A Gibraltar DLT licence is Part 7 permission from the Gibraltar Financial Services Commission (GFSC) that lets a firm use distributed ledger technology to store or move other people's crypto. Gibraltar put this framework in place on 1 January 2018, which made it one of the first places in the world with a purpose-built crypto rulebook. If your business holds customer coins, runs an exchange, or moves crypto for clients, this is the permission you need to work from Gibraltar.
Key points:
- A Gibraltar DLT licence is GFSC permission to hold or move other people's crypto with distributed ledger technology.
- The application fee is a flat £45,000, and most applicants should plan for 9 to 18 months from first contact to approval.
- The licence covers Gibraltar only. It gives no passport into the EU or the UK.
| Fact | Detail |
|---|---|
| Regulator | Gibraltar Financial Services Commission (GFSC) |
| Law | Financial Services Act 2019; DLT and VAA Providers Regulations 2020 |
| Permissions | DLT provider (custody) and VAA provider (exchange and arranging, no custody) |
| Application fee | £45,000 flat |
| Timeline | No fixed timeline; adviser estimates run 9 to 18 months |
| EU/UK passport | None |
Who needs a DLT provider licence?
Any firm that uses distributed ledger technology to store or move value that belongs to someone else. That covers custodial wallets, exchanges that hold client funds, over-the-counter desks, and lending platforms that hold collateral. If you only build software and never touch client money, you probably fall outside the rules. The GFSC judges each business on its own facts, so start with a talk, not a form.
What changed on 27 October 2025?
Before that date, one DLT permission covered most crypto work. Since 27 October 2025, the work splits in two. If you hold client crypto, you need a DLT provider permission. If you only match buyers with sellers or arrange deals without holding their coins, you need a VAA provider permission instead. Same regulator, same £45,000 fee, different permission. Applying for the wrong one is the most common early mistake, and it can cost you months.
Read also: Revolut Wins Gibraltar Licence for 80 Million Customers — What's Next?
How do you apply for a DLT licence?
The GFSC runs a staged process. Here are the steps, in order:
- Early engagement with the GFSC (a few weeks). Talk first. It will tell you early if your model fits.
- Form a Gibraltar company and appoint fit-and-proper people (one to two months). Directors, a money-laundering reporting officer, and key staff, all vetted by the GFSC.
- Build the application pack (several months). A business plan, capital and wind-down planning, governance and risk frameworks, plus anti-money-laundering and Travel Rule controls. The Travel Rule forces firms to share sender and receiver details on crypto transfers.
- Assessment and presentations (up to nine months). The GFSC reviews the pack, asks questions, and holds presentations with your team. Its target is nine months across the first three stages.
- Grant, usually with conditions, then mobilisation (three to six months). You test your systems before going live.
All told, plan for 9 to 18 months. The GFSC publishes no fixed timeline, so any adviser who promises you a date is guessing.
How much does it cost?
The application fee is a flat £45,000, paid when you apply. Each year after that, you pay a £12,254 base fee, 0.1% of your trade activity capped at £92,700, a further £28,183, and a £4,017 anti-money-laundering supervision fee. VAA providers pay the same fees as DLT providers. The regulator's fee is the small part of the bill. Legal fees, staff, systems, and audit cost far more, and the GFSC will also want proof your firm can cover its risks if it stops trading.
One warning — older guides still quote a £2,000 assessment fee plus £10,000, £20,000, or £30,000 by complexity. That tiered schedule is out of date. The current Financial Services (Fees) Regulations charge one flat £45,000. Check the GFSC's current fee page before you plan your budget.
What the licence does not do
A Gibraltar licence covers Gibraltar only. It gives you no passport into the EU, and MiCA, the EU's crypto rulebook, does not apply in Gibraltar. It gives you no route into the UK either, and the UK's own crypto regime is due in October 2027. Gibraltar works as a base for international business, not as a back door into London or Brussels.
That limit is the point most people get wrong. Gibraltar is a small, focused regime, and its rules are ten principles applied in proportion to risk. The tenth, Market Integrity, was added in 2021. Since 26 March 2026, a DLT or VAA provider must also tell the GFSC at least 30 days before it pays a dividend. The framework is light on paper and heavy on judgement, which is why the GFSC vets people as hard as it vets paperwork.
Who already holds one?
eToro, Xapo, Bullish, and LMAX Digital all hold DLT licences. Bullish (GI) Limited has held one since November 2021, under licence number FSC1038FSA. Revolut's new crypto arm won DLT permission on 19 October 2026, and the Gibraltar government said it expected three DLT permissions to be issued that week alone. Before you trust any firm that claims a Gibraltar licence, check the GFSC's public register.
Is Gibraltar the right base for you?
My own read is that Gibraltar suits firms that want a clear rulebook and a regulator that picks up the phone, and that can live without EU or UK clients. It does not suit firms that need those markets, or firms that want a quick, cheap licence. If that sounds like you, read the GFSC's DLT guidance, check the current fee page, then talk to the GFSC before you spend on lawyers. Write down three baseline numbers before you start — your planned headcount in Gibraltar, your first-year budget, and the date you need to be live. Judge every adviser quote against those three numbers, and you will spot the ones that are guessing.
Read also: What Is Crypto Tokenization? A Beginner's Guide to Real-World Assets
Frequently asked questions
Do I need a licence if my exchange never holds client funds? Not a DLT licence. That is a VAA provider permission, which covers exchange and arranging work without custody. The fee is the same £45,000.
How long does it take? Plan for 9 to 18 months. The GFSC sets no fixed timeline.
Can I serve EU customers with a Gibraltar licence? No. There is no passport, and MiCA does not apply in Gibraltar.
Does the licence cover the UK? No. UK customers need a separate UK route, and the UK regime is due in October 2027.
— BitByLine News Desk
This post is for learning only. BitByLine only explains and teaches — this is not financial advice, and we never tell anyone to buy or sell crypto. Whether you buy or not is always your own decision and your own risk, so always do your own research first.
Read our full Disclaimer.
Sources: GibraltarPortal, GFSC, BuyBitcoinSmart, Bullish, Crypto Times.
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