This table provides a side-by-side comparison of crypto licensing requirements across major jurisdictions. It highlights how clearly each regulatory framework addresses critical safeguards for digital asset custodians, exchanges, and related service providers. Use this resource to quickly assess the strengths and gaps in global crypto regulation.
Legend: 0 = missing · 1 = vague/voluntary · 2 = mandatory but qualitative · 3 = mandatory & explicit
| License | Score | Insurance | Backup-Keys | Control of Keys | Ops / Audit | Bankruptcy Remote | Asset Segregation | Cold / Hot Wallet Rules | AML / KYC |
|---|---|---|---|---|---|---|---|---|---|
| Hong Kong TSCP | 21% | 0 | 0 | 0 | 2 | 0 | 0 | 0 | 3 |
| France DASP | 42% | 2 | 0 | 2 | 2 | 0 | 1 | 0 | 3 |
| EU MiCA | 67% | 0 | 2 | 3 | 3 | 3 | 3 | 0 | 2 |
| US SPBD | 50% | 0 | 2 | 3 | 2 | 0 | 3 | 0 | 2 |
| Singapore MPI | 33% | 0 | 0 | 2 | 2 | 0 | 1 | 0 | 3 |
| NY BitLicense | 58% | 2 | 2 | 3 | 2 | 0 | 2 | 0 | 3 |
| South Dakota Custodian | 33% | 3 | 0 | 0 | 2 | 0 | 0 | 0 | 3 |
| UAE VARA | 83% | 2 | 3 | 3 | 2 | 3 | 3 | 1 | 3 |
| Spain VASP | 8% | 0 | 0 | 0 | 0 | 0 | 0 | 0 | 2 |
| National Bank (OCC) | 25% | 2 | 0 | 0 | 2 | 0 | 0 | 0 | 2 |
| Ireland VASP | 21% | 0 | 0 | 0 | 2 | 0 | 0 | 0 | 3 |
Note: This table is a work in progress. Scoring is based on available regulatory texts and may be updated as new information emerges. All information is based on opinions and should not be relied on as a risk rating. Future versions may include additional columns, ratings, and interactive features.
Column Explanations
Score: Simple score for how clearly the licence states each requirement. Not a risk or compliance rating.
Insurance: Mandatory insurance or surety bond that protects clients against loss or theft.
Backup-Keys: Obligation to create and securely store backup copies or shards of signing keys.
Control of Keys: Who must hold signing authority; rules on multi-sig, outsourcing, or exclusive control.
Ops / Audit: Required audits, penetration tests, and other ongoing operational reporting duties.
Bankruptcy Remote: Ensures client assets stay protected if the custodian becomes insolvent.
Asset Segregation: Requires client assets be kept separate from the firm's and from other clients'.
Cold / Hot Wallet Rules: Mandated cold-storage percentages or procedures for using hot wallets.
AML / KYC: Customer identity checks, monitoring, and record-keeping to meet anti-money-laundering laws.