Where and how to register a crypto company

Preparing a license application in Uzbekistan takes considerable time. The company needs to prepare the application package, register the legal entity, set aside and confirm the required capital, host the platform on local servers, and write internal anti-money-laundering documents. This chapter does not give a minimum capital figure for Uzbekistan on purpose. Public sources give different figures depending on the type of license and on the date of the source. A wrong number is worse than no number, so confirm the current figure directly with NAPP before you file.

NAPP also uses its power to stop licensed companies. The public register of licenses on the NAPP website shows licenses that NAPP suspended for six months and licenses that NAPP revoked or annulled between 2024 and 2026. In September 2026, NAPP annulled one license because the company did not apply in time to resume it. For a founder, this means that a license in Uzbekistan is not the end of the work. The licensed company must keep meeting the rules every month. Otherwise, the company can lose the right to operate.

European Union: what is MiCA and how does a CASP license work?

In the European Union, the transition period under MiCA fully ended on July 1, 2026. Before that date, some companies worked under old national rules for VASPs. VASP stands for virtual asset service provider. These old national rules no longer apply. Now the only way to provide crypto services in the European Union is to get CASP status under MiCA. CASP stands for crypto-asset service provider. MiCA stands for Markets in Crypto-Assets, the European Union regulation on crypto-asset markets.

The main advantage of MiCA is that a license from one EU country lets the company work in the other EU countries too. This system is called passporting. Passporting works through a notice, not through a new license. The company with a CASP license tells its home regulator in which other EU countries it wants to offer services. The home regulator sends this information to the regulators of those countries. After that, the company can serve clients in those countries without a separate license in each country.

However, a passport does not mean that every EU country works in the same way. Different EU countries apply MiCA at different speeds. Poland is an example. The Polish parliament passed a national law to apply MiCA three times, and the president of Poland vetoed the law three times: on December 1, 2025, and twice more in 2026, the last time on June 11, 2026. On September 4, 2026, the lower house of the Polish parliament tried to override the third veto, but the vote failed. In that vote, 241 deputies voted in favor and 198 voted against, while 266 votes were needed.

As a result, Poland still has no authority designated to supervise crypto companies under MiCA. The Polish Financial Supervision Authority, known as the KNF, says that it cannot process applications for a CASP license from Polish companies. A company that has a CASP license from another EU country can still serve clients in Poland through a passport. A company that is based in Poland, however, has no way to get a CASP license in Poland itself. For this reason, check the status of MiCA separately in each target country, and especially in the country where you plan to register the company. Do not rely only on the general status of MiCA in the European Union.

How long does a MiCA license take? MiCA sets deadlines for the work of the regulator. The national regulator has 25 working days to check whether the application is complete. After the application is complete, the regulator has 40 working days to assess the application and make a decision. The regulator can pause this period to ask the company for more information. These deadlines cover only the work of the regulator. Before the company even files, it usually spends several months writing the application, hiring people, and building its compliance system.

How much capital does MiCA require?

MiCA sets the capital requirements directly in the regulation. There are three classes, and the class depends on the type of activity.

The first class requires 50,000 euros. It covers executing orders for clients, placing crypto assets, transferring crypto assets for clients, receiving and transmitting orders, giving advice on crypto assets, and managing crypto-asset portfolios.

The second class requires 125,000 euros. It covers everything in the first class, plus holding and administering crypto assets for clients, known as custody, and exchanging crypto assets for money or for other crypto assets.

The third class requires 150,000 euros. It covers everything in the second class, plus running a trading platform for crypto assets.

Check these figures on the date you file.

These fixed amounts are only the minimum. MiCA says that the company must hold the higher of two amounts: the fixed minimum for its class, or one quarter of its fixed overhead costs for the previous year. Fixed overhead costs are the costs that the company pays no matter how much business it does, such as salaries, rent, and software. A new company that has no previous year uses the overhead costs that it planned in its business plan. As a result, a company with a large team can need much more than 150,000 euros, even if it provides only the services of the first class.

MiCA also sets rules on where the company and its managers must be. The company must have a registered office in an EU country where it provides at least part of its services. The company must be effectively managed from the European Union. At least one director must live in the European Union. A virtual office does not meet these rules.

United Arab Emirates: which regulator covers which territory?

The United Arab Emirates, like Kazakhstan, has several regulators for crypto. However, the UAE divides its regulators by territory and by type of zone, not by type of asset.

VARA, the Virtual Assets Regulatory Authority, was created by Dubai Law number 4 of 2022. VARA covers the whole emirate of Dubai, including its free zones, except the Dubai International Financial Centre.

ADGM FSRA, the Financial Services Regulatory Authority of the Abu Dhabi Global Market, covers the Abu Dhabi Global Market, a financial free zone in Abu Dhabi.

DIFC DFSA, the Dubai Financial Services Authority of the Dubai International Financial Centre, covers the Dubai International Financial Centre, a separate financial free zone inside Dubai.

The federal Capital Market Authority, or CMA, covers the rest of the country outside the financial free zones. The CMA rules for virtual-asset service providers are set in CMA Decision number 4 R.M. of 2026.

The name CMA is new. Before January 1, 2026, the federal regulator was called the Securities and Commodities Authority, or SCA. The SCA was renamed the CMA under Federal Decree-Laws number 32 and number 33 of 2025, which took effect on January 1, 2026. If a document or a consultant still calls the federal regulator “SCA,” that information is out of date and should be checked again.

A financial free zone in the UAE, such as the Abu Dhabi Global Market or the Dubai International Financial Centre, is a territory with its own laws, its own regulator, and its own courts for business matters. A company licensed in one financial free zone cannot automatically serve clients in the rest of Dubai or in another zone. For this reason, a founder must first decide where the clients and the team will be, and only then choose the regulator.

How much capital does VARA require?

VARA sets the paid-up capital for each type of activity in its Company Rulebook. Paid-up capital is the money that the owners have actually paid into the company. The amounts in the next paragraphs are in UAE dirhams, the currency of the United Arab Emirates.

For advisory services, the minimum is 100,000 dirhams.

For broker-dealer services, meaning executing trades for clients, the minimum is the higher of 600,000 dirhams or 25 percent of the fixed annual overhead costs of the company.

For custody services, the minimum is the higher of 600,000 dirhams or 25 percent of the fixed annual overhead costs.

For lending and borrowing services, for management and investment services, and for transfer and settlement services, the minimum is the higher of 500,000 dirhams or 25 percent of the fixed annual overhead costs.

For exchange services, the minimum is the higher of 1,500,000 dirhams or 25 percent of the fixed annual overhead costs.

If a company also holds a VARA custody license, or has another approval from VARA, two minimums are lower. For broker-dealer services, the minimum is the higher of 400,000 dirhams or 15 percent of overhead costs. For exchange services, the minimum is the higher of 800,000 dirhams or 15 percent of overhead costs.

These amounts add up. If a company combines several activities, the company must hold the required paid-up capital for each activity separately. The company calculates the requirement for each activity from the fixed overhead costs of that activity only. The company must divide its overhead costs between its activities so that it counts every cost once. The company must also reconcile its paid-up capital every month. Check both the amounts and the exchange rate on the date you file.

United States: is there a federal crypto license?

In the United States, there is still no single federal law that clearly sets the legal status of crypto assets or divides authority between regulators. Today, the main tool is the Howey test. The Howey test comes from the 1946 US Supreme Court decision in SEC versus W. J. Howey Company. The test asks whether an asset is an investment contract, in other words a security. Courts and the Securities and Exchange Commission, known as the SEC, use this test to decide whether a specific token falls under securities law. If a token is a security under the Howey test, the project must either register the token sale with the SEC or use a legal exemption from registration. Chapter 4 explains the four parts of the Howey test and how to apply them to a specific token.

Congress has tried to pass a broad law on the crypto market. The bill is called the CLARITY Act. The House of Representatives passed the CLARITY Act in July 2025 by 294 votes to 134. On September 15, 2026, the bill failed a procedural vote in the Senate by 49 votes to 50. The bill needed 60 votes to move forward, and since then it has not moved forward in the Senate. As a result, it is still unclear which regulator has authority over what: the SEC or the Commodity Futures Trading Commission, known as the CFTC. A founder should not plan a US launch on the assumption that a federal law will pass soon.

One federal crypto law does exist, but only for stablecoins. The GENIUS Act became law on July 18, 2025. It sets federal rules for companies that issue payment stablecoins, meaning tokens that are designed to keep a fixed value against the US dollar. The GENIUS Act covers only stablecoin issuers. It does not decide the legal status of other tokens, and it does not license exchanges.

There is also one federal step that most crypto businesses cannot skip. A company that exchanges crypto for money, or transfers crypto for clients, is usually a money services business, or MSB, under federal rules. An MSB must register with FinCEN, the federal agency that fights money laundering, and must run an anti-money-laundering program. FinCEN registration is not a license, and FinCEN does not review the business model in depth. Still, operating without FinCEN registration is a violation of federal law.

Beyond the federal level, most US states require a separate money transmitter license, or MTL. A company needs an MTL in a state if it holds or converts funds for clients in that state. Each state sets its own capital and bonding requirements. Bonding means a surety bond, a financial guarantee that a licensed company buys from an insurance company. If the licensed company loses client money or breaks the rules, the state can take money from the bond to pay the clients. There is no single federal amount. The company must check the amounts and conditions in each state where it plans to work.

New York has an additional license for virtual currency businesses, known as the BitLicense. The New York State Department of Financial Services issues the BitLicense. A company that wants clients in New York must check the BitLicense rules in addition to the money transmitter rules.

Many founders believe that registering a company in Delaware solves everything. A Delaware registration covers only corporate law: how the company is structured, who the shareholders are, and how meetings are held. A Delaware registration does not answer whether a token passes the Howey test. It also does not give the company a money transmitter license in the states where its clients actually live.

Russia: what does the new law allow?

In Russia, the Federal Law “On Digital Currency and Digital Rights” was signed on August 4, 2026. Its main provisions took effect on September 1, 2026. This is the first Russian law that fully regulates the circulation of cryptocurrency. It is a federal law adopted by parliament, and the Bank of Russia regulates the market under this law. Russia also has a separate law on digital financial assets, which has been in force since 2021.

Under the new law, only companies included in a special register may carry out crypto exchange activity. A company in the register must have equity of at least 15 million rubles and must join a self-regulatory organization of the financial market. A self-regulatory organization is an association of market participants. It sets standards for its members and checks that the members follow them, under the supervision of the Bank of Russia.

Crypto exchanges may keep operating without registration until July 1, 2027. After that date, crypto transactions must go through registered companies. This means that, at the time this chapter was written, Russia is still in a transition period.

The Russian rules are noticeably stricter than the rules in Kazakhstan or Uzbekistan. Using crypto to pay for goods and services inside Russia remains banned, and advertising crypto as a way to pay is also banned. The law allows a few exceptions, such as payments under foreign trade contracts, the use of mined cryptocurrency, and settlements with securities, other digital currencies, or digital rights.

The law divides investors into two groups. Non-qualified investors, meaning ordinary retail investors, may buy only the most liquid cryptocurrencies. They may buy only through a registered intermediary, only after they pass a test, and only up to 300,000 rubles per year with one intermediary. Qualified investors may buy any cryptocurrency. The Bank of Russia decides which cryptocurrencies count as the most liquid. For this reason, check the final list of allowed assets shortly before launch.

Tajikistan: can a crypto company get a license?

In Tajikistan, there is currently no legal way to get a crypto license. In December 2025, the National Bank of Tajikistan stated that trading in virtual assets is not regulated by law and is not a licensed activity. The National Bank also stated that no crypto exchange is officially registered in the country, and that all financial transactions in the country must be in somoni, the national currency.

Of all the countries in this chapter, Tajikistan is the only one where a founder cannot choose a license, because there is no license to choose. Until Tajikistan adopts a special law, any crypto business there works outside the law. Such a business has no protection from a regulator and no legal way to work with local banks as a crypto company. For a founder, this means that Tajikistan is not a realistic main country for an operating crypto company at this time. Tajikistan may become worth watching if it adopts proper rules in the future. However, a business plan should not depend on that.

How do the countries compare?

The following paragraphs compare the main points for each country. Every figure in these paragraphs can change, so check each figure on the website of the regulator on the date you file.

Kazakhstan, national system. The National Bank of Kazakhstan licenses exchange operators and platforms and supervises stablecoins, and ARDFM regulates the other digital financial assets. The minimum capital is set in the rules of the National Bank, and one overview gives 50 million tenge for an exchanger. For the requirements on people and the office, check the rules of the National Bank. The main practical risk is the bank account.

Kazakhstan, AIFC. AFSA licenses crypto activity in the AIFC. The minimum capital depends on the license, and overviews give from about 200,000 US dollars for a trading facility. The company needs real people and a real office in Kazakhstan. The main practical risk is the bank account.

Uzbekistan. NAPP licenses crypto activity in Uzbekistan. The minimum capital depends on the type of license, so confirm the amount with NAPP. The servers of the platform must be inside Uzbekistan. The main practical risk is the suspension or the loss of the license.

The European Union. The national regulator of the chosen EU country licenses crypto activity under MiCA. The minimum capital is 50,000, 125,000, or 150,000 euros, depending on the class of services, or one quarter of the fixed overhead costs if that amount is higher. The company needs a registered office and management in the European Union and at least one director who lives in the European Union. The main practical risk is that EU countries apply MiCA unevenly, as the example of Poland shows.

Dubai, except the Dubai International Financial Centre. VARA licenses crypto activity in Dubai. The minimum capital is from 100,000 dirhams for advice to 1,500,000 dirhams for an exchange, for each activity, and the amounts for several activities add up. The company needs a real team in Dubai. The main practical risk is the cost of the local team.

The United States. At the federal level, the SEC and the CFTC share authority without a clear split, and FinCEN registers money services businesses. Each state issues its own money transmitter license and sets its own capital requirements, and the requirements for people also depend on the state. The main practical risks are the absence of a federal law on the crypto market and licensing state by state.

Russia. The Bank of Russia keeps the register of operators. An operator needs equity of at least 15 million rubles and membership in a self-regulatory organization. The main practical risks are the ban on crypto payments and the limits for investors.

Tajikistan. Tajikistan has no licensing system for crypto activity, so there are no requirements for capital or people, and there is no legal way to operate a crypto business.

Why does minimum capital decide whether I can enter the market?

Founders often skip the topic of minimum capital in the first meeting with a lawyer, because it sounds like a technical detail. In fact, minimum capital decides whether the company can enter the market at all. In every country in this chapter, the regulator sets the amount based on the specific activity. The higher the risk to client money, the higher the capital requirement. Holding client assets and running a full trading platform carry the highest risk. The difference between the lowest and the highest requirement in one country can be large. In Dubai, the minimum for advisory services is 100,000 dirhams, and the minimum for running an exchange is 1,500,000 dirhams, which is fifteen times more.

The practical lesson is simple. A founder cannot estimate a licensing budget from one number, such as “how much does a license in country X cost.” The founder must calculate the budget for the specific set of activities that the company plans to carry out, not for the country in general.

Capital is not the only cost. A licensing budget usually includes four more items. The first item is the application fees and the annual fees of the regulator. The second item is the salaries of the staff that the regulator requires, such as a compliance officer and a money laundering reporting officer, known as an MLRO, who reports suspicious transactions to the authorities. The third item is legal and consulting work on the application. The fourth item is technology, such as software that monitors transactions, and security audits.

Each regulator publishes its own list of fees, so check the fees on the website of the regulator.

Why does the reputation of the country matter for banks?

The reputation of the country is closely linked to capital, and general overviews rarely mention it. The Financial Action Task Force, known as FATF, is an international body that sets standards against money laundering. FATF keeps two lists of countries with weak anti-money-laundering rules. The “grey list” includes countries under increased monitoring. The “black list” includes countries that require stronger counter-measures.

A license from a country on either list is still legally valid in that country. However, banks and payment providers around the world consider the reputation of the country when they decide whether to open an account or process payments for a company. As a result, a license that is fully valid under local law may still not give the company access to international banking. A bank in another country can simply refuse and cite its own risk policy, without further explanation.

For this reason, check the current FATF status of a country before you choose it for registration, not after. FATF updates both lists after its plenary meetings, which usually take place three times a year, in February, June, and October. Check the list on the FATF website in the month when you choose the country, and do not rely on an old article.

What does it cost to choose the wrong country?

The cost of choosing the wrong country is real, and it usually comes from several problems at once, not from one problem. A founder who chooses a “cheap” country to save money at the start usually faces three connected consequences.

The first consequence concerns the money of the company. The bank account either does not open at all, or the account that does open does not work with the currency that the business needs. The company then has no legal place to hold client money.

The second consequence concerns the token. The country may not recognize the type of digital asset that the company needs, or it may require a separate and more expensive permit to issue the token. If the company finds this out only after the product launches, fixing the problem costs far more than choosing the right country from the start would have cost.

The third consequence concerns the courts. In a dispute with a client, a partner, or the regulator, a contract signed by a company with a doubtful or incomplete license can turn out to be unenforceable. This often happens in exactly the part of the contract where the company needs protection most.

None of these three problems appears in the first month of operation. Usually six months to a year and a half pass before the money saved on the country turns into one large cost that is several times higher than the original saving. For this reason, a founder should not choose a country only by the entry price. The founder should look at the full picture: what the business model needs, how much capital the full set of planned activities requires, what banking is really available, and what reputation the country has internationally.

How do I choose a country, step by step?

Step one. Describe the business in one paragraph. Write down what the company does with client money and client crypto: whether the company holds it, exchanges it, transfers it, or never touches it.

Step two. Turn this description into a list of activities. Use the list of activities of the regulator itself, for example the list of crypto services in MiCA or the list of activities in the VARA rules. One business often covers two or three activities.