Is Seychelles Still an Alternative to MiCA? VASP Licence vs CASP Authorisation

Content

Company registration in Seychelles for a crypto business now means both setting up a legal entity and obtaining a licence under a dedicated law. The Virtual Asset Service Providers Act, 2024 (Act 12 of 2024) has been in force since 1 September 2024, and the Financial Services Authority (FSA) grants and revokes the licences. In the EU, the MiCA Regulation (EU) 2023/1114 has applied since 30 December 2024. Below we look at who a Seychelles licence suits and who it does not.

Company Registration in Seychelles: What the VASP Act Changed

Domestic companies and international business companies (IBCs) are still available in Seychelles. For a crypto business, registration alone is not enough: the VASP Act prohibits carrying on virtual asset services business in or from Seychelles without an FSA licence. Before you start:
  • Who can obtain a licence: only a company under the Companies Act, 1972, or an IBC under the International Business Companies Act, 2016. An individual cannot obtain a VASP licence.
  • Which services are licensed: the First Schedule to the Act lists four activities — Virtual Asset Wallet Providers, Virtual Asset Exchange, Virtual Asset Broking and Virtual Asset Investment Providers.
  • What is prohibited: mining facilities, mixers and tumblers may not operate in or from Seychelles.
  • Directors: at least two natural persons who pass the fit and proper assessment, and at least one director resident in Seychelles.

Without a licence, an IBC may not provide virtual asset services. When it acts against unlicensed operators, the FSA cites section 5(2)(g)(ii) of the International Business Companies Act, 2016.

Seychelles therefore suits a crypto business only with a VASP licence. The choice between Seychelles and the EU depends above all on where your clients are.

Where to Start a Crypto Business: Seychelles or the EU

Choosing a jurisdiction for a crypto business is a strategic question. Seychelles and the EU can also be compared with other non-EU jurisdictions, such as Singapore; here we cover only these two. The key criteria are:

  • Seychelles (VASP Act 2024): an FSA licence, paid-up capital from USD 25,000 to USD 100,000 depending on the type of service, and real presence in Seychelles. This licence gives no right to serve clients in the EU.
  • EU (MiCA): CASP authorisation in one EU Member State, capital of EUR 50,000, EUR 125,000 or EUR 150,000 by service class, and a passport for the whole EU.
  • Clients: if they are in the EU, MiCA authorisation is required. Serving clients at their own exclusive initiative is a narrow exception, not a business model.
COREDO starts this analysis with a map of the clients: where they are and who initiates the relationship.

MiCA: Impact on Crypto Business in the EU

Illustration for the section "MiCA: Impact on Crypto Business in the EU" in the article "Seychelles Still a Relevant Alternative to MiCA in 2025"
MiCA introduced uniform rules for crypto business in all EU Member States. Regulation (EU) 2023/1114 has applied since 30 December 2024 and requires every crypto-asset service provider to be authorised.

MiCA Requirements for Crypto Companies

Article 59 of MiCA prohibits providing crypto-asset services in the EU without CASP authorisation under Article 63 or the status of a financial entity under Article 60. They include, among others, custody of clients' crypto-assets, operating a trading platform and exchanging crypto-assets for funds or other crypto-assets. To be authorised, a company must:

  • Have a registered office in the EU Member State where it carries out at least part of its services (Art. 59(2)).
  • Be managed from the EU: its place of effective management is in the EU and at least one director is resident in the EU.
  • Always hold prudential safeguards of at least the higher of: the minimum capital under Annex IV or one quarter of the previous year's fixed overheads (Art. 67(1)).
  • Meet the minimum capital for its service class: EUR 50,000 (class 1), EUR 125,000 (class 2, including custody and exchange) or EUR 150,000 (class 3, trading platform).

For services of different classes, the threshold of the highest class applies. ESMA confirmed this in Q&A 2343 of 12 December 2024: for class 1 and class 3 services, the minimum is EUR 150,000.

Beyond authorisation, MiCA sets market rules. A public offer of crypto-assets other than asset-referenced tokens and e-money tokens requires a white paper that is notified and published (Art. 4). Market abuse rules apply to crypto-assets admitted to trading or subject to a request for admission, even outside a trading platform (Art. 86).

Timelines, Passport and Transitional Period

The regulator checks completeness within 25 working days and assesses a complete application within 40 working days (Art. 63). Authorisation opens the whole EU market:

  • A CASP may provide services in all EU Member States through a branch or cross-border, without physical presence in the host Member State (Art. 59(7)).
  • Firms providing services under national law before 30 December 2024 could continue without authorisation until 1 July 2026 at the latest (Art. 143(3)).
This transitional period has ended in every EU Member State. EU clients may now be served only with MiCA authorisation, under Article 60 or within the narrow limits of Article 61.

Against this background, Seychelles and other alternative jurisdictions should be assessed by what their regime requires and what it does not give.

Seychelles Crypto Licence and AML

Illustration for the section "Seychelles Crypto License and AML in 2025" in the article "Seychelles Still a Relevant Alternative to MiCA in 2025"
A crypto licence in Seychelles is a VASP licence that the FSA grants under the 2024 Act. Licensing in Seychelles covers capital, insurance, real presence and the AML system, so an application needs serious preparation.

How to Obtain a VASP Licence in Seychelles

Under the FSA licence application guidelines (version of 28 April 2025), the process runs as follows:

  1. Choice of activity and company: one or more of the four types of services, and a company under the Companies Act, 1972, or an IBC.
  2. Preparing the application pack: a business plan, questionnaires for the directors and owners, proof of the office and of source of funds, an insurance quotation and 11 internal manuals and policies.
  3. Filing the application through the FSA website with payment of the fee. The FSA does not process an incomplete application, and the fee is forfeited.
  4. FSA review: requests for documents and, if needed, an interview or a demonstration of systems. Within 90 working days the FSA says whether the application is incomplete.
  5. Decision: a licence, possibly with conditions, or a refusal. If the FSA rejects an application, a new one may be filed only after 6 months.
The FSA's indicative review time for a complete application is 3 months to 2 years, depending on complexity. COREDO supports the client at every stage of preparation so that the document pack is complete at filing.

Requirements for Economic Presence and Management

Under the Third Schedule to the Act, the core income-generating activities must be carried out from a physical office in Seychelles. A licensee must therefore:

  • Have at least one resident director on its board of directors.
  • Run a fully staffed office in Seychelles with an adequate number of qualified employees.
  • Keep records and documents accessible at the office and handle client complaints in Seychelles.
  • Hold at least 2 board meetings and at least 4 management meetings in Seychelles every year.
Every January the licensee pays the annual fee and files a report on the substance requirements.

AML and Capital: FATF Standards in the Seychelles Law

Once licensed, a VASP becomes a reporting entity under the Anti-Money Laundering and Countering the Financing of Terrorism Act, 2020. The requirements are strict:

  • A compliance officer and an alternate are required, as two different people. The compliance officer works full time for the company; the FSA does not allow outsourcing this function.
  • Simplified due diligence is prohibited for licensed VASPs.
  • Minimum paid-up capital: USD 75,000 for wallet providers, USD 100,000 for an exchange, USD 50,000 for broking and USD 25,000 for investment services. The capital is held for each authorised activity.
  • From the beginning of the third year of operation, the capital requirement is 2.5% of annual turnover. Reserves must cover 100% of liabilities to clients, and professional indemnity insurance is also required.
Capital is held as cash, bonds or other security approved by the FSA. It may be kept in a bank licensed in Seychelles or in a financial institution from a country that meets at least the Basel II requirements.

Opening an Account in Seychelles: Challenges and Solutions

Illustration for the section "Opening an Account in Seychelles 2025: Challenges and Solutions" in the article "Seychelles Still a Relevant Alternative to MiCA in 2025"
Opening an account for a Seychelles VASP depends not only on the bank but also on the capital rules. Regulations under the VASP Act set out where capital, client money and funds for running costs may be held.

Where to Hold Capital and Client Money

The capital regulations (S.I. 72 of 2024) distinguish several kinds of funds:

  • Paid-up capital — in a bank licensed under the Financial Institutions Act or in an FSA-approved financial institution from a country that meets Basel II.
  • Money for discharging liabilities to clients — under the same rules, but excluding providers of alternative financial services outside traditional banks.
The FSA sets no separate requirement to open an account in Seychelles itself. But the bank runs its own checks, so the ownership structure, source of funds and AML policy must be transparent.
COREDO helps select partner banks and prepare the document pack for opening an account. Whether to open a multi-currency account and connect to payment systems is the bank's decision.

Risks of Registering a Crypto Business in Seychelles

Illustration for the section "Risks of Registering a Crypto Business in Seychelles" in the article "Seychelles Still a Relevant Alternative to MiCA in 2025"
The risks of registering a crypto business in Seychelles are now primarily regulatory. Operating without a licence is a criminal offence, and the FSA publicly acts against offenders.

Penalties and FSA Enforcement

The FSA guidelines name these consequences of operating without a licence, and the FSA publishes enforcement cases:

  • For a company — a fine of up to SCR 5,250,000.
  • For an individual — a fine of up to SCR 2,250,000 or imprisonment of up to 15 years, or both.
  • Anyone who did not file a complete application by 31 December 2024 but kept operating on or after 1 January 2025 is liable under section 33 of the Act.
  • On 26 May 2026 the FSA announced action against MX Global Ltd, the operator of the MEXC exchange, for unlicensed virtual asset services. It also announced a planned referral to the competent authority.
The FSA warns the clients of an unlicensed operator directly: it cannot investigate their complaints or help recover their funds.

Scaling: Prospects and Risks

A Seychelles structure can scale, but within the limits that both regimes set:

  • A VASP licence does not open the EU market: services to clients in the EU require MiCA authorisation (Art. 59).
  • If a third-country firm solicits clients in the EU through advertising or partners, the service is not treated as provided at the client's own exclusive initiative (Art. 61(1)).
  • EU tax list: on 17 February 2026 Seychelles was removed from Annex II of the EU tax list, and it is not listed in the EU Council conclusions of 9 October 2026 either.
  • Seychelles is not on the FATF list of jurisdictions under increased monitoring of 19 June 2026.
Regular compliance audits and a transparent corporate structure reduce these risks. Entering the EU market requires a separate CASP authorisation in an EU Member State.

Seychelles or MiCA for Crypto Business

Illustration for the section "Seychelles or MiCA for Crypto Business in 2025" in the article "Seychelles Still a Relevant Alternative to MiCA in 2025"
The choice today is not strict versus free, but between two licensing regimes with different reach. A Seychelles licence serves clients outside the EU, and MiCA authorisation serves the EU market. How can compliance risks be reduced when making this choice?

How to Reduce Compliance Risks?

  • First establish where the clients are and who initiates the relationship.
  • Choose the services: they determine the type of VASP licence or the CASP class and the amount of capital.
  • Develop AML procedures and KYC policies in line with FATF standards and the requirements of the chosen regime.
  • Ensure real presence: an office, staff and a resident director in Seychelles, or management from the EU for a CASP.
  • Update compliance procedures regularly and undergo independent reviews.

Seychelles or MiCA: Comparison of Conditions

Criterion Seychelles (VASP Act 2024) EU (MiCA)
Regulator FSA Competent authority of the EU Member State that granted the authorisation
Review time FSA indicative range: 3 months to 2 years 25 working days for the completeness check, 40 working days to assess a complete application
Capital requirements USD 25,000 to USD 100,000 by type of service; from the third year, 2.5% of turnover EUR 50,000, EUR 125,000 or EUR 150,000 by class, or one quarter of fixed overheads if higher
AML/KYC Reporting entity under the AML/CFT Act; simplified due diligence prohibited Strict, mandatory; systems to detect market abuse (Art. 92)
Real presence Office, staff and resident director in Seychelles Registered office and management in the EU, director resident in the EU
Clients in the EU No, except for the narrow exception of Art. 61 Yes, passport for the whole EU
Transitional period Ended on 1 January 2025 Ended no later than 1 July 2026

Conclusions and Recommendations for Business

Seychelles today is not a simplified offshore alternative to MiCA but a separate licensing regime for clients outside the EU. If your clients are in the EU, you need CASP authorisation under MiCA, and an FSA licence does not replace it. If your market is Asia, Africa or other regions outside the EU, a VASP licence remains a workable option with real presence in Seychelles and a full AML system.

It is recommended to consider Seychelles as a flexible platform for international business, especially if your goal is a quick entry into Asian and African markets, cost optimization, and maintaining control over the corporate structure. The key to success is professional support at all stages, regular compliance audits, and readiness to adapt to changes in global regulation.

COREDO's team is ready to offer comprehensive solutions tailored to your business's specifics and provide reliable support in implementing international projects.

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    COREDO – EU Legal & Compliance Services Expert legal consulting, financial licensing (EMI, PSP, CASP under MiCA), and AML/CFT compliance across the European Union. Headquartered in Prague, we provide seamless regulatory solutions in Germany, Poland, Lithuania, and all 27 EU member states.