Regul8

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Two modes: multiple activities in one jurisdiction, or multiple jurisdictions for one activity.

Data last reviewed: April 2026

Try a preset comparison:

RWA × FR/UAE/SGStablecoin · 4 hubsCustody · 4 hubsTop 4 activities · EU

Pick 1 activity and 2–5 jurisdictions and compare regimes, costs and timelines.

Operations / services(8)
Token issuance(7)
Financial services(2)
Applications(3)

4 jurisdictions compared for Crypto Custody / Wallet

i
Tax treatment

Tax summary per jurisdiction (shared across all activities). General information, not tax advice.

🇪🇺European Union

No EU-wide crypto tax — set per Member State. DAC8 (in force Jan 2026) imposes pan-EU CASP reporting of user holdings to tax authorities; OECD CARF aligned.

🇸🇬Singapore

NO capital-gains tax. Trading as business: 17% corporate income tax. GST exempt on payment tokens (since 2020). Personal income only if classified as business income.

🇦🇪UAE / Dubai

NO personal income tax on crypto for individuals. Companies: 9% corporate tax on profits > AED 375K (since June 2023). VAT exempt on crypto transfers (Nov 2024).

🇬🇧United Kingdom

Individuals: 10–24% Capital Gains Tax above £3,000 annual exemption (2026/27). Income tax up to 45% on mining/staking/airdrops. Crypto-to-crypto IS taxable (HMRC).

Field
🇪🇺European Union
🇸🇬Singapore
🇦🇪UAE / Dubai
🇬🇧United Kingdom
Applicable Regime
The legal text that grounds it all — scope & territorial reach
📜MiCA· custody and administration of crypto-assets on behalf of clients
📜MAS· PSA
•FCA· CASS-like rules upcoming
Risk Level
How critical non-compliance is for your activity
HighMediumMediumMedium
OUTPUTS — What you must do
Licences Required
The concrete authorizations you must obtain
  • 🪪CASP
  • Passport across all EU-27 once granted
  • 🪪MPI🪪SPI
  • Custodial services authorization
  • VARA VA custody licence
  • FCA cryptoasset registration
  • CASS custody rules (proposed)
Key Obligations
Daily compliance duties (KYC, AML, Travel Rule…)
  • Strict client-asset segregation (Art. 75(7))
  • Client agreement specifying rights + liabilities (Art. 75(2))
  • Liability for loss of clients' crypto-assets (Art. 75(8))
  • ICT risk + cybersecurity (DORA, applicable from Jan 2025)
  • Insurance / capital coverage proportional to assets under custody
  • Quarterly reporting to home NCA
  • ICT third-party risk management
  • Safeguarding of customer assets
  • Tech Risk Management
  • AML/KYC
  • Segregation of assets
  • Annual audit
  • Asset segregation
  • Cold storage majority
  • KYC/AML
  • Insurance requirements
  • Tech audit
  • AML/KYC
  • Asset segregation
  • Consumer Duty
  • Adequate insurance
  • Operational resilience
CONTEXT — When, how much, with whom
Estimated Timeline
How long to obtain the licence + go live
9–18 months6–12 months6–12 months12–18 months
Estimated Cost
Licence fees + capital + ongoing costs
€150K–€700K (capital + insurance + ICT)SGD 75K–200K$75K–$200K£50K–£150K
Regulator
The body that supervises and issues the licence
🏛️ESMA🏛️NCA🏛️MAS🏛️VARA🏛️FCA
XRPL-Specific Note
How this plays out on XRPL specifically
On XRPL: SignerList majority + Single Key + IOU gateway models = custodial under MiCA Art. 75. Multi-sig SignerList (minority service participation) + non-custodial wallets = outside Art. 75 scope. MPC/TSS = grey zone (Art. 75 likely applies if service can sign alone).———

🏛️ Official portals by jurisdiction

Regulators, public registers and law texts to verify directly at the source. Opens in a new tab.

🇪🇺European Union
🇸🇬Singapore
🇦🇪UAE / Dubai
🇬🇧United Kingdom

🗺️Arbitrage map — speed vs cost

Where does each jurisdiction sit on the speed × cost axis? Dot size = market access, colour = risk. Find your sweet spot.

0m6m12m18m24m30m36mTime to licence (months)€10K€50K€100K€500K€1000KSetup cost (€, log scale)Fast & expensiveSlow & expensive⭐ Fast & cheapSlow & cheap🇱🇮Liechtenstein🇨🇭Switzerland🇦🇪UAE / Dubai🇸🇬Singapore🇬🇧United Kingdom🇪🇺EU (MiCA)🇭🇰Hong Kong🇺🇸USA🇧🇷Brazil🇯🇵Japan
Risk level (dot color)
Low — progressive regime (TVTG, FINMA)
Medium — structured but friendly (VARA, MAS, FCA)
High — strict or fragmented (MiCA, SFC, US)
Market access (dot size)
Narrow — single country
Wide — region or hub
Huge — EU-27 passport or US national
⭐ Fast & cheap quadrant

Liechtenstein TVTG, Brazil, Switzerland. Ideal starting points when budget and time are the top constraints. Liechtenstein adds EEA passporting as a bonus.

🚀 Fast & structured

Dubai VARA, Singapore MAS. Modern rulebooks, ~9 months, 50-150K€. Strong pick for global operators who want a credible first licence.

🏛 Slow & expensive

US state MTLs, EU MiCA, Hong Kong SFC. Required for access to the biggest markets. Plan capital and 12-24 months; passport or stack once approved.

Ready to pick one?

The diagnostic walks you through speed / cost / market / reputation priorities and outputs a recommended jurisdiction.

Which jurisdiction should I choose? →

General information only. For your specific situation, consult a qualified lawyer.