Crypto Licence in Monaco
We qualify the activity, route it to the authority that owns it and build the agrément or token-offering file under the law in force today.
- Loi n° 1.528, Title II, in force
- The Minister of State, or the CCAF for financial tokens
- No decision period is published, and silence is a refusal
- A bill of 6 August 2026 would replace the regime
What we prepare on a Monaco crypto file
No provider service on digital assets or crypto-assets may be carried on in Monaco outside Title II of Loi n° 1.528 of 7 July 2022, Art. 11. We work out which of the ten statutory services your activity is, route the file and build the dossier Art. 17 asks for. Where the service bears on jetons financiers (financial tokens), Art. 20 sends it to the CCAF under Loi n° 1.338: that is a financial licence in Monaco.
We prepare and steer files. We hold no client funds, crypto-assets or private keys, operate no platform, and place, execute or transmit nothing. We are not a licensed provider, not the CCAF, not a bank and not a law firm: advice in legal, tax and financial matters is itself an authorised activity (Loi n° 1.144, Art. 8).
What is included in the file we prepare
Six blocks of work, in the order the file is built.
Qualification of the activity. Your model read against the three digital-asset services of Art. 12, the seven of Art. 13 and the definitions of Loi n° 1.383, Art. 1er.
Routing the file. To the Minister of State under Art. 14, or to the CCAF under Art. 20 where the service bears on financial tokens.
The company layer. A company registered in Monaco, or one in formation, which Art. 17, 6° allows to apply, plus the ordinary business authorisation every foreign founder needs.
The agrément dossier. Directors, natural persons above 25%, AML and asset-freezing capability, insurance and own funds, premises, staff, internal control, a resilient information system, and the AMSF and AMSN opinions.
The token-offering label file. The document d'information (information document) on the annexed model, the dedicated account in a Monaco bank, the platform, holders disclosed at or above 15%, and the publication calendar.
Life after the licence. Permanent compliance (Art. 19), a prior amendment before any change to a characteristic element (Art. 16), a fresh agrément per new service (Art. 22), the conduct rules of Art. 23.
Which track your activity falls on, and who this page is for
Four groups, and the article that decides which one you are in.
The three digital-asset services (Art. 12). Exchange of digital assets against other digital assets; operating a digital-asset trading platform; exchange against legal tender. The first cannot cover non-fungible tokens, which the statute excludes in terms.
The seven crypto-asset services (Art. 13). Issuance; custody or administration, including private keys; a platform bringing buying and selling interests together; placement; execution of orders; reception and transmission of orders; advice. Custody is Art. 13, 2°, the Minister of State's.
The financial-token carve-out (Art. 20). Placement, execution, reception and transmission of orders and advice, where they bear on jetons financiers, go to the CCAF under Loi n° 1.338. A jeton financier has the characteristics of a financial instrument (Loi n° 1.383, Art. 1er).
What is not a provider service at all. Holding crypto-assets for one family, through that family's own structure, is not a service provided to clients: see family office Monaco. The line is drawn by the definitions, not by size.
How the agrément route works today
Seven steps, with the periods the texts publish and no others.
- 01
silence is a refusal
Art. 15
- 02
and the period is set by an ordinance we could not locate. No total
- 03
no probability
Arts. 12, 13, 14 and 20 drawn as one decision. The only period on the licence route is the absence of one
1. Qualify the activity. Which of the ten services of Arts. 12 and 13 it is, whether the tokens are jetons financiers, and whether non-fungible tokens are involved.
2. Route the file. Minister of State (Art. 14) or CCAF (Art. 20). The Minister decides after a consultative commission's reasoned opinion; a firm the CCAF has already licensed informs it instead of applying again.
3. Build the vehicle. A company registered in Monaco, or in formation, may apply (Art. 17, 6°). Each foreign founder separately needs the ordinary authorisation of Loi n° 1.144, Art. 5: five working days, then forty-five days, where silence grants it. That is opening a company in Monaco.
4. Assemble the Art. 17 dossier. Directors' standing and competence, every natural person above 25% of the capital or the votes, AML and asset-freezing capability, insurance and own funds, premises, staff, internal control and a resilient information system.
5. Admissibility and instruction. The commission, chaired by the Conseiller de Gouvernement-Ministre des Finances et de l'Économie, rules on admissibility and examines a complete file. The AMSF's opinion on AML and the AMSN's on the systems are compulsory.
6. The decision. Notified within a period Art. 15 leaves to a sovereign ordinance. We searched for that ordinance and did not find it, so we state no period. If it passes without an answer, the application "doit être considérée comme rejetée": silence is a refusal, the opposite of step 3.
7. After the agrément. Permanent compliance with Arts. 17 and 18, the amendment and new-agrément rules above, and supervision by the Direction du Développement Économique (DDE), without prejudice to the AMSF.
Not sure whether your activity needs an agrément?
Send the model and the token, and we read it against Arts. 12 and 13 before anything is drafted.
Token offerings: the label under Loi n° 1.491
A separate authorisation, with its own commission, its own figures and a published clock.
- 01
complete file received
- 02
two months to the decision (O.S. n° 8.258, Art. 5), extendable once for the same period, drawn as one extension block
O.S. n° 8.258
- 03
the branch at the end of the period splitting into the label or a deemed refusal
- 04
the labelled information document published at the latest the day before the offering opens
Loi n° 1.491
- 05
funds escrowed on a dedicated account located in Monaco
Art. 4
- 06
the result published within two working days of closing
- 07
annual information certified by a statutory auditor. Each node carries its article and the date the text was read, 2026-09-19. No success rate, no total duratio
The only decision period published anywhere on this page: two months, extendable once, silence a refusal
1. What may be offered. Loi n° 1.491 of 23 June 2020, Art. 1er excludes non-fungible tokens, and financial tokens where the offering is public. Minimum nominal unit value EUR 10,000; a private offering means at least EUR 100,000 per investor, or a unit value of at least EUR 100,000 (O.S. n° 8.258, Arts. 5 and 1er).
2. The issuer. Only a legal person registered in Monaco may run an offering (Art. 3); a company in formation may apply, the label then subject to its registration. Financial tokens are reserved to a société par actions, and the annexed model puts the ledger in Monaco.
3. The file. The document d'information on the annexed model, holders disclosed at or above 15%, criminal-record extracts under three months old, and a platform licensed under Loi n° 1.528 with two years of experience in token offerings.
4. The decision. The Minister of State decides after a six-member commission's reasoned opinion: two months from a complete file, extendable once. No answer within it means the request is rejected.
5. Running the offering. Subscription in cash only. The funds are escrowed for the duration on an account dedicated to the offering, which Art. 4 requires to be located in Monaco: that is a business bank account in Monaco, and nobody can promise a bank will open one.
6. Closing and afterwards. The labelled document is available at the latest the day before the offering opens, the result within two working days of the close. Each year, information goes to subscribers and to the Minister of State with accounts certified by a statutory auditor, under DDE supervision.
The statute requires a list of licensed providers; we could not locate it, so we name none.
What the law requires, and what it leaves unpublished
Eight conditions, each with its article, and three rows where the honest entry is that nothing is published.
| Requirement | Article | What the text publishes | Status |
|---|---|---|---|
| Directors vetted | Loi n° 1.528, Art. 17, 1° | Persons with the power to administer or direct must have the standing and the competence the function requires | In force, read 2026-09-19 |
| Holders above 25% vetted | Art. 17, 2° | Natural persons holding, directly or indirectly, "plus de 25 % du capital ou des droits de vote", or controlling by other means, are assessed for sound and prudent management | In force, read 2026-09-19 |
| AML and asset freezing | Art. 17, 3°, with Loi n° 1.362, Art. 1er, 23° to 28° | The company must be able to comply with the AML statute and with asset-freezing procedures; the AMSF gives a compulsory opinion | In force; Monaco has been on the EU list of high-risk third countries since 5 August 2025 |
| Insurance and own funds | Art. 17, 4° | Professional liability insurance and fonds propres (own funds) are required, "dont les montants et les modalités sont fixés par ordonnance souveraine" | Required, amounts not published. The statute says own funds, not share capital |
| Substance in Monaco | Art. 17, 5° | Premises, equipment and staff for the services, security and internal control, a resilient and secure information system, a conflicts-of-interest system; the AMSN gives a compulsory opinion on the systems | In force, read 2026-09-19 |
| Registration in Monaco | Art. 17, 6° | The company is registered in Monaco; a company in formation in Monaco may nonetheless file the application | In force, read 2026-09-19 |
| The decision period | Art. 15 | The decision is notified within "un délai défini par ordonnance souveraine" from receipt of a complete file, and no answer means the request "doit être considérée comme rejetée" | Silence is a refusal. The period itself is not published, and we did not locate the ordinance |
| A State fee | Loi n° 1.528, Loi n° 1.491, O.S. n° 8.258 | No fee for the agrément or for the label appears in any of the three texts | An absence, checked 2026-09-19. That is not the same as free |
The conditions of Art. 17, with the three places where the statute points at an ordinance nobody has published.
The bill before the National Council: what Projet de loi n° 1.131 proposes
Loi n° 1.528, Title II and Loi n° 1.491 are the law in Monaco today, read on 2026-09-19 with no repeal note against either. Projet de loi n° 1.131 of 6 August 2026 is a bill before the National Council, meant to replace the 2022 regime. Nothing in the right-hand column is law.
| The question | Loi n° 1.528 and Loi n° 1.491, in force | Projet de loi n° 1.131, a bill, not law (6 August 2026) |
|---|---|---|
| Who licenses | The Minister of State, after a consultative commission's reasoned opinion (Art. 14); the CCAF where the service bears on financial tokens (Art. 20) | The bill proposes the CCAF as the single licensing authority (Art. 5) |
| Which services are allowed | The three digital-asset services of Art. 12 and the seven crypto-asset services of Art. 13 | The bill would permit three only: reception and transmission of orders for clients, portfolio management of crypto-assets, and advice (Art. 2) |
| What would be prohibited | Nothing of that kind: the licensed perimeter is those ten services | The bill would prohibit every other service in Monaco, custody, trading platforms, exchange, execution, placement and transfers included, and all issuance of crypto-assets (Art. 4) |
| Who may apply | A company registered in Monaco, or one in formation there (Art. 17, 6°) | The bill would restrict applicants to a société anonyme monégasque, which is forming a SAM in Monaco, or to the Monaco branch of a foreign credit institution the CCAF has licensed, with effective management in Monaco and one resident director (Art. 5) |
| The decision period | Set by a sovereign ordinance we could not locate (Art. 15) | The bill proposes six months from a complete file (Art. 7) |
| Silence | The application is deemed rejected (Art. 15) | Our reading of the tabled text finds no silence rule |
| Penalties | One to five years' imprisonment and the fine of Art. 26, 4) of the Code pénal, raisable to the profit made (Art. 34) | The bill proposes one to five years for providing a permitted service without a licence, and for providing a prohibited one (Art. 38) |
| Token offerings | The label of Loi n° 1.491, on a minimum nominal unit value of EUR 10,000, decided in two months extendable once (O.S. n° 8.258, Art. 5) | The bill would repeal Loi n° 1.491 and Title II of Loi n° 1.528 (Art. 60) |
The law as it stands on the left, a tabled proposal on the right, which has not been voted.
What we do not know: whether the National Council has examined or voted it, what amendments exist, when it would take effect, and whether existing activity would get a transitional rule. The text read on 2026-09-19 has no transitional article and no entry-into-force clause. The government gives two reasons: the commitment Monaco made under the Monetary Agreement of 29 November 2011 to adopt measures equivalent to the European Union's MiCA regulation, and FATF Recommendation 15.
Problems we solve
A plan that rests on a text nobody has voted. Custody, an exchange and a trading platform are licensable today; the section above sets out what the tabled bill would do to them. We map it against your model before anything is signed.
The belief that a licence can be bought with a company. It cannot. The agrément is granted to a named company on a named file: a change to a characteristic element needs a prior amendment (Art. 16), a new service a new agrément (Art. 22), and six months without notable activity is a revocation ground (Art. 30, 1°). The lawful route is buying a business and filing your own authorisation: the existing companies explainer.
A file built on figures nobody published. Capital bands per service class, a four-to-eight-month timetable, an own-funds amount: none of it is in Loi n° 1.528. Planning on them ends at the unpublished period and the refusal by silence.
Marketing into Monaco before the agrément exists. Art. 24 prohibits unsolicited approaches to persons domiciled in Monaco by anyone not licensed, "quel que soit le lieu ou le moyen utilisé", and Art. 37, 4° punishes it. It binds a foreign firm testing the market, and its website.
Bring us the model before the file
Tell us the service, the token and where the clients are, and we map the route.
Why work with us on a Monegasque licence file
Julien Rossi, tax, licensing and compliance lead, works on Monegasque licensing files in French, English and German.
From our practice: reading an activity against the two statutory lists before a structure is drawn, assembling the Art. 17 dossier, mapping what the AMSF and the AMSN will each be asked to sign off, and putting the tabled bill next to the client's model.
Prepared by Julien Rossi · Reviewed by Camille Perrin · Updated {{BUILD_DATE}}
Start your Monaco licence file
Send the activity, the token and where your clients sit, and we come back with the track and the article it rests on.
Start your Monaco file
Tell us the activity, where it will be carried on and who will run it. One of us reads it and comes back with the questions the authorisation file will ask. Our fees are on request.
The authorisation is personal and non-transferable, and it names the activity and the premises. Nothing on this site is sold ready to trade.
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