Editorial · SKY7 Insights
Licensing guides, regulatory updates and field notes from the seniors who file. Written for founders deciding which licence, which jurisdiction, and what to expect before a regulator opens the file.
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A Hong Kong MSO licence lasts two years, and renewal is a deadline machine: Form 2 filed no later than 45 days before expiry, assessment candidates nominated within 7 days, the test sat within 30 - or the licence lapses automatically and operations must cease. The clocks, the fees in force since 15 May 2026, and the buyer's due-diligence checklist.
Four regimes, three regulators, one question: which licence does your model actually need? Remittance and FX sit with Customs and Excise as an MSO; e-wallets with the HKMA under Cap. 584; stablecoin issuance under Cap. 656, in force and tightly gated; VA dealing with an SFC-led regime that is not yet law. Mapped end to end, as of July 2026.
MAS publishes no service standard for payment services licences. What it does publish, on both the Form 1 and Form 2 pages, is a waiting banner: more than a year before an officer is available to review. The on-hold machinery, the stale consultant figures, and what an applicant actually controls.
Cross the s.6(5) thresholds and Singapore law gives you 30 days to file a Form 2 change application - then lets a compliant SPI keep operating while MAS decides. What counts toward the thresholds, what MPI status switches on, and why a pending application may still be refused.
Four FSCA releases tell one story as at 31 March 2026: 533 CASP applications, 310 approvals, 17 declines, 124 withdrawals. The declines are about operational ability and competence; the withdrawals mostly died on a 30-day information request. What the regulator's own scoreboard says about buying versus applying.
Same four letters, two different regimes. A South African CASP is an FSP licensed under the FAIS Act; an EU CASP holds a MiCA authorisation. Neither licence opens the other market - here is how to tell them apart, and which one a crypto business actually needs.
A Category II application costs R16,313 under FSCA General Notice 1 of 2024. The annual levy is a gazetted formula on headcount and assets under management - not revenue. And there is no fixed rand capital floor: the real money sits in Table B liquidity. The official schedules, end to end.
An official-source-only method for checking whether a legal entity is authorised under MiCA, which services it may provide and where cross-border notification applies, as of July 2026.
The last national MiCA transitional period ended on 1 July 2026. If your firm relied on national VASP status, compare a fresh CASP application, an authorised-CASP acquisition, or a provider-led restructure or orderly EU exit.
European VASPs facing MiCA deadlines often have two bottlenecks at once: CASP authorisation timing and banking or EMI onboarding that moves more slowly than the regulatory calendar. There is a structural alternative.
The FCA's rebuilt safeguarding regime - CASS 15, CASS 10A and SUP 3A - has been in force since 7 May 2026. Daily reconciliations, a monthly REP027 return and an annual safeguarding audit now generate a paper trail every EMI must keep current. For anyone buying an EMI, that trail is the diligence file: here is what changed, why, and what to demand from a target before signing.
The FCA does not re-license a purchased e-money institution; it approves the buyer. Part 12 of FSMA 2000 sets a 60-working-day clock with deemed approval on silence - and a criminal cliff for completing early. Thresholds, filing, arithmetic - end to end.
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