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Bermuda

Bermuda wrote a crypto licensing law in 2018 and now has 53 digital asset businesses on its register, from Circle and Coinbase to start-ups.

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53Digital asset businesses on the BMA register (28 Class F, 17 Class M, 7 Class T, 1 class not shown)
50Digital asset businesses the BMA supervised during 2025 (22 Class F, 21 Class M, 7 Class T)
$100,000Minimum net assets for a Class F or M licensee ($10,000 for Class T)

Bermuda legislated for crypto early and by statute.

The Companies and Limited Liability Company (Initial Coin Offering) Amendment Act 2018, in force on 9 July 2018, made token sales a restricted business activity that needed the Minister of Finance's consent.

The Digital Asset Business Act 2018 (DABA) followed on 10 September 2018 and made it an offence to carry on digital asset business in or from Bermuda without a licence from the Bermuda Monetary Authority (BMA).

In May 2020 the Digital Asset Issuance Act 2020 (DAIA) replaced the ICO rules and moved public token offerings under the BMA.

Read the full story

DABA has been widened several times: digital asset derivatives exchanges and trust services were added in 2019, the Class T test licence in December 2020, and digital asset lending and repo services in June 2023.

Licences come in three classes: Class F (full), Class M (modified, for a defined period) and Class T (pilot or beta testing).

On 15 October 2026 the BMA register listed 53 digital asset businesses: 28 Class F, 17 Class M, 7 Class T and one whose class is not shown.

The BMA added custody rules in February 2025 and, in November 2024, guidance for issuers of single-currency pegged stablecoins.

Firms come for a single regulator with a long record of licensing them and for company law built for international business.

A typical structure is an exempted company, LLC or segregated accounts vehicle formed with the Registrar of Companies, which then applies for a DABA licence.

Class F and M licensees must be directed and managed from Bermuda, keep at least $100,000 of net assets and appoint a BMA-approved senior representative with an office on the island.

Holders include Circle, which received the first Class F licence in July 2019, two Coinbase entities, Kraken's parent Payward, HashKey, OSL and Zero Hash.

There is no tax on income or capital gains; a 15% corporate income tax has applied since 2025 only to Bermuda entities of multinational groups with revenue of EUR 750 million or more.

The Government now wants to use the regime at home.

In January 2026, at Davos, it announced plans to become a fully onchain national economy with Circle and Coinbase, with government agencies piloting stablecoin payments.

In May 2026 the Premier told the House of Assembly that the Government plans to amend public finance laws so it can accept stablecoin payments.

The BMA, meanwhile, is consulting on tokenisation, a Payment Services Act and the use of stablecoins by insurers and funds.

Who regulates

  • BMABermuda Monetary Authority

    In charge of

    Bermuda's central bank and single financial regulator under the Bermuda Monetary Authority Act 1969: it supervises banks, insurers, investment firms, funds, trust and corporate service providers and digital asset businesses.

    On crypto

    Licenses digital asset businesses in Classes F, M and T (53 on its register on 15 October 2026) and authorises public token offerings under the DAIA. It writes custody, disclosure and cyber rules, issued stablecoin guidance in November 2024 and consulted on asset tokenisation in April 2026.

    BMA website
  • MoFMinistry of Finance

    In charge of

    Responsible for Bermuda's public finances and tax policy. The Registrar of Companies sits under the Ministry, and the Minister of Finance gives consents and licences under the Companies Act 1981.

    On crypto

    The Minister makes exemption orders under DABA on BMA advice, such as the 2023 order for rewards schemes, in-game assets and intra-group activity, and must consent before a company conducts a digital asset issuance, which is a restricted business activity under the Companies Act.

    MoF website
  • RoCRegistrar of Companies

    In charge of

    Maintains Bermuda's register of legal persons, including local and exempted companies, LLCs and exempted partnerships, and the central register of beneficial ownership under the Beneficial Ownership Act 2025.

    On crypto

    Forms the exempted companies, LLCs, SACs and ISACs that hold DABA licences or issue tokens. Registration gives no right to carry on crypto activity, which needs a separate BMA licence or authorisation.

    RoC website
  • CITACorporate Income Tax Agency

    In charge of

    Set up to administer the Corporate Income Tax Act 2023, in effect from 1 January 2025. In 2026 it became the competent authority for CRS and country-by-country reporting and took over economic substance.

    On crypto

    Bermuda has no crypto-specific tax rules. Crypto firms in multinational groups with revenue of EUR 750 million or more pay 15% CIT; others pay no tax on profits. Its CARF page says reporting obligations and timelines will be published in due course.

    CITA website

Entities crypto firms use

The legal vehicles crypto projects and firms set up in Bermuda, what each is for and why it's chosen. Forming one is not a licence: dealing in virtual assets for others still needs the licences above.

  • Exempted companyCompanies Act 1981 · Registrar of Companies

    The usual vehicle for a DABA licensee, token issuer or group holding company owned from outside Bermuda; forming one gives no right to carry on crypto activity.

    • Not bound by the rule that local companies be at least 60% Bermudian-controlled; share capital in any currency
    • Needs no separate section 129A licence from the Minister to carry on digital asset business in Bermuda once licensed under DABA
    • Must have a Bermuda-resident director, secretary or resident representative
    • Equity issues and transfers involving non-residents need BMA exchange control permission unless a general permission applies
    • Can hold a tax assurance to 31 March 2035, which no longer protects against the 15% corporate income tax
    Official source
  • Limited liability company (LLC)Limited Liability Company Act 2016 · Registrar of Companies

    An alternative to the exempted company for operating and issuing entities whose owners want members and an LLC agreement instead of shareholders and bye-laws.

    • Separate legal entity that continues even if it has no members
    • Managed by its members in proportion to their profit interests, unless the LLC agreement appoints managers
    • The LLC agreement can create classes or groups of members with their own rights and votes
    • An exempted LLC can hold the same 1966 tax assurance and denominate interests in any currency
    • Subject to DABA and the DAIA like any company; its own ICO regime was repealed in 2020
    Official source
  • Segregated accounts company (SAC)Segregated Accounts Companies Act 2000 · Registrar of Companies

    Ring-fencing client or product pools inside one company; On Re SAC Ltd. and Excellar International SAC Ltd. hold DABA licences.

    • Assets linked to a segregated account meet only that account's liabilities and are protected from other creditors
    • Accounts are not separate legal persons; the company acts for each account
    • A company outside insurance needs the Minister's approval to register as a SAC
    • Must appoint a segregated account representative
    • The BMA's guidance for DABA applicants names the SAC as a bankruptcy-remote structure
    Official source
  • Incorporated segregated accounts company (ISAC)Incorporated Segregated Accounts Companies Act 2019 · Registrar of Companies

    Running several digital asset businesses or tokenised products as separate companies under one umbrella; Cor Prime, Meli and Kimber Digital Assets ISACs and ISAs hold DABA licences.

    • Since 22 October 2021 each incorporated segregated account is itself a company with its own memorandum and bye-laws
    • Companies engaged in digital asset business may register as an ISAC without the Minister's approval
    • The Registrar keeps a public register of ISACs and their accounts
    • Where the ISAC or an account is a financial institution, the BMA must not object to registration
    Official source
  • Authorised digital asset issuerDigital Asset Issuance Act 2020 · Bermuda Monetary Authority (authorisation); entity formed with the Registrar of Companies

    The status a Bermuda company, LLC or partnership needs before a public token offering, where it is not issuing tokens as a business.

    • Authorisation for a fixed period on a business plan and a published issuance document
    • Private placements to 150 or fewer persons, qualified acquirers or professionals fall outside, with a placement declaration
    • Qualified acquirers include individuals with $1 million net worth and companies with $5 million of assets
    • Companies also need the Minister of Finance's consent under the Companies Act
    • The BMA proposed in April 2026 an explicit exemption for tokenised funds
    Official source
  • Investment fundInvestment Funds Act 2006 · Bermuda Monetary Authority

    Crypto and tokenised funds, which are registered or authorised as funds rather than licensed as digital asset businesses.

    • Classes include private funds, Professional Class A and B funds, professional closed funds and authorised funds
    • A fund whose manager is licensed under the Investment Business Act 2003, or by a recognised regulator, can claim DABA exemption by notifying the BMA
    • The BMA proposed in April 2026 to allow tokenised fund registers and exempt the administrators running them from DABA
    • The BMA consulted in July 2026 on funds using recognised stablecoins for treasury, settlement and collateral
    Official source

What to watch

  • Whether the BMA turns its April 2026 asset tokenisation consultation into amendments to DABA, the DAIA and the investment laws, including an explicit DAIA exemption for tokenised funds.
  • The Payment Services Act, which would replace the Money Service Business Act 2016 with tiered licence classes and treat stablecoin issuance as a payment activity, with exemptions for DABA-licensed firms.
  • Final BMA guidance on recognised stablecoins in insurance, ILS and fund structures after comments closed on 30 September 2026, and the Government's planned amendments so it can accept stablecoin payments.
  • Bermuda's timetable for the OECD Crypto-Asset Reporting Framework, which the Corporate Income Tax Agency says it will publish in due course.

Quick answers

Who regulates crypto in Bermuda?

Four authorities shape crypto rules in Bermuda. BMA (Bermuda Monetary Authority): integrated financial regulator; licenses digital asset businesses under DABA and authorises token issuances under the DAIA. MoF (Ministry of Finance): sets tax and fiscal policy; the Minister makes DABA exemption orders and consents to restricted business activities. RoC (Registrar of Companies): forms and registers companies, LLCs, partnerships and segregated accounts vehicles; keeps the beneficial ownership register. CITA (Corporate Income Tax Agency): administers the corporate income tax, economic substance and automatic exchange of tax information.

Do crypto exchanges need a licence in Bermuda?

Yes, under a dedicated regime. DABA licensing since 2018 in Classes F, M and T; 53 licensees on the BMA register in October 2026. The main licences are Digital asset business licence, Class F (full) from BMA, held by 28 as of 15 Oct 2026; Digital asset business licence, Class M (modified) from BMA, held by 17 as of 15 Oct 2026; and Digital asset business licence, Class T (test) from BMA, held by 7 as of 15 Oct 2026. Four Pillars rates exchange licensing in Bermuda as comprehensive (reviewed 15 Oct 2026).

Are stablecoins regulated in Bermuda?

Yes, under a dedicated regime. Issuance is a DABA-licensed activity; November 2024 BMA guidance sets backing and attestation standards. The most recent official text is Consultation Paper: Guidance Note on the Use of Recognised Stablecoins within Bermuda Insurance, Insurance-linked Securities and Investment Fund Structures (Bermuda Monetary Authority (BMA), 20 Jul 2026, consultation). Four Pillars rates its stablecoin regime in Bermuda as comprehensive (reviewed 15 Oct 2026).

How is crypto taxed in Bermuda?

No income or capital gains tax; 15% CIT on entities of MNE groups with EUR 750m+ revenue from 2025. Four Pillars rates tax clarity in Bermuda as partial (reviewed 15 Oct 2026).

Can real-world assets be tokenised in Bermuda?

Yes, though the regime is narrow or still phasing in. DABA, the DAIA and fund laws already apply; an April 2026 BMA consultation proposes targeted amendments. Four Pillars rates tokenisation and real-world assets in Bermuda as partial (reviewed 15 Oct 2026).

What changed most recently in Bermuda's crypto rules?

9 Apr 2026: BMA consults on asset tokenisation. It proposed targeted amendments to existing laws rather than a new regime, with comments due by 30 June 2026. 19 Jan 2026: Onchain national economy plan announced. At Davos, the Government said it would work with Circle and Coinbase, with agencies piloting stablecoin payments.

What should companies watch next in Bermuda?

Whether the BMA turns its April 2026 asset tokenisation consultation into amendments to DABA, the DAIA and the investment laws, including an explicit DAIA exemption for tokenised funds. The Payment Services Act, which would replace the Money Service Business Act 2016 with tiered licence classes and treat stablecoin issuance as a payment activity, with exemptions for DABA-licensed firms. Final BMA guidance on recognised stablecoins in insurance, ILS and fund structures after comments closed on 30 September 2026, and the Government's planned amendments so it can accept stablecoin payments.

Timeline

  1. BMA consults on asset tokenisation

    It proposed targeted amendments to existing laws rather than a new regime, with comments due by 30 June 2026.

  2. Onchain national economy plan announced

    At Davos, the Government said it would work with Circle and Coinbase, with agencies piloting stablecoin payments.

  3. Custody of client assets rules take effect

    Licensees providing custodial wallets must segregate client assets and have their controls reviewed every year.

  4. Corporate income tax applies to large groups

    A 15% tax took effect for Bermuda entities of multinational groups with revenue of EUR 750 million or more.

  5. Stablecoin guidance published

    The BMA issued its Single Currency Pegged Stablecoins Guidance, dated November 2024, after consulting from May 2024.

  6. Coinbase Bermuda receives a Class F licence

    The licence covers token issuance, a digital asset exchange, custody and a digital asset derivatives exchange.

  7. Class T test licence created

    The Digital Asset Business Amendment Act 2020 added a licence for pilot and beta testing with $10,000 minimum net assets.

  8. Digital Asset Issuance Act takes effect

    Public token offerings moved under BMA authorisation, and the 2018 ICO provisions were repealed.

  9. Government accepts USDC for taxes and fees

    Bermuda began accepting Circle's USDC stablecoin for taxes, fees and other government services.

  10. Circle receives the first Class F licence

    Circle International Bermuda Limited became the first firm with a full DABA licence.

  11. Digital Asset Business Act comes into force

    Carrying on digital asset business in or from Bermuda without a BMA licence became an offence.

  12. ICO law takes effect

    Token sales by companies and LLCs became a restricted business activity needing the Minister of Finance's consent and a filed ICO offer document.

Cite this page: Four Pillars Asia Digital Asset Policy Center, “Bermuda crypto regulation”, reviewed 15 Oct 2026, https://policy.4pillars.io/bermuda. Free to reuse with attribution; also as markdown and JSON.

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