Virtual Asset (Service Providers) (Amendment) Regulations, 2025
An amendment introducing a dedicated licensing application framework and a revised, significantly increased fee schedule for VASPs.
Virtual_Asset_(Service_Providers)_(Amendment)_Regulations_2025.pdf
2026-04-28
The Virtual Asset (Service Providers) (Amendment) Regulations, 2025 significantly update the virtual-asset-service-providers-regulations-2020 by introducing detailed licensing requirements and a new, comprehensive fee schedule.
Dedicated Licensing Framework
While the 2020 regulations focused heavily on registration, the 2025 amendment introduces Schedule 1A, a dedicated application form for licences (required for custodians and trading platforms). This requires extensive disclosures, including:
- Custodians: Detailed information on custody strategies, cybersecurity, risk management, and the specific mechanisms used to safeguard client virtual assets.
- Trading Platforms: Expected revenues, physical hardware locations, client agreements, conflict of interest policies, market integrity measures (insider trading, price manipulation), and clearing/settlement processes.
Revised Fee Schedule (Schedule 2)
The amendment completely replaces the previous fee schedule with a tiered structure based on revenue, activity, and whether the entity is a local company. Key fees include (source: raw/Virtual_Asset_(Service_Providers)_(Amendment)_Regulations_2025.pdf):
- Registration: Variable fees up to $15,000 for entities offering services outside the Islands with revenues exceeding $500,000.
- Licence Application: A standard $5,000 application fee for all licences.
- Licence Grant:
- Custodian: $30,000 ($3,000 for local companies).
- Trading Platform: $100,000 ($10,000 for local companies).
- Annual Renewal: Highly tiered. For example, a Category F trading platform generating over $20 million in revenue faces an annual fee of $200,000 ($20,000 for local companies).