Vanuatu Crypto License 2026: Complete Guide to VASP Licensing

The VASP Act No. 3 of 2025 introduced five distinct VASP license classes, plus a separate ITO license for token issuers. Each class covers a defined scope of virtual asset activity. You must apply for every class that matches your intended operations (holding a Class D license does not automatically permit custody or token issuance). The table below sets out what each class authorises:

Regardless of class, you must meet the VFSC’s prudential requirements: minimum unimpaired capital of VT 200,000,000 (~USD 1,680,000), at least one director who resides in Vanuatu for 12 consecutive months, a Chief Technology Officer (CTO) who must also reside in Vanuatu for 12 consecutive months, a physical office in the country with at least three resident staff (Manager, Director, and CTO), and an AML/CTF Compliance Officer. The VFSC enforces these through ongoing supervision and audits under the AML/CFT Act No. 13 of 2014.

Before 26 March 2025, crypto businesses in Vanuatu operated under the Financial Dealers License (FDL) framework. The FDL Amendment Act No. 9 of 2021 (in force 22 July 2021) introduced Class D as a digital asset sub-category within the existing four-class FDL structure. Classes A through D were cumulative, so a company wishing to hold Class D had to first obtain Classes A, B, and C, each carrying its own capital and compliance requirements.

This structure had two practical drawbacks. FDL licenses were designed for conventional financial dealers, not virtual asset businesses. The cumulative class requirement also increased setup costs and complexity for applicants whose only interest was crypto activity.

The VASP Act No. 3 of 2025 resolved this by creating purpose-built VASP license classes (D through D.4 and ITO) for virtual asset activities specifically. The FDL Class D remains valid for existing licensees, but the VASP license is now the primary route for any new business seeking to operate a crypto exchange, custody service, or token issuance platform in Vanuatu. In current VFSC practice, applicants are typically expected to also hold FDL Classes A through D before a VASP license is issued.

You pay 0% corporate income tax, 0% capital gains tax, 0% withholding tax, and 0% dividend tax. IBCs incorporated in Vanuatu receive a statutory tax exemption for up to 20 years. The only applicable tax is 15% VAT on taxable supplies within Vanuatu, which typically does not apply to cross-border digital asset services. See the full tax breakdown below.

Vanuatu is a member of the Asia/Pacific Group on Money Laundering (APG), the FATF’s regional body for the Asia-Pacific region. APG membership means Vanuatu undergoes mutual evaluation reviews against FATF recommendations, aligning its AML/CFT framework with EU and OECD standards. The Financial Intelligence Unit (FIU) receives suspicious transaction reports from all regulated entities including VASPs.

The VASP Act introduced substance requirements (physical office, resident key personnel, AML/CTF Compliance Officer, ~$1,680,000 USD minimum capital) that go beyond brass-plate registration. The VFSC conducts on-site audits and can revoke licenses for non-compliance. Full eligibility requirements are detailed below.

A Vanuatu VASP license is not equivalent to an EU authorization under MiCA, but it provides documented regulatory status from a FATF-aligned regulator. That is the baseline for opening correspondent banking relationships and onboarding compliant payment processors in the Asia-Pacific region.

The table below compares Vanuatu against three jurisdictions crypto businesses commonly evaluate. Green cells indicate where Vanuatu offers a material advantage.

Vanuatu’s primary advantage is the zero-tax stack (no corporate, capital gains, withholding, or dividend tax) combined with lower capital requirements than Dubai. Dubai VARA matches the zero withholding and dividend tax profile but carries minimum capital requirements up to $13.6M USD for full exchange activities. Lithuania offers EU regulatory standing but imposes 17% corporate income tax and 15% dividend tax. El Salvador offers a low-cost entry point, though its regulatory framework is less established for institutional counterparties outside the Bitcoin ecosystem.

Source: VFSC VASP Application Guidelines (June 2025), Sections 4–5. Government fees are additional to Fintech Simple service fees listed below.

A Vanuatu VASP license is issued only to an entity incorporated as an International Business Company (IBC) in Vanuatu. In current VFSC practice, applicants are typically expected to also hold all four FDL classes (A through D). You cannot apply through a foreign-registered entity. The IBC must be in good standing with the VFSC before the VASP application is submitted.

Structurally, the minimum requirements are:

• 1 shareholder minimum — may be a corporate entity or a natural person, resident anywhere. Full disclosure of shareholders and beneficial owners is mandatory to the VFSC, even though shareholder information is kept off the public register.
• Company secretary — standard for Vanuatu IBCs. The VFSC application forms call for a full CV for each secretary.
• Registered office — must be a physical, manned address in Vanuatu. Virtual offices and mail-forwarding addresses are explicitly rejected.

The corporate structure must reflect genuine economic substance. The VASP Act 2025, read together with the proposed Resident Entity (Economic Substance) Bill of 2024, requires that the company actually operates from Vanuatu, not merely appears to.

The VASP Act 2025 overhauled the personnel rules. The old claim that “no local director is required” no longer holds; that applied to the pre-2025 FDL Class D framework. Under the current rules:

• Resident director — at least one director must reside in Vanuatu for a minimum of 12 consecutive months. Proof of residency is required at application and must be maintained throughout the license period.
• CTO or technical lead — must reside in Vanuatu for a minimum of 12 consecutive months (same as the director requirement) and have demonstrated virtual asset expertise. The VFSC reviews qualifications and experience; a generic IT background is insufficient.
• AML/CTF Compliance Officer — a dedicated compliance officer is required under the AML/CFT Act No. 13 of 2014. This role cannot be shared with operational functions.
• Multiple employees — the VFSC rejects single-person operations. The application must demonstrate that the business has adequate staffing to deliver its stated VASP activities.

All key persons (directors, the compliance officer, the technical lead, and other senior management) must obtain prior VFSC approval before taking up their roles. VFSC reviews each individual’s fitness, competence, and probity. Submitting an application with unapproved key persons is a common cause of delay.

The capital threshold under the VASP Act 2025 is the single biggest change from the old regime. The $10,000 minimum capital figure that still appears on some websites reflected the pre-2025 IBC rules and has no bearing on the current VASP license.

Under the VFSC VASP Requirements (January 2026), the current thresholds are:

• Minimum unimpaired capital — VT 200,000,000 (approximately $1,680,000 USD at prevailing exchange rates). “Unimpaired” means the capital must be free of any prior claims or encumbrances.
• External auditor certification — the capital must be verified and certified by an independent, qualified external auditor. Self-certification is not accepted.
• Approved custody — the capital must be held at the VFSC or at a financial institution recognized by the VFSC. Holding funds in offshore accounts or unrecognized institutions does not satisfy this requirement.

Applicants should budget for the capital requirement on top of application fees, incorporation costs, physical office setup, and local payroll. The total upfront investment to get a Vanuatu VASP license to the point of approval is materially higher than under the old FDL framework.

Vanuatu’s AML/CTF framework is set by the AML/CFT Act No. 13 of 2014. The Financial Intelligence Unit (FIU) receives suspicious transaction reports from VASPs and conducts financial intelligence analysis under this Act.

Every VASP licensee must build and maintain a compliance framework covering:

• KYC / customer due diligence — full identity verification at onboarding, including beneficial ownership for corporate clients and enhanced due diligence for PEPs.
• Transaction monitoring — automated sanctions screening and real-time flagging of unusual patterns.
• Suspicious transaction reporting — mandatory STR filing with the FIU regardless of transaction size.
• Record retention — customer records and transaction data retained for the prescribed period, available to VFSC and FIU on request.
• Staff training — regular AML/CTF training with documented records (audited by VFSC and FIU).
• Written policies — AML/CTF policies must be in place and submitted as part of the application. VFSC reviews these before granting the license.

The VFSC conducts on-site and off-site inspections of licensed VASPs. Non-compliance can result in license suspension, financial penalties, or referral to the FIU for criminal investigation.

The VFSC charges government fees at the application stage and annually thereafter. Fee amounts vary by license class and are denominated in Vanuatu Vatu (VT). Key person changes carry their own per-person charge. All USD amounts are approximate at prevailing exchange rates (~VT 1 = $0.0083 USD).

The VASP Act 2025 requires genuine economic substance in Vanuatu: a physical office, resident key personnel, and an active compliance function. The VFSC checks substance during supervision and audits. The estimates below represent typical annual outlays for a small VASP operation.

The Virtual Asset Service Providers Act No. 3 of 2025 was passed on 26 March 2025. It is the primary legislation governing crypto licensing in Vanuatu and introduced a dedicated regulatory framework alongside the Financial Dealers Licensing Act for digital asset businesses. The VASP Act creates a standalone licensing regime with dedicated requirements for capital, governance, AML/CFT, and economic substance.

Two earlier instruments remain relevant as context:

The VASP Act sets hard penalties for breaches. Operating without a VASP license carries up to VT 200,000,000 (approximately USD 1.7 million) and 30 years imprisonment for individuals, or VT 300,000,000 for a body corporate. Operating without an ITO license carries VT 25,000,000 and up to 15 years imprisonment for individuals, or VT 250,000,000 for a body corporate.

The Vanuatu Financial Services Commission (VFSC), established in 1993, licenses, supervises, and audits all non-banking financial services in Vanuatu, including VASPs. Under the VASP Act 2025, the VFSC holds broad investigative and enforcement authority: it can conduct on-site inspections, require document production, suspend or revoke licenses, and refer cases for prosecution.

The VFSC also enforces AML/CFT compliance for licensees, a function it carries out alongside the FIU. You deal with the VFSC as the primary point of contact for:

• License applications and renewals — submission, assessment, and approval of VASP license applications under the Act
• Ongoing supervision — periodic audits of AML/CFT programs, capital adequacy, and economic substance requirements
• Enforcement actions — warnings, fines, license suspension, or license revocation for non-compliance
• Criminal referrals — referral to prosecutors where breaches meet the threshold for criminal penalties under the VASP Act

The Financial Intelligence Unit (FIU) operates separately under the AML/CFT Act No. 13 of 2014. It receives Suspicious Transaction Reports (STRs) from VASPs and analyzes financial intelligence. You must report suspicious activity directly to the FIU and maintain records in line with AML/CFT requirements.

Vanuatu’s relationship with crypto began with outright hostility. Under the original Financial Dealers Licensing Act, the VFSC treated cryptocurrency as outside the permitted scope of licensed activity. When licensees referenced crypto in their business activities, the VFSC forfeited their security bonds (approximately VT 5,000,000 / USD 40,000–44,000 per licensee). This effectively banned crypto businesses from operating legally.

The first formal opening came with the FDL (Amendment) Act No. 9 of 2021, which introduced Class D licenses for digital asset businesses. The Class D pathway was constrained (applicants first had to hold Classes A, B, and C) but it created the first legitimate route for crypto firms. Between 2021 and 2025, Class D served as a stopgap not purpose-built for crypto.

The VASP Act No. 3 of 2025, passed on 26 March 2025, replaced that stopgap with a dedicated VASP licensing regime aligned with FATF recommendations. The minimum capital requirement rose from the old bond-based system to approximately VT 200,000,000 (approximately USD 1,680,000), signaling that Vanuatu now targets established operators rather than shell structures.

The table below covers the taxes most relevant to a crypto company operating through a Vanuatu IBC or VASP-licensed entity.

Companies incorporated in Vanuatu as IBCs can lock in a tax exemption for up to 20 years at the time of registration. During that period, any tax introduced after incorporation does not apply to the company. A crypto business starting today could operate through the mid-2040s with statutory protection against new direct taxes, even if Vanuatu introduces corporate tax in the future.

What this means for your operations:

• No retained earnings drag — profits are not reduced by corporate tax before reinvestment or distribution
• No exit tax — selling the company or its assets does not trigger a capital gains event
• No dividend leakage — shareholders in any jurisdiction receive distributions gross of Vanuatu tax
• No withholding on service payments — fees paid to foreign contractors, technology providers, or group entities leave Vanuatu without deduction
• Statutory certainty — the 20-year exemption is written into the IBC framework, not dependent on annual rulings or administrative discretion

By comparison, Gibraltar charges 15% corporate tax (increased from 12.5% on 1 July 2024) and the Cayman Islands has no corporate tax and offers its own codified Tax Exemption Undertaking (up to 30 years) for exempted companies, comparable to Vanuatu’s IBC framework.

Vanuatu’s 15% VAT applies to taxable supplies of goods and services, but financial services (including certain payment and intermediation activities) may qualify as exempt supplies under the VAT legislation. This could remove VAT exposure on core crypto intermediation fees. Confirm the VAT treatment of your specific activities with a Vanuatu tax adviser before structuring revenue flows.

You must submit regular financial, operational, and technology documentation to the VFSC. These filings are how the regulator monitors whether you remain solvent, compliant, and operationally sound. Late filings carry a penalty of VT 100,000 per day for each overdue report.

• Annual audited financial statements — due within 3 months after the end of each financial year. The auditor must have more than 5 years’ experience in the VASP sector and be approved by the VFSC Commissioner. Self-certification and auditors without demonstrated VASP expertise are not accepted.
• Annual technology (DLT) audit — a separate annual audit of your technological infrastructure by an independent DLT auditor, covering smart contract integrity, protocol scalability, interoperability, and code security. This is required from the first year of the license and runs alongside the financial audit.
• Quarterly report — a single quarterly filing to the VFSC covering AML/CFT compliance, transaction activity, staffing, infrastructure status, and any material operational changes. This report confirms you continue to operate from your registered Vanuatu office with resident personnel in place.
• Annual renewal fee — the VASP license renewal fee is ~$420,000 USD per year (VT 50,000,000) for classes D/D.1/D.2/D.3, or ~$210,000 (VT 25,000,000) for class D.4, payable to the VFSC. Late payment triggers a penalty of 10% of the license fee per day of delay.

The reporting framework is set out in Sections 54–55 of the VASP Act and the VFSC VASP Application Guidelines (June 2025), Section 8. The VFSC Requirements (Jan 2026) provide additional supervisory guidance.

Beyond reporting, Vanuatu law requires you to maintain continuous compliance across AML/CFT, physical presence, personnel, and insurance. These are standing obligations, not one-time setup tasks (see full requirements for initial setup details).

• Transaction monitoring and STR reporting — you must operate real-time or post-event transaction monitoring and report suspicious activity to the Financial Intelligence Unit (FIU). Under the AML/CFT Act, suspicious transaction reports must be filed no later than 2 working days after a suspicion is formed.
• Physical office and resident personnel — you must maintain a staffed office in Vanuatu with at least three key personnel (manager, director, and CTO) residing in-country for at least 12 consecutive months on an ongoing basis throughout the life of the license.
• Key person change approval — any change to directors, managers, or other key persons requires prior VFSC approval before the change takes effect. Start the approval process well in advance, as it is not instant.
• Insurance — all VASP licensees (not only exchanges) must hold Professional Indemnity (PI) Insurance and Cybercrime Insurance. Both policies are a condition of license maintenance across all license classes.
• AML/CTF Compliance Officer — a designated Compliance Officer must remain in post at all times. Any vacancy is a compliance breach under the AML&CTF Act No. 13 of 2014.