Summary
Bybit's dual-license strategy in Europe — an EMI license from Austria's FMA for fiat payment services and a MiCA authorization for crypto-asset services — represents a template for how crypto exchanges are navigating the post-MiCA regulatory landscape. The separation of payment and crypto operations under distinct regulatory permissions allows Bybit to offer a unified interface while keeping each subsidiary within its approved regulatory scope. The timing is critical: MiCA's transitional period ends July 1, 2026.
Key Points
- The dual-license structure: Bybit Payments GmbH (EMI license, Austria FMA) handles fiat payment services — electronic money issuance, incoming/outgoing payments, payment transactions, issuing and acquiring payment instruments. Bybit EU GmbH (MiCA authorization) handles crypto-asset services — trading, custody, transfers. Both accessible through Bybit.eu but legally separate.
- Why separate entities matter: Each subsidiary must remain within its approved regulatory scope. The EMI license covers fiat-linked payment activities under Austria's E-Money Act 2010 and Payment Services Act 2018. The MiCA authorization governs crypto services. This structure prevents regulatory confusion and ensures each entity is supervised by the appropriate authority.
- MiCA deadline pressure: MiCA's transitional period ends July 1, 2026. Any CASP without authorization must cease EU operations or face fines up to €15M or 12.5% of annual turnover. Bybit's dual-license approach gives it a regulated foundation for both fiat and crypto services ahead of the deadline.
- Product roadmap: Bybit is considering P2P transfers, e-money products, Strong Customer Authentication features, open banking tools, merchant payment services, and payment cards — all subject to further regulatory approvals. These offerings go well beyond traditional crypto exchange functionality.
- Global expansion context: Bybit also launched in Indonesia in July 2026 via acquisition of PT Enkripsi Teknologi Handal (NOBI), supervised by Indonesia's OJK. The company is building a global network of locally licensed entities.
- EU vs US contrast: The EU's MiCA framework provides a single regional license for crypto services across 27 member states. The US has no equivalent — crypto companies face a combination of federal obligations and state-by-state money transmitter licensing. Bybit's Austrian EMI license applies within the European Economic Area but does not replace US approvals.