CySEC CASP vs FCA vs VARA: Choosing the Right Crypto Licence for Your Business

Why the Regulator Choice Matters More Than You Think

The decision of where to obtain your primary crypto-asset licence is among the most consequential structural decisions a crypto firm can make. It is not merely a compliance question — it determines your market access, your banking relationships, your operational cost base, your AML obligations, and ultimately your competitive positioning.

Too many founding teams approach this decision through the lens of perceived ease — which regulator is “easier” to get licensed by, or which jurisdiction has the lowest initial bar. This framing is strategically backwards. The right question is: which regulatory home best fits your business model, your target markets, and your three-to-five year growth trajectory?

In 2026, three regulatory frameworks dominate the strategic conversation for internationally-oriented crypto firms: the CySEC CASP licence under MiCA in Cyprus, the FCA registration/authorisation framework in the UK, and VARA authorisation in Dubai, UAE. These three represent meaningfully different regulatory philosophies, market access propositions, and compliance architectures.

This article compares them across every dimension that matters for strategic decision-making. It does not advocate for one over another — the right answer depends entirely on your specific business. What it does is give you the analytical framework to reach that answer clearly.

The global regulatory environment for crypto-assets has tightened materially. ComplyFactor’s analysis of FATF’s oVASP risk report and Europol’s SOCTA 2025 both underscore that operating in unregulated or weakly regulated structures carries growing banking, reputational, and enforcement risk. The choice is no longer whether to get regulated — it is where.

The Three Regimes: A Framework for Comparison

Before comparing specifics, it helps to understand the philosophical architecture of each regime.

CySEC CASP under MiCA is an EU harmonised framework. CySEC acts as the national competent authority implementing a pan-EU regulation. The substantive requirements are set by Brussels — capital thresholds, governance standards, conduct obligations — and are identical across all 27 EU member states. CySEC’s differentiation lies in its application process, supervisory culture, and the Cyprus-specific AML layer. The fundamental commercial proposition is EU-wide market access through a single authorisation.

FCA crypto registration/authorisation is a UK national regime operating post-Brexit in an independent regulatory environment. The FCA’s crypto supervisory framework currently comprises two distinct elements: registration under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLRs) for AML/CFT purposes, and — for certain activities — authorisation under the Financial Services and Markets Act 2000 (FSMA) as amended by the Financial Services and Markets Act 2023. The UK is building toward a comprehensive crypto regulatory regime, with the FCA consulting extensively in 2024-2025 on rules for crypto-asset admissions, disclosures, market abuse, and stablecoin issuance. The commercial proposition is access to one of the world’s largest and most sophisticated financial markets.

VARA authorisation is a Dubai-specific regime administered by the Virtual Assets Regulatory Authority, established under Dubai Law No. 4 of 2022. VARA operates exclusively within the Emirate of Dubai (excluding the DIFC, which has its own DFSA regime). Its framework covers virtual asset service providers across a range of licensed activities under the Virtual Assets and Related Activities Regulations 2023. The commercial proposition is access to the UAE market, a Middle Eastern hub position, and a regulatory brand that signals credibility to institutional and HNW counterparties in the GCC and broader emerging markets. For a comprehensive overview of the UAE regulatory landscape including VARA, ADGM, DFSA and CBUAE, see ComplyFactor’s UAE crypto regulation guide 2025.

Regulatory Scope and Services Covered

Understanding what each regime covers — and the gaps — is critical.

CySEC CASP (MiCA)

MiCA defines crypto-asset services comprehensively across 10 service categories (custody, exchange, trading platform, order execution, order reception/transmission, placing, advice, portfolio management, transfer services). The regime covers crypto-assets that are neither financial instruments under MiFID II, nor e-money, nor central bank digital currencies — meaning it captures most utility tokens, asset-referenced tokens (ARTs), and e-money tokens (EMTs), with distinct requirements for the latter two categories. NFTs are generally outside MiCA scope unless they function as financial instruments.

FCA (UK)

The FCA’s current crypto registration under the MLRs covers firms carrying on UK-relevant crypto-asset activities as defined — broadly exchange and custody activities. The pending comprehensive crypto regime will extend to a wider range of activities including stablecoin issuance, crypto lending, and staking. The FCA has been explicit that its forthcoming regime will be closely aligned with global standards — particularly FATF recommendations and FSB principles — while being calibrated for UK market conditions. For the latest on UK regulatory developments, ComplyFactor’s UK regulatory changes 2026 guide provides detailed analysis.

VARA (Dubai)

VARA’s framework covers seven categories of virtual asset activities: Advisory Services, Broker-Dealer Services, Custody Services, Exchange Services, Lending and Borrowing Services, Payments and Remittance Services, and VA Management and Investment Services. Coverage is broad and VARA has been explicit that operating a virtual asset business targeting UAE persons without VARA authorisation is a criminal offence. The VARA regime does not cover DeFi protocols that operate without a central intermediary, though the regulatory perimeter continues to evolve. For VARA-specific marketing obligations — an area of particular VARA enforcement focus — see ComplyFactor’s VARA marketing regulations guide.

Scope Comparison Summary

Dimension	CySEC CASP (MiCA)	FCA (UK)	VARA (Dubai)
Geographic scope of authorisation	EU-wide (27 member states)	UK only	Dubai only (not DIFC)
Stablecoins	Yes — specific ART/EMT rules	Partial — developing regime	Yes
NFTs	Generally excluded	Generally excluded	Case-by-case
DeFi	Generally excluded	Generally excluded	Generally excluded
Staking/lending	Limited — developing	Developing	Yes (specific licence)
Passporting	EU-wide via notification	No — UK-only	No — UAE-only

Capital Requirements: Side-by-Side

Capital requirements are a material factor in licensing strategy, both as a direct cost and as a signal of regulatory ambition.

CySEC CASP Capital (MiCA Article 67)

As detailed in ComplyFactor’s CySEC CASP complete guide, MiCA establishes three capital tiers:

• Class 1: €50,000 — advice, reception/transmission of orders, transfer services
• Class 2: €125,000 — execution, exchange, placing
• Class 3: €150,000 — custody and administration, operation of trading platform

The fixed overhead requirement (one quarter of preceding year fixed overheads) may result in a higher effective requirement for larger operations.

FCA Capital Requirements

The FCA’s current MLR registration does not impose a standalone capital requirement beyond those applicable under other regulatory frameworks (e.g., EMI requirements if the firm is also an EMI). Under the forthcoming comprehensive crypto regime, capital requirements will be introduced — the FCA has consulted on calibrations broadly similar to MiCA’s approach, though final rules are not yet confirmed at the time of writing.

For UK firms that are both FCA-registered crypto firms and FCA-authorised payment institutions or EMIs, the EMI capital requirements (minimum €350,000 for EMIs under the Electronic Money Regulations 2011) are the binding constraint.

VARA Capital Requirements

VARA’s capital requirements are set out in its Minimum Capital Requirements Guidance and vary by activity. EUR equivalents below are indicative and subject to AED/EUR rate fluctuation:

• Advisory Services: AED 500,000 (approximately €125,000)
• Broker-Dealer Services: AED 2,000,000 (approximately €500,000)
• Custody Services: AED 4,000,000 (approximately €1,000,000)
• Exchange Services: AED 4,000,000 (approximately €1,000,000)
• Lending and Borrowing: AED 4,000,000 (approximately €1,000,000)
• VA Management and Investment: AED 2,000,000 (approximately €500,000)
• Payments and Remittance: AED 1,000,000 (approximately €250,000)

VARA’s capital requirements are substantially higher than MiCA’s baseline — reflecting the UAE’s positioning as a premium regulatory environment targeting sophisticated institutional-grade operators.

Capital Requirements Comparison

Service Category	CySEC/MiCA	FCA (current)	VARA (Dubai)
Advisory	€50,000	No standalone requirement	~€125,000
Exchange	€125,000	No standalone requirement	~€1,000,000
Custody	€150,000	No standalone requirement	~€1,000,000
Broker-dealer	€125,000	No standalone requirement	~€500,000

Market Access and Passporting

This dimension is often the decisive factor in licensing strategy.

CySEC CASP: EU-Wide Passporting

A CySEC authorisation unlocks cross-border provision of crypto-asset services across all 27 EU member states through MiCA’s passporting mechanism. The notification process is straightforward — CySEC forwards the notification to the host NCA within 15 working days, and the CASP may commence services from the date of communication. No separate national authorisation is required.

This is transformative for firms targeting EU clients. The pre-MiCA patchwork of national registration regimes — as analysed in ComplyFactor’s country guides for Lithuania, Poland, Czech Republic, and Bulgaria — is replaced by a single passport. A firm that previously needed 5 national registrations to serve clients across major EU markets now needs one CySEC authorisation.

The EU market represents approximately 450 million consumers and one of the highest concentrations of institutional crypto activity globally. For firms with genuine EU client ambitions, the passporting value alone justifies the CySEC route.

FCA: UK Market Only

FCA registration/authorisation provides access to the UK market — approximately 67 million people, with London retaining significant depth in institutional financial services including crypto. Post-Brexit, there is no UK-EU mutual recognition for crypto services — a UK-only regulated firm serving EU clients may trigger MiCA obligations in relevant EU member states. Firms targeting both UK and EU markets should plan for dual regulation.

The UK’s comprehensive crypto regime, when finalised, will create a more structured framework. However, the FCA has historically been one of the more demanding crypto regulators globally — its registration rejection rates under the MLR regime have been notably high, with the majority of applicants either rejected or withdrawing applications. Firms that achieve FCA registration demonstrate a compliance standard that carries reputational weight with institutional counterparties globally.

VARA: Dubai and UAE Market

VARA authorisation covers the Emirate of Dubai. For firms serving UAE clients more broadly, the CBUAE regulatory framework and the separate ADGM and DIFC regimes (each with their own competent authorities) must also be considered. There is no VARA passporting equivalent — access to each jurisdiction requires separate regulatory engagement.

Dubai’s strategic value as a licensing base extends beyond the UAE domestic market. The city’s positioning as a global financial hub means VARA authorisation opens doors to GCC institutional relationships, access to emerging market capital, and proximity to the significant pool of crypto-active HNW individuals who have established UAE residence in recent years.

Market Access Summary

Dimension	CySEC CASP	FCA	VARA
Primary market	EU (27 member states)	UK	Dubai / UAE
Passporting	EU-wide (notification only)	None	None
Market size (consumers)	~450 million	~67 million	~3.5 million (Dubai)
Institutional depth	High	Very high	Growing rapidly
GCC/EM positioning	Limited	Limited	Strong

AML/CFT Obligations Compared

All three regimes impose substantive AML/CFT obligations. The architecture and supervisory intensity differ.

CySEC CASP AML

As detailed in ComplyFactor’s CySEC CASP complete guide, Cyprus-layer AML obligations sit on top of MiCA’s conduct framework. CySEC applies the EU’s AML directives and Cyprus AML law, requiring: business-wide risk assessment, full CDD/EDD programme, automated transaction monitoring, on-chain analytics, Travel Rule compliance under the recast TFR (zero threshold), MLRO appointment and notification, annual AML review, and independent audit.

The forthcoming EU AML Regulation (AMLR) and AMLA will standardise AML obligations further across the EU, reducing member state variation but increasing the baseline standard across the board.

FCA AML

UK crypto firms registered under the MLRs must comply with the full MLR 2017 AML/CFT framework — essentially the UK’s implementation of the EU’s AMLD (the MLRs predate Brexit and carry forward the directive requirements as amended). Key elements: risk assessment, CDD/EDD (with enhanced requirements for high-risk factors), suspicious activity reporting to the National Crime Agency (NCA), sanctions screening (OFSI/UN), transaction monitoring, and staff training.

The FCA has made AML/CFT supervision of crypto firms a stated priority. Its published findings from crypto firm assessments consistently highlight transaction monitoring deficiencies, inadequate risk assessments, and weak EDD as recurring failures. For a detailed understanding of FCA AML audit expectations, see ComplyFactor’s FCA AML audit preparation checklist and analysis of why FCA-regulated firms fail AML inspections.

The UK’s Travel Rule requirements under the amended Cryptoasset Travel Rule came into effect in September 2023, requiring originator and beneficiary information for crypto transfers above £1,000 (note: a higher threshold than the EU’s zero-threshold approach under TFR). For detailed Travel Rule implementation guidance, see ComplyFactor’s Travel Rule guide.

VARA AML

VARA’s AML/CFT framework draws on the UAE’s national AML framework — Federal Decree Law No. 20 of 2018 on Anti-Money Laundering and the Cabinet Decision No. 10 of 2019 — as well as CBUAE/VARA-specific guidance. Key elements align with FATF Recommendation 15 standards: CDD, EDD for high-risk clients, STR filing with the UAE Financial Intelligence Unit (UAEFIU), sanctions screening against UAE, UN, and US OFAC lists, Travel Rule compliance, and ongoing monitoring.

VARA has been increasingly active in AML enforcement, and the reputational environment around UAE AML supervisory standards has elevated since the UAE’s FATF grey-listing (March 2022) and subsequent removal (February 2024) following significant national AML reforms. VARA-licensed firms operate under heightened scrutiny from international counterparties precisely because of the UAE’s recent FATF history — robust AML programmes are non-negotiable for maintaining banking relationships. For broader AML context in the UAE exchange sector, see ComplyFactor’s CBUAE AML guidelines for exchange houses.

AML Obligations Comparison

Dimension	CySEC CASP	FCA (UK)	VARA (Dubai)
AML framework	EU AMLD / Cyprus AML Law	MLR 2017	UAE AML Law / VARA Rulebook
Travel Rule threshold	€0 (zero threshold)	£1,000	~USD 1,000 equivalent (FATF Rec. 16 standard)
STR reporting	CySEC / MOKAS (Cyprus FIU)	NCA	UAEFIU
On-chain analytics expectation	Yes	Yes	Yes
MLRO requirement	Yes — CySEC notified	Yes — FCA registered	Yes — VARA approved
Independent AML audit	Required	Required	Required

Application Process and Timelines

CySEC CASP Application

Full detail in ComplyFactor’s CySEC CASP complete guide. In summary: structured application pack, substantive CySEC review, 40 working day decision clock from completeness confirmation. End-to-end timeline for well-prepared applications: 4–9 months.

FCA Crypto Registration

The FCA’s crypto registration process under the MLRs involves submission of an application through the FCA’s Connect system, covering: business model description, AML/CFT programme documentation, management information, and evidence of systems and controls. The FCA has a 12-month statutory determination period, though it aims to process within this window. In practice, timelines have ranged from 6 to 18+ months, with the FCA having issued a significant number of refusals and withdrawal decisions.

The FCA’s assessment focuses heavily on AML/CFT programme quality — the MLR registration is fundamentally an AML supervisory tool. Firms with weak AML documentation or management teams with limited AML/CFT experience face significant refusal risk. Under the forthcoming comprehensive regime, a separate authorisation process distinct from MLR registration will apply.

VARA Authorisation

VARA’s authorisation process involves several stages: Minimum Viable Product (MVP) licence review, followed by full operational licence. The MVP licence allows limited operations while the full authorisation is progressed. VARA has demonstrated an ability to process applications relatively efficiently when applicants are well-prepared, though end-to-end timelines to full operational licence range from 6 to 12+ months depending on complexity and the completeness of the application.

VARA requires a physical presence in Dubai — not just a registered address. Office lease agreements, staffing plans, and operational readiness assessments are part of the VARA review. For firms planning UAE operations, ComplyFactor’s UAE crypto regulation guide and DFSA Category 3C guide provide relevant context for the broader UAE regulatory landscape.

Timeline Comparison

Dimension	CySEC CASP	FCA	VARA
Statutory decision period	40 working days (from completeness)	12 months	Not fixed
Practical end-to-end timeline	4–9 months	6–18+ months	6–12+ months
Pre-trading permission	No	No	Yes (MVP licence)
Primary process risk	RFI volume	AML programme quality	Substance/local presence

Ongoing Compliance Burden

All three regimes impose material ongoing compliance obligations. The relative burden correlates broadly with regulatory ambition and market access value.

CySEC CASP carries the EU’s comprehensive conduct regime — periodic regulatory reporting, notification obligations on material changes, continuous capital maintenance, annual AML review, passporting notifications for each new market entry. The compliance infrastructure required is proportionate to a firm with EU-wide market access aspirations. For firms with multiple EU markets, the passporting notification administrative overhead is real but manageable.

FCA registration has historically carried a lighter ongoing compliance burden than a full FCA authorisation, though this will change under the comprehensive regime. Current ongoing requirements: annual fee, AML programme maintenance, MLR compliance, FCA supervisory engagement. The FCA has been increasing its supervisory intensity on crypto firms, with thematic reviews and direct firm engagement becoming more common.

VARA requires annual licence renewal, annual audited financial statements submission, ongoing regulatory reporting, VARA supervisory engagement, and compliance with VARA’s evolving rulebook. VARA has demonstrated a willingness to update its requirements iteratively — firms must actively monitor VARA circulars and rulebook amendments. VARA’s supervisory approach has been characterised as engagement-oriented in its early years, though enforcement activity has been increasing as the framework matures.

Cost Comparison: What Does Each Licence Actually Cost?

Total licensing cost has four components: application fees, legal/advisory costs, capital requirements, and ongoing operational costs. The following provides indicative ranges.

Application Fees

CySEC CASP: CySEC charges application fees for CASP authorisation. The specific fee schedule is published by CySEC and varies by application type. Indicative range: €5,000–€15,000.

FCA: The FCA charges application fees for MLR registration based on the size category of the firm (determined by annual revenue/transaction volume). Indicative range: £5,000–£25,000.

VARA: VARA’s fee schedule is published in its Fees Schedule documentation. Fees are structured across the MVP and full licence stages, with additional fees for licence category additions. Indicative range: AED 100,000–500,000+ (approximately €25,000–€125,000+) depending on activities.

Legal and Advisory Costs

Application quality is the primary determinant of timeline and outcome — and application quality requires experienced legal and compliance advisory support. Indicative legal and advisory costs for a well-managed application:

• CySEC CASP: €40,000–€150,000 depending on complexity
• FCA: £30,000–£100,000
• VARA: AED 200,000–600,000 (approximately €50,000–€150,000)

Annual Ongoing Regulatory Costs

Beyond capital, ongoing regulatory fees, compliance staffing (MLRO, compliance officer), annual AML audit, and operational overhead represent material annual costs:

• CySEC CASP: €80,000–€250,000+ per year (depending on team size, outsourcing model, and volume)
• FCA: £60,000–£200,000+ per year
• VARA: AED 300,000–800,000+ per year (approximately €75,000–€200,000+)

Substance Requirements

All three regulators require genuine substance — not just a brass-plate presence. The specific expectations differ.

CySEC CASP requires: Cyprus-incorporated entity, registered office in Cyprus, at least one Cyprus-resident executive director, operational decision-making demonstrably taking place in Cyprus. Nominee directors are not acceptable. Staff levels must be proportionate to the scale and complexity of operations.

FCA requires: UK-registered or UK-established business (or UK branch of EEA/overseas firm in specific cases), appropriate UK presence for the scale of UK activities, key compliance officers (MLRO) accessible and responsive to FCA supervision. The FCA has increasingly scrutinised whether firms have genuine UK operational presence or are using UK registration as a shell for primarily offshore operations.

VARA requires: physical presence in Dubai, office premises (lease agreement required), key personnel resident in Dubai, and operational readiness demonstrable at inspection. VARA’s substance requirements are arguably the most demanding of the three — reflecting the UAE’s broader commitment to ensuring that VARA-licensed firms are genuine Dubai-based operations, not flags of convenience.

Strategic Fit: Which Licence for Which Business?

Based on the comparative analysis above, the following strategic guidance applies — noting that every firm’s situation is specific and warrants tailored advice.

Choose CySEC CASP if:

• Your primary target market is EU consumers or EU-based institutional clients
• You want to serve multiple EU member states from a single regulatory base
• You have or plan to build Cyprus operational substance
• Your capital structure is in the €50,000–€150,000 range (or higher)
• You want to benefit from MiCA’s clear regulatory framework and EU-wide legitimacy signal
• Tax efficiency of the Cyprus structure is a meaningful consideration

Choose FCA if:

• The UK is your primary or dominant target market
• You are targeting UK institutional clients (London remains the deepest institutional market in Europe)
• You can demonstrate robust AML/CFT programme quality — a genuine differentiator with UK institutional counterparties
• You have the compliance infrastructure to operate under one of the more demanding AML supervisory regimes globally
• You understand that FCA registration currently covers AML purposes; further authorisation will be needed under the forthcoming comprehensive regime

Choose VARA if:

• The UAE and GCC markets are your primary commercial focus
• You are targeting HNW, UHNW, or institutional clients in the Middle East and emerging markets
• You have the capital to meet VARA’s materially higher thresholds
• You want the reputational premium of Dubai’s positioning as a leading institutional crypto hub
• You are prepared for genuine Dubai operational presence requirements

Consider dual or multi-licensing if:

• You have genuine multi-jurisdictional client bases (EU + UK, EU + UAE, or all three)
• Your business model involves services that require presence in multiple regulatory perimeters
• You have the compliance and operational infrastructure to manage multiple regulatory relationships

For firms contemplating the risks of operating across jurisdictions without appropriate authorisation — including the growing body of firms that may be triggering regulatory obligations in the UK, EU, or UAE without realising it — ComplyFactor’s analysis of operating as a VASP illegally across jurisdictions is essential reading.

ComplyFactor’s global MLRO services and AML advisory services are structured to support firms across all three regimes — including dual and multi-licensed structures — with integrated compliance programmes that meet each regulator’s requirements without unnecessary duplication.

Can You Hold Multiple Licences?

Yes — and for many internationally-oriented crypto firms, multi-licensing is not just possible but necessary. There is no regulatory prohibition on holding a CySEC CASP licence alongside FCA registration and VARA authorisation simultaneously.

The practical considerations for multi-licensed structures are:

Governance. Each regulator will assess the management body composition independently. Directors must meet the fit and proper requirements of each jurisdiction. Where the same individual is a director in the Cyprus entity, the UK entity, and the UAE entity, their time commitment across all three roles will be scrutinised by each regulator.

Compliance architecture. Multi-licensed firms need an integrated compliance architecture — not three separate silos. A well-designed group compliance framework can leverage shared AML policies and procedures, adapted for jurisdiction-specific requirements, without creating redundant programmes for each entity. ComplyFactor’s complete AML programme blueprint provides a practical framework for this design challenge.

MLRO structure. Each regulated entity typically requires its own named MLRO. Group MLRO structures where a single senior individual oversees multiple entity MLROs are possible but require careful design to ensure each entity’s MLRO meets the relevant regulator’s independence and authority requirements.

Regulatory reporting. Each regulator has its own reporting obligations — these are not shared. Firms must maintain the systems and staffing to produce accurate periodic returns for each regulatory relationship.

Banking. One frequently underappreciated benefit of multi-licensing: holding authorisation from multiple credible regulators significantly strengthens banking relationship conversations. Banks assessing correspondent relationships with crypto firms look for the depth and breadth of regulatory oversight — a VARA + CySEC + FCA licensed entity represents a meaningfully different risk profile from a single-jurisdiction registration. For context on the banking challenges facing crypto firms, see ComplyFactor’s analysis of AML trends every compliance officer needs to follow.

Frequently Asked Questions

Does a CySEC CASP licence allow me to serve UK clients?

No. A CySEC CASP licence provides passporting across EU member states only. The UK left the EU and there is no UK-EU mutual recognition for crypto services. Serving UK clients requires separate FCA registration (or authorisation under the forthcoming regime). Operating in the UK without FCA authorisation where required is a criminal offence under FSMA section 23.

Does a VARA licence allow me to serve clients across the wider UAE?

VARA’s jurisdiction covers the Emirate of Dubai only (excluding the DIFC). Providing virtual asset services in Abu Dhabi may require engagement with the Financial Services Regulatory Authority (FSRA) of the ADGM, or the Central Bank of UAE for payment-related activities. The DIFC is regulated by the DFSA under its own regime — see ComplyFactor’s DFSA Category 3C guide for detail.

Is the FCA’s crypto registration the same as FCA authorisation?

No. MLR registration covers AML/CFT supervision only. It is not a financial services authorisation under FSMA and does not permit the provision of financial services requiring FSMA authorisation. Some crypto activities — particularly those involving crypto-assets that qualify as financial instruments under MiFID — may require full FSMA authorisation. The forthcoming comprehensive UK crypto regime will introduce authorisation (not just registration) for a wider range of activities.

Which regulator is most likely to approve my application?

This is the wrong question. The right question is: which regulatory environment best fits my business model and compliance capabilities? An application to the “easiest” regulator that does not match your market or operational profile creates ongoing regulatory risk — operating under a licence in a jurisdiction you don’t genuinely serve creates substance and compliance issues that regulators will identify over time.

How does ComplyFactor help firms choosing between CySEC, FCA, and VARA?

We provide jurisdiction-neutral regulatory strategy advice — our goal is to identify the optimal licensing structure for your specific business model, target markets, and compliance capabilities. This includes pre-application gap analysis, AML programme development, MLRO appointment, and application support across all three jurisdictions. Contact us for an initial licensing strategy consultation.

What happens if I serve EU clients with only FCA or VARA registration — no CySEC/MiCA authorisation?

From 30 December 2024, providing crypto-asset services to EU clients on a reverse solicitation basis is a narrow exception under MiCA — it applies only where the client exclusively and at their own initiative approaches the firm. Active marketing or solicitation to EU clients by an unauthorised CASP triggers MiCA obligations. ESMA and EU NCAs have signalled that they will treat reverse solicitation claims sceptically. Operating without MiCA authorisation while actively serving EU clients creates enforcement risk across every EU member state where clients are located.