A dual licensing requirement mandates that an entity obtain two separate licenses to operate legally within a specific industry or jurisdiction. This often occurs when a business activity falls under the purview of distinct regulatory frameworks or authorities. In the digital asset sector, a firm might need one license for money transmission and another for offering securities or operating an exchange. This imposes additional regulatory burdens.
Context
Dual licensing requirements are a recurring challenge for digital asset businesses, particularly those operating across different service categories or national borders. The fragmented regulatory landscape often necessitates obtaining multiple permits, increasing operational complexity and compliance costs. News frequently covers legislative efforts to streamline licensing processes or debates about how best to categorize and regulate various digital asset activities to avoid redundant requirements.
The EBA's clarification mandates dual licensing for e-money token services, introducing significant operational friction and double capital requirements by March 2026.
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