The EU — MiCA & CASP
MiCA gives the EU a single, harmonised crypto rulebook across all 27 member states. One CASP authorization from any member state's regulator passports to the entire bloc — roughly 450 million people — without re-licensing. For any business whose market is continental Europe, this is the headline advantage no other regime here can match. Costs and timelines vary by member state, but the license and its market access are uniform.
The UK — FCA
Post-Brexit, the UK is not covered by MiCA. Crypto firms register with the Financial Conduct Authority (FCA) under the Money Laundering Regulations and the evolving FSMA-based regime, with a notoriously rigorous AML registration process and timelines often running 6–12 months. Crucially, a UK registration gives no EU passport — to serve EU customers you need a separate EU authorization. See our UK FCA page.
Switzerland — FINMA
Switzerland sits outside the EU and has its own respected framework, supervised by FINMA and underpinned by the DLT Act (in force 2021) and the Crypto Valley ecosystem in Zug. Switzerland offers strong credibility and legal certainty, with options including the FinTech license. But like the UK, a Swiss authorization provides no passport into the EU — EU market access requires an EU CASP license. See our Switzerland FINMA page.
Side-by-Side Comparison
| EU (MiCA) | UK (FCA) | Switzerland (FINMA) | |
|---|---|---|---|
| In MiCA? | Yes | No | No (non-EU) |
| EU passport | Yes — 27 states | No | No |
| Regulator | National NCA | FCA | FINMA |
| Indicative timeline | 4–7 months | 6–12 months | Varies by license |
| Reputation | Harmonised, rising | Strict AML | High credibility |
| Best for | EU-wide market | UK market | Credibility / Swiss base |
The Passport Factor
This is the heart of the decision. If your market is the EU, only an EU CASP authorization gives you frictionless access to all 27 states from a single license. UK and Swiss licenses are valuable for their own markets and for credibility, but they do not open the EU. Many firms that once defaulted to London or Zug now base their EU operations inside the bloc precisely for the passport — read more in our EU passporting guide.
Dual-License Strategies
The regimes are not mutually exclusive. Common structures include an EU CASP entity (for the 27-state market) paired with a UK FCA registration (for the UK) or a Swiss entity (for credibility and the Swiss market). A UK or Swiss group can establish an EU subsidiary — often in Ireland, Germany, or a Baltic state — to obtain the passport. We design these multi-jurisdiction structures so each license does the job it is best at.
