Two jurisdictions that positioned themselves as regulated crypto hubs have entered a more demanding phase, with the Czech Republic completing its transition to the EU’s Markets in Crypto-Assets Regulation and Hong Kong maintaining a high operational bar under its virtual asset trading platform regime. The combined effect is that crypto service providers face higher capital requirements, tougher custody and governance standards, and longer approval timelines in both markets.
Czech Republic: from a CZK 1 trade licence to MiCA capital tiers. Before MiCA, Czech crypto firms operated under a general trade licence with capital as low as 1 CZK, roughly EUR 0.04, and only AML registration with the Financial Analytical Office was required. That regime ended on 1 July 2026, when the transition period expired and crypto-asset service provider authorisation moved fully under the Czech National Bank. Under MiCA, Class 1 services require at least EUR 50,000 in own funds; Class 2 services, which add custody and exchange services, require EUR 125,000; and Class 3 trading platform operators must hold EUR 150,000. The CNB now assesses governance, internal controls, AML procedures, outsourcing oversight, ICT resilience and client asset protection. The regulator said it had assessed 251 applications by 1 July 2026 and authorised only 11 CASPs. The total upfront cost of obtaining a Czech licence, including minimum capital, advisory fees, application fee and first-year compliance, is estimated at roughly EUR 218,000 to EUR 231,000.
Hong Kong: a securities-style standard for crypto exchanges. Hong Kong’s Securities and Futures Commission listed 13 licensed virtual asset trading platforms as of 26 August 2026, despite the regime being active since 1 June 2023. The latest licence was granted to NewBX Limited, operator of Bixin.com, on 18 May 2026. A centralised exchange serving Hong Kong generally needs approval under both the Anti-Money Laundering and Counter-Terrorist Financing Ordinance and the Securities and Futures Ordinance, with dual licensing recommended. Platforms must keep 98% of client virtual assets in cold storage and maintain an SFC-approved compensation arrangement covering at least 50% of cold-storage assets and 100% of hot or other storage assets. They also need at least two responsible officers, including one executive director and one ordinarily resident in Hong Kong, plus at least one with three years of direct industry experience. Minimum paid-up capital is HK$5 million, with liquid capital equal to the higher of HK$3 million or the regulatory calculation, and 12 months of operating expenses held in liquid assets in Hong Kong.
Compliance professionals stress that licensing is only the start. HashKey Exchange’s head of compliance, Samuel Lok, captured the distinction in a 2024 interview: “Obtaining a license and actually operating are two different domains.” The Czech and Hong Kong updates show that both jurisdictions are tightening market access while trying to preserve regulatory credibility. Hong Kong has expanded what licensed firms can do, including rules for regulated stablecoins after its Stablecoins Ordinance took effect on 1 August 2025, but it has not lowered the entry threshold.
