Crypto regulatory tracker

Fully regulated — MiCA in force, transitional period ended

Regulator(s): National competent authorities in each EU member state, under ESMA/MiCA

The Markets in Crypto-Assets Regulation (MiCA) is the EU's binding framework. Its transitional deadline of 1 July 2026 has passed with no extensions — any crypto-asset service provider (CASP) serving EU clients must hold a MiCA authorisation from a national regulator or cease services. As of June 2026, 204 CASPs held full MiCA authorisation, including Kraken, Coinbase, Binance, OKX, Crypto.com and Bitstamp. A single authorisation passports across all 30 EEA states (27 EU members plus Iceland, Liechtenstein, Norway). Capital requirements scale by activity: €50,000 (advisory/order transmission), €125,000 (exchange/trading platforms), €150,000 (custody). CASPs must meet governance, client-asset safeguarding, IT security and disclosure requirements, including at least one EU-resident director and DORA-aligned ICT security.

Last verified 2026-09-21

Regime finalised, not yet in force — applications open 30 Sept 2026

Regulator(s): Financial Conduct Authority (FCA)

The FCA published final rules for its new cryptoasset regime on 30 June 2026 (the Cryptoassets sourcebook, CRYPTO, plus the Core Prudential and Cryptoassets Prudential sourcebooks). The regime itself is expected to come into force 25 October 2027, but the application window opens earlier — 30 September 2026 to 28 February 2027 — and firms that apply in that window get transitional permission to keep operating while their application is assessed. Several components (DeFi, cryptoasset derivatives, stablecoin policy, audit and financial-crime guidance) are still under active policy development, so the regime is finalised in outline but not yet complete in every detail.

Last verified 2026-09-21

Fragmented — federal guidance issued, comprehensive market-structure law still pending

Regulator(s): Securities and Exchange Commission (SEC), Commodity Futures Trading Commission (CFTC), Office of the Comptroller of the Currency (OCC), State-level regulators

No single comprehensive federal crypto law exists yet. On 17 March 2026 the SEC and CFTC jointly issued an interpretation classifying crypto assets into five categories (digital commodities, digital collectibles, digital tools, stablecoins, digital securities) and clarifying how existing securities/commodities law applies to each. The SEC proposed further rulemaking ("Regulation Crypto Assets") on 18 August 2026 for investment-contract-like crypto assets. Stablecoins are further along: the GENIUS Act has been in force since July 2025, and the OCC proposed a federal framework for payment-stablecoin issuers in February 2026. The broader market-structure bill (the CLARITY Act, passed the House 294–134 in July 2025) remains pending in the Senate. Until it passes, exchanges operate under a patchwork of federal interpretation plus state-level licensing (e.g. NY BitLicense).

Last verified 2026-09-21

Regulated for domestic service, near-frozen for overseas-only providers

Regulator(s): Monetary Authority of Singapore (MAS)

Two separate regimes exist. Digital Payment Token (DPT) licensing under the Payment Services Act covers firms serving Singapore-based customers — 37 entities held an active DPT-related Major Payment Institution licence as of 19 June 2026. Separately, the Digital Token Service Provider (DTSP) licence under the Financial Services and Markets Act 2022 covers Singapore-incorporated entities serving overseas clients only, in force since 30 June 2025 — but as of 7 September 2026, more than 14 months in, no DTSP licence has been publicly granted at all, out of 3,653 entities across 48 licence types in MAS's own directory. MAS has signalled it expects to grant DTSP licences only sparingly, effectively closing that route for most overseas-focused crypto businesses incorporated in Singapore.

Last verified 2026-09-21

Regulated — mandatory licensing, actively enforced

Regulator(s): Virtual Assets Regulatory Authority (VARA) — Dubai, Four other UAE-level regulators for activity outside VARA's Dubai remit

VARA is the sole regulator for virtual-asset activity across Dubai's mainland and free zones (excluding the DIFC financial free zone, which has its own regime). A VARA Virtual Asset Service Provider (VASP) licence is mandatory to run an exchange, custody service, broker-dealer or advisory business in or from Dubai — there are seven distinct licence categories, each requiring separate authorisation with no bundled multi-activity licence. Over 20 entities hold VARA licences directly, and over 80 VASPs are licensed across the UAE's five regulators combined. VARA's updated Exchange Services Rulebook took effect 31 March 2026, and enforcement has tightened through 2026: robust custody segregation, fit-and-proper assessments and ongoing supervisory reporting are now standard expectations, not just guidance.

Last verified 2026-09-21

Regime finalised, transitional — AFS-licence deadline 30 Sept 2026, full regime commences 9 April 2027

Regulator(s): Australian Securities and Investments Commission (ASIC), Australian Transaction Reports and Analysis Centre (AUSTRAC)

The Corporations Amendment (Digital Assets Framework) Bill 2025 received Royal Assent on 8 April 2026, creating a dedicated licensing framework for Digital Asset Platforms (DAPs) and Tokenised Custody Platforms (TCPs). Operators of either must hold an Australian Financial Services Licence (AFSL) from ASIC, bringing them under the same core obligations as brokers or fund managers — client-asset safeguarding, standardised disclosure, misleading-conduct rules and dispute-resolution/compensation arrangements. The regime itself commences 9 April 2027, but businesses currently relying on ASIC's sector-wide no-action position must apply for, or vary, an AFSL by 30 September 2026 or risk civil and criminal exposure once that position lapses. Separately, Australia's expanded AML/CTF regime took effect 1 July 2026, and newly regulated virtual-asset service providers had to register with AUSTRAC by 29 July 2026. Crypto is treated as property for capital gains tax purposes by the Australian Taxation Office; there is no separate crypto-specific tax regime.

Tax note: Crypto is treated as property for capital gains tax (CGT) purposes by the ATO — disposals (including crypto-to-crypto trades) are typically CGT events; no dedicated crypto tax law exists.

Last verified 2026-09-27

Regulated — VATP licensing regime in force, 13 platforms licensed as of Feb 2026

Regulator(s): Securities and Futures Commission (SFC)

Hong Kong's Virtual Asset Trading Platform (VATP) regime requires exchanges serving Hong Kong retail or professional investors to be licensed by the SFC; 13 VATPs held a licence as of February 2026. On 3 November 2025 the SFC published circulars expanding what licensed VATPs can offer — including dropping the prior 12-month track-record requirement before a virtual asset (including stablecoins) can be offered to professional investors — and permitting SFC-licensed platforms to integrate order books with global affiliate VATPs for shared liquidity. Minimum financial requirements for a licence include HK$5 million paid-up share capital and HK$3 million liquid capital, plus a 12-month operating-expense liquidity buffer. Separately, the Financial Services and Treasury Bureau and the SFC published consultation conclusions (24 December 2025) on a further legislative proposal to regulate OTC virtual-asset dealing and custodian services, with a bill expected to be introduced to the Legislative Council in 2026 — meaning the regime is in force for trading platforms but still expanding to cover adjacent activities.

Last verified 2026-09-27

Regulated — crypto oversight moving from the Payment Services Act to the Financial Instruments and Exchange Act, full implementation 13 June 2026

Regulator(s): Financial Services Agency (FSA)

Japan has long required crypto-asset exchange service providers to register with the FSA under the Payment Services Act (PSA). A 2025–2026 amendment cycle, enacted 6 June 2025 with full implementation from 13 June 2026, transfers crypto-asset regulation from the PSA to the stricter Financial Instruments and Exchange Act (FIEA) and broadens which entities must register as exchange or intermediary businesses. The reform also codifies stablecoin reserve, custody and redemption requirements in Cabinet orders and FSA ordinances, and will require every licensed exchange to hold dedicated liability reserves that pay out users immediately in the event of hacks, fraud, operational errors or unauthorised withdrawals. The FSA has signalled more assertive enforcement against unregistered offshore platforms targeting Japanese users, including public warnings and operational pauses. Historically, individual crypto gains have been taxed as miscellaneous income at progressive rates (up to roughly 55% including local tax); a shift to a flat rate aligned with securities taxation has been publicly discussed but is not confirmed as settled law — check current National Tax Agency guidance directly.

Tax note: Historically taxed as miscellaneous income at progressive rates (up to ~55% including local tax); a flat-rate reform has been discussed but confirm current status with the National Tax Agency before filing.

Last verified 2026-09-27

Regulated, transitional — VASP authorisation framework in force, adaptation deadline 30 Oct 2026

Regulator(s): Banco Central do Brasil (BCB), Comissão de Valores Mobiliários (CVM)

Brazil's base crypto law, Law 14.478/2022 (Marco Legal dos Criptoativos), designated the Banco Central do Brasil as primary regulator for non-security virtual assets. On 10 November 2025 the BCB published three implementing resolutions (519, 520 and 521) that establish a full authorisation regime for virtual-asset service providers, formally termed "sociedades prestadoras de serviços de ativos virtuais" (SPSAVs/VASPs). Existing providers have a 270-day adaptation window starting 2 February 2026, with a hard deadline of 30 October 2026 — firms that miss it must cease operations and give clients 30 days to migrate assets to an authorised provider. Minimum capital requirements range from roughly R$10.8 million to R$37.2 million (about US$2.2–7.6 million) depending on business model. The CVM separately oversees crypto instruments that qualify as securities (e.g. tokenised debentures, FIDC quotas) regardless of on-chain format. Foreign platforms serving Brazilian customers must set up locally, transfer customers to a licensed Brazilian entity, or stop serving Brazilian residents. Individuals' capital gains from crypto sales are taxed progressively (15%–22.5%), with a monthly exemption for small-value disposals — confirm current thresholds with Receita Federal.

Tax note: Individual capital gains from crypto sales are taxed progressively (15%–22.5%), with a monthly exemption for small-value disposals; confirm current thresholds with Receita Federal.

Last verified 2026-09-27

Unregulated as a product class — no dedicated crypto law

Regulator(s): Reserve Bank of India (RBI), Securities and Exchange Board of India (SEBI), Ministry of Finance, FIU-IND

Buying, holding and selling crypto is legal in India, but virtual digital assets (VDAs) have no dedicated regulatory law and are not legal tender. No single regulator currently oversees the sector — RBI, SEBI and the Finance Ministry are negotiating a proposed split (SEBI for exchanges/security-like tokens, RBI for cross-border flows, Finance Ministry for policy and tax). Every VDA service provider must register with FIU-IND on the FINgate portal for anti-money-laundering purposes, separate from any product regulation. The RBI has publicly opposed legalising crypto, preferring the Digital Rupee (CBDC) as its alternative; SEBI and industry bodies are pushing for clearer rules.

Tax note: 30% flat tax on crypto gains with no loss offset permitted; 1% TDS on VDA transfers above ₹10,000.

Last verified 2026-09-21