Licence by product · Custody
Crypto Wallet & Custody Licence
The whole question in wallets is one word: custody. Hold client keys and you're a regulated custodian; don't, and you're mostly software. We license the first and structure the second.
overview
What you actually need.
Wallet licensing turns entirely on custody. If your users hold their own keys and your software just signs locally — a non-custodial wallet — you're largely outside licensing perimeters, including MiCA's. The moment you control client keys, run MPC shares on their behalf, or can move their assets without them, you're providing custody: a licensed activity in every serious regime.
For custodial products the routes mirror the exchange map. In the EU, custody is a CASP service under MiCA at the €125,000 capital class, authorised in a member state (Lithuania, Estonia) and passported. Offshore, Seychelles' VASP Act prices the wallet-provider type at a $25,000 capital requirement — the most accessible dedicated custody authorisation — while BVI runs a specific custody category under its VASP Act.
Plenty of wallet businesses are hybrids: non-custodial by default with a custodial recovery or earn feature bolted on. That bolt-on is what triggers licensing — we scope the feature set line by line, and often the cheapest compliance move is re-architecting one feature rather than licensing the whole product.
your options
The routes that work.
Entity placement, terms, AML posture at the edges — no licence, but done properly so partners and stores pass you. Panama and similar bases work here.
Seychelles wallet-type VASP ($25k capital) or BVI custody category — real authorisation at the lowest viable cost.
CASP custody class in Lithuania/Estonia — €125k capital, 3–6 months, passports across the EU. What institutional counterparties ask for.
head to head
Wallet & custody routes compared
| Route | Capital / fees | Timeline | Best for |
|---|---|---|---|
| Non-custodial structuring | no licence — setup costs only | weeks | Self-custody products, DeFi front-ends |
| Seychelles (wallet type) | $25k capital | 3–6 months | Cheapest real custody authorisation |
| BVI (custody category) | $15k application | 8–14 months realistic | Fund/institutional structures |
| Lithuania (MiCA custody) | €125k capital | 3–6 months | EU-facing custodial wallets |
| Estonia (MiCA custody) | €125k capital | 4–6 months | EU custody, VASP-upgrade path |
| Switzerland (SRO/VQF) | no min. capital (AML route) | ≈1–3 months | Swiss-based non-bank custody models |
requirements
Eligibility & docs.
step by step
From product to licence.
- Scope callYour wallet product, target markets and custody model — we confirm which activities are actually licensable, where, and what the all-in number is.Day 1
- Company & structureWe incorporate the entity where the regime wants it — with the substance (director, office, officers) that regulator expects, no more, no less.Week 1–3
- File & evidenceKYC on owners, business plan, AML/CFT programme, key-management architecture and segregation model — we assemble the file and run the regulator dialogue to approval.Week 3+
- Authorisation & railsLicence or registration granted; banking/EMI accounts and on/off-ramps plugged in around it. We stay on for reporting and renewals.Regime-dependent
Want the shortlist for your exact product?
Tell us your product, target markets and payment mix — we'll confirm the route that gets you live fastest at the lowest all-in cost, with the number itemised.
costs
What it costs.
Capital is a balance-sheet requirement, not a fee. The honest first step is the feature audit — it's common that one architectural change removes the licensing trigger entirely, and we'll tell you when that's the case.
go deeper
Jurisdictions & related services.
FAQ
Does a non-custodial wallet need a licence?
Generally no — MiCA and most VASP regimes exclude software where the user alone controls keys. You still need clean structuring for AML exposure at fiat edges and for partner/app-store diligence. The trap is feature creep: recovery or earn features can flip you into custody.
What licence does a custodial wallet need?
A custody authorisation: MiCA CASP custody class (€125k capital) for the EU, Seychelles wallet type ($25k capital) or BVI's custody category offshore. Which fits depends on your clients and counterparties.
Is MPC custody still custody?
If your quorum can move client assets without the client, regulators treat it as custody. Genuine 2-of-2 where the user's share is indispensable is closer to non-custodial — the analysis is architectural, and we do it before any filing.
What does custody authorisation cost?
Seychelles: $25,000 capital plus fees — the cheapest dedicated route. MiCA: €125,000 capital plus authorisation costs, 3–6 months. BVI: $15,000 application with a long realistic timeline (8–14 months).
Can I add exchange or staking later?
Yes — as a licence variation (MiCA: additional service classes; Seychelles/BVI: category change). It's cheaper to scope the roadmap now and file the right activity set once — we map it on the scope call.
other products
Licensing a different product?
Reviewed by the Vantegris licensing team. This page is general information, not legal advice. Fee schedules and timelines mirror our jurisdiction pages and change when regulators change them.
Free consultation
Start your licence file.
Tell us the product — we'll map the licence, banking and structure that gets it live. Free, confidential, no obligation — most enquiries get a reply within 24 hours.