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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Licences

What it takes to operate in Bermuda: 4 licences, who issues each, what it covers and who holds one.

Digital asset business licence, Class F (full)

BMA · Digital Asset Business Act 2018, sections 10 and 12(3)(a)

Any or all DABA activities with no fixed term: issuing or redeeming digital assets, payment services, exchanges, trust services, custodial wallets, derivatives exchanges, services vendors, and lending or repo.

What it takes

Minimum net assets of $100,000, or more if the BMA directs, plus insurance cover for risks of the business
Head office in Bermuda: the business must be directed and managed from Bermuda
A BMA-approved senior representative with an office in Bermuda; at least two persons directing the business
Annual financial statements audited by a BMA-approved auditor, filed within four months of year end
Client assets segregated under the 2025 Custody of Client Assets Rules; risk and fee disclosures to every client

Holders include

CICircle International Bermuda Limited
CBCoinbase Bermuda Limited
CBCoinbase Bermuda Services Limited
PDPayward Digital Solutions Ltd.
HBHashKey Bermuda Limited
OBOSL Bermuda Limited
ZHZero Hash Worldwide Ltd.
BSBitcoin Suisse (International) Ltd.

28holders, 15 Oct 2026Register

Digital asset business licence, Class M (modified)

BMA · Digital Asset Business Act 2018, section 12(3)(b)

Any or all DABA activities for a defined period set by the BMA, which describes the class as for expanding operations for a limited period.

What it takes

Same minimum criteria as Class F, including $100,000 net assets and a Bermuda head office
Licence lapses at the end of its defined period unless the BMA extends it on application
The BMA may limit the activities or attach conditions, as it can for any DABA licence
The register publishes each licence's permitted activities and expiry date

Holders include

CDCEX.IO Digital Ltd.
SLStablehouse Ltd.
VGVNX Global Ltd.
AFApex Fund Services Ltd.
KDKimber Digital Assets Bermuda ISAC Ltd

17holders, 15 Oct 2026Register

Digital asset business licence, Class T (test)

BMA · Digital Asset Business Act 2018, section 12(3)(c), added by the Digital Asset Business Amendment Act 2020

Any DABA activity for a defined period set by the BMA, for pilot or beta testing of that activity.

What it takes

Minimum net assets of $10,000, or more if the BMA directs
No Bermuda head office requirement; the senior representative need not have a Bermuda office if the BMA approves
Must state on its website that it holds a Class T licence for pilot or beta testing
Client and own transaction records kept for five years at its principal place of business

Holders include

BL24X Bermuda Limited
DBDerivaDex Bermuda Ltd.
JMJuno Moneta Bermuda Limited
NINimble Insurance, Ltd.

7holders, 15 Oct 2026Register

Digital asset issuance authorisation

BMA · Digital Asset Issuance Act 2020, sections 11 to 16

Offering digital assets to the public in or from Bermuda by a company, LLC or partnership, for the period stated in the authorisation; issuing as a business needs a DABA licence instead.

What it takes

Application with a business plan, the issuance document and management arrangements
Issuance document published electronically and signed by all directors before the offer
Fit and proper controllers and officers, and conduct in a prudent manner, under Schedule 1
Offers to 150 or fewer persons, qualified acquirers or professionals are not public offers but need a placement declaration
Companies also need the Minister of Finance's consent, as digital asset issuance is a restricted business activity

No public count

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