Regulatory intelligence / Brokerage implementation
Forex Broker Licence Jurisdictions Compared
Compare the permissions, people, substance and capital that shape your brokerage—not just the jurisdiction name.
Editorial concept image · Draft regulatory dossier · final sign-off pending.
Five jurisdictions / operating requirements
Compare the permission and operating commitment.
UAE, Mauritius, Seychelles, Labuan and Vanuatu side by side. Figures and qualifications below come from the existing dossiers; unresolved requirements remain explicitly marked for review.
| Requirement | UAE | Mauritius | Seychelles | Labuan / Malaysia | Vanuatu |
|---|---|---|---|---|---|
| Regulator | Capital Market Authority (CMA), formerly SCA | Financial Services Commission (FSC) | Financial Services Authority (FSA) | Labuan Financial Services Authority | Vanuatu Financial Services Commission (VFSC) |
| Authorisation | Financial activities — Categories 1–7 | Investment Dealer — SEC-2.1B | Securities Dealer | Money Broking | Financial Dealers — Classes A / B / C / D |
| Permission / execution model | Category/activity-specific; Category 5 is not dealing | Agency / principal scope requires final permission check | Agency / principal subject to specified licence business | Intermediary / agency; not principal | Permission depends on cumulative classes and conditions |
| Capital / statutory deposit | Category/activity-specific; verified Category 5 table: AED500,000 paid-up capital. | Current amount withheld pending latest rule/amendment check; no USD startup tier asserted. | US$100,000 minimum paid-up capital in FSA dealer guidelines, 5 March 2026; custody/maintenance mechanics need final review. | RM1,000,000 for paragraph 6.1; RM1,500,000 for paragraphs 6.1 + 6.2. Capital must remain unimpaired by losses; additional capital may be required. | VT5,000,000 statutory deposit held with the Commissioner under section 5 — not a paid-up-capital quotation. |
| Personnel & approvals | The category table lists Head or Manager of Category and Head of Compliance. Activity-specific approved jobs include Financial Analyst for financial consulting and Promotion Manager for promotion; other advisory activities have their own jobs. These are positions, not a universal headcount. Verify examinations, qualifications, role combination and any outsourcing approval before appointment. | Prepare the proposed directors, secretary or management-company arrangement, compliance officer, MLRO/DMLRO and auditor roles for local verification. Do not assume these roles may be combined or outsourced, or that a fixed director count applies without checking the actual structure. | The amended Act requires at least two natural-person directors, including one resident full-time director, and at least one individually licensed representative. Separately, section 65 requires two resident fit-and-proper individuals drawn from the specified director/compliance/management categories. This is not simply a rule requiring two resident directors. Prepare representative applications, questionnaires and compliance-officer evidence. | Controllers, directors and principal officer must meet fit-and-proper requirements. The operational office needs an authoritative stationed contact, potentially the principal officer or another suitable senior officer. Prepare competence and experience evidence; the regulator assesses the applicant holistically rather than a universal published staffing count. | The Act addresses fit-and-proper manager/director arrangements, relevant securities-dealing experience and licensed-manager requirements. A licensed manager is a natural person with appropriate competence, staffing and physical office; residence and continuing supervision provisions also apply. Representative licensing must be checked for the persons performing the actual dealer business. |
| Office & local substance | Prepare premises, organisation, systems, controls, banking and appropriate resources for the approved activity set. Confirm office and staffing evidence against current CMA requirements rather than repeating historical SCA requirements. This mainland framework is not the DIFC DFSA or ADGM FSRA framework. | Local management, registered office and operational substance must be assessed for the proposed company and any Global Business Licence relationship. A registered address is not proof of an operating presence. The decision record should explain where governance and control functions are performed. | The FSA guidance requires a physical place of business in Seychelles and evidence of premises. Maintain suitable recordkeeping premises and the resident management substance required by the Act. A lease, nominee arrangement or registered agent does not by itself evidence the complete operating model. | A furnished operational office in Labuan is required, with capability for records, accounting, statistics and regulatory communication. Distinguish operational substance from tax-substance requirements. Certified paid-up-capital evidence must show funds at a regulated bank in Labuan or Malaysia. | The Act addresses engagement of a licensed manager or an operating Vanuatu office with a manager/director normally resident six months each year. Continuing provisions concern an office with filing, management/accounting and continuity systems. Do not describe the manager route as an unconditional exemption from residence or office obligations; confirm the complete proposed structure with VFSC. |
| Client money / custody | No dealing / client-order execution permission under Category 5 | Permission-specific; do not assume custody | Permission-specific; do not assume custody | Permission-specific; do not assume custody | Permission-specific; do not assume custody |
| Application timing | Plan by dependencies rather than a promised approval date: ownership and funding evidence → personnel/premises readiness → reconciled application → regulator queries → conditions → commencement. There is no guaranteed regulator timetable. Any indicative preparation schedule must be agreed for the actual scope and is not a commitment by the regulator. | Plan by dependencies rather than a promised approval date: ownership and funding evidence → personnel/premises readiness → reconciled application → regulator queries → conditions → commencement. There is no guaranteed regulator timetable. Any indicative preparation schedule must be agreed for the actual scope and is not a commitment by the regulator. | Plan by dependencies rather than a promised approval date: ownership and funding evidence → personnel/premises readiness → reconciled application → regulator queries → conditions → commencement. There is no guaranteed regulator timetable. Any indicative preparation schedule must be agreed for the actual scope and is not a commitment by the regulator. | Plan by dependencies rather than a promised approval date: ownership and funding evidence → personnel/premises readiness → reconciled application → regulator queries → conditions → commencement. There is no guaranteed regulator timetable. Any indicative preparation schedule must be agreed for the actual scope and is not a commitment by the regulator. | Plan by dependencies rather than a promised approval date: ownership and funding evidence → personnel/premises readiness → reconciled application → regulator queries → conditions → commencement. There is no guaranteed regulator timetable. Any indicative preparation schedule must be agreed for the actual scope and is not a commitment by the regulator. |
| Post-authorisation obligations | Maintain approved-person and activity compliance, capital/resources, conduct, client documentation and applicable reporting. Current 2026 rulebook amendments must be checked for scope; no generic capital-buffer percentage is asserted for every Category 5 activity. Initial approval is not permission to commence the regulated activity. | Check financial-resource maintenance, audit, regulatory reporting, AML/CFT, client-asset controls and licence conditions. Keep ownership, personnel, outsourcing and business-model changes within the applicable notification or approval framework. No universal reporting deadline is asserted before final source review. | Provide suitable insurance, an acceptable auditor, annual audit and continuing financial resources, fees and licence-condition compliance. The amended legislation states validity continues unless suspended, revoked or surrendered; do not copy outdated annual-renewal claims from inconsistent guidance. Apply current advertising risk-warning, conduct and financial-statement rules; foreign marketing permissions remain separate. | Maintain approved-auditor audit, AML/CFT and targeted-financial-sanctions controls, statistical submissions, accessible records and counterparty due diligence. Specified ownership, director/principal-officer, capital-reduction, office and outsourcing changes require prior approval. Digital platform incident, technology and change requirements need the additional current platform-rule review. | The Act provides for independent Commissioner-approved audit, statutory insurance and continuing licence requirements. Maintain deposit, appropriate records, reporting and suitability; track changes and renewal/annual obligations against the actual licence and current rules. Capital, the statutory deposit, insurance and running expenses are separate financial concepts. |
| Official sources / review | Review UAE official sources Final regulatory sign-off pending. | Review Mauritius official sources Final regulatory sign-off pending. | Review Seychelles official sources Final regulatory sign-off pending. | Review Labuan / Malaysia official sources Final regulatory sign-off pending. | Review Vanuatu official sources Final regulatory sign-off pending. |
Regulatory capital and deposits are not consultancy fees or formation prices. No route guarantees approval, banking or timing.
UAE CMA / ESCA versus offshore routes
CMA vs Offshore Licence
Start with the activity you intend to conduct—not a “better licence” ranking.
Authorisation, not location
Compare the exact client contract, activities and approved permissions. An offshore location does not establish a common licence scope; the UAE framework also distinguishes categories and activities.
Category 5 is not forex dealing
CMA / ESCA Category 5 covers approved arranging and advisory activities, not forex / CFD execution or principal dealing. Review the relevant UAE dealing activity separately; do not compare Category 5 as if it were a securities-dealer licence.
Dealer versus intermediary
Mauritius, Seychelles and Vanuatu require their own permission/class review. Labuan money broking is intermediary / agency activity, not principal dealing. These are not interchangeable operating models.
Capital is not a package price
Paid-up capital, maintained resources and a statutory deposit are different requirements. The Vanuatu statutory deposit must not be presented as paid-up capital; Mauritius figures remain withheld pending the current-rule check.
People and operating presence
Compare the proposed governance, approved personnel, office and control functions against each dossier. Neither a registered address nor outsourced support proves that all substance requirements are satisfied.
Markets and ongoing responsibility
No route shown grants universal market access, passporting, guaranteed banking or guaranteed authorisation. Assess target client countries, banking, client-money arrangements and ongoing controls independently. The licensed entity retains regulatory responsibility.
Regulatory assessment
Start with the business you intend to operate.
Jurisdiction, permissions, people, substance and trading infrastructure—reviewed as one operating model.
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New licence · Additional jurisdiction · Acquisition · Staffing · Managed regulatory operations