EMI vs MSB vs VASP Licensing: Time & Cost (Bulk) Comparison

When comparing licensing options for fintech businesses, two factors dominate: 1) how long it typically takes to obtain approval, and 2) what the all‑in (bulk) first‑year budget looks like.

This guide compares four regimes:
• UK EMI (FCA)
• EU EMI (e.g. Lithuania, Ireland, Germany)
• Canada MSB (FINTRAC)
UAE VASP (VARA Dubai / ADGM)

Bulk cost refers to the total realistic budget credible operators spend in Year One — including advisory, compliance, tech, staffing, banking, and regulator fees — beyond the official application fee.

Side‑by‑Side: Time & Bulk Cost

RegimeRegulatorOfficial FeeCapital MinimumTypical TimelineBulk Year‑One Budget
UK EMIFCA (UK)£5k small €350k6–12 months£750k–1.2m
EU EMILocal NCAs (e.g. Lithuania, Ireland, BaFin)€5k–10k [2]€350k9–18 months€500k–1m
Canada MSBFINTRAC (Canada)CAD $0 [3]None (federal)6-12 monthsUSD $40k–100k+
UAE VASPVARA Dubai / ADGMUSD 15k–50k [4]AED 1m+ (scope‑dependent)6-12 monthsUSD $200k–500k+


Notes: Timelines depend on application quality, jurisdiction workload, and scope of activity. Bulk budgets are realistic ranges for credible operators; high‑risk models (e.g., exchanges) trend toward the upper end.

Visual: Bulk Year‑One Budget

Visual: Typical Timelines

Jurisdiction Notes

UK EMI (FCA)

• Official fee: £5k [1].
• Capital: €350k (full EMI).
• Timeline: 6–12 months. FCA is documentation‑heavy (30+ policies/manuals).
• Bulk cost: £750k–1.2m for advisory, compliance staff, safeguarding, AML systems, audits and Capital.

EU EMI (e.g. Lithuania, Ireland, BaFin)

• Official fee: €5k–10k [2].
• Capital: €350k (full EMI).
• Timeline: 9–18 months, depending on NCA. Lithuania fastest, Ireland and BaFin often slower.
• Bulk cost: €500k–1m realistic Year One, lower than UK in some markets but slower to process.
• Notes: Passporting across EU remains a key advantage.

Canada MSB (FINTRAC)

• Official fee: CAD $0 (federal registration) [3].
• Capital: None federally (banks still expect financial resilience).
• Timeline: 6+ months (incorporation + FINTRAC review).
• Bulk cost: USD $40k–100k+, including incorporation, compliance officer, AML tools, training.

UAE VASP (VARA Dubai / ADGM)

• Official fee: USD 15k–50k depending on category [4].
• Capital: AED 1m+ for most categories, higher for exchanges.
• Timeline: 6+ months, depending on scope and regulator.
• Bulk cost: USD $200k–500k+ for a modest operation; higher for high‑risk models.

References

  1. [1] FCA – Authorisation and registration application fees. https://www.fca.org.uk/firms/authorisation/apply/fees
  2. [2] Central Bank of Lithuania – EMI licensing guidelines. https://www.lb.lt/en/sfi-financial-market-participants
  3. [3] FINTRAC – Register your money services business. https://fintrac-canafe.canada.ca/msb-esm/register-inscrire/reg-ins-eng
  4. [4] VARA – Licence applications & fee schedules. https://www.vara.ae/en/licenses-and-register/licence-applications/
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