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DAB License in Bermuda

Establish your crypto, FinTech, exchange, custody, payment or digital asset business in Bermuda under the Digital Asset Business Act 2018 (DABA). Manimama will determine the appropriate Class T, Class M or Class F License, structure your Bermuda company and guide you through the complete BMA licensing process.

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A Bermuda DAB License is issued by the Bermuda Monetary Authority (BMA) and provides a regulated framework for conducting approved digital asset business activities in or from Bermuda. The appropriate license class depends on the maturity, scale and operational readiness of the business.

Key regulatory highlights of obtaining a DAB License in Bermuda

Bermuda operates a dedicated digital asset licensing regime under DABA. Businesses can enter the framework through Class T, Class M or Class F, depending on whether the project is testing its model, developing operations or preparing for full-scale regulated activity.

Primary regulator

The licensing and supervision of digital asset businesses is carried out by the Bermuda Monetary Authority (BMA).

Legal framework

Digital asset businesses are primarily regulated under the Digital Asset Business Act 2018 and related BMA rules, codes and guidance.

License classes

Bermuda provides three principal license classes: Class T, Class M and Class F.

Minimum net assets

The minimum starts from USD 10,000 for Class T, USD 100,000 for Class M, and USD 100,000+ for Class F.

Application filing fees

The filing fee is USD 1,000 for Class T and USD 2,266 for Class M or Class F.

Local presence

A licensed company other than a Class T licensee is generally required to maintain its head office in Bermuda.

Key personnel

The structure generally includes directors, a Compliance Officer, MLRO and senior representative, with controllers and officers subject to fit-and-proper requirements.

Licensing timeline

A practical licensing estimate is approximately 3–8 months, depending on the license class and application complexity.

Digital asset activities

The framework covers exchanges, payments, custody, digital asset issuance, trust services, derivatives, lending and other regulated digital asset services.

Tax framework

Bermuda does not impose VAT or generally impose capital gains tax, although Corporate Income Tax may apply to certain in-scope multinational enterprise groups.

Why crypto, FinTech and digital asset businesses choose Bermuda

Bermuda combines dedicated digital asset legislation, specialised financial supervision and a tiered licensing framework that can accommodate businesses at different stages of development.

DAB licensees operate within a formal regulatory framework supervised by the BMA.

Class T, M and F allow businesses to select a regulatory pathway that reflects their development stage, scale and risk profile.

Bermuda regulates digital asset businesses through a specific legal framework rather than relying solely on traditional financial services rules.

Bermuda is an established international financial centre supporting businesses operating across international markets.

Class T and Class M can provide a regulated route for testing, developing or scaling innovative digital asset business models.

The framework can accommodate exchanges, custody businesses, payment providers, token businesses, digital asset services, derivatives and lending models.

What activities can be covered by a Bermuda DAB License?

A DAB License covers only the digital asset activities approved by the BMA. The regulatory scope therefore needs to reflect the actual services, transaction flows and role of the company.

Issuing, selling or redeeming virtual coins, tokens or other forms of digital assets.

Providing payment or fund transfer services using digital assets.

Operating an electronic marketplace for digital asset issuance, distribution, conversion or trading.

Acting as fiduciary, agent or trustee in relation to the administration or management of digital assets.

Storing or maintaining digital assets or digital asset wallets on behalf of customers.

Operating a platform for digital asset derivatives, including related clearing and settlement activities.

Conducting transactions on behalf of others, exercising authority over digital assets, market making or providing specified benchmark services.

Facilitating digital asset lending or repurchase transactions as principal or agent.

Who regulates digital asset businesses in Bermuda?

The Bermuda Monetary Authority is the principal regulator responsible for licensing and supervising digital asset businesses operating in or from Bermuda.

Bermuda Monetary Authority — BMA

The BMA assesses DAB applications, grants licenses and supervises licensed digital asset businesses.

Digital Asset Business Act 2018 — DABA

DABA establishes the principal licensing framework for regulated digital asset businesses.

Digital Asset Issuance Act 2020 — DAIA

Certain digital asset issuance activities may also fall under DAIA and the related issuance rules.

Proceeds of Crime Act 1997

Provides part of Bermuda's statutory framework for preventing money laundering.

Anti-Terrorism (Financial and Other Measures) Act 2004

Establishes requirements relevant to counter-terrorist financing.

AML/ATF Regulations 2008

Licensed businesses must comply with applicable anti-money laundering and anti-terrorist financing regulations.

BMA rules, codes and guidance

Licensees must comply with applicable rules, codes of practice, guidance and supervisory expectations issued by the BMA.

Sanctions requirements

Digital asset businesses must also maintain systems capable of complying with applicable international sanctions requirements in Bermuda.

Who may need a DAB License in Bermuda?

A DAB License may be required where a business carries on regulated digital asset activities in or from Bermuda. The requirement depends on what the company actually does rather than simply whether it identifies itself as a crypto or blockchain company.

Digital asset exchanges

Platforms facilitating digital asset issuance, distribution, conversion or trading.

Custody and wallet providers

Businesses safeguarding digital assets or maintaining wallets on behalf of customers.

Digital asset payment providers

Businesses providing payments or fund transfer services using digital assets.

Token and digital asset businesses

Companies issuing, selling or redeeming digital assets where DABA applies.

Digital asset service providers

Businesses executing transactions for clients, exercising authority over assets or acting as market makers.

Digital asset trust providers

Businesses managing or administering digital assets in a fiduciary, trustee or agency capacity.

Digital asset derivatives businesses

Businesses operating exchanges for digital asset derivatives.

Digital asset lending businesses

Companies facilitating digital asset lending or repurchase transactions.

How Manimama supports Bermuda DAB License applicants

Manimama provides end-to-end legal, regulatory and compliance support for businesses establishing a digital asset company and applying for a DAB License in Bermuda.

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Business model assessment

We analyse the services, transaction flows, digital assets and customer relationships to determine whether DABA applies.

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License class assessment

We determine whether Class T, Class M or Class F is the appropriate route for the proposed business.

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Bermuda company formation

We assist with corporate establishment and preparation of the required Bermuda company documentation.

Regulatory documentation

We prepare the business plan, AML/ATF framework and other policies and procedures required for licensing.

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Key personnel and governance support

We assist with structuring directors, controllers, compliance functions and other relevant personnel.

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DAB License application

We prepare and coordinate submission of the licensing package to the BMA.

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BMA communication

We assist with regulatory questions, clarification requests and additional documentation during the review.

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Operational and post-licensing support

We can assist with banking preparation, KYC/KYB integrations, audit arrangements, reporting and ongoing compliance.

How Manimama guides you through the Bermuda DAB licensing process

We follow a structured process from initial regulatory assessment to company formation, documentation, BMA licensing and ongoing regulatory support.

Initial consultation

We review your business model, intended services, transaction flows, target markets and client structure.

Licensing roadmap

We prepare a roadmap covering incorporation, personnel, documentation and regulatory requirements.

Regulatory documentation

We prepare the business plan, AML/ATF framework, governance documentation, cybersecurity policies and internal procedures.

BMA review and licensing decision

We coordinate responses to regulator questions and support the project through the formal BMA assessment.

Regulatory assessment

We determine whether DABA applies and identify the appropriate license class and regulated activities.

Pre-registration and company setup

Where applicable, we support the BMA non-objection stage and establish the Bermuda corporate structure.

DAB License application

The appropriate Class T, M or F application is prepared and submitted to the BMA.

Post-licensing support

After authorization, we assist with regulatory reporting, compliance updates and ongoing obligations.

Start Your Bermuda DAB License Process Today

Receive complete legal and regulatory support for your Bermuda digital asset business — from business model assessment and company formation to regulatory documentation, BMA communication and post-licensing compliance.

Manimama helps crypto exchanges, custody providers, payment businesses, token projects, digital asset service providers, derivatives platforms, trust businesses and lending projects build a licensing-ready Bermuda structure and navigate the BMA regulatory process.

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Bermuda DAB License Requirements & Application Roadmap

Understand the key business models, company requirements, personnel obligations, capital, documents, timelines, tax rules, and practical risks before applying for a DAB License in Bermuda.

What business models are suitable for Bermuda?

Bermuda's DAB framework can accommodate a broad range of digital asset businesses. The appropriate license class depends on the maturity, scale and operational readiness of the project.

  • Digital asset exchanges

    Suitable for businesses facilitating digital asset issuances, distributions, conversions or trading.

  • Custody and wallet businesses

    Suitable for companies safeguarding digital assets or maintaining customer wallets.

  • Digital asset payment businesses

    For businesses using digital assets for payments and fund transfers.

  • Token and digital asset issuers

    For businesses issuing, selling or redeeming digital assets, subject to determining whether DABA, DAIA or another framework applies.

  • Digital asset service providers

    For businesses executing transactions for clients, acting as market makers or providing other regulated digital asset services.

  • Digital asset derivatives businesses

    For platforms operating digital asset derivative exchanges.

  • Digital asset trust service providers

    For businesses administering or managing digital assets as fiduciary, agent or trustee.

  • Digital asset lending businesses

    For businesses facilitating digital asset lending or repurchase transactions.

What company structure and local presence are required for a Bermuda DAB License?

A DAB applicant must establish a corporate, governance and operational structure capable of satisfying the BMA's regulatory requirements.

  • Bermuda company

    The DAB application is generally structured through an appropriate Bermuda corporate entity.

  • Shareholder

    At least 1 shareholder is required.

  • Directors

    The company must have at least 2 directors.

  • Fit-and-proper persons

    Controllers and officers must satisfy applicable BMA fit-and-proper requirements.

  • Governance framework

    Governance arrangements must be proportionate to the nature, size, complexity and risk profile of the business.

  • Head office in Bermuda

    A licensed company other than a Class T licensee is generally required to maintain its head office in Bermuda.

  • Compliance Officer

    The business must appoint an appropriate Compliance Officer.

  • Money Laundering Reporting Officer

    An MLRO must be appointed to perform the relevant AML/ATF responsibilities.

  • Combined Compliance Officer / MLRO role

    The two functions may be performed by the same individual where permitted and appropriate.

  • Senior representative

    The company must appoint a senior representative in accordance with the applicable Bermuda requirements.

What personnel and compliance functions are required for a Bermuda DAB License?

The BMA expects a licensed digital asset business to maintain qualified management, effective compliance functions and internal controls proportionate to its activities and risk profile.

  • Qualified directors

    At least two directors must form part of the company structure.

  • Fit-and-proper controllers and officers

    Relevant persons must demonstrate appropriate competence, integrity and suitability.

  • Compliance Officer

    A Compliance Officer must oversee compliance with applicable regulatory requirements.

  • MLRO

    The company must appoint an MLRO responsible for relevant AML/ATF reporting functions.

  • Combined compliance roles

    Compliance Officer and MLRO responsibilities may be combined where permitted and appropriate.

  • Senior representative

    The company must maintain the required senior representative function.

  • Governance framework

    Governance arrangements must correspond to the scale, complexity and risks of the licensed business.

  • AML/ATF framework

    The company must maintain appropriate AML/ATF policies, procedures, systems and controls.

  • Customer due diligence

    The compliance framework should address customer identification, beneficial ownership and risk-based due diligence.

  • Sanctions compliance

    Internal procedures must enable the business to comply with applicable sanctions requirements.

  • Cybersecurity controls

    The applicant must establish cybersecurity arrangements appropriate to the technology and services it operates.

  • Regulatory reporting and supervision

    Licensed companies remain subject to BMA supervision and applicable regulatory reporting obligations.

What documents do you need for a DAB License in Bermuda?

The exact documentation depends on the selected license class, regulated activities, corporate structure and risk profile of the proposed business.

  • Application form

    The appropriate Class T, Class M or Class F application form.

  • Corporate and beneficial ownership documents

    Corporate establishment documents and information relating to ownership and beneficial owners.

  • Business Plan

    A detailed description of the proposed business, services, operations and commercial model.

  • Management and governance documentation

    Information regarding directors, management arrangements, governance and relevant key persons.

  • AML/ATF documentation

    Policies and procedures appropriate to the company's regulated activities and risk profile.

  • Cybersecurity documentation

    Policies demonstrating appropriate technology, information security and cyber risk controls.

  • Other internal policies

    Additional policies and procedures required for the proposed business and selected license class.

  • Evidence of application fee

    Evidence that the applicable BMA application filing fee has been paid. The BMA may request additional information or supporting documentation during its assessment.

What are the capital and official fee requirements for a Bermuda DAB License?

Bermuda applies different minimum net asset and fee requirements depending on the relevant license class.

  • No single financial threshold

    The applicable financial requirement depends on whether the business applies for Class T, M or F.

  • Class T minimum net assets

    Minimum net assets start from USD 10,000.

  • Class M minimum net assets

    Minimum net assets start from USD 100,000.

  • Class F minimum net assets

    Minimum net assets start from USD 100,000+, subject to applicable requirements.

  • Class T application fee

    The application filing fee is USD 1,000.

  • Class M application fee

    The application filing fee is USD 2,266.

  • Class F application fee

    The application filing fee is USD 2,266.

  • Annual licensing fees

    Class M and Class F are subject to the applicable BMA annual licensing fee structure.

  • Insurance requirements

    Class M and Class F licensees are generally subject to applicable insurance requirements.

  • Operational budget

    The total setup budget should also consider incorporation, legal support, personnel, Bermuda substance, compliance, cybersecurity, audit and other operational costs.

How does the Bermuda DAB licensing process work?

The process starts with defining the regulated activities and appropriate license class, followed by company establishment, documentation preparation, BMA submission and regulatory review.

  • Initial regulatory assessment

    The business model and digital asset activities are analysed to determine whether DABA applies.

  • License class selection

    The project is assessed for Class T, Class M or Class F based on its stage and operational model.

  • Pre-registration stage

    Where applicable, documentation required for incorporation and the BMA regulatory process is prepared.

  • Company incorporation

    The company name, corporate documents and beneficial ownership structure are prepared and the Bermuda company is established.

  • Application preparation

    The licensing package is prepared together with the business plan, management information, AML/ATF policies and cybersecurity documentation.

  • Application submission

    The relevant application and filing fee are submitted to the BMA.

  • BMA assessment

    The regulator reviews the application against the applicable minimum licensing criteria and may request additional information.

  • Licensing decision

    If the BMA is satisfied, the DAB License may be granted subject to any applicable conditions or restrictions.

How long does it take to obtain a Bermuda DAB License?

The licensing timeline depends on the license class, business complexity, operational maturity, completeness of the application and the extent of additional information requested by the BMA. A practical estimate is approximately 3–8 months.

  • Regulatory assessment

    The first stage is determining whether DABA applies and selecting the correct license class.

  • Corporate structuring

    The Bermuda entity, ownership structure, governance and personnel arrangements must be established.

  • Documentation preparation

    The applicant prepares the business plan, AML/ATF documentation, cybersecurity framework and other policies.

  • Application submission

    The complete Class T, M or F application is submitted to the BMA.

  • BMA regulatory review

    The Authority reviews the application against the relevant minimum licensing criteria.

  • Additional information requests

    The BMA may ask for explanations, amendments or supplementary supporting documentation.

  • Licensing decision

    The final decision is made after the Authority completes its assessment. Practical overall estimate — around 3–8 months. The actual duration depends on the complexity, maturity and readiness of the applicant.

What tax and ongoing obligations apply after obtaining a Bermuda DAB License?

A DAB License creates continuing regulatory obligations. The company must maintain the governance, compliance, financial and operational arrangements applicable to its license and business model.

  • Corporate Income Tax

    Bermuda Corporate Income Tax may apply to Bermuda entities forming part of certain in-scope multinational enterprise groups.

  • Capital gains tax

    Bermuda generally does not impose capital gains tax.

  • VAT

    Bermuda does not impose VAT.

  • Governance requirements

    The licensed company must continue maintaining governance arrangements appropriate to its activities.

  • AML/ATF compliance

    AML/ATF policies, procedures, systems and controls must remain operational and up to date.

  • Regulatory reporting

    Depending on the license class, the company may need to submit financial, compliance and other regulatory information to the BMA.

  • Minimum net assets and financial resources

    The company must continue satisfying applicable financial requirements.

  • Insurance

    Applicable insurance requirements must be maintained, particularly for relevant Class M and Class F businesses.

  • Cybersecurity

    Cybersecurity controls must remain appropriate to the company's operations and BMA requirements.

  • Internal policies and controls

    Compliance, governance, risk and operational procedures need to remain aligned with the actual business.

  • Ongoing BMA supervision

    Licensed digital asset businesses remain subject to regulatory supervision after authorization.

  • Bermuda operational presence

    Where applicable, the company must continue maintaining its required Bermuda head office and operational substance.

What should businesses consider before applying for a Bermuda DAB License?

Bermuda provides a clear digital asset framework, but obtaining a DAB License requires a licensing-ready corporate, compliance and operational structure rather than only establishing a legal entity.

  • The correct license class must be selected

    Class T, M and F are intended for different development stages and operating models.

  • License scope is activity-specific

    Each regulated activity should be identified and reflected correctly in the application.

  • Local substance may be required

    Class M and Class F businesses are generally expected to maintain an appropriate Bermuda presence.

  • Fit-and-proper assessment

    Controllers and officers must satisfy BMA suitability requirements.

  • AML/ATF compliance burden

    Applicants need a functioning AML/ATF framework proportionate to their customer and transaction risks.

  • Cybersecurity requirements

    Technology-dependent businesses must demonstrate appropriate cyber and information security controls.

  • Financial and insurance requirements

    Minimum net assets and applicable insurance requirements must be considered before applying.

  • Regulatory supervision continues after licensing

    A DAB License creates ongoing obligations and BMA supervision.

  • Banking is not guaranteed

    Obtaining a DAB License does not automatically guarantee a bank or payment account.

  • Tax assumptions must be checked

    Bermuda should not automatically be treated as a zero-tax structure for every business, particularly where the company forms part of an in-scope multinational enterprise group.

Expert view on obtaining a DAB License in Bermuda

“Bermuda is particularly interesting because its regulatory framework can support a digital asset business at different stages of development. The key is choosing the correct class from the beginning. A testing-stage project and a mature exchange or custody business should not be structured in the same way. The BMA will look not only at the business model, but also at governance, AML/ATF, cybersecurity, local substance and whether the company is genuinely ready to operate within the requested licence scope.”

Ganna Voievodina

CEO & Co-founder of Manimama

Frequently asked questions about a Bermuda DAB License

This section answers the most common questions about DAB licensing, license classes, regulated activities, capital, local presence, personnel, timelines, taxation and ongoing compliance.

A DAB License is an authorization issued by the BMA allowing a company to conduct approved digital asset business activities in or from Bermuda under DABA.

Digital asset businesses are regulated by the Bermuda Monetary Authority.

Bermuda provides Class T for testing-stage businesses, Class M for time-limited developing operations and Class F for full licensed operations.

The framework covers issuance and redemption, payments, exchanges, custodial wallets, trust services, derivative exchanges, digital asset services, lending and repurchase transactions.

The minimum starts from USD 10,000 for Class T, USD 100,000 for Class M and USD 100,000+ for Class F.

The filing fee is USD 1,000 for Class T and USD 2,266 for Class M or Class F. Additional licensing and operational expenses may apply.

A head office in Bermuda is generally required for licensed companies other than Class T licensees.

The structure generally requires at least two directors, a Compliance Officer, MLRO and senior representative, while controllers and officers must satisfy fit-and-proper requirements.

Yes. Foreign founders may establish a Bermuda company and apply, subject to applicable corporate, local presence, governance and regulatory requirements.

A practical estimate is approximately 3–8 months, depending on the class, complexity, completeness of the application and BMA review.

No. Banking and licensing are separate processes and financial institutions perform their own compliance assessment.

No. Bermuda does not impose VAT and generally does not impose capital gains tax, but Corporate Income Tax may apply to certain in-scope multinational enterprise groups.

Yes. Class T is designed for pilot or beta testing of a digital asset business activity for a defined period.

Class M allows approved DAB activities for a defined period determined by the BMA, while Class F represents a full licensing framework subject to the approved scope and conditions.

Applicants generally need the relevant application form, corporate documents, business plan, governance information, AML/ATF framework, cybersecurity documentation and supporting internal policies.

Yes. Manimama can support regulatory assessment, license class selection, Bermuda incorporation, documentation, BMA communication and ongoing post-licensing compliance.

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Ready to Move Forward with Your Bermuda DAB License?

Tell us about your crypto exchange, custody, digital asset payment, token, derivatives, trust, lending or other digital asset business. Manimama will assess your model, determine the applicable regulated activities and Class T, Class M or Class F pathway, and prepare a clear legal and regulatory roadmap for establishing your business in Bermuda.

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