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.

1
question decides everything: who holds the keys
€125k
MiCA capital for the custody class
$25k
Seychelles capital for the wallet-provider type
Not sure which jurisdiction fits? Answer six questions and the Licence Finder shortlists the routes for your product, markets and budget.
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overview

What licence does a wallet or custody service 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.

Keys = licence Control of client private keys (including MPC quorums you dominate) is custody — licensable everywhere that matters.
Non-custodial ≠ lawless You still face AML exposure at fiat touchpoints and app-store/partner diligence — structure matters even without a licence.
Feature creep triggers Recovery, staking, earn and swap features can each flip a non-custodial product into licensable territory — audit before you ship.

your options

Licence routes for a wallet or custody service

01Non-custodial — structure only

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.

02Custodial, offshore

Seychelles wallet-type VASP ($25k capital) or BVI custody category — real authorisation at the lowest viable cost.

03Custodial, EU (MiCA)

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

Crypto wallet & custody licence requirements

Entity where the regime requires (we incorporate)
KYC on founders/UBOs
Local officers where required (AML officer, director)
Source-of-funds for capital
Key-management design: HSM/MPC, quorum policy, disaster recovery
Client-asset segregation — on-chain and in the books
Wallet policy: hot/cold split, withdrawal controls
Insurance or reserve arrangements where the regime asks
AML/CFT programme + Travel-Rule flow for transfers
Transaction monitoring and screening tooling
Custody-specific disclosures and client terms
Periodic reporting — handled by us post-authorisation
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step by step

How to get a crypto wallet & custody licence

  1. Scope call Your wallet product, target markets and custody model — we confirm which activities are actually licensable, where, and what the all-in number is. Day 1
  2. Company & structure We incorporate the entity where the regime wants it — with the substance (director, office, officers) that regulator expects, no more, no less. Week 1–3
  3. File & evidence KYC 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+
  4. Authorisation & rails Licence or registration granted; banking/EMI accounts and on/off-ramps plugged in around it. We stay on for reporting and renewals. Regime-dependent

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costs

How much does a crypto wallet & custody licence cost?

Regulator fee schedules
Seychelles — capital, wallet-provider type$25,000
MiCA CASP — capital, custody class€125,000
BVI — application fee (custody)$15,000
Switzerland — VQF/SRO routeno statutory capital
Non-custodial structuringsetup costs only

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

Where to license a wallet or custody service

Crypto wallet & custody licence 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 something other than a wallet or custody service?

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.

Proven track record
300+ operators licensed across 40+ jurisdictions.

From crypto casinos to B2B platform providers, operators trust Vantegris to move fast without cutting compliance corners.

Itemised fees Regulator schedule shown separately from our service fee.
We stay after issuance Renewals, reporting and banking, handled long-term.
NDA on request Confidential from the first message.

Free consultation

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