Reference
MiCA vs the UK, US, Switzerland, and UAE: crypto licensing compared
A neutral comparison of the main crypto-licensing regimes a founder weighs alongside MiCA. The honest question is usually where your customers are, not which licence is easiest. None of these substitutes for another; a licence in one place does not authorise you in the others.
Last updated 2026-06-20. Regimes are evolving quickly, especially the UK and US; confirm current status with each regulator.
| Jurisdiction | Regulator | Single licence? | Market coverage | Status | Key trait |
|---|---|---|---|---|---|
| EU | National NCAs + ESMA/EBA (MiCA) | Yes | All 27 member states plus the EEA via one passport | In force; CASP regime live since 30 December 2024 | A single comprehensive regime covering issuers and service providers; the passport is its main draw |
| United Kingdom | FCA (with HM Treasury) | Not yet | UK only; no passport into the EU | AML registration and a financial-promotions regime today; a broader regulated-activities regime is being built | Moving toward a fuller framework; positioned as an alternative hub, but not interchangeable with MiCA |
| United States | SEC, CFTC, and state regulators | No | Federal plus state-by-state (for example a New York BitLicense) | Fragmented and enforcement-led; federal market-structure and stablecoin legislation has been advancing | No single federal licence; classification (security vs commodity) drives which regulator applies |
| Switzerland | FINMA | Activity-based | Switzerland; outside the EU and the MiCA passport | Mature; the DLT Act framework has been in force since 2021 | Principle-based licences keyed to the activity (banking, securities, fintech), not a single crypto licence |
| UAE (Dubai) | VARA (Dubai); ADGM/FSRA in Abu Dhabi; SCA federally | Per jurisdiction | Single emirate or free zone; not EU-passportable | Comprehensive and crypto-specific; among the more built-out non-EU regimes | Activity-based VASP licences with detailed rulebooks; popular for non-EU market access |
How to choose
Start from your customers. If the EU is a target market, MiCA is the access route, and one authorisation covers all 27 member states; see where to get it. If your users are mostly outside the EU, weigh the cost of an EU entity and ongoing supervision against the revenue at stake, and remember that reverse solicitation is a narrow exemption, not a market-entry plan. Most scaling firms end up holding more than one licence, because these regimes do not recognise each other.
Two moving targets to watch: the UK is building out a fuller regulated-activities regime, and the US has been advancing federal market-structure and stablecoin legislation. Both could change the calculus, so treat this as a snapshot and confirm current status before deciding.
Editorial. Not legal advice. Confirm current requirements with each regulator.