Crypto Law Profile

Seychelles Virtual Asset Service Providers Act, 2024

Seychelles’ Virtual Asset Service Providers Act, 2024 establishes FSA licensing for crypto service providers and registration for ICOs and NFTs, with local substance, financial safeguards and AML/CFT oversight.

Seychelles Effective Act Sep 1, 2024
Identifier
Act 12 of 2024
Enacted
Aug 26, 2024
Last verified
Nov 2, 2026

At a glance

Jurisdiction Seychelles; national legislation.
Status In force since September 1, 2024; verified November 2, 2026.
Regulator Financial Services Authority (FSA).
Scope Wallet, exchange, broking and investment services; ICO and NFT registration.

Overview

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.

Key provisions

VASP licensing

Four categories cover wallet providers, exchanges, brokers and investment providers. Seychelles-incorporated companies remain in scope when operating abroad.

Licensing & Registration Sep 1, 2024 Source

Eligible companies

Domestic companies and international business companies are eligible; overseas companies and natural persons cannot obtain a VASP licence.

Licensing & Registration Sep 1, 2024 Source

Local substance

Staffed Seychelles office, resident director, locally accessible records and complaint handling; at least two local board and four management meetings annually.

Licensing & Registration Sep 1, 2024 Source

Financial safeguards

Regulations prescribe capital by activity, insurance requirements and reserves or money covering 100% of liabilities for client assets held.

Consumer protection Source

Client custody protections

Custodians must safeguard ownership, reconcile holdings and protect client assets. Use for another account requires explicit prior consent on specified terms.

Custody Source

Cybersecurity controls

Regulations address cyber risk management, system testing, incident reporting, data protection and business continuity.

Privacy & Cybersecurity Source

AML/CFT reporting

VASPs are reporting entities, subject to customer due diligence, suspicious-transaction reporting and recordkeeping requirements.

AML/CFT Source

ICO and NFT registration

Issuance requires registration; promoters need a VASP or Securities Act licence. The statutory process includes a 30-working-day no-objection mechanism.

Token Issuance Sep 1, 2024 Source

Offering disclosures

Registration applications require a white paper covering project purposes, token rights, use of proceeds, risks and other specified information.

Disclosure & Marketing Source

Stablecoin guidance

The FSA’s May 2026 guidance excludes current stablecoin issuance from this Act but says related exchange, broking, custody or advice may require licensing.

Stablecoins Source

Prohibited businesses

Section 5 prohibits operating mining facilities and mixer or tumbler services in or from Seychelles.

Mining Sep 1, 2024 Source

Enforcement and appeals

FSA powers include inspections, corrective directions and licence suspension or revocation. Specified offences attract criminal penalties; certain decisions may be appealed.

Enforcement & Asset Recovery Sep 1, 2024 Source

Transitional applications

Existing operators needed complete applications by December 31, 2024. Eligible applicants may continue while the FSA determines their applications.

Licensing & Registration Source

Timeline

  1. Presidential assent

    President Wavel Ramkalawan assented to Act 12 of 2024. This is separate from Gazette publication and commencement.

  2. Gazette publication

    Act 12 of 2024 was published in the Supplement to the Official Gazette.

    Enacted Source
  3. Commencement

    S.I. 65 of 2024 expressly brought the Act into operation on this date.

    In force Source
  4. Implementing regulations published

    Regulations on custody, advertising, cybersecurity, capital, licensing and ICO/NFT registration were gazetted.

    Enacted Source
  5. Transitional application deadline

    Deadline for existing operators to submit complete applications; eligible applicants could continue pending the FSA’s determination.

  6. Stablecoin clarification

    FSA guidance distinguished stablecoin issuance from associated services that may require licensing.

  7. Section 40 compliance notice

    FSA reported corrective company-name changes under the Act, evidencing ongoing implementation.

Official sources

Virtual Asset Service Providers Act, 2024 (Act 12 of 2024) Government of Seychelles Primary legislation Aug 30, 2024 English High VASP Act (Commencement) Notice, 2024 (S.I. 65) Government of Seychelles Commencement notice Aug 30, 2024 English High VASP FAQs Financial Services Authority Regulator guidance English High VASP questions and answers Seychelles Financial Intelligence Unit Regulator guidance English High VASP Capital and other Financial Requirements Regulations, 2024 (S.I. 72) Government of Seychelles Implementing regulations Sep 6, 2024 English High VASP Safekeeping and Management of Client’s Assets Regulations, 2024 (S.I. 69) Government of Seychelles Implementing regulations Sep 6, 2024 English High VASP Cyber Security Requirements Regulations, 2024 (S.I. 71) Government of Seychelles Implementing regulations Sep 6, 2024 English High VASP Advertisements Regulations, 2024 (S.I. 70) Government of Seychelles Implementing regulations Sep 6, 2024 English High VASP ICO and NFT Registration Regulations, 2024 (S.I. 74) Government of Seychelles Implementing regulations Sep 6, 2024 English High Clarification on the Regulatory Treatment of Stablecoins Under the VASP Act Financial Services Authority Regulator statement May 20, 2026 English High End of Transitional Period under the VASP Act, 2024 Financial Services Authority Regulator notice Dec 13, 2024 English High Licensed VASPs and providers under assessment Financial Services Authority Regulatory register English High Compliance to Section 40 of the VASP Act, 2024 Financial Services Authority Regulator notice Oct 28, 2026 English High

Editorial note

Verified on November 2, 2026. Assent, Gazette publication and commencement are separate dates. Eligible transitional applicants may continue pending determination. The FSA’s May 2026 stablecoin guidance distinguishes issuance from associated licensed services.