There is no Labuan crypto exchange licence. Labuan FSA issues nothing called a digital asset, digital currency or digital token exchange licence either. Those names appear on the websites of firms that sell licences, not in any Labuan FSA document. Its own list of digital financial service providers sorts every operator into existing categories: money broker, credit token business, exchange, payment system, securities licensee, digital bank.
So the question is not which crypto licence to pick. It is which existing licence your business falls into, and that turns on your token.
What actually decides your route?
Whether your token is securities, as defined in section 2 of the Labuan Financial Services and Securities Act 2010. Whether you run a venue or hold client assets matters too, but only once that first question is settled.
Labuan FSA draws the line from three directions. The securities token offering guidelines define a security token as securities under section 2, represented in digital form and subject to the same regime as any securities offering. The money broking guidelines say the digital assets a broker may trade must not have the features of securities. The credit token guidelines classify a token issued under that licence as non-securities. Settle which side of that line you are on and the licence question mostly answers itself.
Which licence for which activity?
| What you actually do | Licence | Basis, as stated by Labuan FSA |
|---|---|---|
| Run a venue for trading non-securities tokens | Labuan money broker, digital asset scope | Part VI, sections 90 and 92 |
| Run a venue where securities or security tokens list and trade | Labuan exchange | Part IX, section 134 |
| Issue non-securities tokens, wallets or stored value | Labuan credit token business | Part VI, section 90 |
| Advise on or deal in securities, no venue, no client money | Labuan securities licensee | Part IV |
Those provisions are the ones Labuan FSA names in its own documents: the money broking guidelines of September 2024, the credit token guidelines of February 2025, and the application form for a Labuan exchange.
What does the money broking route require?
Most crypto platforms land here. A Labuan money broker brings counterparties together and provides the system that matches their orders to trade or exchange digital assets. It acts strictly as an intermediary: no proprietary book, no market making on its own account.
Minimum paid-up capital is RM1,000,000 (Malaysian ringgit), unimpaired by losses, rising to RM1,500,000 where you also broker digital assets. Three obligations come with the digital side:
- A Digital Currency Oversight Committee of at least two senior managers with relevant expertise in digital currency business or internal control functions.
- Admissibility. Only digital currencies that pass Labuan FSA's framework may be traded. Privacy coins and algorithmic stablecoins do not.
- Segregation. Client monies sit in separate accounts and are never mixed with the broker's own assets.
What does the exchange route require?
A Labuan exchange is established under section 134 with prior written approval from Labuan FSA, for listing and trading financial instruments, including digital securities and security tokens. Labuan FSA looks at systems for risk management, protection of client assets, security and financial crime controls, and at whether directors and the principal officer are fit and proper.
Be careful with capital figures you read elsewhere. The RM500,000 that circulates as "capital for a Labuan digital exchange" is a misreading: under the securities token offering guidelines it is the minimum for the issuer of a public STO. It says nothing about a trading platform. Confirm exchange capital with Labuan FSA on your own application.
Where does the credit token licence fit?
It covers the issuer, not the venue, and confusing the two costs months. A credit token business issues non-securities tokens on a distributed ledger, backed by an asset Labuan FSA recognises, and the token gives its holder rights of use or access but not ownership. Raising money from investors points to a securities offering instead.
Minimum paid-up capital is RM1,000,000. Material published before February 2025 still quotes RM300,000 or no minimum at all, and both are out of date.
What changes on 1 January 2027
Labuan FSA issued guidelines on the management of a digital money broking platform in December 2025. They take effect on 1 January 2027. Anyone quoting them today as current requirements is a year early, and anyone building on today's rules alone is designing for a regime with a known end date. If you are scoping a digital money broking platform in the next twelve months, build against both.
Before you pick a licence
Work through it in this order, because getting the sequence wrong is what costs money.
- Is your token securities under section 2 of the Act? That decides the regime.
- Are you a venue, an intermediary or an issuer? That decides the licence inside the regime.
- Will you hold client money? A securities licensee may not hold clients' monies or assets at all. A money broker may, segregated.
- Can you meet the substance your licence carries? For a money broker that means at least two full-time staff in Labuan and RM100,000 of annual spend, and it decides whether the 3% tax rate holds.
Founders usually arrive with the product already built and ask which licence covers it. The perimeter question sets the capital, the substance and the timeline, and it is far cheaper to answer first.
Our licence application pages set out each route in full, and our compliance function team runs the AML and reporting side once you are licensed. If the tax condition is what you are weighing, our piece on Labuan's 3% tax takes that apart on its own.
Frequently Asked Questions
Is there a Labuan crypto exchange licence?
No. Labuan FSA issues no licence under that name, and none under digital asset exchange, digital currency exchange or digital token exchange either. Digital activity is fitted into existing licences under the Labuan Financial Services and Securities Act 2010. The official list of Labuan digital financial service providers groups every operator under categories such as money broker, credit token business, exchange and payment system.
What decides which Labuan licence a crypto business needs?
Whether the token is securities as defined in section 2 of the Labuan Financial Services and Securities Act 2010. A token with the features of securities runs under the securities regime and the same rules as any other securities offering. A token without them is a non-securities token, and the money broking and credit token regimes apply instead.
What licence does a platform for trading Bitcoin or other cryptocurrency need in Labuan?
The money broking route. A Labuan money broker with digital asset scope brings counterparties together and provides the system that matches orders to trade or exchange digital assets. It acts as an intermediary and may not trade on its own account. Minimum paid-up capital is RM1,500,000 where digital assets are brokered.
Can a Labuan exchange list security tokens?
Yes. A Labuan exchange is established under section 134 of the Act for the listing and trading of financial instruments, including the listing of digital securities and the trading of security tokens. Prior written approval from Labuan FSA is required.
Which digital currencies are not allowed in Labuan?
Privacy coins and algorithmic stablecoins are not admissible under Labuan FSA's admissibility framework for digital currencies. Tokens with the features of securities are also excluded from the digital assets a money broker may trade, because they fall under the securities regime instead.
Does the Travel Rule apply to a Labuan digital asset business?
Yes, since 1 January 2025, under the Anti-Money Laundering, Anti-Terrorism Financing and Proceeds of Unlawful Activities Act 2001. It reaches Labuan banks and investment banks, money brokers, exchanges, payment systems and Labuan trust companies, because they can hold digital assets in custody. The threshold is USD1,000. At or below it, the originator's name and account or wallet address travel with the transfer. Above it, an identity document number and address are added. Sending the information after the transfer is not permitted.
How is a Labuan crypto business taxed?
At 3% of chargeable profits, taken from the audited accounts, under the Labuan Business Activity Tax Act 1990. The rate is conditional: miss the substance requirements for a basis period and it becomes 24% for that year of assessment. A Labuan money broker needs at least two full-time employees in Labuan and RM100,000 of annual operating expenditure there, under P.U.(A) 423/2021. Substance scales by licence type, so confirm the tier for an exchange, a credit token business or a securities licensee separately.