Non-passporting licence routeVASP licence / registrationNo passporting

VASP Registration in India

India is a practical FIU-facing VASP licence and registration route for crypto businesses that need an India-market compliance posture, local substance and AML readiness, while accepting no passporting, high banking friction and activity-specific scope review.

Processing time
From 1 month
Service price
22 100 EUR
Required share capital
Not required
State fee
No state fee
Annual supervision fee
No annual fee
Banking difficulty
High
RegulatorFinancial Intelligence Unit
Market access
No passporting

India page is based on user-provided CSV facts and needs local legal review before client-facing reliance.

Regulatory status should be confirmed by local counsel before relying on this route.

What is the India VASP route?

India is positioned as a Financial Intelligence Unit-facing VASP licence and registration route. The commercial value is strongest for India-facing operating models that need an AML-compliant local posture, not for projects looking for international passporting or a low-risk offshore label.

VASP
Jurisdiction
India
Regulator
Financial Intelligence Unit
Regime
VASP
Legal basis
Regulator in the CSV snapshot: Financial Intelligence Unit.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

VASP activity scope in India

Treat India as an activity-specific route. Exchange, custody, brokerage, hosted wallet, advisory, transfer or payment-related features should be mapped before describing the project as covered by one generic VASP registration.

  • Exchange

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • Custody

    Conditional

    Custody may require separate review or additional controls.

  • Brokerage

    Conditional

    Brokerage or OTC activity typically fits within scope.

  • Wallet provider

    Conditional

    Exchange activity may require additional scope or separate licensing.

  • EU market

    Not covered

    EU passporting not available from this route.

  • Startups

    Conditional

    High setup complexity means significant budget is needed.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

India FIU operating model

The file should connect the Indian entity, local staff, physical office, audit readiness, customer geography, AML controls and activity scope into one operating model. A short processing estimate does not remove the need for a complete evidence pack.

  • Define the actual services, customer segments, fiat flows and token policy before application planning.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Prepare AML, sanctions, customer due diligence, transaction monitoring, outsourcing and recordkeeping materials.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Align the local office and staff plan with the risk profile of the proposed VASP activities.

    Operational control area that should be covered in the applicant's governance and compliance model.

  • Use the CSV processing estimate from 1 month as an application indicator, not as a promise that banking, PSP onboarding, audit setup and hiring will finish in the same period.

    Operational control area that should be covered in the applicant's governance and compliance model.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

India-facing registration vs passporting routes

India is useful when the business case is tied to the Indian market and FIU-facing compliance. It is a weaker choice for low-risk international passporting, EU access or projects that mainly need a high-reputation cross-border regulatory brand.

  • Regulatory reputation

    Onshore (this jurisdiction)

    Medium

    Offshore comparison

    Lower recognition

  • Banking access

    Onshore (this jurisdiction)

    Challenging

    Offshore comparison

    Often restricted

  • Compliance burden

    Onshore (this jurisdiction)

    High

    Offshore comparison

    Variable

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

When India VASP is not suitable

India is a poor fit where the objective is low-risk international passporting, minimal local substance, quick global PSP access or a broad claim that one permission covers every crypto service. It should also be treated as an ongoing compliance framework, not a one-off filing.

  • The project needs EU/EEA passporting or a pan-regional licence narrative.

  • The team cannot support local staff, physical office and audit requirements.

  • The operating model depends on low-friction banking or PSP onboarding.

  • The product includes staking, DeFi, lending, derivatives or securities-like features that have not been legally reviewed.

  • The team cannot maintain AML, sanctions, customer due diligence, transaction monitoring and recordkeeping controls after registration.

Consider instead

  • Malta (MiCA) MICAEU/EEA passporting and stronger regulatory reputation for European clients
  • Dubai (VARA) VASPHigher-reputation VASP route for UAE and MENA positioning
  • Canada (MSB) MSBRegistration-style route with stronger international familiarity

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Activity fit for this route

Review which crypto activities fit within the scope of this route.

Exchange
Conditional

Exchange activity may require additional scope or separate licensing.

Custody
Conditional

Custody may require separate review or additional controls.

Brokerage
Conditional

Brokerage or OTC activity typically fits within scope.

Wallet provider
Conditional

Exchange activity may require additional scope or separate licensing.

EU market
Not suitable

EU passporting not available from this route.

Startups
Conditional

High setup complexity means significant budget is needed.

Not sure if your model fits? Request a licensing assessment

Business model fit — India

Assess how well this route covers your planned activities.

Fit score

Good fit
0/6
Partial fit
6/6
Poor fit
0/6

India may not cover your primary activities

Consider an alternative route that better matches your activity profile.

Is India VASP authorisation right for your project?

Best for

  • India-facing FIU registration models

Not suitable for

  • Low-risk international passporting strategy
  • Projects without a prepared banking strategy

Banking difficulty is high for this route. Prepare a banking strategy before committing to the India route.

Core requirements

Use this section to check the main regulatory and operational requirements before committing to a jurisdiction.

Required share capitalNot required
Not required
Local staffRequired
Required
Physical officeRequired
Required
AuditRequired
Required

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Local staff, office and audit substance

India is not a no-substance route. The CSV snapshot lists local staff, physical office and audit as required, while share capital is marked as not required. That profile suits teams ready to operate locally, not shell-company setups.

Local staff

Required

Required

At least one locally-accountable staff member or director is expected.

Physical office

Required

Required

A genuine office presence is expected, not a nominal registered address.

Audit

Required

Required

External audit is required for ongoing supervision compliance.

Planning notes

  • Plan local staff responsibilities for compliance, operations and management oversight.
  • Prepare a physical office setup that supports the activity scope and FIU-facing controls.
  • Include audit readiness and recordkeeping in the launch budget, even where no state fee or annual fee is listed.
  • Service price in the CSV snapshot is 22 100 EUR; budget separately for local staff, office, audit, policies, compliance operations, banking preparation and legal review.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Service price (professional fees)Application preparation and professional services.
22 100 EUR EURFixed
State fee
No state feeFrom
Annual supervision feeRecurring annual cost after authorisation.
No annual feeNot applicable
Required share capitalMust be held, not an expenditure.
Not requiredNot applicable
Medium ongoing cost

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Cost breakdown — India

Budget for service price, regulatory fees, share capital and ongoing costs separately.

Cost itemAmount
Service priceApplication preparation and professional services.€22,100

Summary

One-off costs
€22,100
Annual (year 1)
€0
Total year 1
€22,100

Adjust to convert to your base currency.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Application process

The sequence below shows the usual project flow. Exact steps depend on the regulator, business model and application scope. India — From 1 month.

Total timelineFrom 1 month
  1. Pre-assessment and scope review

    1–3 weeks

    Define the activity scope, governance model and target markets before formal preparation.

  2. Company setup in India

    2–6 weeks

    Establish legal entity, appoint local staff and set up local operating structure.

  3. Documentation and compliance packBottleneck risk

    3–8 weeks

    Prepare AML/CFT policies, governance documents, controls framework and application materials.

  4. Application submission to Financial Intelligence Unit

    1–2 weeks

    Submit complete application with all required documentation.

  5. Regulator reviewBottleneck risk

    From 1 month

    Regulator reviews the application. May request clarifications. Incomplete files extend this phase.

    Depends on: File quality and completeness

  6. Authorisation or registration confirmation

    1–4 weeks

    Regulator confirms authorisation or registration. Commence operations.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

What can delay or increase cost

These factors are most likely to affect timelines and budgets for this route.

Banking difficulty
High

Banking difficulty is rated high. Opening accounts for crypto businesses in India requires extensive documentation.

Likely impactBanking can delay or block operations for 3–6 months after authorisation.
MitigationIdentify and pre-qualify banking partners before submitting the application.
Regulatory risk
High

Regulatory risk is rated high. Enforcement focus and compliance expectations are above average for India.

Likely impactAdditional review rounds, requests for evidence, or timeline extension.
MitigationPrepare an evidence-based compliance file. Engage local counsel early.
Application completeness
Medium

Incomplete files are the most common cause of delay. Regulator queries extend review by weeks or months.

Likely impactEach regulator query adds 2–6 weeks to the review phase.
MitigationUse a structured compliance pack. Review file completeness before submission.

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Banking and PSP risk in India

Banking is marked high difficulty and PSP availability is low to medium. An FIU-facing registration file can support counterparty discussions, but banks and payment providers will still challenge crypto activity scope, fiat flows, client geography and AML controls.

Banking difficulty
High

Reflects how challenging it is to open and maintain business bank accounts in this jurisdiction.

Medium PSP availability
Medium

Reflects availability of payment service providers willing to onboard crypto-licensed entities.

A licence or registration does not guarantee bank account or payment provider approval. Banking feasibility should be reviewed before the application strategy is finalized.

Preparation checklist

  • Do not treat FIU registration as a bank account or PSP onboarding guarantee.
  • Prepare a banking pack covering source of funds, sanctions exposure, transaction monitoring, token policy and fiat flow diagrams.
  • Consider alternative jurisdictions if the commercial model depends on quick, low-friction international PSP access.

Compliance documentation

Most crypto licensing routes require a documented compliance framework before submission, not only after approval.

  • Required
    AML/CFT policy and risk assessmentDocument your customer risk model and control framework.
  • Required
    Customer due diligence (CDD) procedures
  • Required
    Enhanced due diligence (EDD) proceduresFor high-risk clients and jurisdictions.
  • Required
    Transaction monitoring system and rules
  • Required
    Sanctions screening procedures
  • Required
    Suspicious activity reporting (SAR) process
  • Required
    MLRO / Compliance officer appointmentLocal accountability may be required.
  • Recommended
    Board-approved governance charter
  • Conditional
    Outsourcing policy and monitoringRequired if functions are outsourced.
  • Recommended
    ICT / cybersecurity policy
  • Required
    Complaints handling procedure
  • Required
    Annual external audit engagementRequired for ongoing supervision compliance.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Documents to prepare

Preparing these materials before filing reduces regulator questions and helps with banking or payment provider onboarding.

0 / 11 required
Required
Recommended
Depends on scope

Corporate documents

AML and compliance

Operational

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

Regulator profile

Regulatory authority · India

Financial Intelligence Unit

Official regulator website
Regulatory reputation
Medium

Moderate reputation; assess banking and partner acceptance case by case.

Setup complexity
Medium

Reflects documentation depth, governance requirements and expected review friction.

Regulatory risk
High

Reflects likelihood of delays, additional information requests or policy uncertainty.

Country-specific regulatory statements should be checked against current regulator guidance before relying on this route.

Risk assessment

Main risk dimensions for the India route.

Regulatory risk
High

Route risk rating — regulatory risk: High. Weak compliance, vague scope or insufficient controls increase review risk.

Mitigation: Prepare an evidence-based compliance file before submission.

Banking difficulty
High

Route risk rating — banking difficulty: High. Authorisation does not guarantee bank account opening.

Mitigation: Start banking outreach and compliance preparation before the application.

Setup complexity
Medium

Route risk rating — setup complexity: Medium.

Maintenance cost
Medium

Route risk rating — maintenance cost: Medium. Budget for ongoing compliance, fees and supervision separately.

Regulatory reputation
Medium

Route risk rating — regulatory reputation: Medium.

This content is for general orientation only. Crypto regulation changes quickly and the final scope should be confirmed through a jurisdiction-specific legal review before filing or incorporation.

India vs other crypto licence routes

Use India when the target model is India-facing FIU registration. Compare Malta for EU passporting, Dubai for UAE/MENA VASP positioning and Canada MSB for a faster registration-style route with a different regulatory perimeter.

Current

India

VASP

Price
22 100 EUR
Timeline
From 1 month
Passporting
No passporting
Banking
High
Reputation
Medium

Malta (MiCA)

MICA

Price
20 700 EUR
Timeline
From 6 months
Passporting
EU/EEA
Banking
Medium
Reputation
High

+ EU/EEA passporting and stronger regulatory reputation for European clients

Longer authorisation path and EU substance requirements

View route

Dubai (VARA)

VASP

Price
22 300 EUR
Timeline
From 6 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Higher-reputation VASP route for UAE and MENA positioning

Higher local substance and supervision cost than India

View route

Canada (MSB)

MSB

Price
20 600 EUR
Timeline
From 2 months
Passporting
No passporting
Banking
Medium
Reputation
High

+ Registration-style route with stronger international familiarity

Not a broad crypto licence and no India market positioning

View route

Fees, timelines and capital figures are indicative and may vary by business model, regulator feedback, application scope and third-party costs.

India vs other VASP jurisdictions

Compare key parameters across VASP-regulated jurisdictions.

Sort by:

Check your readiness for India VASP authorisation

Documented AML/CFT policies, risk assessment, compliance officer.

AML/CFT framework

Documented AML/CFT policies, risk assessment, compliance officer.

Governance structure

Board, management, accountability chain defined.

Banking preparation

Banking strategy and identified partners.

Local substance plan

Local staff and office in India.

Readiness status

Answer the criteria on the left to see your readiness status.

Frequently asked questions

No. The scope should be mapped activity by activity. Exchange, custody, wallet, brokerage, advisory, payment, staking, DeFi and securities-like models can create different compliance and legal issues.

Usually no. India is better for India-facing FIU registration models with local staff, office and audit readiness. It is not positioned as a low-substance offshore shortcut.

No. The CSV snapshot marks passporting as no. EU/EEA access should be assessed through MiCA/CASP or another relevant jurisdictional route.

Prepare the activity map, Indian operating model, local staff and office plan, audit readiness, AML and sanctions controls, transaction monitoring, token policy, customer geography and banking or PSP package.

The CSV snapshot marks banking difficulty as high and PSP availability as low to medium. FIU registration can support the file, but it does not guarantee bank or PSP onboarding.

The page is not legal advice and should not be relied on as a substitute for advice from qualified counsel in the relevant jurisdiction.

Your dedicated specialists

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    Enrico

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    Andrej

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    Marta

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    Katrin

  • Inga Stankavičiūtė

    Inga

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