)
- Fees
- Registration and license tax, other FIEA registrations (Type I, investment management, investment advisory)JPY 150,000 per registration (not confirmed this session)
- Clients
- Professional only
- Conditions
- Investors limited to qualified investors, and total investment assets are capped at JPY 20 billion (FSA guidebook, FIEA Art. 29-5(1)).
- Systems
- Hedge FundFund Management CompanyAsset Management CompanyPrivate Equity FirmPrivate Credit FundDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
05Art. 63 fund GP exemptionSpecially Permitted Business for Qualified Institutional Investors (FIEA Art. 63) – notification, not registrationNo fixed figureMinimum capital
- Permits
- Self-offering and self-managing fund interests (e.g. LPS, TK) where at least one investor is a qualified institutional investor and other investors are eligible investors (fewer than 50).
- Minimum capital
- None. The business is started by advance notification to the competent authority as a Special Business Notifier (FIEA Art. 63), not registration; neither the FSA guidebook nor the Tokyo Metropolitan Government registration guidebook lists a capital or net assets requirement. The statute itself was not read.
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- At least one qualified institutional investor among domestic investors, and no more than 49 other domestic investors, all of whom must be eligible investors; no disqualified investors. Common for PE, VC and hedge fund GPs. Conduct rules and ongoing reporting apply after the 2015 tightening. A separate special-business notification route for overseas investment managers also exists.
- Systems
- Private Equity FirmVenture Capital FirmHedge FundPrivate Credit FundSingle-Family Office
- Reading
- From a secondary source
- Sources
06Investment adviserInvestment Advisory and Agency Business (FIEA Art. 28(3))No fixed figureMinimum capital
- Permits
- Giving investment advice under advisory contracts and acting as agent or intermediary for advisory or discretionary investment contracts.
- Minimum capital
- No stated capital or net assets requirement. A business security deposit of JPY 5 million must be lodged (FIEA Art. 31-2; FSA Financial Market Entry guidebook).
- Fees
- Registration and license tax, other FIEA registrations (Type I, investment management, investment advisory)JPY 150,000 per registration (not confirmed this session)Operating security deposit, investment advisory and agency businessJPY 5,000,000
- Clients
- Retail permitted
- Conditions
- Individuals and corporations may register. Prohibited from receiving client money or securities.
- Systems
- Investment Advisory FirmWealth Management FirmMulti-Family Office
- Reading
- Read in the rulebook
- Sources
07Proprietary trading system (PTS)PTS operation authorization (FIEA Art. 30) for a Type I firmUSD 2.01 mMinimum capital
- Permits
- Operating an electronic trading venue for listed securities or security tokens outside the exchanges.
- Minimum capital
- A Type I firm seeking PTS authorization under FIEA Art. 30 faces an additional stated capital requirement of JPY 300 million (FSA briefing material, August 2024). Under the 2024 FIEA amendments (enacted 15 May 2024), a venue that trades only unlisted securities with volume up to JPY 60 billion per quarter may run on Type I registration alone, without authorization and without the JPY 300 million requirement. (≈USD 2.01 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Requires Type I registration plus specific authorization. Security token PTS venues operate under this route. The small unlisted-securities PTS route is registration-only, and the FSA also eased system-duplication requirements for it. This session did not confirm the date the 2024 amendment took effect, and did not read the Enforcement Order text that sets the JPY 300 million figure.
- Systems
- ECN & DMA VenueTokenization Platform
- Reading
- Read in the rulebook
- Sources
08Crypto-asset exchangeCrypto-Asset Exchange Service Provider registration (Payment Services Act Art. 63-2)USD 67 kMinimum capital
- Permits
- Buying, selling and exchanging crypto-assets, intermediating such transactions, and managing crypto-assets for customers.
- Minimum capital
- Stated capital of at least JPY 10 million and net assets not below zero; a provider that manages customers' crypto-assets must instead have net assets of at least the yen value of its performance-guarantee crypto-assets (Cabinet Office Order on Crypto-Asset Exchange Service Providers, Art. 9, under Payment Services Act Art. 63-5(1)(iii)). (≈USD 67 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Stock company or foreign company with an office in Japan. Customer crypto-assets largely in cold wallets, with hot-wallet amounts covered by equivalent own assets. Japan Virtual and Crypto Assets Exchange Association (JVCEA) membership expected. Token listings reviewed through the JVCEA. Crypto derivatives require Type I registration.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
09Stablecoin intermediaryElectronic Payment Instruments Exchange Service Provider registration (Payment Services Act, in force June 2023)USD 67 kMinimum capital
- Permits
- Buying, selling, exchanging, intermediating and managing electronic payment instruments (fiat-backed stablecoins) for customers.
- Minimum capital
- Stated capital of at least JPY 10 million and net assets not negative (Cabinet Office Order on Electronic Payment Instruments Service Providers, Cabinet Office Order No. 48 of 2023, Art. 12, under Payment Services Act Art. 62-6(1)(iii)). (≈USD 67 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Stablecoins themselves may be issued only by banks, funds transfer service providers and trust companies. Intermediaries handling foreign-issued stablecoins face additional conditions.
- Systems
- Stablecoin Issuance StructureOTC Digital Asset DeskCustody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
10Funds transfer, Type 1Funds Transfer Service Provider – Type 1 (registration plus approval of a business implementation plan, Payment Services Act Art. 40-2)No fixed figureMinimum capital
- Permits
- Funds transfers above JPY 1 million per transaction by a non-bank.
- Minimum capital
- No minimum stated capital is set in the Payment Services Act or the Cabinet Office Order on Funds Transfer Service Providers. Registration requires an adequate financial basis, which the FSA's administrative guidelines test as net assets that are not negative (KPMG AZSA summary, 2025). Transfer obligations must be fully secured (deposit, guarantee or trust).
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Registration plus FSA approval of a business implementation plan (Art. 40-2). May not hold customer funds beyond what a specific transfer needs.
- Systems
- Money Services BusinessPayment Service ProviderElectronic Money Institution
- Reading
- From a secondary source
- Sources
11Funds transfer, Type 2Funds Transfer Service Provider – Type 2 (registration, Payment Services Act)No fixed figureMinimum capital
- Permits
- Funds transfers of up to JPY 1 million per transaction, including domestic and cross-border remittance and stored balances for transfer. Funds transfer providers may also issue fiat-backed stablecoins.
- Minimum capital
- No minimum stated capital is set in the Payment Services Act or the Cabinet Office Order on Funds Transfer Service Providers. Registration requires an adequate financial basis, which the FSA's administrative guidelines test as net assets that are not negative (KPMG AZSA summary, 2025). Outstanding obligations must be fully secured.
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- The most common route for remittance and wallet businesses. Reportedly the route JPYC used for a yen stablecoin in 2025 (not re-verified).
- Systems
- Money Services BusinessPayment Service ProviderElectronic Money InstitutionStablecoin Issuance Structure
- Reading
- From a secondary source
- Sources
12Funds transfer, Type 3Funds Transfer Service Provider – Type 3 (registration, Payment Services Act)No fixed figureMinimum capital
- Permits
- Small-value funds transfers of up to JPY 50,000 per transaction.
- Minimum capital
- No minimum stated capital is set in the Payment Services Act or the Cabinet Office Order on Funds Transfer Service Providers. Registration requires an adequate financial basis, which the FSA's administrative guidelines test as net assets that are not negative (KPMG AZSA summary, 2025). Asset preservation can use a lighter deposit method.
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Lighter security arrangements than Type 2.
- Systems
- Money Services BusinessPayment Service Provider
- Reading
- From a secondary source
- Sources
13BankBank license (Banking Act Art. 4)USD 13.4 mMinimum capital
- Permits
- Deposit-taking, lending and exchange transactions, including private banking, trade finance, treasury and digital banking.
- Minimum capital
- Stated capital of at least JPY 2 billion (Banking Act Art. 5(1); Order for Enforcement of the Banking Act Art. 3). (≈USD 13.4 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Stock company with board and audit structures. Major shareholder approval above 20%. Basel III capital adequacy. Foreign banks may open licensed branches. Internet-only banks are licensed as ordinary banks.
- Systems
- Private BankDigital BankInvestment BankCorrespondent Banking StructureTrade Finance HouseTreasury & Liquidity DeskCard Issuing ProgramStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
14Trust companyTrust company license or registration (Trust Business Act)USD 335 kMinimum capital
- Permits
- Trust business, including custody of client assets and issuance of trust-type stablecoins and trust beneficiary interest security tokens.
- Minimum capital
- Licensed (investment-based) trust company: stated capital of at least JPY 100 million (Trust Business Act Art. 5(2)(ii); Order for Enforcement Art. 3). Registered custodian-type trust company: at least JPY 50 million (Act Art. 10(1)(ii); Order Art. 8). Business security deposits are separate: JPY 25 million for a non-custodian trust company and JPY 10 million for a custodian-type company (Order Art. 9). The JPY 10 million figure is a deposit, not the custodian-type capital minimum. Registration under Act Art. 50-2(1) (large-scale self-declared trusts) requires JPY 30 million (Order Art. 15-4). (≈USD 335 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Route for trust-type stablecoins (specified trust beneficiary interests) and for custody of tokenized assets. From 1 June 2026 (2025 Payment Services Act amendment, Act No. 66 of 2025), the reserves behind specified trust beneficiary interests may be partly invested in certain government bonds and in time deposits that allow early withdrawal, subject to eligible-asset rules and maximum allocation ratios set by Cabinet Office Order; before that they had to be held in demand deposits. This session did not confirm the cap (a 50% figure is reported). capital_min_usd uses the custodian-type trust company minimum; the Art. 50-2 registration is not a trust company license.
- Systems
- Custody & Wallet InfrastructureStablecoin Issuance StructureTokenization Platform
- Reading
- Read in the rulebook
- Sources
15InsurerInsurance business license (Insurance Business Act)USD 6.7 mMinimum capital
- Permits
- Life or non-life insurance and reinsurance.
- Minimum capital
- Stated capital (or total foundation funds for a mutual company) of at least JPY 1 billion (Insurance Business Act Art. 6(1); Order for Enforcement of the Insurance Business Act Art. 2-2). (≈USD 6.7 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Separate licenses for life and non-life business. Small-amount short-term insurers have a lighter registration regime.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
No passport. Japan participates in the Asia Region Funds Passport. Foreign firms generally need a Japanese registration or a branch, though limited exemptions exist for managers serving only qualified institutional investors or overseas investors.
Passage
No regulator service standard was confirmed this session. Market practice: 6–12 months of pre-consultation with the Local Finance Bureau before formal filing for FIEA registrations; crypto-asset exchange and bank licenses often take a year or more.
Licensed elsewhere
Commodity futures and commodity derivatives brokers: METI and MAFF under the Commodity Derivatives Act. Credit card issuing and merchant acquiring: METI under the Installment Sales Act. Prepaid payment instruments: FSA registration under the Payment Services Act (not covered here). Money lending: registration with the FSA/Local Finance Bureau or prefecture under the Money Lending Business Act, relevant to direct-lending private credit. Exchanges: FSA license for financial instruments exchanges (e.g. JPX). Sovereign vehicles (GPIF) are statutory. Mining and validation are not licensed. Japan has no dedicated Islamic finance license. White-label brokerage has no dedicated pathway: the brand must register itself or act as a Financial Instruments Intermediary Service Provider tied to a registered firm.
Notes. Capital figures were confirmed in October 2026 from the FSA Financial Market Entry guidebook and from English translations of the Cabinet Orders and Cabinet Office Orders on japaneselawtranslation.go.jp; translations may lag the latest Japanese text. 2025 Payment Services Act amendment (Act No. 66 of 2025, promulgated 13 June 2025): the FSA announced on 22 May 2026 that it and its Cabinet Orders and Cabinet Office Orders took effect on 1 June 2026. It lets the reserves backing trust-type stablecoins (specified trust beneficiary interests) be partly invested in certain government bonds and early-withdrawable time deposits, and it creates a new electronic payment instruments and crypto-asset service intermediary business (registration). FSA rules also allow orders requiring electronic payment instruments and crypto-asset service providers to hold assets in Japan. 2024 FIEA amendment (enacted 15 May 2024): small PTS for unlisted securities may operate on Type I registration without PTS authorization. A further FIEA amendment passed on 15 July 2026 takes effect on 1 April 2027 (AMT); its effect on licensing categories was not reviewed. FSA proposals to move crypto-assets under the FIEA were not re-verified. The first yen stablecoin from JPYC (a registered funds transfer provider) in 2025 was not re-verified. FX conversions use JPY 1 = USD 0.0067.
Asia-Pacific · Malaysia · Labuan
Labuan FSA
Labuan Financial Services Authority
Labuan FSA regulates the Labuan International Business and Financial Centre, a federal offshore center in Malaysia. It licenses conventional businesses under the Labuan Financial Services and Securities Act 2010 (LFSSA) and Islamic businesses under the Labuan Islamic Financial Services and Securities Act 2010 (LIFSSA). Labuan entities generally deal in foreign currency with non-residents. Business with Malaysian residents or in ringgit is restricted and needs onshore approval from Bank Negara Malaysia or the Securities Commission. A preferential 3% tax on net audited profits applies to Labuan trading activities that meet substance requirements (minimum employees and operating expenditure in Labuan).
#24of 34
Balanced score
56 of 100
56 of 100
Scorecard
Credibility ×35%35Breadth ×15%60Entry threshold ×20%79Speed ×15%100Reach ×15%28
Categories17
Systems covered28 of 47
Typical timeline2–4 monthsmarket practice
Lowest capitalUSD 35 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 5001 item · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 1 k–40 k11 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
Labuan FSA raised most fees on 1 January 2026, with existing brokers, fund managers, securities licensees and insurers phased in to 2028; new licensees pay the full rate. Regulator fees are low in absolute terms; substance spending in Labuan to keep the 3% tax rate is the larger recurring cost.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Licence application processing feeRaised from USD 350 on 1 January 2026. Optional fast-track processing under LFSSA/LIFSSA: USD 1,500. | USD 500 | Labuan money broking license (LFSSA Part VI), money and FX markets only; Labuan money broking license (LFSSA Part VI), with digital asset activities; Labuan securities licensee (LFSSA s. 55; Islamic under LIFSSA); Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) and 8 more | Read in the rulebook |
| Every year | |||
| Annual license fee, Labuan commercial bankRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Up from USD 30,000. The schedule does not list a separate digital bank fee. | USD 40,000 per year | Labuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA) | Read in the rulebook |
| Annual license fee, Labuan investment bankRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Up from USD 30,000. | USD 35,000 per year | Labuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business) | Read in the rulebook |
| Annual license fee, money broker (conventional)Revised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Existing licensees pay transitional rates: USD 1,500 in 2026, USD 3,250 in 2027, USD 5,000 from 2028. New licensees pay the full revised rate. | USD 5,000 per year | Labuan money broking license (LFSSA Part VI), money and FX markets only | Read in the rulebook |
| Annual license fee, money broker (digital asset)Revised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Existing licensees pay transitional rates: USD 1,500 in 2026, USD 5,750 in 2027, USD 10,000 from 2028. New licensees pay the full revised rate. | USD 10,000 per year | Labuan money broking license (LFSSA Part VI), with digital asset activities | Read in the rulebook |
| Annual license fee, securities licenseeRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Existing licensees pay transitional rates: USD 1,500 in 2026, USD 2,000 in 2027, USD 2,500 from 2028. New licensees pay the full revised rate. | USD 2,500 per year | Labuan securities licensee (LFSSA s. 55; Islamic under LIFSSA) | Read in the rulebook |
| Annual license fee, fund managerRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Existing licensees pay transitional rates: USD 1,500 in 2026, USD 2,250 in 2027, USD 3,000 from 2028. New licensees pay the full revised rate. | USD 3,000 per year | Labuan fund manager license (LFSSA s. 40; LIFSSA s. 45) | Read in the rulebook |
| Annual approval fee, Labuan exchangeRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. New category; exchanges established before 31 December 2025 pay from 2027. | USD 13,000 per year | Labuan exchange approval (LFSSA s. 134; Form LEB) | Read in the rulebook |
| Annual license fee, general or life (re)insurerRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Existing licensees pay transitional rates: USD 15,000 in 2026, USD 20,000 in 2027, USD 25,000 from 2028. New licensees pay the full revised rate. | USD 25,000 per year | Labuan direct insurer license, general or life (LFSSA; takaful operators under LIFSSA); Labuan reinsurer license (retakaful under LIFSSA) | Read in the rulebook |
| Annual license fee, pure captiveRevised schedule effective 1 January 2026 (subject to gazettement); due on or before 15 January each year. Up from USD 3,000. | USD 4,000 per year | Labuan captive insurer license: pure, group, association or multi-owner captive | Read in the rulebook |
| Annual license fee, rent-a-captive and protected cell captivesMaster rent-a-captive USD 4,000; subsidiary or external rent-a-captive USD 1,000; PCC captive core USD 9,500, cell USD 3,000. | USD 1,000 to 9,500 per year | Labuan captive insurer license: rent-a-captive or protected cell captive | Read in the rulebook |
| Labuan company annual fee (Registrar)Payable by every Labuan company in addition to any license fee; up from USD 800 (foreign USD 1,500) on 1 January 2026. Funds structured as trusts or partnerships pay USD 300 or USD 400 instead. | USD 1,000 per year (foreign Labuan company USD 2,500) | All categories | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 236 k
Securities licenseeLabuan securities licensee (LFSSA s. 55; Islamic under LIFSSA)
USD 35 k
Islamic financial institutionLabuan Islamic financial business (LIFSSA 2010): Islamic bank, Islamic investment bank, takaful and retakaful, Islamic fund manager, Islamic securities licensee
USD 35 k
Fund managerLabuan fund manager license (LFSSA s. 40; LIFSSA s. 45)
USD 71 k
Captive insurerLabuan captive insurer license: pure, group, association or multi-owner captive
USD 71 k
Security token issuerLabuan securities token offering (Guidelines on Labuan Securities Token Offering, 6 Oct 2023)
USD 118 k
Rent-a-captive / cell captiveLabuan captive insurer license: rent-a-captive or protected cell captive
USD 118 k
Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets only
USD 236 k
Money broker (FX and digital assets)Labuan money broking license (LFSSA Part VI), with digital asset activities
USD 354 k
Direct insurerLabuan direct insurer license, general or life (LFSSA; takaful operators under LIFSSA)
USD 1.77 m
Labuan bankLabuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA)
USD 2.36 m
Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business)
USD 2.36 m
ReinsurerLabuan reinsurer license (retakaful under LIFSSA)
USD 2.36 m
Labuan digital bankLabuan digital banking license (Labuan Digital Banking Framework, Dec 2020)
USD 11.8 m
10k100k1m10m100m
13 of 17 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
17 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Money broker (FX)Labuan money broking license (LFSSA Part VI), money and FX markets onlyUSD 236 kMinimum capital
- Permits
- Arranging transactions between buyers and sellers in the money or foreign exchange markets.
- Minimum capital
- Minimum paid-up capital RM1,000,000 or foreign-currency equivalent, unimpaired by losses (Guidelines on the Establishment of Money Broking Business in Labuan IBFC, 9 Sep 2024, para 7.1(i)). Labuan FSA may require more. (≈USD 236 k)
- Fees
- Licence application processing feeUSD 500Annual license fee, money broker (conventional)USD 5,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Professional only
- Conditions
- Arranging only: acting as principal is prohibited, and CFDs on anything outside the money and FX markets are not permitted. Clients are institutional investors (corporates with net assets of at least USD 3 million) and high-net-worth individuals (USD 1 million net assets or USD 150,000 annual income). Client money segregated and reconciled monthly; withdrawals paid within three working days. Operational office in Labuan with staff; at least two directors. Capital must be deposited with a regulated bank in Labuan or Malaysia. Non-residents only for ringgit and resident business, as for all Labuan entities. Maximum client leverage 100:1 (1% margin) with mandatory stop-loss or similar safeguards.
- Systems
- Private BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
02Money broker (FX and digital assets)Labuan money broking license (LFSSA Part VI), with digital asset activitiesUSD 354 kMinimum capital
- Permits
- Money and FX broking plus bringing counterparties together to trade and exchange digital assets that do not have securities features under LFSSA s. 2.
- Minimum capital
- Minimum paid-up capital RM1,500,000 or foreign-currency equivalent, unimpaired by losses (Money Broking Guidelines, 9 Sep 2024, para 7.1(ii)). (≈USD 354 k)
- Fees
- Licence application processing feeUSD 500Annual license fee, money broker (digital asset)USD 10,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Professional only
- Conditions
- Arranging only: acting as principal is prohibited, and CFDs on anything outside the money and FX markets are not permitted. Clients are institutional investors (corporates with net assets of at least USD 3 million) and high-net-worth individuals (USD 1 million net assets or USD 150,000 annual income). Client money segregated and reconciled monthly; withdrawals paid within three working days. Operational office in Labuan with staff; at least two directors. Capital must be deposited with a regulated bank in Labuan or Malaysia. Non-residents only for ringgit and resident business, as for all Labuan entities. Leverage on digital asset trades capped at 1:1. Only digital currencies admissible under the Admissibility Framework for Digital Currencies (30 Dec 2024). Platform operators must also meet the Guidelines on the Management of Digital Money Broking Platform (issued 16 Dec 2025, effective 1 Jan 2027): no credit to clients, best-terms execution, fair access criteria. This is Labuan's main route for crypto trading platforms; Labuan FSA does not publish a separate digital asset exchange guideline.
- Systems
- OTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
03Securities licenseeLabuan securities licensee (LFSSA s. 55; Islamic under LIFSSA)USD 35 kMinimum capital
- Permits
- Investment advice (securities advice, research, corporate finance and financial planning), administrative services (submissions to Labuan FSA, issuing prospectus documents) and dealing in securities (two-way quotes, dealing, arranging sales or purchases, including unlisted securities).
- Minimum capital
- Minimum paid-up capital RM150,000 or foreign-currency equivalent, unimpaired by losses (Guidelines on the Establishment of Labuan Securities Licensee, updated 14 May 2019; Directive on Minimum Capital Requirement 2015). (≈USD 35 k)
- Fees
- Licence application processing feeUSD 500Annual license fee, securities licenseeUSD 2,500 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- May not hold client money or assets, so it cannot run a custodial brokerage. Registered office in Labuan; marketing office in Kuala Lumpur or Iskandar permitted under separate guidelines. Labuan FSA may require more capital based on risk.
- Systems
- Investment Advisory FirmInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
04Fund managerLabuan fund manager license (LFSSA s. 40; LIFSSA s. 45)USD 71 kMinimum capital
- Permits
- Managing Labuan funds and other funds, and clients' discretionary accounts including Labuan private funds; Islamic fund management with prior approval.
- Minimum capital
- Minimum paid-up capital RM300,000 or foreign-currency equivalent, unimpaired by losses; where AUM exceeds RM150 million, additional capital of 0.2% of AUM above RM150 million (Guidelines on the Establishment of Labuan Fund Manager, updated 14 May 2019, para 8.1; Directive on Minimum Capital Requirement 2015). (≈USD 71 k)
- Fees
- Licence application processing feeUSD 500Annual license fee, fund managerUSD 3,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- Registered office in Labuan and business carried on from Labuan; at least two directors; client assets segregated under LFSSA Part III Division 4; annual audit (LFSSA s. 174).
- Systems
- Asset Management CompanyFund Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundWealth Management FirmMulti-Family OfficeDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
05Private fundLabuan private fund (LFSSA s. 28)No fixed figureMinimum capital
- Permits
- Mutual fund not offered to the general public, launched on prior written notification to Labuan FSA with an information memorandum lodged through a Labuan trust company, bank, investment bank or fund manager.
- Minimum capital
- Not applicable: no capital requirement for the fund.
- Fees
- Labuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Professional only
- Conditions
- Either up to 50 investors each investing at least RM250,000 equivalent on first subscription, or any number of investors each investing at least RM500,000 equivalent (Guidelines on the Establishment of Labuan Mutual Funds, updated 20 Jun 2025). May appoint its own manager and administrator; auditor must confirm return of assets on wind-down.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundDigital Asset FundReal Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
06Public fundLabuan public fund (LFSSA s. 33)No fixed figureMinimum capital
- Permits
- Mutual fund offered to any member of the public; registration required before business starts (provisional acceptance allows promotion only).
- Minimum capital
- Not applicable: no capital requirement for the fund; minimum subscription conditions apply.
- Fees
- Labuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail permitted
- Conditions
- Must appoint an approved fund manager, trustee, administrator and custodian, with manager and custodian/trustee independent; prospectus with full, true and plain disclosure (LFSSA s. 35); annual audit within six months. A foreign public fund registered in an IOSCO member jurisdiction and managed or administered by a Labuan licensee need not register as a public fund but must notify Labuan FSA and lodge its prospectus. Offers to Malaysian residents need onshore approval.
- Systems
- Mutual Fund & UCITSReal Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
07Labuan bankLabuan bank (LFSSA Part VI; Labuan Islamic bank under LIFSSA)USD 2.36 mMinimum capital
- Permits
- Banking business in foreign currency, including deposit-taking from non-residents, lending, trade finance and treasury.
- Minimum capital
- Subsidiary: minimum paid-up capital RM10 million unimpaired by losses; Tier 1 ratio of at least 4% and total capital ratio of at least 8% under the risk-weighted capital adequacy guidelines. Branch: ratio computed at head-office level, no local working funds requirement (Directive on Minimum Capital Requirement, 5 Oct 2015). (≈USD 2.36 m)
- Fees
- Licence application processing feeUSD 500Annual license fee, Labuan commercial bankUSD 40,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- Applicant must itself be a bank or financial institution with an acceptable credit rating, a good operating history and a competent home supervisor, plus a parent guarantee or undertaking; physical presence in Labuan; annual license fee RM100,000 (Guidelines on Entry Criteria for Labuan Bank, 14 May 2019). A founder without a regulated parent will not qualify.
- Systems
- Private BankTrade Finance HouseTreasury & Liquidity DeskCorrespondent Banking Structure
- Reading
- Read in the rulebook
- Sources
08Labuan investment bankLabuan investment bank (LFSSA; Guidelines on the Establishment of Labuan Investment Banking Business)USD 2.36 mMinimum capital
- Permits
- Credit facilities, advisory and consultancy, dealing in securities, managing investments for others, FX, interest rate swaps and derivatives; may not accept deposits.
- Minimum capital
- Minimum paid-up capital RM10 million or foreign-currency equivalent (Guidelines on the Establishment of Labuan Investment Banking Business, updated 20 Jun 2025, para 7.1; Directive on Minimum Capital Requirement 2015). Labuan FSA may require more based on risk. (≈USD 2.36 m)
- Fees
- Licence application processing feeUSD 500Annual license fee, Labuan investment bankUSD 35,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- No deposit-taking. Operational office in Labuan under the substance rules. Syndicated financing to BNM-approved residents should involve Labuan banking institutions where possible; Malaysian foreign exchange rules apply where relevant.
- Systems
- Investment BankStructured Products IssuerMulti-Asset BrokerageTreasury & Liquidity Desk
- Reading
- Read in the rulebook
- Sources
09Labuan digital bankLabuan digital banking license (Labuan Digital Banking Framework, Dec 2020)USD 11.8 mMinimum capital
- Permits
- Digital-only banking business in foreign currency from Labuan.
- Minimum capital
- Framework minimum: capital unimpaired by losses of RM200 million plus a non-interest-bearing security deposit of RM5 million, refundable after three years. Relaxed by Circular 293/2023/ALL (29 Nov 2023) to RM50 million and a RM2.5 million deposit until 31 December 2026. (≈USD 11.8 m)
- Fees
- Licence application processing feeUSD 500Labuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- The RM50 million relaxation expires on 31 December 2026; check whether Labuan FSA has extended it before applying, otherwise RM200 million applies. Operational office in Labuan and an in-house core banking system (Shearn Delamore summary, Feb 2021).
- Systems
- Digital Bank
- Reading
- Read in the rulebook
- Sources
10Islamic digital bank (sandbox)Labuan Islamic digital bank under sandbox regulatory requirements (iBOX)No fixed figureMinimum capital
- Permits
- Shariah-compliant digital banking under a provisional sandbox license (LIFSSA s. 63), graduating to full operations when prudential requirements are met.
- Minimum capital
- Not confirmed: the iBOX FAQ and press releases reviewed do not state a capital figure.
- Fees
- Labuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- Applications had to be filed within six months of the guideline's issue; no cap on participant numbers; a bank that cannot graduate may seek an extension of up to 24 months. Two conditional approvals were granted in 2025 (press release 10 Oct 2025); they may not start business until operational and prudential requirements are met.
- Systems
- Digital BankIslamic Finance Structure
- Reading
- To be confirmed
- Sources
11Labuan exchangeLabuan exchange approval (LFSSA s. 134; Form LEB)No fixed figureMinimum capital
- Permits
- Operating an exchange in Labuan; the application form includes a 'digital related' option, so it can also be used for digital asset venues.
- Minimum capital
- No published minimum. The application asks for the proposed paid-up capital or working fund, three years of the shareholder's audited accounts and a three-year projection; Labuan FSA sets the amount case by case.
- Fees
- Licence application processing feeUSD 500Annual approval fee, Labuan exchangeUSD 13,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- Requires a corporate shareholder, a letter of guarantee, draft exchange by-laws and rules, a business plan (with white paper for digital venues) and a KYC/AML framework. No exchange-specific guideline was found.
- Systems
- ECN & DMA VenueDigital Asset Exchange
- Reading
- To be confirmed
- Sources
12Security token issuerLabuan securities token offering (Guidelines on Labuan Securities Token Offering, 6 Oct 2023)USD 118 kMinimum capital
- Permits
- Issuing or offering securities tokens in or from Labuan IBFC, privately or to the public.
- Minimum capital
- Issuer must maintain capital of RM500,000 or foreign-currency equivalent at all times (Labuan IBFC regulatory brief on the STO Guidelines, Nov 2023). (≈USD 118 k)
- Fees
- Labuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- The summary does not say whether the RM500,000 applies to private offers, public offers or both; check the guideline text.
- Systems
- Tokenization Platform
- Reading
- From a secondary source
- Sources
13Direct insurerLabuan direct insurer license, general or life (LFSSA; takaful operators under LIFSSA)USD 1.77 mMinimum capital
- Permits
- Writing general or life insurance business from Labuan.
- Minimum capital
- Subsidiary: paid-up capital RM7.5 million; branch: RM7.5 million surplus of assets in Labuan. Composite general and life: RM10 million. Solvency margin the greater of RM7.5 million or 20% of prior-year net premium income (Directive on Minimum Capital Requirement, 5 Oct 2015). (≈USD 1.77 m)
- Fees
- Licence application processing feeUSD 500Annual license fee, general or life (re)insurerUSD 25,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- The 2015 Directive restates the figures in the 1997 (amended 2001) application guideline, so they remain current; no later capital directive was found. Labuan FSA may impose higher amounts.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
14ReinsurerLabuan reinsurer license (retakaful under LIFSSA)USD 2.36 mMinimum capital
- Permits
- Reinsurance business from Labuan.
- Minimum capital
- Paid-up capital RM10 million (subsidiary) or RM10 million surplus of assets (branch); solvency margin the greater of RM7.5 million or 20% of prior-year net premium income plus 3% of the latest life actuarial valuation (Directive on Minimum Capital Requirement, 5 Oct 2015). (≈USD 2.36 m)
- Fees
- Licence application processing feeUSD 500Annual license fee, general or life (re)insurerUSD 25,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Professional only
- Conditions
- Same source and currency position as the direct insurer category.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
15Captive insurerLabuan captive insurer license: pure, group, association or multi-owner captiveUSD 71 kMinimum capital
- Permits
- Insuring the risks of the owner or owner group.
- Minimum capital
- Paid-up capital RM300,000 (subsidiary) or RM300,000 surplus of assets (branch); solvency margin the greatest of RM300,000, 20% of prior-year net premium income or 3% of the life actuarial valuation (Directive on Minimum Capital Requirement, 5 Oct 2015). (≈USD 71 k)
- Fees
- Licence application processing feeUSD 500Annual license fee, pure captiveUSD 4,000 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Professional only
- Conditions
- Islamic (takaful) captives follow the same figures. Insurance brokers, underwriting managers and insurance managers also need RM300,000.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
16Rent-a-captive / cell captiveLabuan captive insurer license: rent-a-captive or protected cell captiveUSD 118 kMinimum capital
- Permits
- Insuring third-party risks through a rent-a-captive or protected cell structure.
- Minimum capital
- Paid-up capital RM500,000 (subsidiary) or RM500,000 surplus of assets (branch); solvency margin the greatest of RM500,000, 20% of prior-year net premium income or 3% of the life actuarial valuation (Directive on Minimum Capital Requirement, 5 Oct 2015). (≈USD 118 k)
- Fees
- Licence application processing feeUSD 500Annual license fee, rent-a-captive and protected cell captivesUSD 1,000 to 9,500 per yearLabuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Professional only
- Conditions
- Islamic cell structures follow the same figures.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
17Islamic financial institutionLabuan Islamic financial business (LIFSSA 2010): Islamic bank, Islamic investment bank, takaful and retakaful, Islamic fund manager, Islamic securities licenseeUSD 35 kMinimum capital
- Permits
- Shariah-compliant banking, investment banking, takaful and retakaful, fund management and securities business.
- Minimum capital
- Same minimums as the conventional equivalents (Directive on Minimum Capital Requirement, 5 Oct 2015): Islamic bank or investment bank RM10 million; takaful operator RM7.5 million; retakaful or composite RM10 million; Islamic fund manager RM300,000; Islamic securities licensee RM150,000. (≈USD 35 k)
- Fees
- Labuan company annual fee (Registrar)USD 1,000 per year (foreign Labuan company USD 2,500)
- Clients
- Retail, with conditions
- Conditions
- Requires Shariah adviser or committee. Islamic digital banks use the separate iBOX sandbox. Labuan is used for sukuk and Islamic fund structures for non-residents.
- Systems
- Islamic Finance Structure
- Reading
- Read in the rulebook
- Sources
Reach
None. A Labuan license gives no access to onshore Malaysia or other markets; dealing with Malaysian residents requires onshore authorization.
Passage
No regulator service standard found. Market practice is roughly 2 to 4 months for most licenses after a complete application; banking, digital banking and exchange approvals take longer. Labuan private funds launch on prior notification; public funds need registration first.
Licensed elsewhere
Onshore Malaysia: banks, Islamic banks, insurers, takaful operators, e-money issuers, payment system operators and money services businesses (remittance, money-changing) are licensed by Bank Negara Malaysia. Capital markets services licenses, recognized market operators (including digital asset exchanges) and onshore funds are licensed by the Securities Commission Malaysia. Labuan entities may not serve Malaysian residents or deal in ringgit without onshore approval. Retail FX/CFD brokerage is not available in Labuan: money brokers may only arrange FX and money market deals for institutional and high-net-worth clients. Labuan international commodity trading companies (LITC) are approved under a tax-incentive regime with a turnover test (normally USD 50 million, relaxed to USD 25 million for petroleum products and USD 10 million for others until 31 Dec 2026), not a capital-based license. Labuan FSA also licenses credit token (card) companies, not covered here. Mining, sovereign vehicles and stablecoin issuance have no Labuan license. Family wealth structures typically use Labuan foundations and trusts; Labuan trust companies need RM150,000 paid-up capital.
Notes. Revised Oct 2026 against Labuan FSA guidelines. The Directive on Minimum Capital Requirement by Labuan Licensed Entities (5 Oct 2015, ref. 182/2015/ALL) is the base capital table; money brokers have since moved to RM1 million (RM1.5 million with digital assets) under the 9 Sep 2024 guidelines, which also ban principal dealing and non-FX CFDs. Digital bank capital relief (RM50 million instead of RM200 million) runs to 31 Dec 2026 under Circular 293/2023/ALL; check for an extension. Guidelines on the Management of Digital Money Broking Platform take effect 1 Jan 2027. The Admissibility Framework for Digital Currencies (30 Dec 2024) limits which digital currencies Labuan entities may deal in. Uncertain: iBOX Islamic digital bank capital and Labuan exchange capital (no published figure). Substance requirements for the 3% tax rate were tightened under the Labuan Business Activity Tax (Requirements for Labuan Business Activity) Regulations 2021. FX conversions use MYR 1 = USD 0.236.
Africa · South Africa
FSCA
Financial Sector Conduct Authority
The FSCA is the market-conduct regulator in South Africa's twin-peaks system under the Financial Sector Regulation Act 2017. It licenses financial services providers (FSPs) under the FAIS Act 2002, authorizes OTC derivative providers and market infrastructures under the Financial Markets Act 2012, and registers collective investment scheme managers under CISCA 2002. Prudential supervision of banks and insurers sits with the Prudential Authority inside the South African Reserve Bank.
#17of 34
Balanced score
66 of 100
66 of 100
Scorecard
Credibility ×35%65Breadth ×15%55Entry threshold ×20%80Speed ×15%70Reach ×15%52
Categories10
Systems covered26 of 47
Typical timeline3–12 monthsmarket practice
Lowest capitalUSD 57 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 154–27 k8 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearFormula2 items · Recurring fees and levies
OtherUSD 83–7042 items · Mandatory charges that arise in operation
FSCA application fees are modest (ZAR 2,697 to 61,692), but annual FSCA levies scale with the number of key individuals and representatives and, for discretionary managers, with assets under management (capped at about ZAR 2.78 million). Separate levies apply to ODPs and CIS managers, and FAIS Ombud and FIC obligations add further cost.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| FAIS FSP authorization application, Category ICrypto asset FSPs apply under Category I (subcategory 1.27) or Category II; a Category II crypto applicant pays the Category II fee (ZAR 16,313). FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 2,697≈ USD 154 | FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund; FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | From a secondary source |
| FAIS FSP authorization application, Category IISame fee for Category IIA. FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 16,313≈ USD 932 | FAIS Category II FSP (discretionary) | From a secondary source |
| FAIS FSP authorization application, Category IIA (hedge fund FSP)FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 16,313≈ USD 932 | FAIS Category IIA FSP (hedge fund FSP) | From a secondary source |
| FAIS FSP authorization application, Category IIIFSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 49,015≈ USD 3 k | FAIS Category III FSP (administrative FSP / LISP) | From a secondary source |
| FAIS FSP authorization application, Category IVFSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 2,697≈ USD 154 | FAIS Category IV FSP (assistance business) | From a secondary source |
| OTC derivative provider authorization application (Financial Markets Act)FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 53,000≈ USD 3 k | Authorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018 | From a secondary source |
| CIS manager registration application (incl. one portfolio)Same fee for securities, property, participation bond and hedge fund CIS managers. Change in controlling shareholding of a CIS manager ZAR 12,137. FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 61,692≈ USD 4 k | Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002); Manager of a hedge fund CIS (CISCA declaration of hedge funds, 2015): Retail Hedge Fund (RHF) and Qualified Investor Hedge Fund (QIHF) portfolios | From a secondary source |
| Market infrastructure license application (Financial Markets Act)The notice lists this as a market infrastructure license fee and does not use the word exchange; applying it to an exchange license is an inference. FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 477,000≈ USD 27 k | Exchange license, Financial Markets Act 2012 | To be confirmed |
| Every year | |||
| FSCA levy, FAIS Category I or IV FSP (2025/26)Levied under Schedule 2 of the Financial Sector and Deposit Insurance Levies Act; 2025/26 figures as proposed in GN 6590 (9 September 2025), up 5% from ZAR 3,816 and ZAR 551.20. Maximum levy per FSP ZAR 2,782,500. The 7.5% special levy ends in 2025/26. 2026/27 figures were not confirmed. | ZAR 4,006.80 base plus ZAR 578.76 per key individual and representative | FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund; FAIS Category IV FSP (assistance business); FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | From a secondary source |
| FSCA levy, FAIS Category II, IIA or III FSP (2025/26)2025/26 figures as proposed in GN 6590 (9 September 2025), up from ZAR 7,950 and 0.0019711%. Maximum levy per FSP ZAR 2,782,500. Separate levy formulas apply to ODPs, CIS managers and exchanges and were not captured. 2026/27 figures were not confirmed. | ZAR 8,347.50 base plus a per-KI/representative amount plus 0.0020697% of assets under management | FAIS Category II FSP (discretionary); FAIS Category IIA FSP (hedge fund FSP); FAIS Category III FSP (administrative FSP / LISP); FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022) | From a secondary source |
| Other | |||
| FAIS key individual approvalAmendment of categories or subcategories ZAR 1,595 (10% discount for Categories I, II, IIA and IV, 20% for Category III, when added to another application or by an existing FSP). FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 1,460 per key individual≈ USD 83 | FAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fund; FAIS Category II FSP (discretionary); FAIS Category IIA FSP (hedge fund FSP); FAIS Category III FSP (administrative FSP / LISP) and 2 more | From a secondary source |
| Approval of a significant owner (Financial Sector Regulation Act)FSCA Determination of Fees 2024 (General Notice 1 of 2024), in force 1 October 2024 after a 6% increase; no later fee determination was found, so check the FSCA site for a 2025 or 2026 update. | ZAR 12,317≈ USD 704 | All categories | From a secondary source |
Threshold
Minimum capital, category by category
Middle halfMedian USD 99 k
CIS manager (ManCo)Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002)
USD 57 k
Hedge fund CIS managerManager of a hedge fund CIS (CISCA declaration of hedge funds, 2015): Retail Hedge Fund (RHF) and Qualified Investor Hedge Fund (QIHF) portfolios
USD 57 k
Hedge fund managerFAIS Category IIA FSP (hedge fund FSP)
USD 171 k
Investment administration platformFAIS Category III FSP (administrative FSP / LISP)
USD 171 k
10k100k1m
4 of 10 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
10 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Advice and intermediary FSPFAIS Category I FSP (non-discretionary), relevant subcategories incl. 1.8 Shares, 1.12 Bonds, 1.13 Derivative instruments, 1.14 Participatory interests in CIS, 1.15 Forex investment business, 1.26 Participatory interests in a hedge fundNo fixed figureMinimum capital
- Permits
- Rendering advice and/or intermediary services (other than discretionary management) on the financial products in the licensed subcategories.
- Minimum capital
- No fixed rand minimum. If the FSP does not hold client assets: assets must at all times exceed liabilities (BN 194 of 2017, s.45). If it holds or controls client assets or premiums: current assets must exceed current liabilities and liquid assets must be at least 4/52 of annual expenditure (BN 194 of 2017, s.48 and Table B).
- Fees
- FAIS FSP authorization application, Category IZAR 2,697FAIS key individual approvalZAR 1,460 per key individualApproval of a significant owner (Financial Sector Regulation Act)ZAR 12,317FSCA levy, FAIS Category I or IV FSP (2025/26)ZAR 4,006.80 base plus ZAR 578.76 per key individual and representative
- Clients
- Retail permitted
- Conditions
- Key individual and representatives must meet FAIS fit-and-proper requirements (honesty, competence incl. RE exams and class-of-business training, experience, operational ability, financial soundness). A FAIS license does not allow a firm to issue CFDs or other OTC derivatives as principal: that requires ODP authorization under the FMA. The common South African retail CFD model is a FAIS-licensed FSP distributing the products of an authorized ODP.
- Systems
- Retail BrokeragePrivate BrokerageWhite-Label BrokerageInvestment Advisory Firm
- Reading
- Read in the rulebook
- Sources
02Discretionary investment managerFAIS Category II FSP (discretionary)No fixed figureMinimum capital
- Permits
- Discretionary management of clients' investments in the licensed product subcategories, including managing CIS portfolios on mandate from a CIS manager and segregated mandates.
- Minimum capital
- No fixed rand minimum. Assets must exceed liabilities, current assets must exceed current liabilities, and liquid assets must be at least 8/52 of annual expenditure (BN 194 of 2017, s.48 and Table B).
- Fees
- FAIS FSP authorization application, Category IIZAR 16,313FAIS key individual approvalZAR 1,460 per key individualApproval of a significant owner (Financial Sector Regulation Act)ZAR 12,317FSCA levy, FAIS Category II, IIA or III FSP (2025/26)ZAR 8,347.50 base plus a per-KI/representative amount plus 0.0020697% of assets under management
- Clients
- Retail permitted
- Conditions
- Experience and qualification requirements for key individuals are stricter than Category I. Half-yearly liquidity (Form A) submissions. Private equity and venture capital managers in South Africa typically hold Category I or II licenses for the fund-management activity; the fund vehicles themselves (often en commandite partnerships) are not licensed.
- Systems
- Asset Management CompanyWealth Management FirmMulti-Family OfficePension & Endowment ManagerPrivate Equity FirmVenture Capital FirmPrivate Credit FundQuantitative Trading Desk
- Reading
- Read in the rulebook
- Sources
03Hedge fund managerFAIS Category IIA FSP (hedge fund FSP)USD 171 kMinimum capital
- Permits
- Discretionary management of hedge fund portfolios, i.e. strategies using leverage or net short positions.
- Minimum capital
- Assets must exceed liabilities by at least ZAR 3 million; current assets must exceed current liabilities; liquid assets of at least 13/52 of annual expenditure (BN 194 of 2017, s.48 and Table B). (≈USD 171 k)
- Fees
- FAIS FSP authorization application, Category IIA (hedge fund FSP)ZAR 16,313FAIS key individual approvalZAR 1,460 per key individualApproval of a significant owner (Financial Sector Regulation Act)ZAR 12,317FSCA levy, FAIS Category II, IIA or III FSP (2025/26)ZAR 8,347.50 base plus a per-KI/representative amount plus 0.0020697% of assets under management
- Clients
- Retail, with conditions
- Conditions
- Requires three years of Category IIA experience for the FSP and its representatives and one year of management experience for key individuals (BN 194 of 2017, s.19). Retail access is only through a Retail Hedge Fund CIS portfolio under CISCA; otherwise qualified investors only.
- Systems
- Hedge FundQuantitative Trading Desk
- Reading
- Read in the rulebook
- Sources
04Investment administration platformFAIS Category III FSP (administrative FSP / LISP)USD 171 kMinimum capital
- Permits
- Administrative FSP services, chiefly linked investment service provider (LISP) platforms that administer investments on behalf of clients and product suppliers.
- Minimum capital
- Assets must exceed liabilities by at least ZAR 3 million; current assets must exceed current liabilities; liquid assets of at least 13/52 of annual expenditure (BN 194 of 2017, s.48 and Table B). (≈USD 171 k)
- Fees
- FAIS FSP authorization application, Category IIIZAR 49,015FAIS key individual approvalZAR 1,460 per key individualApproval of a significant owner (Financial Sector Regulation Act)ZAR 12,317FSCA levy, FAIS Category II, IIA or III FSP (2025/26)ZAR 8,347.50 base plus a per-KI/representative amount plus 0.0020697% of assets under management
- Clients
- Retail permitted
- Conditions
- Platform administration only; investment decisions require Category II. Not the primary license for any of the 47 systems, but often part of a wealth-platform build.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
05Assistance business FSPFAIS Category IV FSP (assistance business)No fixed figureMinimum capital
- Permits
- Intermediary services related to assistance policies (e.g. funeral cover) under the Insurance Act.
- Minimum capital
- No fixed rand minimum. Current assets must exceed current liabilities; liquid assets of at least 4/52 of annual expenditure (BN 194 of 2017, s.48 and Table B).
- Fees
- FAIS FSP authorization application, Category IVZAR 2,697FAIS key individual approvalZAR 1,460 per key individualApproval of a significant owner (Financial Sector Regulation Act)ZAR 12,317FSCA levy, FAIS Category I or IV FSP (2025/26)ZAR 4,006.80 base plus ZAR 578.76 per key individual and representative
- Clients
- Retail permitted
- Conditions
- Listed for completeness. Not relevant to the 47 systems.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
06Crypto asset service provider (CASP)FAIS FSP with subcategory 1.27 / Category II crypto assets (crypto assets declared a financial product, October 2022)No fixed figureMinimum capital
- Permits
- Advice, intermediary services and (with Category II) discretionary management in relation to crypto assets, which the FSCA declared a financial product under FAIS in October 2022.
- Minimum capital
- No separate crypto capital figure. Financial soundness follows the FAIS category held (Category I with client assets: liquid assets of at least 4/52 of annual expenditure; Category II: 8/52) (BN 194 of 2017, Table B).
- Fees
- FAIS FSP authorization application, Category IZAR 2,697FAIS key individual approvalZAR 1,460 per key individualApproval of a significant owner (Financial Sector Regulation Act)ZAR 12,317FSCA levy, FAIS Category I or IV FSP (2025/26)ZAR 4,006.80 base plus ZAR 578.76 per key individual and representativeFSCA levy, FAIS Category II, IIA or III FSP (2025/26)ZAR 8,347.50 base plus a per-KI/representative amount plus 0.0020697% of assets under management
- Clients
- Retail permitted
- Conditions
- Existing crypto businesses had to apply within a transition window that closed on 30 November 2023. CASPs are also accountable institutions under the Financial Intelligence Centre Act. There is no separate exchange or custodian license; exchanges, brokers and custodial wallet providers serving South African clients apply for FAIS licenses with the crypto subcategory. Cross-border crypto flows also fall under SARB exchange control.
- Systems
- Digital Asset ExchangeOTC Digital Asset DeskCustody & Wallet InfrastructureDigital Asset Fund
- Reading
- From a secondary source
- Sources
07OTC derivative providerAuthorized OTC Derivative Provider (ODP), Financial Markets Act 2012 and FMA Regulations 2018; criteria in FSCA Conduct Standard 1 of 2018No fixed figureMinimum capital
- Permits
- Acting as principal, as a regular feature of the business, in originating, issuing or selling OTC derivatives (including CFDs and rolling spot FX) or making a market in them.
- Minimum capital
- No fixed rand minimum was found. The FMA Regulations 2018 (GN R98) set no ODP capital figure (regs 2-5 cover authorization, reporting and clearing only). The authorization criteria, as summarized by practitioners, require sufficient operational capital and liquid net assets to operate for at least 6 months (assets liquid within 5 business days) plus a viable plan to raise more equity; non-bank applicants also file a capital adequacy form.
- Fees
- OTC derivative provider authorization application (Financial Markets Act)ZAR 53,000Approval of a significant owner (Financial Sector Regulation Act)ZAR 12,317
- Clients
- Retail permitted
- Conditions
- Required for any firm that issues CFDs as principal. Retail distribution also needs a FAIS license (own or a partner FSP). ODPs must report to an authorized trade repository and are subject to Joint Standard 2 of 2020 (margin for non-centrally cleared OTC derivatives). In August 2025 the FSCA said it is developing bank-like capital requirements for non-bank ODPs and mandatory central clearing for some products, possibly within three years; no draft standard with figures was found. Approval history is slow, and most retail CFD brands operate as FAIS FSPs on a third-party ODP. The 6-month liquid-assets test comes from a secondary summary of the criteria, not the FSCA text itself.
- Systems
- Retail BrokerageMulti-Asset BrokerageInstitutional BrokeragePrime-of-PrimeStructured Products Issuer
- Reading
- From a secondary source
- Sources
08CIS manager (ManCo)Manager of a collective investment scheme in securities / property / participation bonds (registration under CISCA 2002)USD 57 kMinimum capital
- Permits
- Operating and administering registered collective investment schemes (unit trusts) offered to the public, including JSE-listed exchange-traded CIS portfolios and property CIS.
- Minimum capital
- Board Notice 91 of 2014 (CISCA s.88, Gazette 37895, 8 August 2014) for managers of CIS in securities: basic capital equal to 13 weeks' fixed expenditure (previous year's expenses divided by four), held liquid and invested only in a money market portfolio; seed capital of ZAR 1 million in each portfolio, withdrawable once the portfolio reaches ZAR 50 million NAV; position risk capital where the manager deals for own account (10% money market, 15% income, 25% other portfolios); professional indemnity or fidelity cover of at least ZAR 5 million. (≈USD 57 k)
- Fees
- CIS manager registration application (incl. one portfolio)ZAR 61,692Approval of a significant owner (Financial Sector Regulation Act)ZAR 12,317
- Clients
- Retail permitted
- Conditions
- Each portfolio needs FSCA approval and a trustee or custodian (usually a bank). Investment management of portfolios is often delegated to a FAIS Category II FSP. Foreign CIS marketed in South Africa need approval under CISCA s.65. Capital returns are monthly, within 14 business days of month-end (BN 91 para 3). BN 91 covers CIS in securities; separate determinations apply to property and participation bond schemes and were not checked here. The ZAR 1 million is seed capital per portfolio, not a single entity-level floor.
- Systems
- Mutual Fund & UCITSFund Management CompanyAsset Management CompanyETF PlatformReal Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
09Hedge fund CIS managerManager of a hedge fund CIS (CISCA declaration of hedge funds, 2015): Retail Hedge Fund (RHF) and Qualified Investor Hedge Fund (QIHF) portfoliosUSD 57 kMinimum capital
- Permits
- Operating hedge fund portfolios as regulated CIS, either open to the public (RHF) or limited to qualified investors (QIHF).
- Minimum capital
- Board Notice 84 of 2015 (CISCA s.88, Gazette 38693, 17 April 2015): basic capital equal to 13 weeks' fixed expenditure, held liquid in a money market portfolio; seed capital of ZAR 1 million in each portfolio; position risk capital where the manager deals in its own scheme's participatory interests (35% QIHF, 40% RHF); professional indemnity or fidelity cover of at least ZAR 5 million. (≈USD 57 k)
- Fees
- CIS manager registration application (incl. one portfolio)ZAR 61,692Approval of a significant owner (Financial Sector Regulation Act)ZAR 12,317
- Clients
- Retail, with conditions
- Conditions
- Retail Hedge Fund portfolios carry tighter leverage, liquidity and concentration limits; QIHF portfolios are for qualified investors only. The portfolio manager needs a FAIS Category IIA license. No single entity-level rand floor; the ZAR 1 million is per portfolio.
- Systems
- Hedge Fund
- Reading
- Read in the rulebook
- Sources
10Licensed exchangeExchange license, Financial Markets Act 2012No fixed figureMinimum capital
- Permits
- Operating a market where securities, including derivative instruments, are traded under exchange rules.
- Minimum capital
- No fixed rand minimum. FMA Regulations 2018 (GN R98), reg. 8: capital, retained earnings and reserves proportional to risk, and liquid net assets funded by equity in South Africa equal to at least six months of operating expenses (more if the risk profile requires), plus a board-approved plan to raise further equity; quarterly reporting to the Authority (reg. 8(2)).
- Fees
- Market infrastructure license application (Financial Markets Act)ZAR 477,000Approval of a significant owner (Financial Sector Regulation Act)ZAR 12,317
- Clients
- Retail, with conditions
- Conditions
- Licensed by the FSCA with Prudential Authority involvement for market infrastructures. Several smaller exchanges have been licensed alongside the JSE. The same reg. 8 test applies to CSDs, clearing houses and trade repositories.
- Systems
- ECN & DMA Venue
- Reading
- Read in the rulebook
- Sources
Reach
None. South African licenses do not passport. Offshore firms serving South African clients generally need a local FAIS license or must act through a licensed local FSP; foreign CIS marketed to the public need FSCA approval under CISCA s.65.
Passage
No statutory decision deadline was confirmed for FAIS or ODP applications. Market practice: several months for a FAIS license; ODP authorization has been much slower (the FSCA closed the first ODP application window on 14 June 2019, and by April 2021 only six ODPs, all large banks, were listed as approved).
Licensed elsewhere
Banks, including digital banks and mutual banks, are registered by the Prudential Authority under the Banks Act (private-bank, digital-bank, investment-bank, correspondent-banking, treasury-desk, trade-finance). Insurers and reinsurers are licensed by the Prudential Authority under the Insurance Act 2017 (insurance-vehicle). Payments, clearing and settlement are overseen by the SARB under the National Payment System Act, with participation managed through PASA (psp, emi, card-issuing, merchant-acquiring). Cross-border money transfer and foreign-exchange dealing require SARB Financial Surveillance appointment as an Authorized Dealer or an Authorized Dealer in foreign exchange with Limited Authority (msb). Lending is registered with the National Credit Regulator (private-credit lending activity). Islamic banking runs through PA-registered banks. No licensing regime applies to stablecoin issuance or crypto mining, and no specific regime covers sovereign vehicles or single-family offices (an SFO that manages only family wealth may fall outside FAIS).
Notes. Crypto assets were declared a financial product under FAIS in October 2022, and CASPs were added as accountable institutions under the FIC Act. FAIS fit-and-proper requirements are in Board Notice 194 of 2017 as amended in 2020. The Conduct of Financial Institutions (COFI) Bill would replace FAIS licensing with activity-based licensing; its enactment status should be checked before planning a long build. CIS and hedge fund manager capital comes from BN 91 of 2014 and BN 84 of 2015. No fixed rand capital figure exists for ODPs; in August 2025 the FSCA signaled bank-like capital rules for non-bank ODPs, not yet published as of October 2026. In August 2026 the FSCA and PA consulted on a QPMM reporting notice for ODPs (comments by 12 October 2026). USD conversions use about ZAR 17.5 per USD.
Africa · Mauritius
FSC Mauritius
Financial Services Commission
The FSC is the integrated non-bank regulator of Mauritius under the Financial Services Act 2007, the Securities Act 2005, the Insurance Act 2005 and the Virtual Asset and Initial Token Offering Services (VAITOS) Act 2021. It licenses investment dealers, investment advisers, CIS managers and funds, insurers, virtual asset service providers and global business companies. Cross-border structures normally run through a Global Business Company (GBC) administered by a licensed management company, and must meet substance requirements.
#19of 34
Balanced score
60 of 100
60 of 100
Scorecard
Credibility ×35%35Breadth ×15%60Entry threshold ×20%91Speed ×15%100Reach ×15%40
Categories25
Systems covered28 of 47
Typical timeline2–4 monthsmarket practice
Lowest capitalUSD 11 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 300–5 k23 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 1 k–10 k24 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
FSC fees rose across the board on 1 July 2026 (GN 119 of 2026), and a GBC pays its Global Business Licence fee (now USD 2,600) on top of the activity license fee. Fees are low in absolute terms; the real cost is substance (local directors, officers and management company).
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Processing fee, SEC-2.1A Investment Dealer (Full Service Dealer incl. Underwriting)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Other fees as prescribed under the Stock Exchange (Brokerage) Regulations 1989. | USD 3,000 (Rs 100,000 for domestic applicants) | Investment Dealer (Full Service Dealer, including Underwriting) | Read in the rulebook |
| Processing fee, SEC-2.1B Investment Dealer (Full Service Dealer excl. Underwriting)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 750 processing, USD 2,500 annual. | USD 1,000 (Rs 7,500 for domestic applicants) | Investment Dealer (Full Service Dealer, excluding Underwriting) | Read in the rulebook |
| Processing fee, SEC-2.1C Investment Dealer (Derivatives)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 1,000 (Rs 30,000 for domestic applicants) | Investment Dealer (Derivatives) | Read in the rulebook |
| Processing fee, SEC-2.2 Investment Dealer (Broker)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 500 processing, USD 2,000 annual. | USD 700 (Rs 4,500 for domestic applicants) | Investment Dealer (Broker) | Read in the rulebook |
| Processing fee, SEC-2.3 Investment Dealer (Discount Broker)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 250 processing, USD 1,500 annual. | USD 300 (Rs 2,500 for domestic applicants) | Investment Dealer (Discount Broker) | Read in the rulebook |
| Processing fee, SEC-2.4 Investment Adviser (Unrestricted)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 500 processing, USD 1,900 annual. | USD 600 (Rs 6,200 for domestic applicants) | Investment Adviser (Unrestricted) | Read in the rulebook |
| Processing fee, SEC-2.5 Investment Adviser (Restricted)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 500 processing, USD 1,200 annual. | USD 600 (Rs 5,000 for domestic applicants) | Investment Adviser (Restricted) | Read in the rulebook |
| Processing fee, SEC-2.5A Investment Adviser (Corporate Finance Advisory)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 750 processing, USD 2,500 annual. | USD 900 (Rs 9,500 for domestic applicants) | Investment Adviser (Corporate Finance Advisory) | Read in the rulebook |
| Processing fee, SEC-4.2 CIS ManagerRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 1,000 (Rs 25,000 for domestic applicants) | CIS Manager (Securities Act 2005; also manages Closed-End Funds) | Read in the rulebook |
| Processing fee, SEC-4.1 Custodian for CISRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Figures read from the 1 July 2026 consolidated text only. | USD 1,000 (Rs 32,000 for domestic applicants) | Custodian license for collective investment schemes (Securities Act 2005 s.100; Securities (CIS and CEF) Regulations 2008, reg. 7) | Read in the rulebook |
| Processing fee, FS-1.7 Custodian Services (non-CIS)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 900 (Rs 31,000 for domestic applicants) | Custodian Services (non-CIS), Financial Services Act 2007 s.14 | Read in the rulebook |
| Processing fee, FS-2.9 Payment Intermediary ServicesRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 1,000 processing, USD 1,900 annual. | USD 1,400 (Rs 25,000 for domestic applicants) | Payment Intermediary Services (Financial Services Act 2007 s.14) | Read in the rulebook |
| Processing fee, FS-1.15 Single Family OfficeRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 2,500 (Rs 100,500 for domestic applicants) | Family Office (Single) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026) | Read in the rulebook |
| Processing fee, FS-1.16 Multiple Family OfficeRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 5,000 (Rs 201,000 for domestic applicants) | Family Office (Multiple) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026) | Read in the rulebook |
| Processing fee, VA-1.1 VASP Class M (Virtual Asset Broker-Dealer)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 1,000 (Rs 45,000 for domestic applicants) | Virtual Asset Service Provider, Class M (Virtual Asset Broker-Dealer), VAITOS Act 2021 | Read in the rulebook |
| Processing fee, VA-1.2 VASP Class O (Virtual Asset Wallet Services)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 1,000 (Rs 45,000 for domestic applicants) | Virtual Asset Service Provider, Class O (Virtual Asset Wallet Services), VAITOS Act 2021 | Read in the rulebook |
| Processing fee, VA-1.3 VASP Class R (Virtual Asset Custodian)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. | USD 1,500 (Rs 70,000 for domestic applicants) | Virtual Asset Service Provider, Class R (Virtual Asset Custodian), VAITOS Act 2021 | Read in the rulebook |
| Processing fee, VA-1.4/1.5 VASP Class S (Virtual Asset Advisory Services)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. The schedule prints identical fees for VA-1.4 and VA-1.5 (advisory services and market place), so the class-letter labels in the extracted text do not affect the amount. | USD 3,000 (Rs 135,000 for domestic applicants) | Virtual Asset Service Provider, Class S (Virtual Asset Advisory Services), VAITOS Act 2021 | Read in the rulebook |
| Processing fee, VA-1.4/1.5 VASP Class I (Virtual Asset Market Place)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. The schedule prints identical fees for VA-1.4 and VA-1.5 (advisory services and market place). | USD 3,000 (Rs 135,000 for domestic applicants) | Virtual Asset Service Provider, Class I (Virtual Asset Market Place), VAITOS Act 2021 | Read in the rulebook |
| Processing fee, CI-1.1A Captive Insurance BusinessRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Non-GBL applicants pay the Rs equivalent at the Bank of Mauritius indicative rate on the payment date. | USD 1,000 | Captive Insurance (Captive Insurance Act 2015): pure captive, multi-owner pure captive, Class 1, 2 and 3 third-party captives | Read in the rulebook |
| Processing fee, CIS or closed-end fund (single fund)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Multi-fund structures: USD 1,400 for the first fund and USD 300 per additional fund. | USD 1,200 (Rs 32,000 CIS / Rs 25,000 CEF for domestic funds) | Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | Read in the rulebook |
| ITO issuer registration processing feeRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. No annual fee is listed for ITO issuers. | USD 2,000 (Rs 90,000) | Issuer of Initial Token Offerings (registration under VAITOS Act 2021) | Read in the rulebook |
| Processing fee, insurer (long-term or general, domestic)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Professional reinsurer: USD 1,000 (Rs 22,500). | Rs 102,000≈ USD 2 k | Insurer license (Insurance Act 2005): general insurance, long-term insurance, reinsurance | Read in the rulebook |
| Every year | |||
| Annual license fee, SEC-2.1A Investment Dealer (Full Service Dealer incl. Underwriting)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Other fees as prescribed under the Stock Exchange (Brokerage) Regulations 1989. Late payment: +25% within one month, then +1% a month. | USD 9,500 (Rs 290,000 for domestic licensees) | Investment Dealer (Full Service Dealer, including Underwriting) | Read in the rulebook |
| Annual license fee, SEC-2.1B Investment Dealer (Full Service Dealer excl. Underwriting)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 750 processing, USD 2,500 annual. Late payment: +25% within one month, then +1% a month. | USD 3,400 (Rs 75,000 for domestic licensees) | Investment Dealer (Full Service Dealer, excluding Underwriting) | Read in the rulebook |
| Annual license fee, SEC-2.1C Investment Dealer (Derivatives)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 3,000 (Rs 90,000 for domestic licensees) | Investment Dealer (Derivatives) | Read in the rulebook |
| Annual license fee, SEC-2.2 Investment Dealer (Broker)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 500 processing, USD 2,000 annual. Late payment: +25% within one month, then +1% a month. | USD 2,700 (Rs 54,000 for domestic licensees) | Investment Dealer (Broker) | Read in the rulebook |
| Annual license fee, SEC-2.3 Investment Dealer (Discount Broker)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 250 processing, USD 1,500 annual. Late payment: +25% within one month, then +1% a month. | USD 2,000 (Rs 45,000 for domestic licensees) | Investment Dealer (Discount Broker) | Read in the rulebook |
| Annual license fee, SEC-2.4 Investment Adviser (Unrestricted)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 500 processing, USD 1,900 annual. Late payment: +25% within one month, then +1% a month. | USD 2,400 (Rs 71,000 for domestic licensees) | Investment Adviser (Unrestricted) | Read in the rulebook |
| Annual license fee, SEC-2.5 Investment Adviser (Restricted)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 500 processing, USD 1,200 annual. Late payment: +25% within one month, then +1% a month. | USD 1,500 (Rs 36,000 for domestic licensees) | Investment Adviser (Restricted) | Read in the rulebook |
| Annual license fee, SEC-2.5A Investment Adviser (Corporate Finance Advisory)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 750 processing, USD 2,500 annual. Late payment: +25% within one month, then +1% a month. | USD 3,100 (Rs 94,000 for domestic licensees) | Investment Adviser (Corporate Finance Advisory) | Read in the rulebook |
| Annual license fee, SEC-4.2 CIS ManagerRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 2,500 (Rs 75,000 for domestic licensees) | CIS Manager (Securities Act 2005; also manages Closed-End Funds) | Read in the rulebook |
| Annual license fee, SEC-4.1 Custodian for CISRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Figures read from the 1 July 2026 consolidated text only. Late payment: +25% within one month, then +1% a month. | USD 2,500 (Rs 94,000 for domestic licensees) | Custodian license for collective investment schemes (Securities Act 2005 s.100; Securities (CIS and CEF) Regulations 2008, reg. 7) | Read in the rulebook |
| Annual license fee, FS-1.7 Custodian Services (non-CIS)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 1,700 (Rs 71,000 for domestic licensees) | Custodian Services (non-CIS), Financial Services Act 2007 s.14 | Read in the rulebook |
| Annual license fee, FS-2.9 Payment Intermediary ServicesRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Before 1 July 2026: USD 1,000 processing, USD 1,900 annual. Late payment: +25% within one month, then +1% a month. | USD 2,600 (Rs 57,000 for domestic licensees) | Payment Intermediary Services (Financial Services Act 2007 s.14) | Read in the rulebook |
| Annual license fee, FS-1.15 Single Family OfficeRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 4,000 (Rs 161,000 for domestic licensees) | Family Office (Single) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026) | Read in the rulebook |
| Annual license fee, FS-1.16 Multiple Family OfficeRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 10,000 (Rs 402,000 for domestic licensees) | Family Office (Multiple) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026) | Read in the rulebook |
| Annual license fee, VA-1.1 VASP Class M (Virtual Asset Broker-Dealer)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 2,000 (Rs 90,000 for domestic licensees) | Virtual Asset Service Provider, Class M (Virtual Asset Broker-Dealer), VAITOS Act 2021 | Read in the rulebook |
| Annual license fee, VA-1.2 VASP Class O (Virtual Asset Wallet Services)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 1,900 (Rs 85,000 for domestic licensees) | Virtual Asset Service Provider, Class O (Virtual Asset Wallet Services), VAITOS Act 2021 | Read in the rulebook |
| Annual license fee, VA-1.3 VASP Class R (Virtual Asset Custodian)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Late payment: +25% within one month, then +1% a month. | USD 2,500 (Rs 110,000 for domestic licensees) | Virtual Asset Service Provider, Class R (Virtual Asset Custodian), VAITOS Act 2021 | Read in the rulebook |
| Annual license fee, VA-1.4/1.5 VASP Class S (Virtual Asset Advisory Services)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. The schedule prints identical fees for VA-1.4 and VA-1.5 (advisory services and market place), so the class-letter labels in the extracted text do not affect the amount. Late payment: +25% within one month, then +1% a month. | USD 5,000 (Rs 220,000 for domestic licensees) | Virtual Asset Service Provider, Class S (Virtual Asset Advisory Services), VAITOS Act 2021 | Read in the rulebook |
| Annual license fee, VA-1.4/1.5 VASP Class I (Virtual Asset Market Place)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. The schedule prints identical fees for VA-1.4 and VA-1.5 (advisory services and market place). Late payment: +25% within one month, then +1% a month. | USD 5,000 (Rs 220,000 for domestic licensees) | Virtual Asset Service Provider, Class I (Virtual Asset Market Place), VAITOS Act 2021 | Read in the rulebook |
| Annual license fee, CI-1.1A Captive Insurance BusinessRevised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Non-GBL applicants pay the Rs equivalent at the Bank of Mauritius indicative rate on the payment date. Late payment: +25% within one month, then +1% a month. | USD 2,000 | Captive Insurance (Captive Insurance Act 2015): pure captive, multi-owner pure captive, Class 1, 2 and 3 third-party captives | Read in the rulebook |
| Annual license fee, CIS or closed-end fund (single fund)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Multi-fund: USD 4,000 first fund, USD 600 per additional fund. Special Purpose Fund or REIT authorization adds Rs 200,000 a year (USD 6,300 for a CIS, USD 5,000 for a CEF). | USD 3,700 (Rs 112,000 CIS / Rs 90,000 CEF for domestic funds) | Collective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company) | Read in the rulebook |
| Global Business Licence annual feeRaised from USD 1,950 with effect from 1 July 2026. Payable by every GBC, so a GBC that also holds an FSC business license (investment dealer, CIS manager, VASP) pays it on top of that license fee. Late scale: USD 3,250 within one month, USD 3,900 at 1 to 3 months, USD 5,200 at 3 to 6 months; license lapses after 6 months unpaid. The 1 July 2026 consolidated text shows a GBL processing fee of USD 600 (previously USD 500); not cross-checked. | USD 2,600 | Global Business Licence (Global Business Company, GBC), Financial Services Act 2007 s.71 | Read in the rulebook |
| Authorized Company annual feeRaised from USD 350 with effect from 1 July 2026; excludes the USD 65 Registrar of Companies fee. Late scale up to USD 2,800. | USD 1,400 | Authorized Company (Financial Services Act 2007 s.71A) | Read in the rulebook |
| Annual fee, insurer (long-term or general, domestic)Revised First Schedule (GN 119 of 2026) in force 1 July 2026. USD fees apply to Global Business Licence applicants and holders; domestic applicants pay the Rs figure. Professional reinsurer: USD 1,900 (Rs 52,000) annual. | Rs 169,000 fixed plus 0.35% of gross premium (paid quarterly)≈ USD 4 k | Insurer license (Insurance Act 2005): general insurance, long-term insurance, reinsurance | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 43 k
Investment adviser (advice only)Investment Adviser (Restricted)
USD 11 k
Execution-only brokerInvestment Dealer (Discount Broker)
USD 13 k
Investment adviser with discretionary managementInvestment Adviser (Unrestricted)
USD 13 k
BrokerInvestment Dealer (Broker)
USD 15 k
Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting)
USD 22 k
Derivatives dealerInvestment Dealer (Derivatives)
USD 22 k
Corporate finance adviserInvestment Adviser (Corporate Finance Advisory)
USD 22 k
CIS / CEF managerCIS Manager (Securities Act 2005; also manages Closed-End Funds)
USD 22 k
VA broker-dealerVirtual Asset Service Provider, Class M (Virtual Asset Broker-Dealer), VAITOS Act 2021
USD 43 k
Payment intermediaryPayment Intermediary Services (Financial Services Act 2007 s.14)
USD 43 k
Multi-family officeFamily Office (Multiple) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026)
USD 50 k
Captive insurerCaptive Insurance (Captive Insurance Act 2015): pure captive, multi-owner pure captive, Class 1, 2 and 3 third-party captives
USD 65 k
VA custodianVirtual Asset Service Provider, Class R (Virtual Asset Custodian), VAITOS Act 2021
USD 109 k
VA exchangeVirtual Asset Service Provider, Class I (Virtual Asset Market Place), VAITOS Act 2021
USD 141 k
Full-service dealer with underwritingInvestment Dealer (Full Service Dealer, including Underwriting)
USD 217 k
CIS custodianCustodian license for collective investment schemes (Securities Act 2005 s.100; Securities (CIS and CEF) Regulations 2008, reg. 7)
USD 217 k
Insurer / reinsurerInsurer license (Insurance Act 2005): general insurance, long-term insurance, reinsurance
USD 543 k
10k100k1m
17 of 25 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
25 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Full-service dealer with underwritingInvestment Dealer (Full Service Dealer, including Underwriting)USD 217 kMinimum capital
- Permits
- Dealing in securities as agent and principal, underwriting and distributing securities for issuers, giving ancillary advice, and managing client portfolios.
- Minimum capital
- MUR 10,000,000 minimum stated unimpaired capital, fully paid (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 217 k)
- Fees
- Processing fee, SEC-2.1A Investment Dealer (Full Service Dealer incl. Underwriting)USD 3,000 (Rs 100,000 for domestic applicants)Annual license fee, SEC-2.1A Investment Dealer (Full Service Dealer incl. Underwriting)USD 9,500 (Rs 290,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Professional indemnity cover is required. At least two officers with relevant experience. GBC licensees must meet substance requirements under FSA 2007 s.71.
- Systems
- Multi-Asset BrokerageInvestment BankInstitutional BrokerageStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
02Full-service dealerInvestment Dealer (Full Service Dealer, excluding Underwriting)USD 22 kMinimum capital
- Permits
- Dealing in securities as agent and as principal for resale to clients, giving ancillary advice and managing client portfolios. No underwriting.
- Minimum capital
- MUR 1,000,000 minimum stated unimpaired capital (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 22 k)
- Fees
- Processing fee, SEC-2.1B Investment Dealer (Full Service Dealer excl. Underwriting)USD 1,000 (Rs 7,500 for domestic applicants)Annual license fee, SEC-2.1B Investment Dealer (Full Service Dealer excl. Underwriting)USD 3,400 (Rs 75,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- This is the usual Mauritius license for FX/CFD brokers that take the other side of client trades (market-making or hybrid models). No statutory retail leverage cap was identified. Requires professional indemnity cover, compliance officer, MLRO and deputy MLRO, and Mauritius substance if held through a GBC.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokeragePrime-of-Prime
- Reading
- Read in the rulebook
- Sources
03BrokerInvestment Dealer (Broker)USD 15 kMinimum capital
- Permits
- Executing client orders as agent, and, as stated in the application, managing client portfolios and advising on securities transactions. No dealing as principal.
- Minimum capital
- MUR 700,000 minimum stated unimpaired capital (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 15 k)
- Fees
- Processing fee, SEC-2.2 Investment Dealer (Broker)USD 700 (Rs 4,500 for domestic applicants)Annual license fee, SEC-2.2 Investment Dealer (Broker)USD 2,700 (Rs 54,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Agency only. Representatives and officers must meet minimum competency standards.
- Systems
- Private BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
04Execution-only brokerInvestment Dealer (Discount Broker)USD 13 kMinimum capital
- Permits
- Executing client orders without giving advice.
- Minimum capital
- MUR 600,000 minimum stated unimpaired capital (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 13 k)
- Fees
- Processing fee, SEC-2.3 Investment Dealer (Discount Broker)USD 300 (Rs 2,500 for domestic applicants)Annual license fee, SEC-2.3 Investment Dealer (Discount Broker)USD 2,000 (Rs 45,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Execution-only agency model, for example STP/agency routing to a third-party liquidity provider. No principal dealing and no advice.
- Systems
- Retail BrokerageWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
05Derivatives dealerInvestment Dealer (Derivatives)USD 22 kMinimum capital
- Permits
- Acting as an intermediary in the execution of client orders in derivatives contracts only, and acting as a market maker admitted by an FSC-licensed securities exchange in futures contracts (Securities (Licensing) Rules 2007, rule 4(1)(d), as replaced by GN 246 of 2019).
- Minimum capital
- MUR 1,000,000 minimum stated unimpaired capital at all times (Securities (Licensing) (Amendment) Rules 2019, GN 246 of 2019, Fourth Schedule). (≈USD 22 k)
- Fees
- Processing fee, SEC-2.1C Investment Dealer (Derivatives)USD 1,000 (Rs 30,000 for domestic applicants)Annual license fee, SEC-2.1C Investment Dealer (Derivatives)USD 3,000 (Rs 90,000 for domestic licensees)
- Clients
- Retail, with conditions
- Conditions
- Created with effect from 16 November 2019, replacing the former Commodity Derivatives Segment, Currency Derivatives Segment and Equity Segment dealer categories, so one license covers derivatives on any underlying. Only a body corporate may apply; it must employ a licensed representative at all times unless it holds a Global Business Licence. The scope is agency execution and exchange market making in derivatives; it does not cover dealing in securities or underwriting. Whether it suits an OTC CFD book run as principal was not confirmed; offshore FX/CFD brokers in Mauritius more commonly hold the Full Service Dealer (excluding Underwriting) license (market practice).
- Systems
- Multi-Asset BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
06Investment adviser with discretionary managementInvestment Adviser (Unrestricted)USD 13 kMinimum capital
- Permits
- Giving investment advice on securities and managing portfolios of securities under a discretionary mandate.
- Minimum capital
- MUR 600,000 minimum stated unimpaired capital (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 13 k)
- Fees
- Processing fee, SEC-2.4 Investment Adviser (Unrestricted)USD 600 (Rs 6,200 for domestic applicants)Annual license fee, SEC-2.4 Investment Adviser (Unrestricted)USD 2,400 (Rs 71,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Common license for wealth managers and multi-family offices; portfolio management mandates are discretionary.
- Systems
- Wealth Management FirmMulti-Family OfficeInvestment Advisory FirmAsset Management Company
- Reading
- Read in the rulebook
- Sources
07Investment adviser (advice only)Investment Adviser (Restricted)USD 11 kMinimum capital
- Permits
- Giving investment advice on securities without managing client portfolios.
- Minimum capital
- MUR 500,000 minimum stated unimpaired capital (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 11 k)
- Fees
- Processing fee, SEC-2.5 Investment Adviser (Restricted)USD 600 (Rs 5,000 for domestic applicants)Annual license fee, SEC-2.5 Investment Adviser (Restricted)USD 1,500 (Rs 36,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Often used as the sub-adviser to a CIS manager.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
08Corporate finance adviserInvestment Adviser (Corporate Finance Advisory)USD 22 kMinimum capital
- Permits
- Corporate finance advice, such as advice on capital raising, listings, and mergers and acquisitions.
- Minimum capital
- MUR 1,000,000 minimum stated unimpaired capital (Securities (Licensing) Rules 2007, Rule 14 and Fourth Schedule). (≈USD 22 k)
- Fees
- Processing fee, SEC-2.5A Investment Adviser (Corporate Finance Advisory)USD 900 (Rs 9,500 for domestic applicants)Annual license fee, SEC-2.5A Investment Adviser (Corporate Finance Advisory)USD 3,100 (Rs 94,000 for domestic licensees)
- Clients
- Professional only
- Conditions
- Advisory boutique model; underwriting requires the full-service dealer (including underwriting) license.
- Systems
- Investment Bank
- Reading
- Read in the rulebook
- Sources
09CIS / CEF managerCIS Manager (Securities Act 2005; also manages Closed-End Funds)USD 22 kMinimum capital
- Permits
- Managing collective investment schemes and closed-end funds (retail, professional, expert and specialized schemes), including the investment management of the fund.
- Minimum capital
- MUR 1,000,000 minimum stated unimpaired capital (stated capital plus revenue reserves) at all times (CIS Regulations 2008, reg. 38; FSC CIS Manager licensing criteria). (≈USD 22 k)
- Fees
- Processing fee, SEC-4.2 CIS ManagerUSD 1,000 (Rs 25,000 for domestic applicants)Annual license fee, SEC-4.2 CIS ManagerUSD 2,500 (Rs 75,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- A domestic company must have two full-time officers in Mauritius familiar with CIS management. A GBC manager must meet FSA 2007 s.71(3)(a) substance. Auditor approval by the FSC. There is no separate CEF manager license: closed-end funds are managed by a licensed CIS manager. Funds can invest in digital assets under FSC guidance for sophisticated and expert investors.
- Systems
- Fund Management CompanyAsset Management CompanyHedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleMutual Fund & UCITSDigital Asset Fund
- Reading
- Read in the rulebook
- Sources
10Fund vehicleCollective Investment Scheme or Closed-End Fund authorization (incl. Expert Fund, Professional CIS, Specialised CIS; may be a Variable Capital Company)No fixed figureMinimum capital
- Permits
- Authorization of the fund vehicle itself, open-ended (CIS) or closed-ended (CEF), for retail or sophisticated investors.
- Minimum capital
- No minimum capital for the fund vehicle was identified; capital requirements fall on the manager.
- Fees
- Processing fee, CIS or closed-end fund (single fund)USD 1,200 (Rs 32,000 CIS / Rs 25,000 CEF for domestic funds)Annual license fee, CIS or closed-end fund (single fund)USD 3,700 (Rs 112,000 CIS / Rs 90,000 CEF for domestic funds)
- Clients
- Retail, with conditions
- Conditions
- Retail schemes are open to the public; expert and professional schemes are restricted to qualifying investors. Requires a licensed CIS manager, custodian and administrator.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment VehicleMutual Fund & UCITSDigital Asset Fund
- Reading
- From a secondary source
- Sources
11Global business companyGlobal Business Licence (Global Business Company, GBC), Financial Services Act 2007 s.71No fixed figureMinimum capital
- Permits
- Corporate license for a Mauritius resident company that conducts business mainly outside Mauritius. Required as the base entity for most cross-border structures; financial activities need an additional FSC license.
- Minimum capital
- No minimum capital for the GBC license itself; capital requirements attach to any financial services license it holds.
- Fees
- Global Business Licence annual feeUSD 2,600
- Clients
- Professional only
- Conditions
- Must be applied for through a licensed management company. The majority of its investment must be outside Mauritius. Must meet substance requirements (resident directors, local bank account, administration in Mauritius) to access treaty benefits and the partial tax exemption.
- Systems
- Single-Family Office
- Reading
- From a secondary source
- Sources
12Authorized companyAuthorized Company (Financial Services Act 2007 s.71A)No fixed figureMinimum capital
- Permits
- Registration for a company whose place of effective management is outside Mauritius and which carries on business mainly outside Mauritius.
- Minimum capital
- No minimum capital.
- Fees
- Authorized Company annual feeUSD 1,400
- Clients
- Professional only
- Conditions
- An Authorized Company cannot conduct financial services activities (FSC Licensing FAQs). Not a license for any of the 47 systems; occasionally used as a non-financial holding or trading entity.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- From a secondary source
- Sources
13Single family officeFamily Office (Single) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026)No fixed figureMinimum capital
- Permits
- Providing family office services to one family and its structures: core services (investment oversight, policy support and portfolio management; asset and investment holding; asset, estate and real estate management; finance, accounting, cash flow and reporting) and ancillary services (governance, risk, tax and compliance, succession planning, lifestyle and concierge) under the Third Schedule.
- Minimum capital
- No minimum stated capital is set for a Single Family Office. The net value of assets under management or administration must be at least USD 5 million at all times (Family Office Rules 2026, rule 5(3)(a)), valued at fair market value or book value.
- Fees
- Processing fee, FS-1.15 Single Family OfficeUSD 2,500 (Rs 100,500 for domestic applicants)Annual license fee, FS-1.15 Single Family OfficeUSD 4,000 (Rs 161,000 for domestic licensees)
- Clients
- Professional only
- Conditions
- The 2026 Rules took effect on 1 June 2026 and revoke the 2020 Rules; existing licensees stay under the 2020 Rules until 31 December 2026 and must comply with the 2026 Rules after that (rule 16). The USD 5 million is a family-asset threshold, not capital.
- Systems
- Single-Family Office
- Reading
- Read in the rulebook
- Sources
14Multi-family officeFamily Office (Multiple) license, Financial Services Act 2007 s.14; Financial Services (Family Office) Rules 2026 (GN 62 of 2026)USD 50 kMinimum capital
- Permits
- Providing the same core and ancillary family office services as a single family office to more than one family, within the limits in the 2026 Rules (rules 3(2) and 5).
- Minimum capital
- USD 50,000 fully paid minimum stated unimpaired capital at all times (Family Office Rules 2026, rule 7(1)). Aggregate net assets under management or administration of at least USD 25 million, with at least USD 5 million per family (rule 5(3)(b)). (≈USD 50 k)
- Fees
- Processing fee, FS-1.16 Multiple Family OfficeUSD 5,000 (Rs 201,000 for domestic applicants)Annual license fee, FS-1.16 Multiple Family OfficeUSD 10,000 (Rs 402,000 for domestic licensees)
- Clients
- Professional only
- Conditions
- Effective 1 June 2026; existing licensees transition by 31 December 2026 (rule 16). The Rules also apply to holders of other licenses authorized to carry on Multiple Family Office business. Discretionary management of client portfolios beyond the Third Schedule services may still need an Investment Adviser (Unrestricted) license; confirm scope with the FSC.
- Systems
- Multi-Family Office
- Reading
- Read in the rulebook
- Sources
15VA broker-dealerVirtual Asset Service Provider, Class M (Virtual Asset Broker-Dealer), VAITOS Act 2021USD 43 kMinimum capital
- Permits
- Exchanging virtual assets for fiat or other virtual assets, and arranging or dealing in virtual assets for clients.
- Minimum capital
- MUR 2,000,000 or equivalent minimum own funds; must also hold at least one quarter of the previous year's fixed overheads if higher (VAITOS (Capital and Other Financial Requirements) Rules 2022, GN 173 of 2022, Rules 5 to 7 and Schedule). (≈USD 43 k)
- Fees
- Processing fee, VA-1.1 VASP Class M (Virtual Asset Broker-Dealer)USD 1,000 (Rs 45,000 for domestic applicants)Annual license fee, VA-1.1 VASP Class M (Virtual Asset Broker-Dealer)USD 2,000 (Rs 90,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Holding several VASP classes requires the sum of the capital for each. Intangible assets are excluded from capital. Separate risk management, custody, AML/CFT and cybersecurity rules apply.
- Systems
- OTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
16VA wallet providerVirtual Asset Service Provider, Class O (Virtual Asset Wallet Services), VAITOS Act 2021No fixed figureMinimum capital
- Permits
- Providing virtual asset wallet services.
- Minimum capital
- No fixed amount: sufficient working capital in fiat currency to continue business for 12 months under realistic scenarios; also at least one quarter of fixed overheads (GN 173 of 2022, Schedule and Rule 7).
- Fees
- Processing fee, VA-1.2 VASP Class O (Virtual Asset Wallet Services)USD 1,000 (Rs 45,000 for domestic applicants)Annual license fee, VA-1.2 VASP Class O (Virtual Asset Wallet Services)USD 1,900 (Rs 85,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Wallet services for clients; full safekeeping as custodian requires Class R.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
17VA custodianVirtual Asset Service Provider, Class R (Virtual Asset Custodian), VAITOS Act 2021USD 109 kMinimum capital
- Permits
- Safekeeping and administration of virtual assets on behalf of clients.
- Minimum capital
- MUR 5,000,000 or equivalent minimum own funds, or one quarter of fixed overheads if higher (GN 173 of 2022, Schedule). (≈USD 109 k)
- Fees
- Processing fee, VA-1.3 VASP Class R (Virtual Asset Custodian)USD 1,500 (Rs 70,000 for domestic applicants)Annual license fee, VA-1.3 VASP Class R (Virtual Asset Custodian)USD 2,500 (Rs 110,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Custody rules require segregation of client assets.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
18VA adviserVirtual Asset Service Provider, Class S (Virtual Asset Advisory Services), VAITOS Act 2021No fixed figureMinimum capital
- Permits
- Giving advice in relation to virtual assets.
- Minimum capital
- No fixed amount: sufficient working capital to meet debts as they fall due, plus at least one quarter of fixed overheads (GN 173 of 2022, Schedule and Rule 7).
- Fees
- Processing fee, VA-1.4/1.5 VASP Class S (Virtual Asset Advisory Services)USD 3,000 (Rs 135,000 for domestic applicants)Annual license fee, VA-1.4/1.5 VASP Class S (Virtual Asset Advisory Services)USD 5,000 (Rs 220,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- Advisory only; no dealing or custody.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
19VA exchangeVirtual Asset Service Provider, Class I (Virtual Asset Market Place), VAITOS Act 2021USD 141 kMinimum capital
- Permits
- Operating a virtual asset marketplace or trading platform.
- Minimum capital
- MUR 6,500,000 or equivalent minimum own funds, or one quarter of fixed overheads if higher (GN 173 of 2022, Schedule). (≈USD 141 k)
- Fees
- Processing fee, VA-1.4/1.5 VASP Class I (Virtual Asset Market Place)USD 3,000 (Rs 135,000 for domestic applicants)Annual license fee, VA-1.4/1.5 VASP Class I (Virtual Asset Market Place)USD 5,000 (Rs 220,000 for domestic licensees)
- Clients
- Retail permitted
- Conditions
- An exchange that also holds client assets needs Class R (custodian) as well, with capital summed.
- Systems
- Digital Asset Exchange
- Reading
- Read in the rulebook
- Sources
20ITO issuerIssuer of Initial Token Offerings (registration under VAITOS Act 2021)No fixed figureMinimum capital
- Permits
- Offering digital tokens to the public through an initial token offering.
- Minimum capital
- No fixed amount: sufficient working capital to meet debts as they fall due (GN 173 of 2022, Schedule).
- Fees
- ITO issuer registration processing feeUSD 2,000 (Rs 90,000)
- Clients
- Retail, with conditions
- Conditions
- Registration, not a VASP license. Requires a white paper filed with the FSC. Tokens that are securities fall under the Securities Act instead.
- Systems
- Tokenization Platform
- Reading
- Read in the rulebook
- Sources
21CIS custodianCustodian license for collective investment schemes (Securities Act 2005 s.100; Securities (CIS and CEF) Regulations 2008, reg. 7)USD 217 kMinimum capital
- Permits
- Holding the assets of collective investment schemes for safekeeping; every CIS must appoint a custodian (reg. 21).
- Minimum capital
- MUR 10 million minimum stated unimpaired capital for a trust company that is a bank subsidiary or a trustee of a trust (CIS Regulations 2008, reg. 7(3)); the same floor applies to non-bank sub-custodians (reg. 23(1)). No separate figure is set for a bank acting as custodian. (≈USD 217 k)
- Fees
- Processing fee, SEC-4.1 Custodian for CISUSD 1,000 (Rs 32,000 for domestic applicants)Annual license fee, SEC-4.1 Custodian for CISUSD 2,500 (Rs 94,000 for domestic licensees)
- Clients
- Professional only
- Conditions
- In practice held mostly by banks and bank-owned trust companies. A Global scheme may appoint a foreign custodian with FSC approval (reg. 7(4)). The FSC's online text of the Regulations is unofficial; the Gazette text governs. For virtual assets use VASP Class R instead.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
22Securities custodian (non-CIS)Custodian Services (non-CIS), Financial Services Act 2007 s.14No fixed figureMinimum capital
- Permits
- Safekeeping of financial assets for clients other than collective investment schemes.
- Minimum capital
- No capital figure was confirmed; no FSC rule or licensing criteria stating an amount was found.
- Fees
- Processing fee, FS-1.7 Custodian Services (non-CIS)USD 900 (Rs 31,000 for domestic applicants)Annual license fee, FS-1.7 Custodian Services (non-CIS)USD 1,700 (Rs 71,000 for domestic licensees)
- Clients
- Professional only
- Conditions
- Mostly held by banks. Capital: uncertain; confirm with the FSC.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- To be confirmed
- Sources
23Payment intermediaryPayment Intermediary Services (Financial Services Act 2007 s.14)USD 43 kMinimum capital
- Permits
- Cross-border payment intermediation such as e-wallets, fund transfers and online payment gateways, conducted outside Mauritius.
- Minimum capital
- MUR 2,000,000 minimum capital according to a service-provider summary; not confirmed in an FSC rule. (≈USD 43 k)
- Fees
- Processing fee, FS-2.9 Payment Intermediary ServicesUSD 1,400 (Rs 25,000 for domestic applicants)Annual license fee, FS-2.9 Payment Intermediary ServicesUSD 2,600 (Rs 57,000 for domestic licensees)
- Clients
- Retail, with conditions
- Conditions
- Business must be conducted exclusively outside Mauritius. Domestic payment services require Bank of Mauritius licensing under the National Payment Systems Act 2018.
- Systems
- Payment Service ProviderElectronic Money Institution
- Reading
- From a secondary source
- Sources
24Captive insurerCaptive Insurance (Captive Insurance Act 2015): pure captive, multi-owner pure captive, Class 1, 2 and 3 third-party captivesUSD 65 kMinimum capital
- Permits
- Writing captive insurance business for the parent group (pure) or defined third-party risks (third-party captives).
- Minimum capital
- Minimum unimpaired paid-up capital: MUR 3 million (pure captive), MUR 25 million (multi-owner pure captive), MUR 5 million (Class 1 third-party), MUR 10 million (Class 2 and Class 3 third-party). The capital requirement is the higher of this and the risk-based asset plus underwriting capital (Captive Insurance (Captive Insurance Business) Rules 2024, GN 31 of 2024, First Schedule and Rule 8). (≈USD 65 k)
- Fees
- Processing fee, CI-1.1A Captive Insurance BusinessUSD 1,000Annual license fee, CI-1.1A Captive Insurance BusinessUSD 2,000
- Clients
- Professional only
- Conditions
- In force from 26 February 2024. Minimum solvency ratio 100%; at least 40% of minimum paid-up capital held in cash or cash equivalents.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
25Insurer / reinsurerInsurer license (Insurance Act 2005): general insurance, long-term insurance, reinsuranceUSD 543 kMinimum capital
- Permits
- Carrying on general, long-term or reinsurance business, including takaful windows where approved.
- Minimum capital
- Stated capital of not less than MUR 25 million (Insurance Regulations 2007, reg. 5(1), under Insurance Act s.24(1)(a)); an external insurer needs the equivalent of MUR 25 million or another amount proportionate to its risks set by the FSC (reg. 5(2)). Solvency on top: long-term insurers' minimum capital requirement is the higher of a stress-test requirement and the higher of MUR 25 million or 13 weeks' operating expenses (Long-Term Insurance Business Solvency Rules 2007, r.13); general insurers' MCR is a risk-based sum, with a solvency margin of at least 100% of MCR and a target capital requirement ratio of at least 150% (General Insurance Business Solvency Rules 2007, r.3). (≈USD 543 k)
- Fees
- Processing fee, insurer (long-term or general, domestic)Rs 102,000Annual fee, insurer (long-term or general, domestic)Rs 169,000 fixed plus 0.35% of gross premium (paid quarterly)
- Clients
- Retail permitted
- Conditions
- Risk-based solvency regime; actuarial sign-off for long-term business. The consolidated Insurance Regulations text read is as at 28 March 2013 and the long-term solvency rules as at 3 September 2022; later amendments were not checked. Captives fall under the separate Captive Insurance Act 2015 category.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
None. Mauritius has double-tax treaties and is a member of SADC and COMESA, but FSC licenses give no passporting rights into other markets.
Passage
The FSC says it aims for a 60-day turnaround on complete applications for funds and advisory services (FSC newsletter); it does not guarantee that turnaround for incomplete applications. Other processing times depend on completeness and complexity (FSC Licensing FAQs). Market practice for investment dealers is about 2 to 4 months.
Licensed elsewhere
Banks, including private banking and digital banking, are licensed by the Bank of Mauritius under the Banking Act 2004 (private-bank, digital-bank, investment-bank, correspondent-banking, treasury-desk, trade-finance, card-issuing, merchant-acquiring). Domestic payment service providers and payment systems are licensed by the Bank of Mauritius under the National Payment Systems Act 2018 (psp, emi). Money changers and foreign exchange dealers are licensed by the Bank of Mauritius (msb). Islamic banking runs through BoM-licensed banks. No FSC license covers stablecoin issuance specifically, crypto mining or sovereign vehicles.
Notes. Fourth Schedule capital figures in the Securities (Licensing) Rules 2007 have been amended several times (most recently noted GN 246 of 2019, which created the Investment Dealer (Derivatives) category); the figures above are from the FSC's consolidated text. VAITOS rules came into force on 1 July 2022. The Financial Services (Family Office) Rules 2026 (GN 62 of 2026) took effect on 1 June 2026, replacing the 2020 Rules, with transition for existing licensees to 31 December 2026. CIS administrators currently need MUR 500,000 stated capital (CIS Regulations 2008, reg. 38(2)); an FSC consultation paper of 2 June 2026 proposes Full and Restricted CIS Administrator licenses at MUR 10,000,000 and MUR 2,500,000. The FSC also licenses pension scheme administrators under the Private Pension Schemes Act 2012, relevant to pension-manager builds. USD conversions use about MUR 46 per USD.
Africa · Seychelles
FSA Seychelles
Financial Services Authority
The FSA is the non-bank financial regulator of Seychelles under the Financial Services Authority Act 2013. It licenses securities dealers, investment advisers and exchanges under the Securities Act 2007, funds and fund administrators under the Mutual Fund and Hedge Fund Act 2008, insurers under the Insurance Act 2008 and virtual asset service providers under the VASP Act 2024. A Seychelles license now requires a real physical office and resident staff.
#32of 34
Balanced score
50 of 100
50 of 100
Scorecard
Credibility ×35%25Breadth ×15%43Entry threshold ×20%75Speed ×15%90Reach ×15%43
Categories13
Systems covered20 of 47
Typical timeline3–6 monthsmarket practice
Lowest capitalUSD 25 k
IOSCO MMoUB
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 750–5 k7 items · Paid once, when the application is filed
On grant—0 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 1 k–31 k10 items · Recurring fees and levies
OtherUSD 5003 items · Mandatory charges that arise in operation
The 2025 reforms doubled dealer fees (USD 3,000 application, USD 6,000 a year) and added USD 1,000 a year for each extra website domain or trade name, which matters for multi-brand retail brokers. VASP annual fees are much higher (SCR 150,000 to 450,000 per activity set) and staffing rules rule out a shell set-up.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Securities dealer license application feeSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. | USD 3,000 | Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | Read in the rulebook |
| Investment adviser license application feeSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. Same for company and individual advisers. | USD 2,000 | Investment Adviser license (Securities Act 2007) | Read in the rulebook |
| Securities exchange license application feeSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. Clearing agency and securities facility: USD 4,000. | USD 5,000 | Securities Exchange license (Securities Act 2007) | Read in the rulebook |
| Fund administrator license application feeRestricted administrator USD 1,000; full mutual fund administrator USD 1,500. Mutual Fund and Hedge Fund Act Schedule 1 as amended by S.I. 13 of 2020; later amendments not checked. | USD 1,000 to 1,500 | Fund Administrator license (Seychelles Fund Administrator or Restricted), Mutual Fund and Hedge Fund Act 2008 | Read in the rulebook |
| Private or professional fund license application feePrivate fund USD 750; professional fund USD 1,000. S.I. 13 of 2020; later amendments not checked. | USD 750 to 1,000 | Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | Read in the rulebook |
| Public fund license application feeApproval of offering document or amendment USD 500. S.I. 13 of 2020; later amendments not checked. | USD 1,500 | Mutual Fund license: Public Fund (Mutual Fund and Hedge Fund Act 2008) | Read in the rulebook |
| VASP license application feeVASP Act 2024, Second Schedule. Forfeited if the application is incomplete. USD at about SCR 14.5 per USD. | SCR 75,000≈ USD 5 k | VASP license: Virtual Asset Wallet Provider (VASP Act 2024, First Schedule); VASP license: Virtual Asset Exchange (VASP Act 2024, First Schedule); VASP license: Virtual Asset Broking (VASP Act 2024, First Schedule); VASP license: Virtual Asset Investment Provider (VASP Act 2024, First Schedule) | Read in the rulebook |
| Every year | |||
| Securities dealer annual license feeSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. First annual fee is pro-rated by quarter for licenses granted after March; late annual fees attract 1/12 of the annual fee per month. Exempt securities dealer: USD 500 application, USD 1,000 annual. | USD 6,000 | Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024) | Read in the rulebook |
| Investment adviser annual license feeSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. First annual fee is pro-rated by quarter for licenses granted after March; late annual fees attract 1/12 of the annual fee per month. | USD 5,000 | Investment Adviser license (Securities Act 2007) | Read in the rulebook |
| Securities exchange annual license feeSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. Clearing agency and securities facility: USD 8,000. | USD 10,000 | Securities Exchange license (Securities Act 2007) | Read in the rulebook |
| Fund administrator annual license feeRestricted administrator USD 1,500; full administrator USD 2,000. S.I. 13 of 2020; later amendments not checked. | USD 1,500 to 2,000 | Fund Administrator license (Seychelles Fund Administrator or Restricted), Mutual Fund and Hedge Fund Act 2008 | Read in the rulebook |
| Private or professional fund annual license feePrivate fund USD 1,000; professional fund USD 1,250. S.I. 13 of 2020; later amendments not checked. | USD 1,000 to 1,250 | Mutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008) | Read in the rulebook |
| Public fund annual license feeS.I. 13 of 2020; later amendments not checked. | USD 1,500 | Mutual Fund license: Public Fund (Mutual Fund and Hedge Fund Act 2008) | Read in the rulebook |
| VASP annual license fee, virtual asset wallet providerVASP Act 2024, Second Schedule. An activity fee is added for each permitted activity, so a multi-activity licensee pays the base once plus each activity fee. Due by 1 January with a compliance form; pro-rated by quarter in the first year. USD at about SCR 14.5 per USD. | SCR 375,000 (base SCR 75,000 plus activity fee SCR 300,000)≈ USD 26 k | VASP license: Virtual Asset Wallet Provider (VASP Act 2024, First Schedule) | Read in the rulebook |
| VASP annual license fee, virtual asset exchangeVASP Act 2024, Second Schedule. An activity fee is added for each permitted activity, so a multi-activity licensee pays the base once plus each activity fee. Due by 1 January with a compliance form; pro-rated by quarter in the first year. USD at about SCR 14.5 per USD. | SCR 450,000 (base SCR 75,000 plus activity fee SCR 375,000)≈ USD 31 k | VASP license: Virtual Asset Exchange (VASP Act 2024, First Schedule) | Read in the rulebook |
| VASP annual license fee, virtual asset brokingVASP Act 2024, Second Schedule. An activity fee is added for each permitted activity, so a multi-activity licensee pays the base once plus each activity fee. Due by 1 January with a compliance form; pro-rated by quarter in the first year. USD at about SCR 14.5 per USD. | SCR 225,000 (base SCR 75,000 plus activity fee SCR 150,000)≈ USD 16 k | VASP license: Virtual Asset Broking (VASP Act 2024, First Schedule) | Read in the rulebook |
| VASP annual license fee, virtual asset investment providerVASP Act 2024, Second Schedule. An activity fee is added for each permitted activity, so a multi-activity licensee pays the base once plus each activity fee. Due by 1 January with a compliance form; pro-rated by quarter in the first year. USD at about SCR 14.5 per USD. | SCR 150,000 (base SCR 75,000 plus activity fee SCR 75,000)≈ USD 10 k | VASP license: Virtual Asset Investment Provider (VASP Act 2024, First Schedule) | Read in the rulebook |
| Other | |||
| Securities representative licenseSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. | USD 500 application, USD 750 annual per representative | Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024); Investment Adviser license (Securities Act 2007) | Read in the rulebook |
| Additional website domain or trade nameSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. Introduced in 2025 for dealers operating several brands or sites. | USD 500 application plus USD 1,000 annual, per additional domain or trade name | Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024); Investment Adviser license (Securities Act 2007) | Read in the rulebook |
| Approval of change in key position or of share issue/transferSecurities (Forms and Fees) (Amendment of Second Schedule) Regulations 2024 (S.I. 120 of 2024, made 30 December 2024), aligned with the Securities (Amendment) Act 2024 in force 1 January 2025; fees roughly doubled. Change of name USD 500; prospectus review USD 1,500. | USD 500 per approval | Securities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024); Investment Adviser license (Securities Act 2007); Securities Exchange license (Securities Act 2007) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 50 k
Investment adviserInvestment Adviser license (Securities Act 2007)
USD 25 k
VA investment providerVASP license: Virtual Asset Investment Provider (VASP Act 2024, First Schedule)
USD 25 k
Captive insurerNon-domestic captive insurer (Insurance Act 2008; Regulations 2009)
USD 25 k
VA brokerVASP license: Virtual Asset Broking (VASP Act 2024, First Schedule)
USD 50 k
ReinsurerNon-domestic reinsurer (Insurance Act 2008; Regulations 2009)
USD 50 k
VA wallet / custodyVASP license: Virtual Asset Wallet Provider (VASP Act 2024, First Schedule)
USD 75 k
Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024)
USD 100 k
VA exchangeVASP license: Virtual Asset Exchange (VASP Act 2024, First Schedule)
USD 100 k
Non-domestic insurerNon-domestic insurer: general, long-term or combined (Insurance Act 2008; Insurance (Non-Domestic Insurance Business) Regulations 2009)
USD 100 k
10k100k
9 of 13 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
13 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Securities dealerSecurities Dealer license (Securities Act 2007, as amended by the Securities (Amendment) Act 2024)USD 100 kMinimum capital
- Permits
- Dealing in securities, including CFDs and FX, as agent or principal.
- Minimum capital
- USD 100,000 minimum paid-up capital (FSA Securities Dealer Application Guidelines; raised from USD 50,000 by the Securities (Amendment) Act 2024, effective 1 January 2025). Existing licensees had until 30 June 2026 to comply. (≈USD 100 k)
- Fees
- Securities dealer license application feeUSD 3,000Securities dealer annual license feeUSD 6,000Securities representative licenseUSD 500 application, USD 750 annual per representativeAdditional website domain or trade nameUSD 500 application plus USD 1,000 annual, per additional domain or trade nameApproval of change in key position or of share issue/transferUSD 500 per approval
- Clients
- Retail permitted
- Conditions
- Physical office in Seychelles, at least two natural-person directors, at least one licensed representative and a compliance officer. Capital must be held in a bank approved by the FSA. Since 2025: prominent fixed risk warning on websites and apps, jurisdiction disclosure, and fees per website domain. Annual license renewal. CFDs on virtual assets fall under the Securities Act, not the VASP Act (FSA Circular No. 3 of 2025, reported by advisers). No statutory retail leverage cap was identified.
- Systems
- Retail BrokeragePrivate BrokerageInstitutional BrokerageMulti-Asset BrokeragePrime-of-Prime
- Reading
- Read in the rulebook
- Sources
02Investment adviserInvestment Adviser license (Securities Act 2007)USD 25 kMinimum capital
- Permits
- Giving investment advice on securities to clients.
- Minimum capital
- USD 25,000 minimum paid-up capital (FSA Investment Advisor Application Guidelines, version 24 March 2022). (≈USD 25 k)
- Fees
- Securities representative licenseUSD 500 application, USD 750 annual per representativeAdditional website domain or trade nameUSD 500 application plus USD 1,000 annual, per additional domain or trade nameApproval of change in key position or of share issue/transferUSD 500 per approvalInvestment adviser license application feeUSD 2,000Investment adviser annual license feeUSD 5,000
- Clients
- Retail permitted
- Conditions
- Physical office, at least one licensed representative, compliance officer. Core income-generating activities must be in Seychelles to access the tax concession.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
03Securities exchangeSecurities Exchange license (Securities Act 2007)No fixed figureMinimum capital
- Permits
- Operating a securities exchange as the company's sole activity.
- Minimum capital
- No minimum capital is stated in the FSA Securities Exchange Application Guidelines (version 27 May 2025); the FSA judges adequacy of resources.
- Fees
- Approval of change in key position or of share issue/transferUSD 500 per approvalSecurities exchange license application feeUSD 5,000Securities exchange annual license feeUSD 10,000
- Clients
- Retail permitted
- Conditions
- At least three independent dealer members, clearing and settlement and surveillance arrangements, default rules, a compensation fund arrangement, and at least two experienced directors. Service standard 6 months.
- Systems
- ECN & DMA VenueTokenization Platform
- Reading
- Read in the rulebook
- Sources
04Fund administratorFund Administrator license (Seychelles Fund Administrator or Restricted), Mutual Fund and Hedge Fund Act 2008No fixed figureMinimum capital
- Permits
- Providing fund administration to mutual and hedge funds, which under the Act includes managing substantially all of a fund's assets, administering it, providing its principal office or acting as operator. The restricted license covers only named funds.
- Minimum capital
- No minimum capital is stated in the FSA guidelines (version 15 January 2026); the applicant must show adequate expertise, resources and source of funds.
- Fees
- Fund administrator license application feeUSD 1,000 to 1,500Fund administrator annual license feeUSD 1,500 to 2,000
- Clients
- Retail, with conditions
- Conditions
- Registered office in Seychelles and at least two natural-person directors. Must be independent of the fund custodian. A foreign administrator can be approved instead. In Seychelles the fund administrator license is the license held by a fund's operator or manager under the Mutual Fund and Hedge Fund Act; a firm offering discretionary portfolio management outside a fund needs a securities dealer or investment adviser license under the Securities Act.
- Systems
- Fund Management Company
- Reading
- Read in the rulebook
- Sources
05Private or professional fundMutual Fund license: Private Fund or Professional Fund (Mutual Fund and Hedge Fund Act 2008)No fixed figureMinimum capital
- Permits
- Licensing a fund vehicle limited to 50 investors or private invitations (Private Fund), or to professional investors (Professional Fund). Hedge fund strategies are permitted under the same Act.
- Minimum capital
- No minimum capital for the fund. Professional Fund: initial investment of at least USD 100,000 per investor; individual professional investors need net worth above USD 1,000,000 (FSA Mutual Fund Guidelines).
- Fees
- Private or professional fund license application feeUSD 750 to 1,000Private or professional fund annual license feeUSD 1,000 to 1,250
- Clients
- Professional only
- Conditions
- Must be administered by a licensed Seychelles fund administrator or approved foreign administrator.
- Systems
- Hedge FundPrivate Equity FirmVenture Capital FirmPrivate Credit FundReal Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
06Public fundMutual Fund license: Public Fund (Mutual Fund and Hedge Fund Act 2008)No fixed figureMinimum capital
- Permits
- Licensing a mutual fund offered to the public, i.e. any fund that is not a Private or Professional Fund.
- Minimum capital
- No minimum capital for the fund is stated in the FSA Mutual Fund Guidelines.
- Fees
- Public fund license application feeUSD 1,500Public fund annual license feeUSD 1,500
- Clients
- Retail permitted
- Conditions
- At least two natural-person directors, general partners or trustees. If the manager is not the administrator, it must show it is regulated.
- Systems
- Mutual Fund & UCITS
- Reading
- Read in the rulebook
- Sources
07VA wallet / custodyVASP license: Virtual Asset Wallet Provider (VASP Act 2024, First Schedule)USD 75 kMinimum capital
- Permits
- Providing virtual asset wallet and safekeeping services.
- Minimum capital
- USD 75,000 minimum initial paid-up capital for a new entrant, proven at application; from the beginning of the third year of operation, 2.5% of annual turnover, proven at payment of the third annual license fee. Entities already operating at commencement: 2.5% of annual turnover (VASP (Capital and other Financial Requirements) Regulations 2024, S.I. 72 of 2024, reg. 5 and Schedule). (≈USD 75 k)
- Fees
- VASP license application feeSCR 75,000VASP annual license fee, virtual asset wallet providerSCR 375,000 (base SCR 75,000 plus activity fee SCR 300,000)
- Clients
- Retail permitted
- Conditions
- Reserve assets equal to 100% of client liabilities, held in separate accounts (reg. 6); professional indemnity insurance and client-asset cover (reg. 8); an administrative expenses account (reg. 7); records kept seven years (reg. 9). Annual renewal by 1 January. Capital must be held with a Seychelles-licensed bank or an approved foreign institution, in cash, bonds or approved securities (reg. 5(2)-(3)), and a separate amount is required for each authorized activity (reg. 5(4)), so combined licenses add up. The Regulations show amounts with a '$' sign without defining the currency; it is read here as USD.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
08VA exchangeVASP license: Virtual Asset Exchange (VASP Act 2024, First Schedule)USD 100 kMinimum capital
- Permits
- Operating a virtual asset exchange.
- Minimum capital
- USD 100,000 minimum initial paid-up capital for a new entrant, proven at application (S.I. 72 of 2024, reg. 5 and Schedule Part 1). The Schedule's figure for exchanges already operating at commencement (Part 2) could not be read clearly. (≈USD 100 k)
- Fees
- VASP license application feeSCR 75,000VASP annual license fee, virtual asset exchangeSCR 450,000 (base SCR 75,000 plus activity fee SCR 375,000)
- Clients
- Retail permitted
- Conditions
- Exchanges holding client assets usually also hold the wallet license. Mining facilities, mixers and tumblers are prohibited. 100% reserve assets against client liabilities (reg. 6) and indemnity insurance (reg. 8) apply. Capital must be held with a Seychelles-licensed bank or an approved foreign institution, in cash, bonds or approved securities (reg. 5(2)-(3)), and a separate amount is required for each authorized activity (reg. 5(4)), so combined licenses add up. The Regulations show amounts with a '$' sign without defining the currency; it is read here as USD.
- Systems
- Digital Asset Exchange
- Reading
- Read in the rulebook
- Sources
09VA brokerVASP license: Virtual Asset Broking (VASP Act 2024, First Schedule)USD 50 kMinimum capital
- Permits
- Arranging and executing virtual asset transactions for clients.
- Minimum capital
- USD 50,000 minimum initial paid-up capital for a new entrant, proven at application (S.I. 72 of 2024, reg. 5 and Schedule Part 1). (≈USD 50 k)
- Fees
- VASP license application feeSCR 75,000VASP annual license fee, virtual asset brokingSCR 225,000 (base SCR 75,000 plus activity fee SCR 150,000)
- Clients
- Retail permitted
- Conditions
- 100% reserve assets against client liabilities (reg. 6) and indemnity insurance (reg. 8) apply. Capital must be held with a Seychelles-licensed bank or an approved foreign institution, in cash, bonds or approved securities (reg. 5(2)-(3)), and a separate amount is required for each authorized activity (reg. 5(4)), so combined licenses add up. The Regulations show amounts with a '$' sign without defining the currency; it is read here as USD.
- Systems
- OTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
10VA investment providerVASP license: Virtual Asset Investment Provider (VASP Act 2024, First Schedule)USD 25 kMinimum capital
- Permits
- Providing virtual asset investment services, such as managing or advising on virtual asset portfolios.
- Minimum capital
- USD 25,000 minimum initial paid-up capital for a new entrant, proven at application (S.I. 72 of 2024, reg. 5 and Schedule Part 1). (≈USD 25 k)
- Fees
- VASP license application feeSCR 75,000VASP annual license fee, virtual asset investment providerSCR 150,000 (base SCR 75,000 plus activity fee SCR 75,000)
- Clients
- Retail permitted
- Conditions
- Indemnity insurance (reg. 8) applies. Capital must be held with a Seychelles-licensed bank or an approved foreign institution, in cash, bonds or approved securities (reg. 5(2)-(3)), and a separate amount is required for each authorized activity (reg. 5(4)), so combined licenses add up. The Regulations show amounts with a '$' sign without defining the currency; it is read here as USD.
- Systems
- Digital Asset Fund
- Reading
- Read in the rulebook
- Sources
11Non-domestic insurerNon-domestic insurer: general, long-term or combined (Insurance Act 2008; Insurance (Non-Domestic Insurance Business) Regulations 2009)USD 100 kMinimum capital
- Permits
- Carrying on general and/or long-term insurance business outside Seychelles.
- Minimum capital
- USD 100,000 minimum paid-up capital held with a Seychelles-licensed bank (Regulations 2009, reg. 4(1)). (≈USD 100 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- The FSA may accept a lower amount backed by an adequate guarantee (reg. 4(2)).
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
12ReinsurerNon-domestic reinsurer (Insurance Act 2008; Regulations 2009)USD 50 kMinimum capital
- Permits
- Carrying on reinsurance business only.
- Minimum capital
- USD 50,000 minimum paid-up capital (Insurance (Non-Domestic Insurance Business) Regulations 2009, reg. 4(1)). (≈USD 50 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Held with a Seychelles-licensed bank.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
13Captive insurerNon-domestic captive insurer (Insurance Act 2008; Regulations 2009)USD 25 kMinimum capital
- Permits
- Carrying on captive insurance business only.
- Minimum capital
- USD 25,000 minimum paid-up capital (Insurance (Non-Domestic Insurance Business) Regulations 2009, reg. 4(1)). (≈USD 25 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Held with a Seychelles-licensed bank.
- Systems
- Insurance & Reinsurance Vehicle
- Reading
- Read in the rulebook
- Sources
Reach
None. Since 2025 securities dealers must tell the FSA where they do or plan to do business and, where the target market requires local approval, show proof of it.
Passage
FSA service standard: 30 working days from receipt of a complete application for securities dealer, investment adviser and fund administrator licenses; 6 months for a securities exchange; 2 months for an approved foreign administrator. The clock stops when the FSA requests more information (FSA application guidelines). Market practice is closer to 3 to 6 months.
Licensed elsewhere
Banks are licensed by the Central Bank of Seychelles under the Financial Institutions Act 2004 (private-bank, digital-bank, investment-bank, correspondent-banking, treasury-desk, trade-finance). Payment service providers and e-money are licensed by the Central Bank under the National Payment System Act 2014 (psp, emi, card-issuing, merchant-acquiring), and bureaux de change by the Central Bank (msb). The FSA registers international business companies and foundations, which are often used for single-family-office holding structures, but there is no family office license. Crypto mining is prohibited under the VASP Act 2024. No regime covers stablecoin issuance, sovereign vehicles or pension management.
Notes. Securities (Amendment) Act 2024 took effect on 1 January 2025: dealer capital doubled to USD 100,000, annual fees doubled to USD 6,000, new website-domain fees, and existing dealers had until 30 June 2026 to comply, so the deadline has now passed. VASP Act 2024 took effect on 1 September 2024; existing operators had to apply by 31 December 2024. VASP capital is set by the VASP (Capital and other Financial Requirements) Regulations 2024 (S.I. 72 of 2024, made 5 September 2024); the gazetted figures (wallet 75,000, exchange 100,000, broking 50,000, investment provider 25,000) match the 2024 draft, and adviser figures that differ should be disregarded. VASP application fee is SCR 75,000 (FSA guidelines, 28 April 2025). Advisers report an FSA Code of Corporate Governance effective 1 January 2026.
Africa · Kenya
CMA Kenya
Capital Markets Authority
The CMA regulates Kenya's capital markets under the Capital Markets Act (Cap. 485A). It licenses stockbrokers, dealers, broker-dealers, investment banks, fund managers, investment advisers, REIT managers and online FX brokers. Licensing requirements were overhauled by the Capital Markets (Licensing Requirements) (General) Regulations 2025 (Legal Notice 197 of 2025, 11 December 2025); online FX remains under the Capital Markets (Online Foreign Exchange Trading) Regulations 2017.
#30of 34
Balanced score
52 of 100
52 of 100
Scorecard
Credibility ×35%40Breadth ×15%40Entry threshold ×20%68Speed ×15%70Reach ×15%52
Categories13
Systems covered19 of 47
Typical timeline3–12 monthsmarket practice
Lowest capitalUSD 78 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 78–7759 items · Paid once, when the application is filed
On grantUSD 388–2 k8 items · Paid once, when the license is granted
Deposits & guarantees—0 items · Held or lodged, beyond the minimum capital
Every yearUSD 388–2 k9 items · Recurring fees and levies
Other—0 items · Mandatory charges that arise in operation
Fees under the 2025 Regulations are low, but fund managers now pay an AUM-based annual fee (0.05% for CIS, up to KES 15 million), and online FX brokers face a reported 3% levy on gross trading revenue. Kenya remains on the FATF grey list, which raises banking and correspondent costs.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Application fee, investment bankCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 20,000≈ USD 155 | Investment Bank (LN 197 of 2025) | From a secondary source |
| Application fee, stockbrokerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 10,000≈ USD 78 | Stockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025) | From a secondary source |
| Application fee, dealerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 10,000≈ USD 78 | Dealer (LN 197 of 2025) | From a secondary source |
| Application fee, broker-dealerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 10,000≈ USD 78 | Broker-Dealer (new hybrid category, LN 197 of 2025) | From a secondary source |
| Application fee, investment adviserCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 10,000≈ USD 78 | Investment Adviser, including automated/robo-advisers (LN 197 of 2025) | From a secondary source |
| Application fee, fund managerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 10,000≈ USD 78 | Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | From a secondary source |
| Application fee, securities exchangeCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000≈ USD 775 | Securities Exchange (LN 197 of 2025) | From a secondary source |
| Application fee, OTC platform or ISP providerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 10,000≈ USD 78 | OTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | From a secondary source |
| Online forex broker license application feeCMA licensing checklist for online forex brokers. Licence and annual fees for online FX brokers were not confirmed. | KES 10,000≈ USD 78 | Non-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017); Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | Read in the rulebook |
| On grant | |||
| Licensing fee, investment bankCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 250,000≈ USD 2 k | Investment Bank (LN 197 of 2025) | From a secondary source |
| Licensing fee, stockbrokerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000≈ USD 775 | Stockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025) | From a secondary source |
| Licensing fee, dealerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000≈ USD 775 | Dealer (LN 197 of 2025) | From a secondary source |
| Licensing fee, broker-dealerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 200,000≈ USD 2 k | Broker-Dealer (new hybrid category, LN 197 of 2025) | From a secondary source |
| Licensing fee, investment adviserCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000≈ USD 775 | Investment Adviser, including automated/robo-advisers (LN 197 of 2025) | From a secondary source |
| Licensing fee, fund managerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000 (KES 50,000 if licensed under the Retirement Benefits Act)≈ USD 388 | Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | From a secondary source |
| Licensing fee, securities exchangeCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 200,000≈ USD 2 k | Securities Exchange (LN 197 of 2025) | From a secondary source |
| Licensing fee, OTC platform or ISP providerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. ISP provider KES 50,000; OTC platform KES 100,000. | KES 50,000 to 100,000≈ USD 388 | OTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | From a secondary source |
| Every year | |||
| Annual regulatory fee, investment bankCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 250,000≈ USD 2 k | Investment Bank (LN 197 of 2025) | From a secondary source |
| Annual regulatory fee, stockbrokerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000≈ USD 775 | Stockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025) | From a secondary source |
| Annual regulatory fee, dealerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 100,000≈ USD 775 | Dealer (LN 197 of 2025) | From a secondary source |
| Annual regulatory fee, broker-dealerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | KES 200,000≈ USD 2 k | Broker-Dealer (new hybrid category, LN 197 of 2025) | From a secondary source |
| Annual regulatory fee, investment adviserCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. Up from KES 50,000 under the 2002 Regulations. | KES 100,000≈ USD 775 | Investment Adviser, including automated/robo-advisers (LN 197 of 2025) | From a secondary source |
| Annual regulatory fee, fund managerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. Replaces the former flat KES 100,000. Existing licensees have until 11 December 2026 to comply with the new regime. | CIS: 0.05% of AUM, min KES 100,000, max KES 15,000,000; non-CIS (excluding pension funds): 0.01% of AUM, max KES 15,000,000 | Fund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023) | From a secondary source |
| Annual regulatory fee, securities exchangeCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. | 1% of gross earnings (excluding transaction fees) | Securities Exchange (LN 197 of 2025) | From a secondary source |
| Annual regulatory fee, OTC platform or ISP providerCapital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025), Sixth Schedule, per PwC Kenya legal alert (April 2026); the gazetted text was not read directly. ISP provider KES 50,000; OTC platform KES 100,000. | KES 50,000 to 100,000≈ USD 388 | OTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025) | From a secondary source |
| Online forex broker regulatory levyReported in 2023 as an amendment to the Capital Markets (Online Foreign Exchange Trading) Regulations 2017 (new regulation after reg. 25, rate in the Third Schedule). Final adoption and current rate were not confirmed. | 3% a year of gross trading revenue (including commissions and rebates from third-party service providers) | Non-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017); Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017) | To be confirmed |
Threshold
Minimum capital, category by category
Middle halfMedian USD 300 k
Online FX money managerMoney Manager (Capital Markets (Online Foreign Exchange Trading) Regulations 2017)
USD 78 k
REIT managerREIT Manager (Capital Markets (Real Estate Investment Trusts) (Collective Investment Schemes) Regulations 2013)
USD 78 k
DealerDealer (LN 197 of 2025)
USD 155 k
Fund managerFund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023)
USD 155 k
Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017)
USD 233 k
Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017)
USD 388 k
StockbrokerStockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025)
USD 388 k
Broker-dealerBroker-Dealer (new hybrid category, LN 197 of 2025)
USD 543 k
Investment bankInvestment Bank (LN 197 of 2025)
USD 1.16 m
Securities exchangeSecurities Exchange (LN 197 of 2025)
USD 7.75 m
10k100k1m10m
10 of 13 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
13 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01Non-dealing online FX brokerNon-Dealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017)USD 233 kMinimum capital
- Permits
- Acting as an intermediary between clients and the online FX market without taking the opposite side of client trades.
- Minimum capital
- KES 30 million minimum paid-up share capital; liquid capital of the higher of KES 30 million or 8% of total liabilities (CMA online forex brokers licensing checklist). (≈USD 233 k)
- Fees
- Online forex broker license application feeKES 10,000Online forex broker regulatory levy3% a year of gross trading revenue (including commissions and rebates from third-party service providers)
- Clients
- Retail permitted
- Conditions
- Capital must be allocated to and kept in Kenya and segregated. Leverage is capped at 400:1 for any currency pair (as reported). Client funds segregated. Fit and proper directors and key staff.
- Systems
- Retail BrokerageWhite-Label Brokerage
- Reading
- Read in the rulebook
- Sources
02Dealing online FX brokerDealing Online Foreign Exchange Broker (Capital Markets (Online Foreign Exchange Trading) Regulations 2017)USD 388 kMinimum capital
- Permits
- Acting as counterparty to client online FX and CFD trades (market-making).
- Minimum capital
- KES 50 million minimum paid-up share capital; liquid capital of the higher of KES 30 million or 8% of total liabilities (CMA online forex brokers licensing checklist). (≈USD 388 k)
- Fees
- Online forex broker license application feeKES 10,000Online forex broker regulatory levy3% a year of gross trading revenue (including commissions and rebates from third-party service providers)
- Clients
- Retail permitted
- Conditions
- Same conditions as the non-dealing broker. Leverage capped at 400:1 (as reported). Applicants operating abroad must ring-fence capital in Kenya.
- Systems
- Retail BrokerageMulti-Asset Brokerage
- Reading
- Read in the rulebook
- Sources
03Online FX money managerMoney Manager (Capital Markets (Online Foreign Exchange Trading) Regulations 2017)USD 78 kMinimum capital
- Permits
- Managing client funds for online FX trading on a discretionary basis.
- Minimum capital
- KES 10 million minimum capital; liquid capital of the higher of KES 5 million or 8% of total liabilities (CMA money manager licensing checklist). (≈USD 78 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Trades for clients through a licensed online FX broker.
- Systems
- Quantitative Trading Desk
- Reading
- Read in the rulebook
- Sources
04StockbrokerStockbroker (Capital Markets (Licensing Requirements) (General) Regulations 2025)USD 388 kMinimum capital
- Permits
- Buying and selling securities on a securities exchange as agent for clients.
- Minimum capital
- KES 50 million shareholders' funds/paid-up capital; liquid capital of the higher of KES 30 million or 8% of total liabilities (LN 197 of 2025; unchanged from 2002). (≈USD 388 k)
- Fees
- Application fee, stockbrokerKES 10,000Licensing fee, stockbrokerKES 100,000Annual regulatory fee, stockbrokerKES 100,000
- Clients
- Retail permitted
- Conditions
- Must be a trading participant of a licensed exchange such as the NSE.
- Systems
- Private BrokerageInstitutional Brokerage
- Reading
- From a secondary source
- Sources
05DealerDealer (LN 197 of 2025)USD 155 kMinimum capital
- Permits
- Dealing in securities on own account as a business.
- Minimum capital
- KES 20 million shareholders' funds/paid-up capital; liquid capital of the higher of KES 10 million or 8% of total liabilities (LN 197 of 2025; liquid capital reduced from KES 30 million). (≈USD 155 k)
- Fees
- Application fee, dealerKES 10,000Licensing fee, dealerKES 100,000Annual regulatory fee, dealerKES 100,000
- Clients
- Professional only
- Conditions
- Own-account dealing only; client business needs a stockbroker or broker-dealer license.
- Systems
- Proprietary Trading FirmQuantitative Trading Desk
- Reading
- From a secondary source
- Sources
06Broker-dealerBroker-Dealer (new hybrid category, LN 197 of 2025)USD 543 kMinimum capital
- Permits
- Combining stockbroking for clients with dealing on own account.
- Minimum capital
- KES 70 million paid-up share capital; liquid capital of the higher of KES 50 million or 8% of total liabilities (LN 197 of 2025). (≈USD 543 k)
- Fees
- Application fee, broker-dealerKES 10,000Licensing fee, broker-dealerKES 200,000Annual regulatory fee, broker-dealerKES 200,000
- Clients
- Retail permitted
- Conditions
- New category from December 2025. A full multi-asset build also needs a dealing online FX broker license for FX/CFDs.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrivate Brokerage
- Reading
- From a secondary source
- Sources
07Investment bankInvestment Bank (LN 197 of 2025)USD 1.16 mMinimum capital
- Permits
- Corporate finance and advisory, underwriting, and securities brokerage and dealing.
- Minimum capital
- KES 150 million paid-up share capital and shareholders' funds; liquid capital of the higher of KES 50 million or 8% of total liabilities (LN 197 of 2025; paid-up capital reduced from KES 250 million). (≈USD 1.16 m)
- Fees
- Application fee, investment bankKES 20,000Licensing fee, investment bankKES 250,000Annual regulatory fee, investment bankKES 250,000
- Clients
- Retail permitted
- Conditions
- Not a deposit-taking bank; deposit-taking requires a CBK banking license.
- Systems
- Investment BankMulti-Asset Brokerage
- Reading
- From a secondary source
- Sources
08Fund managerFund Manager (LN 197 of 2025; Capital Markets (Collective Investment Schemes) Regulations 2023)USD 155 kMinimum capital
- Permits
- Managing collective investment schemes and discretionary portfolios, including pension fund assets.
- Minimum capital
- KES 20 million shareholders' funds (LN 197 of 2025; up from KES 10 million). No separate liquid capital figure prescribed in the 2025 regulations. (≈USD 155 k)
- Fees
- Application fee, fund managerKES 10,000Licensing fee, fund managerKES 100,000 (KES 50,000 if licensed under the Retirement Benefits Act)Annual regulatory fee, fund managerCIS: 0.05% of AUM, min KES 100,000, max KES 15,000,000; non-CIS (excluding pension funds): 0.01% of AUM, max KES 15,000,000
- Clients
- Retail permitted
- Conditions
- Investments in related companies capped at 10% of assets under management (reg. 39(3)). Pension fund managers must also be registered with the Retirement Benefits Authority.
- Systems
- Asset Management CompanyFund Management CompanyMutual Fund & UCITSWealth Management FirmMulti-Family OfficePension & Endowment ManagerHedge Fund
- Reading
- From a secondary source
- Sources
09Investment adviserInvestment Adviser, including automated/robo-advisers (LN 197 of 2025)No fixed figureMinimum capital
- Permits
- Giving investment advice on securities, including through automated or algorithm-based platforms.
- Minimum capital
- No fixed minimum under the 2025 regulations; the adviser must hold adequate resources (as reported by a Kenyan law firm).
- Fees
- Application fee, investment adviserKES 10,000Licensing fee, investment adviserKES 100,000Annual regulatory fee, investment adviserKES 100,000
- Clients
- Retail permitted
- Conditions
- Must be a Kenyan-incorporated company or LLP (reg. 12(a)). Monthly risk-based capital adequacy report within 15 days of month end. Principal bank account in Kenya.
- Systems
- Investment Advisory Firm
- Reading
- From a secondary source
- Sources
10REIT managerREIT Manager (Capital Markets (Real Estate Investment Trusts) (Collective Investment Schemes) Regulations 2013)USD 78 kMinimum capital
- Permits
- Managing a development (D-REIT) or income (I-REIT) real estate investment trust.
- Minimum capital
- KES 10 million minimum paid-up capital (CMA REIT manager licensing checklist). (≈USD 78 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Requires a licensed REIT trustee (a bank or licensed trustee). Corporate governance regulations for market intermediaries apply.
- Systems
- Real Estate Investment Vehicle
- Reading
- Read in the rulebook
- Sources
11Securities exchangeSecurities Exchange (LN 197 of 2025)USD 7.75 mMinimum capital
- Permits
- Operating a licensed securities exchange.
- Minimum capital
- KES 1 billion minimum paid-up capital (LN 197 of 2025, as reported by Kenyan law firms). (≈USD 7.75 m)
- Fees
- Application fee, securities exchangeKES 100,000Licensing fee, securities exchangeKES 200,000Annual regulatory fee, securities exchange1% of gross earnings (excluding transaction fees)
- Clients
- Retail permitted
- Conditions
- New explicit capital minimum introduced in 2025.
- Systems
- ECN & DMA Venue
- Reading
- From a secondary source
- Sources
12OTC platform / ISPOTC Platform and Intermediary Service Platform (ISP) Provider (new categories, LN 197 of 2025)No fixed figureMinimum capital
- Permits
- Operating over-the-counter trading platforms, or digital platforms that intermediate capital markets services.
- Minimum capital
- No capital figure was confirmed; reported criteria are similar to those for traditional intermediaries.
- Fees
- Application fee, OTC platform or ISP providerKES 10,000Licensing fee, OTC platform or ISP providerKES 50,000 to 100,000Annual regulatory fee, OTC platform or ISP providerKES 50,000 to 100,000
- Clients
- Retail, with conditions
- Conditions
- Previously unregulated operators had to apply within 12 months of 11 December 2025. Capital figure: uncertain.
- Systems
- ECN & DMA Venue
- Reading
- To be confirmed
- Sources
13Regulatory sandboxRegulatory Sandbox admission (CMA Regulatory Sandbox Policy Guidance Note 2019)No fixed figureMinimum capital
- Permits
- Live testing of innovative capital markets products and services under CMA supervision for a limited period, without a full license.
- Minimum capital
- No minimum capital set; the CMA sets conditions per firm.
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Time-limited admission with restrictions on client numbers and exposure. A route to test tokenization, robo-advice or digital asset models before the VASP Act framework is in place.
- Systems
- Tokenization Platform
- Reading
- From a secondary source
- Sources
Reach
None. Kenya is in the East African Community, but there is no capital markets passport. Foreign online FX brokers must license a Kenyan entity and keep the required capital in Kenya.
Passage
No statutory decision deadline was confirmed. Market practice: several months, longer for online FX licenses, which the CMA has granted sparingly.
Licensed elsewhere
Banks, including Islamic banks and digital banking, are licensed by the Central Bank of Kenya under the Banking Act (private-bank, digital-bank, correspondent-banking, treasury-desk, trade-finance). Payment service providers and e-money issuers are authorized by the CBK under the National Payment System Act 2011 (psp, emi, card-issuing, merchant-acquiring), and money remittance providers and forex bureaus by the CBK (msb). Non-deposit-taking digital credit providers are licensed by the CBK (private-credit lending). Insurers and takaful operators are licensed by the Insurance Regulatory Authority (insurance-vehicle); pension schemes by the Retirement Benefits Authority. Virtual asset service providers fall under the Virtual Asset Service Providers Act 2025, which splits licensing between the CMA and the CBK by activity (digital-asset-exchange, otc-digital-desk, custody-wallet, stablecoin).
Notes. The Capital Markets (Licensing Requirements) (General) Regulations 2025 (LN 197 of 2025, 11 December 2025) repealed the 2002 Regulations. Existing licensees have until 11 December 2026 to meet new requirements. Main changes: investment bank paid-up capital cut to KES 150 million, fund manager raised to KES 20 million, new broker-dealer, OTC platform and ISP categories, and an explicit exchange minimum. The 2025 figures come from law firm summaries because the gazetted text could not be read directly. The Virtual Asset Service Providers Act 2025 was enacted in 2025; implementing regulations and the CMA/CBK split of license classes should be confirmed before relying on them. USD conversions use about KES 129 per USD.
Africa · Nigeria
SEC Nigeria
Securities and Exchange Commission
The SEC is the apex capital markets regulator in Nigeria under the Investments and Securities Act 2025 (ISA 2025), which replaced the ISA 2007. It registers capital market operators (brokers, dealers, fund managers, issuing houses, advisers, exchanges) and, under ISA 2025, digital asset service providers, because the Act treats digital assets as securities. Minimum capital for every category was raised sharply by Circular 26-1 of 16 January 2026, with compliance due by 30 June 2027.
#22of 34
Balanced score
59 of 100
59 of 100
Scorecard
Credibility ×35%65Breadth ×15%60Entry threshold ×20%47Speed ×15%70Reach ×15%46
Categories22
Systems covered28 of 47
Typical timeline3–12 monthsmarket practice
Lowest capitalUSD 33 k
IOSCO MMoUA
Passportnone
Costs
What the license costs
Fees paid to the regulator and to mandatory schemes, by moment. Capital is shown per category, below. Amounts in the regulator’s currency, with USD equivalents.
ApplicationUSD 67–2674 items · Paid once, when the application is filed
On grantUSD 133–7 k4 items · Paid once, when the license is granted
Deposits & guaranteesFormula1 item · Held or lodged, beyond the minimum capital
Every year—0 items · Recurring fees and levies
OtherUSD 671 item · Mandatory charges that arise in operation
One-off SEC fees are moderate (up to NGN 10 million for fund managers), but the January 2026 capital circular (Circular 26-1, compliance by 30 June 2027) sharply raised minimum capital, and a fidelity bond of 20% of that capital is required. For digital asset firms, SEC proposals of August 2026 (not yet in force) would set a NGN 30 million registration fee plus NGN 100,000 processing and NGN 300,000 application fees, and turnover-based supervisory fees.
| Fee | Amount | Applies to | Reading |
|---|---|---|---|
| Application | |||
| Filing/application fee plus processing fee, broker-dealerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). | NGN 100,000 filing plus NGN 300,000 processing≈ USD 267 | Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services) | Read in the rulebook |
| Filing/application fee plus processing fee, fund/portfolio managerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). The checklist predates the 2026 tiering of fund managers. | NGN 100,000 filing plus NGN 300,000 processing≈ USD 267 | Tier 1 Fund/Portfolio Manager (Full Scope); Tier 2 Fund/Portfolio Manager (Limited Scope) | Read in the rulebook |
| Filing/application fee plus processing fee, digital sub-brokerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). | NGN 100,000 filing plus NGN 300,000 processing≈ USD 267 | Sub-Broker (Digital) | Read in the rulebook |
| Filing/application fee plus processing fee, commodities broker/dealerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). | NGN 50,000 filing plus NGN 50,000 processing≈ USD 67 | Commodities Broker/Dealer | Read in the rulebook |
| On grant | |||
| Registration fee, broker-dealerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). | NGN 5,000,000≈ USD 3 k | Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services) | Read in the rulebook |
| Registration fee, fund/portfolio managerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). The checklist prints the figure as "N10,000,00,000.00" but the words say Ten Million Naira. The checklist predates the 2026 tiering. | NGN 10,000,000≈ USD 7 k | Tier 1 Fund/Portfolio Manager (Full Scope); Tier 2 Fund/Portfolio Manager (Limited Scope) | Read in the rulebook |
| Registration fee, digital sub-brokerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). | NGN 1,000,000≈ USD 667 | Sub-Broker (Digital) | Read in the rulebook |
| Registration fee, commodities broker/dealerSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). Sponsored individuals NGN 30,000 each (NGN 15,000 if transferring). | NGN 200,000≈ USD 133 | Commodities Broker/Dealer | Read in the rulebook |
| Deposits & guarantees | |||
| Fidelity insurance bondThis is insurance cover, so the cost is the premium, not the face amount. Proposed digital asset rules (August 2026) would set it at 25% of minimum capital for digital asset operators. | Bond cover of at least 20% of minimum paid-up capital, valid to 31 December | Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services); Tier 1 Fund/Portfolio Manager (Full Scope); Tier 2 Fund/Portfolio Manager (Limited Scope); Sub-Broker (Digital) and 1 more | Read in the rulebook |
| Other | |||
| Director fee and sponsored individual feesSEC registration checklist. The checklist still shows pre-2026 minimum capital, so check that fees were not revised with SEC Circular 26-1 (16 January 2026). At least three sponsored individuals (including the MD and compliance officer) are required per function; change of registration NGN 100,000, transfer and change of status NGN 150,000. | NGN 100,000 per director; NGN 100,000 per sponsored individual (NGN 50,000 if transferring)≈ USD 67 | Broker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services); Tier 1 Fund/Portfolio Manager (Full Scope); Tier 2 Fund/Portfolio Manager (Limited Scope); Sub-Broker (Digital) | Read in the rulebook |
Threshold
Minimum capital, category by category
Middle halfMedian USD 516 k
Investment adviserInvestment Adviser (Corporate)
USD 33 k
Commodities broker-dealerCommodities Broker/Dealer
USD 33 k
Digital sub-brokerSub-Broker (Digital)
USD 67 k
Robo-adviserRobo Adviser
USD 67 k
VC fund managerTier 3 Alternative Investment Fund Manager: Venture Capital Fund Manager
USD 133 k
Crowdfunding portalCrowd Funding Intermediary
USD 133 k
Ancillary VASPAncillary Virtual Asset Service Provider (AVASP)
USD 200 k
PE fund managerTier 3 Alternative Investment Fund Manager: Private Equity Fund Manager
USD 333 k
Digital asset intermediaryDigital Assets Intermediary (DAI)
USD 333 k
Digital asset platform operatorDigital Assets Platform Operator (DAPO), including token issuers
USD 333 k
BrokerBroker (client execution only)
USD 400 k
DealerDealer (proprietary trading only)
USD 667 k
Digital asset offering platformDigital Assets Offering Platform (DAOP)
USD 667 k
RWA tokenization platformReal-world Assets Tokenization and Offering Platform (RATOP)
USD 667 k
Broker-dealerBroker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services)
USD 1.33 m
Fund manager, limited scopeTier 2 Fund/Portfolio Manager (Limited Scope)
USD 1.33 m
Issuing houseIssuing House, Tier 1
USD 1.33 m
Digital asset exchangeDigital Assets Exchange (DAX)
USD 1.33 m
Digital asset custodianDigital Assets Custodian
USD 1.33 m
Fund manager, full scopeTier 1 Fund/Portfolio Manager (Full Scope)
USD 3.33 m
Securities exchange (non-composite)Non-Composite Securities Exchange
USD 3.33 m
Issuing house with underwritingIssuing House, Tier 2 (with Underwriting)
USD 4.67 m
10k100k1m10m
22 of 22 categories set a fixed figure. USD on a logarithmic scale; conversions approximate.
The categories
22 license categories
Open a category for what it permits, its capital and fees, its conditions and the systems it fits.
01BrokerBroker (client execution only)USD 400 kMinimum capital
- Permits
- Executing securities transactions for clients as agent.
- Minimum capital
- NGN 600 million (previously NGN 200 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 400 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Sponsored individuals must be SEC-registered. Membership of the relevant exchange is needed for exchange trading.
- Systems
- Private BrokerageInstitutional Brokerage
- Reading
- Read in the rulebook
- Sources
02DealerDealer (proprietary trading only)USD 667 kMinimum capital
- Permits
- Trading securities for the firm's own account.
- Minimum capital
- NGN 1 billion (previously NGN 100 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 667 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- No client business.
- Systems
- Proprietary Trading FirmQuantitative Trading Desk
- Reading
- Read in the rulebook
- Sources
03Broker-dealerBroker-Dealer (client execution, proprietary trading, margin/securities lending and advisory services)USD 1.33 mMinimum capital
- Permits
- Client execution, proprietary trading, margin lending, securities lending and advisory services.
- Minimum capital
- NGN 2 billion (previously NGN 300 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 1.33 m)
- Fees
- Filing/application fee plus processing fee, broker-dealerNGN 100,000 filing plus NGN 300,000 processingRegistration fee, broker-dealerNGN 5,000,000Director fee and sponsored individual feesNGN 100,000 per director; NGN 100,000 per sponsored individual (NGN 50,000 if transferring)Fidelity insurance bondBond cover of at least 20% of minimum paid-up capital, valid to 31 December
- Clients
- Retail permitted
- Conditions
- The SEC has no license category for retail FX or CFD brokerage; FX is under CBN control. A Nigerian multi-asset build is limited to securities and exchange-traded derivatives.
- Systems
- Multi-Asset BrokerageInstitutional BrokeragePrivate Brokerage
- Reading
- Read in the rulebook
- Sources
04Digital sub-brokerSub-Broker (Digital)USD 67 kMinimum capital
- Permits
- Operating a digital investment platform that routes client orders through a registered broker or broker-dealer.
- Minimum capital
- NGN 100 million (previously NGN 10 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 67 k)
- Fees
- Filing/application fee plus processing fee, digital sub-brokerNGN 100,000 filing plus NGN 300,000 processingRegistration fee, digital sub-brokerNGN 1,000,000Director fee and sponsored individual feesNGN 100,000 per director; NGN 100,000 per sponsored individual (NGN 50,000 if transferring)Fidelity insurance bondBond cover of at least 20% of minimum paid-up capital, valid to 31 December
- Clients
- Retail permitted
- Conditions
- Operates under the sponsoring broker's registration and infrastructure. Corporate sub-broker NGN 50 million; individual NGN 10 million.
- Systems
- White-Label Brokerage
- Reading
- Read in the rulebook
- Sources
05Fund manager, full scopeTier 1 Fund/Portfolio Manager (Full Scope)USD 3.33 mMinimum capital
- Permits
- Managing collective investment schemes, alternative investment funds and private portfolios above NGN 20 billion NAV/AuM, or with foreign-instrument exposure up to 40% of NAV.
- Minimum capital
- NGN 5 billion (previously NGN 150 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). The circular set an add-on for managers with NAV/AuM above NGN 100 billion at 10% of NAV/AuM; press reports of 17–18 January 2026 cite SEC sources correcting this to 0.1%, but the correction had not been formally confirmed by mid-2026. (≈USD 3.33 m)
- Fees
- Filing/application fee plus processing fee, fund/portfolio managerNGN 100,000 filing plus NGN 300,000 processingRegistration fee, fund/portfolio managerNGN 10,000,000Director fee and sponsored individual feesNGN 100,000 per director; NGN 100,000 per sponsored individual (NGN 50,000 if transferring)Fidelity insurance bondBond cover of at least 20% of minimum paid-up capital, valid to 31 December
- Clients
- Retail permitted
- Conditions
- Each CIS (unit trust, ETF, REIT, sukuk or non-interest fund) needs separate SEC registration with a trustee and custodian. Confirm the large-manager add-on (10% or 0.1% of AuM) with the SEC before relying on it.
- Systems
- Asset Management CompanyFund Management CompanyMutual Fund & UCITSETF PlatformReal Estate Investment VehicleWealth Management FirmMulti-Family OfficeHedge FundPrivate Credit FundIslamic Finance Structure
- Reading
- Read in the rulebook
- Sources
06Fund manager, limited scopeTier 2 Fund/Portfolio Manager (Limited Scope)USD 1.33 mMinimum capital
- Permits
- Managing pooled funds and private portfolios up to NGN 20 billion, with foreign-instrument exposure up to 20%.
- Minimum capital
- NGN 2 billion (previously NGN 150 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 1.33 m)
- Fees
- Filing/application fee plus processing fee, fund/portfolio managerNGN 100,000 filing plus NGN 300,000 processingRegistration fee, fund/portfolio managerNGN 10,000,000Director fee and sponsored individual feesNGN 100,000 per director; NGN 100,000 per sponsored individual (NGN 50,000 if transferring)Fidelity insurance bondBond cover of at least 20% of minimum paid-up capital, valid to 31 December
- Clients
- Retail permitted
- Conditions
- Must move to Tier 1 when it exceeds the NAV/AuM or foreign-exposure limits.
- Systems
- Asset Management CompanyFund Management CompanyMutual Fund & UCITSReal Estate Investment VehicleWealth Management FirmMulti-Family OfficeHedge FundPrivate Credit FundIslamic Finance Structure
- Reading
- Read in the rulebook
- Sources
07PE fund managerTier 3 Alternative Investment Fund Manager: Private Equity Fund ManagerUSD 333 kMinimum capital
- Permits
- Managing private equity funds.
- Minimum capital
- NGN 500 million (previously NGN 150 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 333 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Private funds offered to qualified or sophisticated investors.
- Systems
- Private Equity Firm
- Reading
- Read in the rulebook
- Sources
08VC fund managerTier 3 Alternative Investment Fund Manager: Venture Capital Fund ManagerUSD 133 kMinimum capital
- Permits
- Managing venture capital funds.
- Minimum capital
- NGN 200 million (previously NGN 20 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 133 k)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Private funds offered to qualified or sophisticated investors.
- Systems
- Venture Capital Firm
- Reading
- Read in the rulebook
- Sources
09Issuing houseIssuing House, Tier 1USD 1.33 mMinimum capital
- Permits
- Arranging and managing public offers and private placements of securities, and corporate finance advisory.
- Minimum capital
- NGN 2 billion (previously NGN 200 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 1.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- No underwriting.
- Systems
- Investment Bank
- Reading
- Read in the rulebook
- Sources
10Issuing house with underwritingIssuing House, Tier 2 (with Underwriting)USD 4.67 mMinimum capital
- Permits
- Issuing house activities plus underwriting of securities issues.
- Minimum capital
- NGN 7 billion (previously NGN 200 million); a standalone Underwriter registration is NGN 5 billion (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 4.67 m)
- Fees
- No fee recorded for this category.
- Clients
- Professional only
- Conditions
- Highest capital tier for core corporate finance work.
- Systems
- Investment BankStructured Products Issuer
- Reading
- Read in the rulebook
- Sources
11Investment adviserInvestment Adviser (Corporate)USD 33 kMinimum capital
- Permits
- Giving investment advice on securities.
- Minimum capital
- NGN 50 million (previously NGN 5 million); individual investment adviser NGN 10 million (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 33 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Advice only; managing client money needs a fund/portfolio manager registration.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
12Robo-adviserRobo AdviserUSD 67 kMinimum capital
- Permits
- Providing automated, algorithm-based investment advice.
- Minimum capital
- NGN 100 million (previously NGN 10 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 67 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Classified as a fintech category in the circular.
- Systems
- Investment Advisory Firm
- Reading
- Read in the rulebook
- Sources
13Crowdfunding portalCrowd Funding IntermediaryUSD 133 kMinimum capital
- Permits
- Operating an investment crowdfunding portal for small issuers under the SEC Crowdfunding Rules.
- Minimum capital
- NGN 200 million (previously NGN 100 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 133 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Investor and issuer limits apply under the SEC crowdfunding rules. Not the primary license for any of the 47 systems.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
14Ancillary VASPAncillary Virtual Asset Service Provider (AVASP)USD 200 kMinimum capital
- Permits
- Ancillary services supporting digital asset activity, as defined in the SEC digital asset rules.
- Minimum capital
- NGN 300 million (new category) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 200 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Exact scope should be checked against the SEC digital asset rules.
- Systems
- No system of the forty-seven maps to this category alone.
- Reading
- Read in the rulebook
- Sources
15Digital asset intermediaryDigital Assets Intermediary (DAI)USD 333 kMinimum capital
- Permits
- Brokering and dealing in digital assets for clients.
- Minimum capital
- NGN 500 million (new category) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 333 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Digital assets are securities under ISA 2025, so SEC registration is required.
- Systems
- OTC Digital Asset Desk
- Reading
- Read in the rulebook
- Sources
16Digital asset platform operatorDigital Assets Platform Operator (DAPO), including token issuersUSD 333 kMinimum capital
- Permits
- Operating digital asset platforms, including issuing tokens.
- Minimum capital
- NGN 500 million (new category) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 333 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail, with conditions
- Conditions
- Token issuers fall in this category under the circular. A naira-pegged stablecoin would also need engagement with the CBN.
- Systems
- Tokenization PlatformStablecoin Issuance Structure
- Reading
- Read in the rulebook
- Sources
17Digital asset offering platformDigital Assets Offering Platform (DAOP)USD 667 kMinimum capital
- Permits
- Hosting offerings of digital assets to investors.
- Minimum capital
- NGN 1 billion (previously NGN 500 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 667 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Offerings must comply with SEC digital asset issuance rules.
- Systems
- Tokenization Platform
- Reading
- Read in the rulebook
- Sources
18RWA tokenization platformReal-world Assets Tokenization and Offering Platform (RATOP)USD 667 kMinimum capital
- Permits
- Tokenizing real-world assets and offering the tokens to investors.
- Minimum capital
- NGN 1 billion (new category) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 667 k)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- New category from January 2026.
- Systems
- Tokenization Platform
- Reading
- Read in the rulebook
- Sources
19Digital asset exchangeDigital Assets Exchange (DAX)USD 1.33 mMinimum capital
- Permits
- Operating a digital asset trading venue.
- Minimum capital
- NGN 2 billion (previously NGN 500 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 1.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Digital assets are securities under ISA 2025; operating without SEC registration is an offence.
- Systems
- Digital Asset Exchange
- Reading
- Read in the rulebook
- Sources
20Digital asset custodianDigital Assets CustodianUSD 1.33 mMinimum capital
- Permits
- Safekeeping digital assets for clients.
- Minimum capital
- NGN 2 billion (previously NGN 500 million) (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 1.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Custody of securities by banks is set by the CBN; a non-bank securities custodian needs NGN 50 billion plus 0.1% of assets under custody.
- Systems
- Custody & Wallet Infrastructure
- Reading
- Read in the rulebook
- Sources
21Securities exchange (non-composite)Non-Composite Securities ExchangeUSD 3.33 mMinimum capital
- Permits
- Operating a securities exchange for a limited range of products.
- Minimum capital
- NGN 5 billion (previously NGN 500 million); a Composite Securities Exchange is NGN 10 billion (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 3.33 m)
- Fees
- No fee recorded for this category.
- Clients
- Retail permitted
- Conditions
- Market infrastructure registration with high governance requirements.
- Systems
- ECN & DMA Venue
- Reading
- Read in the rulebook
- Sources
22Commodities broker-dealerCommodities Broker/DealerUSD 33 kMinimum capital
- Permits
- Brokering and dealing in commodities and commodity contracts on registered commodity exchanges.
- Minimum capital
- NGN 50 million (previously NGN 10 million); Commodities Broker NGN 30 million; Commodities Dealer NGN 20 million (SEC Circular 26-1 on Revised Minimum Capital, 16 January 2026; compliance by 30 June 2027). (≈USD 33 k)
- Fees
- Filing/application fee plus processing fee, commodities broker/dealerNGN 50,000 filing plus NGN 50,000 processingRegistration fee, commodities broker/dealerNGN 200,000Fidelity insurance bondBond cover of at least 20% of minimum paid-up capital, valid to 31 December
- Clients
- Retail permitted
- Conditions
- Covers exchange-based commodity trading. Physical commodity merchanting outside an exchange is not an SEC-registered activity.
- Systems
- Commodities Trading House
- Reading
- Read in the rulebook
- Sources
Reach
None. No passporting into other markets. Foreign firms must register a Nigerian entity.
Passage
No statutory decision deadline or published service standard was confirmed. Market practice: several months for capital market operator registration, longer for digital asset categories.
Licensed elsewhere
Banks, including commercial, merchant and non-interest (Islamic) banks, are licensed by the Central Bank of Nigeria (private-bank, digital-bank, investment-bank, correspondent-banking, treasury-desk, trade-finance, islamic-finance). Payment service providers, mobile money operators, switches and card schemes are licensed by the CBN (psp, emi, card-issuing, merchant-acquiring). International money transfer operators (IMTOs) and bureaux de change are licensed by the CBN (msb). Retail FX/CFD brokerage has no SEC license category; FX dealing is under CBN control. Pension fund administrators and custodians are licensed by the National Pension Commission (pension-manager). Insurers and takaful operators are licensed by NAICOM (insurance-vehicle). No regime covers crypto mining or sovereign vehicles; the Nigeria Sovereign Investment Authority is established by its own statute.
Notes. The brief refers to a January 2025 capital revision. The circular in force is SEC Circular 26-1, Revised Minimum Capital for Regulated Capital Market Entities, dated 16 January 2026, with compliance due by 30 June 2027; firms that miss it risk suspension or withdrawal of registration. It replaced the 2015 capital regime. The Investments and Securities Act 2025 (signed in March 2025) repealed ISA 2007, treats digital and virtual assets as securities, and brings VASPs under the SEC. USD conversions use about NGN 1,500 per USD and will move with the naira.
The rankings
Thirty-four regulators, in order
Five measures, each scored from 0 to 100, weighted and added. The bar on each row shows how much each measure contributes, so a high rank can be read for what it rests on.
Credibility35%
Standing among banks and counterparties, IOSCO membership and FATF status
Breadth15%
Share of the forty-seven systems the regulator can license
Entry threshold20%
Money needed to open, across a basket of common systems; a lower amount earns a higher score
Speed15%
Typical months from a complete application to grant; faster scores higher
Reach15%
Cross-border passport and access to retail clients
CredibilityBreadthEntry thresholdSpeedReach
Weights: Credibility 35% · Breadth 15% · Entry threshold 20% · Speed 15% · Reach 15%
RankRegulatorWhere the score comes fromScore
1 BaFinGermany · Tier 1852 CSSFLuxembourg · Tier 1853 SFCHong Kong · Tier 1804 FSA JapanJapan · Tier 1805 FCAUnited Kingdom · Tier 1806 ASICAustralia · Tier 1797 CBI IrelandIreland · Tier 1798 MASSingapore · Tier 1789 FSRAUAE · Abu Dhabi, ADGM · Tier 17610 FINMASwitzerland · Tier 17511 Bank of LithuaniaLithuania · Tier 27512 DFSAUAE · Dubai, DIFC · Tier 17513 SECUnited States · Tier 17414 MFSAMalta · Tier 27315 CFTC · NFAUnited States · Tier 16816 CySECCyprus · Tier 26817 FSCASouth Africa · Tier 26618 SAMASaudi Arabia · Tier 26219 FSC MauritiusMauritius · Offshore6020 CBBBahrain · Tier 26021 SCB BahamasThe Bahamas · Offshore5922 SEC NigeriaNigeria · Tier 25923 NYDFSUnited States · New York · Tier 15824 Labuan FSAMalaysia · Labuan · Offshore5625 CMA UAEUAE · Federal · Tier 25626 VARAUAE · Dubai · Tier 25327 BMABermuda · Offshore5328 QFCRAQatar · QFC · Tier 25229 CIMACayman Islands · Offshore5230 CMA KenyaKenya · Tier 25231 CMA SaudiSaudi Arabia · Tier 25132 FSA SeychellesSeychelles · Offshore5033 CBUAEUAE · Federal · Tier 24934 BVI FSCBritish Virgin Islands · Offshore44
Weights: Credibility 55% · Breadth 10% · Entry threshold 10% · Speed 10% · Reach 15%
RankRegulatorWhere the score comes fromScore
1 BaFinGermany · Tier 1912 CSSFLuxembourg · Tier 1913 FSA JapanJapan · Tier 1864 CBI IrelandIreland · Tier 1865 ASICAustralia · Tier 1866 SFCHong Kong · Tier 1857 FCAUnited Kingdom · Tier 1858 MASSingapore · Tier 1839 FINMASwitzerland · Tier 18210 FSRAUAE · Abu Dhabi, ADGM · Tier 18211 DFSAUAE · Dubai, DIFC · Tier 18112 SECUnited States · Tier 18113 CFTC · NFAUnited States · Tier 17814 Bank of LithuaniaLithuania · Tier 27315 NYDFSUnited States · New York · Tier 17116 MFSAMalta · Tier 27117 CySECCyprus · Tier 26818 FSCASouth Africa · Tier 26419 SAMASaudi Arabia · Tier 26220 CBBBahrain · Tier 26121 SEC NigeriaNigeria · Tier 26022 CMA UAEUAE · Federal · Tier 25823 CMA SaudiSaudi Arabia · Tier 25724 QFCRAQatar · QFC · Tier 25625 VARAUAE · Dubai · Tier 25526 CBUAEUAE · Federal · Tier 25427 FSC MauritiusMauritius · Offshore5028 SCB BahamasThe Bahamas · Offshore5029 CMA KenyaKenya · Tier 24830 Labuan FSAMalaysia · Labuan · Offshore4731 CIMACayman Islands · Offshore4532 BMABermuda · Offshore4433 FSA SeychellesSeychelles · Offshore4134 BVI FSCBritish Virgin Islands · Offshore31
Weights: Credibility 15% · Breadth 10% · Entry threshold 35% · Speed 30% · Reach 10%
RankRegulatorWhere the score comes fromScore
1 SFCHong Kong · Tier 1802 FSC MauritiusMauritius · Offshore773 BaFinGermany · Tier 1764 CSSFLuxembourg · Tier 1755 Bank of LithuaniaLithuania · Tier 2746 ASICAustralia · Tier 1747 FCAUnited Kingdom · Tier 1738 SCB BahamasThe Bahamas · Offshore739 MFSAMalta · Tier 27210 Labuan FSAMalaysia · Labuan · Offshore7211 FSA JapanJapan · Tier 17012 FSRAUAE · Abu Dhabi, ADGM · Tier 17013 MASSingapore · Tier 17014 FSCASouth Africa · Tier 27015 SECUnited States · Tier 16916 SAMASaudi Arabia · Tier 26917 DFSAUAE · Dubai, DIFC · Tier 16818 FINMASwitzerland · Tier 16719 FSA SeychellesSeychelles · Offshore6520 CySECCyprus · Tier 26421 CFTC · NFAUnited States · Tier 16322 BMABermuda · Offshore6323 CIMACayman Islands · Offshore6324 CBI IrelandIreland · Tier 16325 CMA KenyaKenya · Tier 26026 BVI FSCBritish Virgin Islands · Offshore5927 SEC NigeriaNigeria · Tier 25828 VARAUAE · Dubai · Tier 25729 CBBBahrain · Tier 25630 CMA UAEUAE · Federal · Tier 25331 QFCRAQatar · QFC · Tier 24932 CMA SaudiSaudi Arabia · Tier 24633 CBUAEUAE · Federal · Tier 24334 NYDFSUnited States · New York · Tier 141
How each measure is scored
Credibility. Tier 1 scores 100, Tier 2 65, offshore 35. Ten points come off for an IOSCO MMoU Appendix B signatory, twenty for a securities regulator that has not signed, and twenty-five where the jurisdiction is under FATF increased monitoring.
Breadth. Systems the regulator can license, as a share of forty-seven.
Entry threshold. For a basket of twelve common systems, the cheapest fitting category’s capital, deposits and fees at start; the median of those, scored 100 at USD 10 thousand and 0 at USD 100 million on a logarithmic scale.
Speed. Typical months from a complete application to grant: 3 months scores 100, 18 months scores 0. Where no timeline is recorded the score is held at 50.
Reach. Half from the share of categories open to retail clients, half from passporting: an EU/EEA passport scores 100, a narrower passport 60, none 20.
Read it with care
Scores measure fit to the forty-seven systems the House designs, not the quality of a regulator, and the ranking is not a recommendation. A ranking compresses judgment into a number. It is a starting point for a mandate, not its conclusion: the right regulator is the one whose clients, counterparties and passport fit the institution being built.
Standing reflects how banks, liquidity providers and institutional clients read the license, and is the House’s editorial view. Timelines are typical, not promised. Where a fee schedule could not be read, the entry threshold rests on capital alone.
The costs
What a license costs, and when
Fees are recorded for every regulator whose schedule could be read, by the moment they fall due. Capital is recorded per category. The two are kept apart: one is spent, the other is held.
Filing
Grant
Opening
Every year
At filing
Application
Processing or vetting fee paid when the file goes in. Usually not refunded.
At grant
On grant
License issue or registration fee, and any first contribution to a compensation fund.
Held throughout
Minimum capital
Own funds the firm must keep. It stays on the balance sheet but cannot be spent below the floor.
Held throughout
Deposits & guarantees
Security deposits, bonds or bank guarantees lodged beyond the capital.
Every year
Annual fees & levies
License renewal, supervision fees and levies, often scaled to income.
As it arises
Other charges
Approved persons, change of control, new funds or new activities.
Spent
Fees leave the business
Application, grant, annual and other fees are costs. They reduce profit and are not recovered.
Held
Capital and deposits stay on the balance sheet
They remain the firm’s assets, but must be kept above the regulatory floor. They are a funding need, not a cost.
Compare
The cost of opening, by system
Choose a system. Each row is the cheapest fitting category at one regulator.
Retail Brokerage
Opening a retail brokerage: what is held, and what is spent
Held: capital and depositsSpent: application, grant and first annual fees
Regulator
Held at opening · capital and deposits
Fees recorded for year one · formula levies excluded
FSC MauritiusUSD 2 k
USD 100 k
USD 9 k
USD 122 k
USD 26 k
USD 174 k
USD 16 k
USD 174 k
not recorded
CSSFUSD 174 k
USD 77 k
USD 174 k
USD 35 k
USD 200 k
USD 18 k
USD 200 k
USD 65 k
USD 233 k
USD 78
BMAUSD 250 k
USD 6 k
USD 335 k
USD 1 k
USD 390 k
USD 2 k
USD 500 k
USD 90 k
USD 700 k
USD 86 k
USD 870 k
USD 15 k
USD 870 k
not recorded
FINMAUSD 1.88 m
USD 25 k
USD 2.66 m
USD 2 k
USD 3.85 m
USD 33 k
USD 8.17 m
not recorded
CFTC · NFAUSD 20 m
USD 150 k
The lowest-cost fitting category at each regulator. Both columns on logarithmic scales, in USD. Fees not recorded are left blank rather than assumed to be zero. Fees set as a share of income are excluded, so year-one figures are partial. A regulator is left out where no fitting category has a fixed capital figure.
Fund Management Company
Opening a fund management company: what is held, and what is spent
Held: capital and depositsSpent: application, grant and first annual fees
Regulator
Held at opening · capital and deposits
Fees recorded for year one · formula levies excluded
BMAUSD 12 k
USD 6 k
USD 13 k
USD 1 k
USD 22 k
USD 4 k
USD 40 k
USD 15 k
USD 50 k
USD 20 k
USD 57 k
USD 4 k
USD 67 k
USD 1 k
USD 71 k
USD 4 k
USD 105 k
USD 2 k
USD 145 k
USD 18 k
USD 145 k
not recorded
BaFinUSD 145 k
USD 39 k
USD 145 k
USD 70 k
USD 145 k
USD 22 k
USD 145 k
not recorded
Bank of LithuaniaUSD 145 k
not recorded
CMA KenyaUSD 155 k
USD 466
USD 195 k
USD 4 k
USD 250 k
USD 11 k
USD 266 k
USD 2 k
USD 272 k
not recorded
SEC NigeriaUSD 1.33 m
USD 7 k
USD 5.33 m
not recorded
The lowest-cost fitting category at each regulator. Both columns on logarithmic scales, in USD. Fees not recorded are left blank rather than assumed to be zero. Fees set as a share of income are excluded, so year-one figures are partial. A regulator is left out where no fitting category has a fixed capital figure.
Digital Asset Exchange
Opening a digital asset exchange: what is held, and what is spent
Held: capital and depositsSpent: application, grant and first annual fees
Regulator
Held at opening · capital and deposits
Fees recorded for year one · formula levies excluded
SECUSD 5 k
USD 9 k
USD 10 k
USD 2 k
USD 67 k
not recorded
FSA SeychellesUSD 100 k
USD 36 k
USD 141 k
USD 8 k
USD 174 k
not recorded
BaFinUSD 174 k
not recorded
CSSFUSD 174 k
USD 46 k
USD 174 k
USD 35 k
USD 174 k
USD 23 k
USD 174 k
not recorded
MASUSD 195 k
not recorded
FCAUSD 200 k
USD 37 k
USD 200 k
USD 65 k
USD 218 k
USD 82 k
USD 272 k
USD 185 k
USD 642 k
USD 1 k
USD 798 k
USD 270
USD 1.25 m
USD 9 k
USD 1.33 m
not recorded
The lowest-cost fitting category at each regulator. Both columns on logarithmic scales, in USD. Fees not recorded are left blank rather than assumed to be zero. Fees set as a share of income are excluded, so year-one figures are partial. A regulator is left out where no fitting category has a fixed capital figure.
Electronic Money Institution
Opening a electronic money institution: what is held, and what is spent
Held: capital and depositsSpent: application, grant and first annual fees
Regulator
Held at opening · capital and deposits
Fees recorded for year one · formula levies excluded
FSC MauritiusUSD 43 k
USD 4 k
USD 78 k
USD 5 k
USD 250 k
USD 30 k
USD 375 k
USD 4 k
USD 406 k
USD 8 k
USD 406 k
not recorded
CSSFUSD 406 k
USD 64 k
USD 406 k
not recorded
MFSAUSD 406 k
USD 58 k
USD 500 k
USD 15 k
USD 533 k
USD 5 k
USD 4.08 m
not recorded
The lowest-cost fitting category at each regulator. Both columns on logarithmic scales, in USD. Fees not recorded are left blank rather than assumed to be zero. Fees set as a share of income are excluded, so year-one figures are partial. A regulator is left out where no fitting category has a fixed capital figure.
Private Bank
Opening a private bank: what is held, and what is spent
Held: capital and depositsSpent: application, grant and first annual fees
Regulator
Held at opening · capital and deposits
Fees recorded for year one · formula levies excluded
CIMAUSD 488 k
USD 5 k
USD 1.5 m
USD 325 k
USD 2.36 m
USD 42 k
USD 5 m
USD 50 k
USD 5.8 m
USD 40 k
USD 5.8 m
not recorded
CBI IrelandUSD 5.8 m
USD 339 k
USD 5.8 m
USD 99 k
USD 5.8 m
not recorded
QFCRAUSD 9.62 m
USD 15 k
USD 10 m
USD 115 k
USD 10 m
USD 30 k
USD 10.09 m
USD 222 k
USD 12.5 m
USD 31 k
USD 13.4 m
not recorded
CBUAEUSD 27.23 m
not recorded
MASUSD 78 m
USD 92 k
USD 100 m
USD 35 k
The lowest-cost fitting category at each regulator. Both columns on logarithmic scales, in USD. Fees not recorded are left blank rather than assumed to be zero. Fees set as a share of income are excluded, so year-one figures are partial. A regulator is left out where no fitting category has a fixed capital figure.
Multi-Family Office
Opening a multi-family office: what is held, and what is spent
Held: capital and depositsSpent: application, grant and first annual fees
Regulator
Held at opening · capital and deposits
Fees recorded for year one · formula levies excluded
BMAUSD 12 k
USD 6 k
USD 13 k
USD 1 k
USD 13 k
USD 3 k
USD 25 k
USD 18 k
USD 33 k
USD 1 k
USD 58 k
USD 64 k
USD 66 k
USD 2 k
USD 71 k
USD 4 k
USD 87 k
USD 16 k
USD 87 k
not recorded
CBI IrelandUSD 87 k
USD 35 k
USD 87 k
USD 9 k
USD 100 k
USD 7 k
USD 125 k
USD 2 k
USD 140 k
USD 40 k
USD 155 k
USD 466
USD 174 k
not recorded
MASUSD 195 k
USD 4 k
USD 250 k
USD 50 k
USD 250 k
USD 15 k
USD 250 k
not recorded
CMA UAEUSD 817 k
not recorded
SEC NigeriaUSD 1.33 m
USD 7 k
USD 5.33 m
not recorded
The lowest-cost fitting category at each regulator. Both columns on logarithmic scales, in USD. Fees not recorded are left blank rather than assumed to be zero. Fees set as a share of income are excluded, so year-one figures are partial. A regulator is left out where no fitting category has a fixed capital figure.
Fee schedules
By regulator
The number is the count of fee items recorded. Open a sheet for the full schedule.
BaFin
Germany
6fees
CSSF
Luxembourg
21fees
SFC
Hong Kong
6fees
FSA Japan
Japan
3fees
FCA
United Kingdom
20fees
ASIC
Australia
11fees
CBI Ireland
Ireland
7fees
MAS
Singapore
19fees
FSRA
UAE · Abu Dhabi, ADGM
27fees
FINMA
Switzerland
13fees
Bank of Lithuania
Lithuania
4fees
DFSA
UAE · Dubai, DIFC
14fees
SEC
United States
13fees
MFSA
Malta
24fees
CFTC · NFA
United States
15fees
CySEC
Cyprus
6fees
FSCA
South Africa
12fees
SAMA
Saudi Arabia
5fees
FSC Mauritius
Mauritius
47fees
CBB
Bahrain
17fees
SCB Bahamas
The Bahamas
22fees
SEC Nigeria
Nigeria
10fees
NYDFS
United States · New York
9fees
Labuan FSA
Malaysia · Labuan
12fees
CMA UAE
UAE · Federal
7fees
VARA
UAE · Dubai
6fees
BMA
Bermuda
17fees
QFCRA
Qatar · QFC
2fees
CIMA
Cayman Islands
17fees
CMA Kenya
Kenya
26fees
CMA Saudi
Saudi Arabia
0fees
FSA Seychelles
Seychelles
20fees
CBUAE
UAE · Federal
0fees
BVI FSC
British Virgin Islands
22fees
The coverage
Who licenses what
Each of the forty-seven systems, with the regulators that grant a category for it, the highest ranked first. Select a system for its full comparison, or a regulator for its sheet.
Tier 1 Tier 2 OffshoreOrder: balanced rank
Capital Markets
Where price is discovered, and risk is carried.Asset & Wealth
Where capital is gathered, mandated and stewarded.Sovereign Investment Vehicle0 of 34
Not licensed as such by any of the thirty-four; see the system page.
Banking & Payments
Where money is held, moved and settled.Alternative Systems
Where new instruments and new rails are built.The stations
One practice for each regulator
Every regulator on the chart has a station: a single law firm or licensing practice admitted in that jurisdiction, with which the House coordinates the applications its clients make. A station is held by one practice at a time, and stations are open to admitted practices.
OpenBaFinGermany
OpenCSSFLuxembourg
OpenSFCHong Kong
OpenFSA JapanJapan
OpenFCAUnited Kingdom
OpenASICAustralia
OpenCBI IrelandIreland
OpenMASSingapore
OpenFSRAUAE · Abu Dhabi, ADGM
OpenFINMASwitzerland
OpenBank of LithuaniaLithuania
OpenDFSAUAE · Dubai, DIFC
OpenSECUnited States
OpenMFSAMalta
OpenCFTC · NFAUnited States
OpenCySECCyprus
OpenFSCASouth Africa
OpenSAMASaudi Arabia
OpenFSC MauritiusMauritius
OpenCBBBahrain
OpenSCB BahamasThe Bahamas
OpenSEC NigeriaNigeria
OpenNYDFSUnited States · New York
OpenLabuan FSAMalaysia · Labuan
OpenCMA UAEUAE · Federal
OpenVARAUAE · Dubai
OpenBMABermuda
OpenQFCRAQatar · QFC
OpenCIMACayman Islands
OpenCMA KenyaKenya
OpenCMA SaudiSaudi Arabia
OpenFSA SeychellesSeychelles
OpenCBUAEUAE · Federal
OpenBVI FSCBritish Virgin Islands
Admission
A practice admitted in the jurisdiction, with a record of authorizations granted by that regulator, may ask to hold its station.
Exclusivity
The House intends to work with one practice per station, and not to divide a jurisdiction between practices or run them against each other.
How to ask
Through Submit an Inquiry, choosing the provider or partner path and naming the station.
Method & sources
How the chart was drawn
Categories and capital
Each regulator was read from its own rulebook, statutes and published guidance, corrected to November 2026. Where a figure could only be found in a secondary source, such as a law firm’s guide, it is marked so; where sources disagreed or a figure could not be confirmed, it is marked to be confirmed and nothing is invented to fill it. Of 563 categories, 325 were read in the rulebook, 192 from a secondary source and 46 are to be confirmed. A second reading checked the principal figures; its corrections are applied.
Fees
Fees were read from each regulator’s fee rules or schedule and sorted by the moment they fall due: on application, on grant, as deposits, every year, or as they arise. Of 460 fee items, 308 were read in the regulator’s own text, 124 from a secondary source and 28 are to be confirmed. Fees set as a formula, such as a share of income, are described and left out of the totals. Where a regulator prices by activity, the totals for a category take its principal fee together with any fee that applies to every firm; add-ons for further activities are listed on the regulator’s sheet. Where no schedule could be read, the sheet says so; the absence of a fee is not taken to mean that none is charged.
Currency
Figures are kept in the regulator’s currency. USD equivalents are approximate and are given only so that regimes can be compared.
Mapping to the systems
A category is mapped to a system when it is the license a founder would apply for to build that system in that jurisdiction. Where a system needs two permissions, both are listed. Where a regulator does not license a system, its sheet names the authority that does.
The ranking
Five measures, each scored from 0 to 100, are weighted and added. The formulas are set out on the rankings page. IOSCO status and FATF status were read in November 2026; FATF status follows the plenary of 28 to 30 October 2026, which changed the standing of no jurisdiction on the chart.
What this is not
The Chart Room is a reference instrument of the House. It is not legal, tax or regulatory advice, and it is not a substitute for counsel admitted in the jurisdiction. X‑CHASE is not licensed, registered or authorized as a bank, broker-dealer, investment adviser or asset manager in any jurisdiction.
Corrections
Rules change, and the chart is corrected as they do. Corrections are welcome through Submit an Inquiry.
From the House of X‑CHASE
The Chart Room · XC·IS·CR-02 · Second edition
Index
Everything on the chart, A to Z
Regulators
ASIC AustraliaBaFin GermanyBank of Lithuania LithuaniaBMA BermudaBVI FSC British Virgin IslandsCBB BahrainCBI Ireland IrelandCBUAE UAE · FederalCFTC · NFA United StatesCIMA Cayman IslandsCMA Kenya KenyaCMA Saudi Saudi ArabiaCMA UAE UAE · FederalCSSF LuxembourgCySEC CyprusDFSA UAE · Dubai, DIFCFCA United KingdomFINMA SwitzerlandFSA Japan JapanFSA Seychelles SeychellesFSC Mauritius MauritiusFSCA South AfricaFSRA UAE · Abu Dhabi, ADGMLabuan FSA Malaysia · LabuanMAS SingaporeMFSA MaltaNYDFS United States · New YorkQFCRA Qatar · QFCSAMA Saudi ArabiaSCB Bahamas The BahamasSEC United StatesSEC Nigeria NigeriaSFC Hong KongVARA UAE · Dubai
Systems
Asset Management CompanyCard Issuing ProgramCommodities Trading HouseCorrespondent Banking StructureCustody & Wallet InfrastructureDigital Asset ExchangeDigital Asset FundDigital BankECN & DMA VenueElectronic Money InstitutionETF PlatformFund Management CompanyHedge FundInstitutional BrokerageInsurance & Reinsurance VehicleInvestment Advisory FirmInvestment BankIslamic Finance StructureMerchant AcquiringMining & Validation OperationMoney Services BusinessMulti-Asset BrokerageMulti-Family OfficeMutual Fund & UCITSOTC Digital Asset DeskPayment Service ProviderPension & Endowment ManagerPrime BrokeragePrime-of-PrimePrivate BankPrivate BrokeragePrivate Credit FundPrivate Equity FirmProprietary Trading FirmQuantitative Trading DeskReal Estate Investment VehicleRetail BrokerageSingle-Family OfficeSovereign Investment VehicleStablecoin Issuance StructureStructured Products IssuerTokenization PlatformTrade Finance HouseTreasury & Liquidity DeskVenture Capital FirmWealth Management FirmWhite-Label Brokerage