Seychelles’ Virtual Asset Service Providers Act, 2024 (Act 12 of 2024) establishes Financial Services Authority (FSA) supervision of crypto service businesses and registration of initial coin offerings (ICOs) and non-fungible tokens (NFTs). It entered into force on September 1, 2024 under S.I. 65 of 2024 and remains in force as of November 2, 2026. Commencement notice. Current FSA enforcement.
Who the Seychelles VASP Act covers
The licensing framework covers wallet providers, exchanges, brokers and investment providers. Eligible applicants are Seychelles domestic companies and international business companies; overseas companies and individuals are ineligible. The FSA states that Seychelles incorporation creates a licensing obligation even when services are conducted abroad without a local office. FIU overview. FSA licensing guidance.
The statutory virtual-asset definition covers digitally transferable or tradable value used for payments or investment, excluding digital representations of fiat currencies, securities and other financial assets. Section 5 prohibits operating mining facilities and mixer or tumbler services in or from Seychelles. Act, sections 2 and 5.
Local presence and operating safeguards
Licensees face fit-and-proper checks and must maintain a staffed Seychelles office, a resident director, locally accessible records and local complaint handling. The Third Schedule also requires at least two board meetings and four management meetings in Seychelles annually. Act, sections 12–14 and Third Schedule.
Implementing regulations impose activity-specific capital requirements, insurance requirements and reserves or money covering 100% of liabilities for client assets held. Custody rules require ownership safeguards, reconciliation and controls separating client property from the provider’s assets. Use of client assets for another account requires explicit prior consent on specified terms. Omnibus custody is permitted, provided each client’s holdings remain identifiable and reconciled. Capital regulations, regulations 4–8. Custody regulations, regulations 4–6.
Capital requirements apply to each authorised activity where a provider holds multiple permissions. The financial rules also permit FSA-approved alternatives to insurance where the provider demonstrates that it has exhausted efforts to obtain cover. Capital regulations, regulations 5 and 8.
Cybersecurity rules address risk controls, testing, incident reporting and business continuity. VASPs are also AML/CFT reporting entities, subject to customer due diligence, suspicious-transaction reporting and recordkeeping. Advertising rules require balanced, accurate information and prohibit misleading claims of regulatory approval. References to licensing cannot imply that the FSA guarantees the soundness of an asset or offering. Cybersecurity regulations. FIU reporting guidance. Advertising regulations, regulations 5–6.
ICO, NFT and stablecoin treatment
Section 27 separates issuance registration from promotion: promoters must hold a licence under the VASP Act or Securities Act, 2007. Registration regulations require a white paper explaining the project, token rights, use of proceeds and risks. After receipt of an application meeting the prescribed requirements, issuance may proceed following written FSA no-objection or 30 working days without objection. The FSA retains powers to intervene subsequently. Registrations are valid for no more than 12 months; extensions follow a separate process. Act, section 27. Registration regulations, regulations 4–9 and Schedule.
In May 2026, the FSA clarified that stablecoin issuance is not currently regulated under this Act, referring to stablecoins’ current domestic form and use. It also stated that related exchange, broking, custody and investment-advice services may require a VASP licence depending on the activity. FSA stablecoin clarification.
Supervision and enforcement
The FSA can inspect businesses, demand information, direct corrective action and suspend or revoke licences. Section 33(1) sets company fines of up to SCR5.25 million for specified offences, including unlicensed services; individuals can face fines and imprisonment. Certain licensing decisions can be appealed to the FSA Appeals Board. Act, sections 28–36.
Enactment and transition
Presidential assent was given on August 26, 2024; Gazette publication followed on August 30. The September 1 commencement date is distinct from both. Official Act. S.I. 65 of 2024.
Existing operators had until December 31, 2024 to submit complete licence or registration applications. Eligible applicants could continue pending the FSA’s decision; the deadline did not automatically end all transitional operations. New entrants needed the relevant authorisation before starting. The FSA’s current register continues to distinguish operators under assessment from licensed providers. FSA transitional notice. FSA register explanation.
