Meet Dr. Marcus Hartmann
Dr. Marcus Hartmann has spent over two decades at the intersection of financial law and emerging technology. Based in Zug, Switzerland's Crypto Valley, he has guided exchanges, custodians, and institutional investors through the full VASP and CASP licensing journey, where managing the timeline is often the difference between a launch on schedule and one that slips by quarters.
He has run licensing projects under MiCA, the New York BitLicense, the Singapore MAS regime, and FATF-aligned frameworks across the Gulf and Asia, and advises founders on jurisdiction selection where review speed, banking access, and market credibility have to be balanced across more than 60 jurisdictions.
Most crypto licenses take six to twelve months end to end, covering preparation, submission, regulator review, and post-license setup. The formal review clock is shorter, roughly three months under MiCA, but it only starts once your application is complete. Fast jurisdictions like Lithuania clear in three to six months; the New York BitLicense can take eighteen to twenty-four months or more.
- End to end, plan for six to twelve months for most crypto licenses, with preparation usually the longest stage and the one you control
- Under MiCA Article 63 the statutory clock is 25 working days for completeness plus 40 working days for assessment, about three months once your file is complete
- Fast tier: Lithuania three to six months, Poland and the Czech Republic four to eight months, assuming a complete application
- Slow tier: Singapore six to eighteen months, Hong Kong nine to eighteen months, New York BitLicense twelve to twenty-four months or more
- The biggest delay is almost always an incomplete or generic application, not the regulator's processing speed
How Long It Really Takes
The honest answer is that there are two timelines, and confusing them is the most common planning mistake we see. The first is the statutory review clock, the period the regulator has to assess a complete file. The second is the end-to-end timeline, the full elapsed time from the day you decide to apply to the day you can legally operate. For most crypto licenses, that end-to-end figure is six to twelve months.
The review clock is usually far shorter than the end-to-end figure. Under MiCA, the EU framework, it is roughly three months once your application is complete. But complete is the operative word. Before the clock even starts you must form the entity, arrange capital, write your anti-money-laundering and know-your-customer policies, appoint fit-and-proper directors and a compliance officer, and assemble a stack of supporting evidence. That preparation routinely takes longer than the review itself.
Timelines also vary enormously by jurisdiction and by how complex your business is. A simple wallet or brokerage clears faster than a full exchange, a custodian, or a stablecoin issuer. If your priority is speed, our companion guide on the fastest crypto licenses ranks the quickest routes, while the broader how to get a crypto license walkthrough covers the full application step by step.
Sources: MiCA Article 63 statutory timeline; Bank of Lithuania CASP authorisation; MAS licensing guidance; NYDFS BitLicense practice. Figures are indicative ranges for well-prepared applicants.
The Five Stages of a Crypto License
Every crypto license, in every jurisdiction, follows the same five-stage shape. The detail and the legal labels change, but the sequence does not. Understanding where the time actually goes lets you plan realistically and avoid the trap of budgeting only for the part the regulator controls. The infographic below maps the stages and shows where the calendar usually expands.
"Founders ask how long the regulator takes, but that is the wrong question. The regulator's clock is fixed and short. What varies is how long it takes the applicant to hand over a file the regulator can actually approve. We have seen identical business models clear in four months in one case and stall for over a year in another, purely because of the quality of the application."
Dr. Marcus Hartmann, Senior Licensing Advisor
The MiCA 25 plus 40 Working-Day Rule
For any EU crypto-asset service provider, the review clock is set out in Article 63 of MiCA, the Markets in Crypto-Assets Regulation. It has two distinct phases. First, the national competent authority has 25 working days from receiving your application to check whether it is complete. If anything is missing, the regulator tells you and you supply it. Second, once the file is complete, the authority has 40 working days to assess it fully and issue a reasoned decision granting or refusing authorisation.
Added together, 25 plus 40 working days is roughly three months of regulator time. That figure is what a lot of marketing material quotes when it suggests a MiCA license takes only a couple of months. It is technically true and practically misleading, because the clock only runs against a complete application, and reaching completeness is the part that takes most of the calendar.
There is also a pause mechanism. If the regulator requests further information during the 40-day assessment, the clock can be suspended while you respond, up to a maximum of 20 working days. Every query you trigger therefore extends the review. This is precisely why the quality of your initial submission matters so much: a thin or generic file generates rounds of questions that each add weeks. The same MiCA timeline applies in every EU member state, so the differences between, say, Lithuania and Germany come down to regulator workload and how each authority handles its queue, not the headline statutory numbers.
Crypto License Timeline by Jurisdiction
The table below compares realistic end-to-end timelines against the statutory or pledged review period for the major crypto-licensing regimes in 2026. End-to-end figures assume a well-prepared applicant and a reasonably standard business model. More complex operations, custody, stablecoins, or full exchanges, sit at the upper end of every range. You can explore each route in depth through our crypto licenses hub.
| Jurisdiction | Typical End-to-End | Statutory / Pledged Review |
|---|---|---|
| Lithuania (CASP) | 3–6 months | MiCA: 25 + 40 working days |
| Czech Republic (CASP) | 3–6 months | MiCA: 25 + 40 working days |
| Poland (CASP) | 4–8 months | MiCA: 25 + 40 working days |
| EU average (CASP) | 6–12 months | MiCA: 25 + 40 working days |
| Singapore (MAS) | 6–18 months | No fixed clock; 6–18 mo processing |
| Hong Kong (SFC VATP) | 9–18 months | Pledge: up to 15 weeks processing |
| New York (BitLicense) | 12–24+ months | No statutory deadline |
Indicative ranges for well-prepared applicants in 2026. Statutory review periods cover only the regulator's processing time, not preparation or post-license setup. Sources listed below.
Read the two columns together: a short statutory review does not guarantee a short project. Hong Kong pledges fifteen weeks of processing, yet end-to-end VATP licensing still runs nine to eighteen months once you add system build-out and the external assessment. Always plan around the end-to-end column, not the review clock.
Want a realistic timeline for your specific model and market? Get a free 30-minute consultation. We will map the stages, the statutory clock, and the likely end-to-end date for your chosen jurisdiction.
Get Free Consultation →The Fast Jurisdictions
Inside the EU, the fastest crypto licenses tend to come from authorities with a streamlined queue and a track record of processing crypto applications efficiently. Lithuania is the standout. The Bank of Lithuania frequently completes CASP review in three to six months, and a well-documented file can move through in as little as three to four months in total. That speed, combined with EU passporting once authorised, makes it a popular first port of call.
Poland and the Czech Republic sit just behind, typically in the four to eight-month range for a mid-sized exchange with complete documentation. It is worth noting that national implementation of MiCA has progressed at different speeds across the bloc, so the practical availability and queue length in any given member state can shift from quarter to quarter. We track these moving parts so clients pick a jurisdiction that is genuinely open and fast at the moment they apply, not one that was fast last year.
Across all of these EU routes the same MiCA statutory clock applies. The speed advantage comes from regulator workload, local processing efficiency, and how quickly the authority turns around its queries, not from a shorter legal deadline. You can read more on the specifics in our Lithuania crypto license overview, which sets out capital, requirements, and the realistic calendar in detail.
The Slow Jurisdictions
At the other end of the spectrum sit regimes prized for credibility and market access but known for long, demanding reviews. The New York BitLicense, issued by the NYDFS, is the clearest example. There is no statutory deadline at all. Simple exchange or wallet models average twelve to eighteen months, while complex custody or stablecoin businesses can take twenty-four months or more. Historically, some applicants waited three to four years for approval, a reflection of the depth of scrutiny applied to governance, capital, and AML controls.
Singapore is similarly thorough. A well-prepared applicant should plan for six to nine months from start to grant, but the processing stage alone runs six to twelve months for standard payment institutions and nine to eighteen months for major payment institutions. The Monetary Authority of Singapore tests fit-and-proper status, governance, capital, AML, custody, and technology-risk controls in detail, and admits only applicants who can evidence all of it.
Hong Kong rounds out the slow tier. The SFC's performance pledge is to process applications in up to fifteen weeks, but the real-world Virtual Asset Trading Platform timeline runs far longer, typically nine to eighteen months once system build-out and the external assessment are included. Since January 2025 the SFC has expedited the process with a single external assessment in place of the earlier two-phase report, which trims, but does not eliminate, the front-loaded compliance work.
Across our licensing work in more than 60 jurisdictions, the single biggest cause of a blown timeline is not the regulator. It is an application that looks complete on the surface but cannot withstand the first round of substantive questions. Generic AML policies, capital that is committed but not yet evidenced, and key personnel whose fit-and-proper documentation is thin will each trigger queries that add weeks, and under MiCA can suspend the clock for up to twenty working days at a time.
We also see founders pick a jurisdiction purely for speed and then lose all of that saved time at the post-license stage, when banking partners and counterparties hesitate over a lesser-known regulator. The most reliable way to hit a target launch date is to invest in the preparation phase, build the file alongside the AML and KYC framework rather than after it, and choose a jurisdiction whose review speed and market standing both fit the business.
How to Shorten the Timeline
Because the review clock is largely fixed, almost all of the time you can save sits in your own hands. The most effective lever is submitting a complete, well-evidenced file the first time. Regulators slow down predictably when policies are generic, when capital is asserted rather than proven, and when key personnel are not properly documented. Closing those gaps before submission prevents the rounds of queries that otherwise stretch the review out by months.
Choosing the right jurisdiction is the second lever. A faster authority with a shorter queue can save you several months over a slower one for the same business model, provided the faster route still gives you the banking access and market credibility you need. Engaging advisors early, and where possible pre-clearing your business model with the regulator, lets you fix problems on paper rather than mid-review.
Finally, match the jurisdiction to your business complexity. A simple wallet or brokerage will clear faster almost everywhere, so if speed is the priority, keep the initial scope tight and expand once you are authorised. When you are ready to map a realistic calendar for your specific case, get in touch with our team and we will set out the stages and the likely end-to-end date for each option on your shortlist.
Crypto License Timelines: Common Questions
Sources & Official References
- EUR-Lex: Regulation (EU) 2023/1114 (MiCA), Article 63 authorisation procedure and timelines
- ESMA: Markets in Crypto-Assets Regulation (MiCA) overview
- Bank of Lithuania: Authorisation of crypto-asset service providers
- MAS: Guidelines on Licensing for Digital Token Service Providers
- SFC Hong Kong: Virtual asset trading platform operators and licensing
- NYDFS: Virtual Currency Business Activity (BitLicense)
- VARA: Dubai Virtual Assets Regulatory Authority (cross-reference)