Nikolai Timofejev
15 years in FinTech and payments. Maps your business model to the right licence scope and leads the file all the way to the BMA licence, including banking and payment rails.
Get a payment license in Bermuda.
Bermuda licenses one thing under the Money Service Business Act 2016, and section 11(3) makes it a condition of every licence that a licensed undertaking shall not hold client monies or any other client assets. That sentence decides whether your model fits before anything else does. Section 4(2) sets the scope of the licence: money transmission, cashing and guaranteeing cheques, issuing, selling or redeeming drafts, money orders or traveller's cheques, payment service business, and operating a bureau de change. Fees are $2,840 to apply, $6,460 on licensing and $6,460 a year. The Bermuda Monetary Authority publishes no statutory clock but would not expect an application to remain outstanding beyond three months.
27 yrs
on the international marketon the market
60+
in-house specialistsspecialists
400+
Licenses obtainedlicenses obtained
Updated
Bermuda in brief
One licence, five activities, and a statutory ban on holding client money.
Start with section 11(3) of the Money Service Business Act 2016, because it decides which business models fit: it is a condition of every licence issued under this Act that a licensed undertaking shall not hold client monies or any other client assets. There is no safeguarding regime in Bermuda for money service business, because holding the money is not permitted in the first place. Section 4(2) then sets the scope of the single licence - money transmission services; cashing cheques made payable to customers and guaranteeing cheques; issuing, selling or redeeming drafts, money orders or traveller's cheques for cash; payment service business; and operating a bureau de change whereby cash in one currency is exchanged for cash in another. No classes, no lighter registration tier, and banks sit outside the Act. Fees are printed: $2,840 to apply under section 10(2)(e), $6,460 on licensing under section 13(1)(a) and $6,460 a year under section 13(1)(b), payable on grant and on or before 31 March each year.
The minimum criteria for licensing sit in Schedule 1 to the Act under section 11(2), and the consolidated text published online truncates before that schedule, so the money service business minimum net assets figure is confirmed for your case rather than quoted from a secondary source. What the guidance notes do print is the qualitative test: controllers and officers fit and proper, business conducted in a prudent manner, corporate governance with the necessary integrity and skill, and full cooperation where there is consolidated supervision. The register is one name. At 31 December 2024 the authority supervised a single money service business licensee, and 36 digital asset businesses under the Digital Asset Business Act 2018 - 18 Class F, 10 Class M and 8 Class T, with net assets of $10,000 for Class T and $100,000 for Class M and above, and fees running from $15,000 to $450,000. The authority sets no statutory decision period; its guidance notes say it would not expect an application to remain outstanding in excess of three months.
Section 11(3) of the Money Service Business Act 2016 makes it a condition of every licence that the undertaking holds no client monies or client assets. That decides the model first. Section 4(2) then covers money transmission, cheque cashing and guaranteeing, drafts and money orders, payment service business and bureau de change.
Fees: $2,840 to apply, $6,460 on licensing, $6,460 a year. No statutory clock; the authority would not expect an application outstanding beyond three months. One MSB licensee and 36 digital asset businesses at 31 December 2024 - 18 Class F, 10 Class M, 8 Class T. We run it from London.
The routes
Money service business - or a digital asset licence in Class T, M or F.
Bermuda has one payment licence and one digital asset framework beside it, and the two answer different questions about whether you may hold anything for a customer. We fix the route first, then build once.
One money service licence - or a digital asset class under the 2018 Act.
01 - MONEY SERVICE BUSINESS
Money service business licence
The single licence under the Money Service Business Act 2016 over the five activities of section 4(2), granted on the Schedule 1 minimum criteria - and conditioned by section 11(3) on the undertaking holding no client monies or any other client assets.
The single licence under the Money Service Business Act 2016 over the five activities of section 4(2), granted on the Schedule 1 minimum criteria - and conditioned by section 11(3) on the undertaking holding no client monies or any other client assets.
- ✓Money transmission services (s. 4(2))
- ✓Cheque cashing and cheque guaranteeing
- ✓Drafts, money orders and traveller's cheques for cash
- ✓Payment service business and bureau de change
- ✓No client monies or client assets held (s. 11(3))
- ✓Fees $2,840 apply · $6,460 licence · $6,460 a year
02 - DIGITAL ASSET BUSINESS
Classes T, M and FDigital Asset Business Act 2018
Three classes under section 12(3): Class T for a pilot or beta test, Class M as a time-limited licence extendable under section 12(4), and Class F without a term limit for any or all digital asset business activities.
DABA Classes T, M and F: net assets $10,000 for Class T, $100,000 for Class M and above; fees from $15,000 to $450,000.
- ✓Class T - test or pilot licence, $1,000 a year
- ✓Class M - time-limited, extendable (s. 12(4))
- ✓Class F - indefinite, all digital asset activities
- ✓Net assets $10,000 Class T · $100,000 Class M and above
- ✓Grant and annual fees from $15,000 to $450,000
- ✓Head office in Bermuda for Classes M and F (s. 21(1))
Costs and timelines are confirmed for your case before any work begins. The money service business minimum net assets sit in Schedule 1, which the official consolidated text truncates before; we obtain and confirm the figure for your case, and it is itemised in your quote.
Why Bermuda
A clean line on client money, and fees you can put in a budget.
Bermuda is the wrong jurisdiction for a wallet and the right one for a business that never touches customer funds. The statute says so in one sentence, which is worth more than a safeguarding annex.
✓
The client-money line is drawn in the Act
Section 11(3) makes it a condition of every licence that the undertaking holds no client monies or any other client assets. No trust account to build, no insurance to buy, no safeguarding audit to pass.Section 11(3) settles the model.
✓
Five activities, one licence
Section 4(2) covers money transmission, cheque cashing and guaranteeing, drafts and money orders, payment service business and bureau de change. The Minister may amend the list by order after consulting the authority.One licence under section 4(2).
✓
Fees that are printed
$2,840 with the application, $6,460 on licensing and $6,460 every year by 31 March. There is no percentage charge on volume and no per-branch fee in the schedule.$2,840, $6,460, $6,460 a year.
✓
Three months, said out loud
The Act imposes no time limit, and the guidance notes say the authority would not expect an application to remain outstanding in excess of three months. That is an expectation, not a right, and it works both ways.The authority's stated expectation.
✓
A digital asset framework beside it
36 digital asset businesses at 31 December 2024 across three classes, and the Class T pilot licence is Bermuda's sandbox for digital asset business.36 businesses across three classes.
✓
Corporate tax only above EUR 750 million
Individuals pay no income tax. The Corporate Income Tax Act 2023 charges 15% on in-scope multinational groups above EUR 750 million of revenue, from 1 January 2025, and leaves everyone else on payroll tax.15% only above EUR 750 million.
How it compares
How Bermuda differs from the other Caribbean and Atlantic routes.
Bermuda has the lowest annual fee of the four and the hardest constraint on the product. The honest comparison is below.
Bermuda vs other jurisdictions
| Feature |  Bermuda | Other jurisdictions |
|---|---|---|
| Client money | Not held at all (s. 11(3)) | Segregated in the BVI · custodian account in The Bahamas |
| Licence scope | One licence over five activities | Seven classes in the BVI |
| Annual fee | $6,460 | CI$20,000 in Cayman · $10,000 in The Bahamas |
| Decision period | No clock · three months expected | 45 days in The Bahamas · 4-6 weeks in Cayman |
Client money
BermudaNot held at all (s. 11(3))
Other jurisdictionsSegregated in the BVI · custodian account in The Bahamas
Licence scope
BermudaOne licence over five activities
Other jurisdictionsSeven classes in the BVI
Annual fee
Bermuda$6,460
Other jurisdictionsCI$20,000 in Cayman · $10,000 in The Bahamas
Decision period
BermudaNo clock · three months expected
Other jurisdictions45 days in The Bahamas · 4-6 weeks in Cayman
Country by country
| Country | License type | Taxation | Requirements |
|---|---|---|---|
| Bermuda | Money service business (BMA) | 15% above EUR 750M | No client money held (s. 11(3)) |
 Cayman Islands | Money services business (CIMA) | No direct taxes | Net worth $30,000 · 4-6 weeks |
 British Virgin Islands | Financing and money services (FSC) | No CIT · payroll 10-14% | Seven classes · s. 19C segregation |
 The Bahamas | Payment institution (central bank) | No CIT · VAT 10% | B$100,000 · 45-day decision |
BermudaLicense typeMoney service business (BMA)
Taxation15% above EUR 750M
RequirementsNo client money held (s. 11(3))
Cayman IslandsLicense typeMoney services business (CIMA)
TaxationNo direct taxes
RequirementsNet worth $30,000 · 4-6 weeks
British Virgin IslandsLicense typeFinancing and money services (FSC)
TaxationNo CIT · payroll 10-14%
RequirementsSeven classes · s. 19C segregation
The BahamasLicense typePayment institution (central bank)
TaxationNo CIT · VAT 10%
RequirementsB$100,000 · 45-day decision
Before you apply
Requirements for the BMA licence.Requirements for the licence.
Section 10(2) sets the application, section 11(2) and Schedule 1 the criteria, and section 11(3) the constraint that decides everything else. The checklist below is what a passing file contains.
01
A business model that holds no client monies and no other client assets - section 11(3) makes that a condition of every licence, so wallet balances and float-holding products belong in a different jurisdiction.
02
An activity inside section 4(2): money transmission, cheque cashing and guaranteeing, drafts, money orders or traveller's cheques for cash, payment service business, or a bureau de change.
03
An application under section 10(2) with a business plan describing the nature and scale of the activity, the management arrangements, and the policies and procedures for compliance with the Act and the anti-money-laundering regulations.
04
The $2,840 application fee with the application, $6,460 on licensing, and $6,460 every year on or before 31 March.
05
The Schedule 1 minimum criteria met: controllers and officers fit and proper, business conducted in a prudent manner, corporate governance with the necessary integrity and skill, and full cooperation where there is consolidated supervision.
06
Minimum net assets at the Schedule 1 level - the published consolidated text truncates before the schedule, so we obtain and confirm the figure for your case before the file is built.
07
Operational cyber risk management to the authority's code of conduct of 26 September 2022, applied proportionately to the scale of the business.
08
The Act applies to persons carrying on money service business in or from within Bermuda; the sections we read impose no express local-incorporation or resident-director rule, and the authority's expectations on presence are settled before filing rather than assumed.
09
For a digital asset business instead, a Class T, M or F licence under section 12(3) of the Digital Asset Business Act 2018, with net assets of $10,000 for Class T and $100,000 for Class M and above.
10
For Classes M and F, a head office in Bermuda from which the business is directed under section 21(1) of that Act; Class T needs local incorporation without meeting the full head-office test.
01
A model that holds no client money (s. 11(3)).
02
An activity inside section 4(2).
03
Section 10(2) application and business plan.
04
Fees $2,840, $6,460, $6,460 by 31 March.
05
Schedule 1 minimum criteria met.
06
Net assets confirmed for your case.
07
Cyber risk code of conduct applied.
08
Presence settled with the authority.
09
Digital assets: Class T, M or F.
10
Head office for Classes M and F (s. 21(1)).
Reflects the Money Service Business Act 2016, its guidance notes, code of practice and statement of principles of 16 December 2016, the 2025 Bermuda Monetary Authority fees and the Digital Asset Business Act 2018 as amended, as of 2026.Money Service Business Act 2016 with its 2016 guidance notes and code of practice; 2025 BMA fees; Digital Asset Business Act 2018 as amended.
How it works
From first call to the BMA licence.
01
Route and constraint
Does the model hold client money? If not, which section 4(2) activity applies, and does a digital asset class fit better - fixed in writing.Client money test, then the activity.
02
Company and net assets
Bermuda company formed, controllers and officers documented for the fit-and-proper test, Schedule 1 net assets confirmed and funded.Formed, officers documented, funded.
03
The application file
Section 10(2) business plan, management arrangements, AML policies and procedures, cyber risk material and the $2,840 fee - complete before filing.Plan, AML, cyber, $2,840 fee.
04
BMA review
No statutory clock; the authority would not expect the application to remain outstanding beyond three months - plan on five to eight months end to end.Three months expected; 5-8 months real.
05
Licence and launch
Licensing fee of $6,460 paid on grant, the annual fee calendared for 31 March, and reporting to the authority under way.$6,460 on grant; annual by 31 March.
Quick facts
RegulatorBermuda Monetary Authority
LawMoney Service Business Act 2016
LicenceOne MSB licence · DABA Classes T, M, F
Client moneyNot held (s. 11(3))
Net assetsSchedule 1 · confirmed for your case
Fees$2,840 · $6,460 · $6,460 a year
DecisionThree months expected, no clock
TaxPayroll 0.5-9.50% · CIT 15% above EUR 750M
The authority published a discussion paper on 15 April 2025 proposing to replace the Money Service Business Act 2016 with a Payment Services Act on four tiers - Class T, Class M, Class F and Class PG for institutional and high-net-worth clients. Consultation closed on 15 May 2025 and we track what follows.
Your Bermuda desk
Run from our Caribbean desk.
Prifinance - Caribbean desk
London · coordinating Bermudian mandates
7 Bell Yard, London
01
Model test against section 11(3)
Before anything is drafted we check whether the product ever holds customer funds. If it does, we say so and move the mandate to a jurisdiction that allows it.Section 11(3) checked before drafting.
02
Bermuda company formation
The company, the controllers and officers who have to pass the fit-and-proper test, and the net assets figure confirmed against Schedule 1.Controllers, officers, net assets.
03
The BMA file
The section 10(2) application: business plan by nature and scale, management arrangements, AML policies and procedures, and the cyber risk material.Section 10(2) answered in order.
04
Digital assets where they fit
Class T for a pilot, Class M for a time-limited launch, Class F for the full permission - with the head-office test under section 21(1) planned from the start.Class T, M or F where it fits.
We also have offices in
Tallinn
Estonia
Roseni 13
Vilnius
Lithuania
Gedimino pr. 2
Prague
Czech Republic
Vlkova 532/8, Žižkov
Dubai
UAE
33 Level, Al Saqr Business Tower
Madeira
Portugal
Rua da Alegria 31, 1F
Budapest
Hungary
Korányi Sándor u. 4
Istanbul
Turkey
Perpa Ticaret Merkezi, A Blok
Good to know
Taxation of payment companies in Bermuda.
No personal income tax and no tax on profit below the global threshold. Payroll tax is the operating charge, and a 15% corporate rate now applies to the largest groups.
No personal income tax
The government states plainly that individuals in Bermuda do not pay personal income tax. There is no capital gains tax, no value added tax and no dividend withholding tax.For individuals, on any income.
Employer payroll tax
By annual payroll: 0.5% under $200,000; 2.00% from $200,000 to $350,000; 4.75% to $500,000; 7.00% to $1,000,000; and 9.50% above that, for the year to 31 March 2027.0.5% to 9.50% by payroll.
Exempt undertakings 9.75%
All exempt undertakings pay 9.75%. Government, approved schools, charities, new start-ups for four quarters and Economic Empowerment Zone employers for nine quarters pay nothing.9.75% flat.
The employee share
Progressive over five bands: 0.25% to $48,000; 7.75% to $96,000; 10.75% to $200,000; 11.50% to $500,000; 12.50% to $1,000,000. The tax cap remains at $1,000,000 per person.Up to 12.50%; cap $1,000,000.
Corporate income tax 15%
The Corporate Income Tax Act 2023 charges 15% of the net taxable income of a Bermuda constituent entity group, less foreign tax credits, for in-scope groups above EUR 750 million. It took effect from 1 January 2025.Groups above EUR 750 million.
Land tax
Charged from 0.80% to 50% by annual rental value band. For a licensee it is a premises cost rather than a business tax, and it belongs in the operating budget.0.80% to 50% by rental value.
Tax summary
Personal income taxNone
Employer payroll tax0.5% to 9.50% by annual payroll
Exempt undertakings9.75%
Employee share0.25% to 12.50% · cap $1,000,000
Corporate income tax15% for groups above EUR 750 million
Land tax0.80% to 50% by rental value
*Figures as of 2026 per the Government of Bermuda and the Corporate Income Tax Agency. Treaty and regime positions are assessed per structure.
Turnkey professional support
Experienced lawyers and international consultants.
We provide end-to-end support, from company registration and the application file to regulatory interaction and compliance oversight - with an individualized approach to each client.
Oleksii Kindratenko
Builds the application itself: Bermuda company, AML/KYC policy pack, capital structure and tax registrations. His document sets are the reason reviews finish in months, not years.
Eugeniu Bevziuc
First point of contact for international founders. Runs the whole setup remotely, across time zones and languages - from the first call to a live, licensed money service business.
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Request a free conclusion →FAQ
The Bermuda money service business licence, answered.
What licence does a payment business need in Bermuda?+
A money service business licence from the Bermuda Monetary Authority under the Money Service Business Act 2016. Section 4(2) puts money transmission, cheque cashing and guaranteeing, drafts, money orders and traveller's cheques, payment service business and bureau de change inside one licence. There are no classes and no lighter registration tier.
Can a licensee hold client money?+
No. Section 11(3) makes it a condition of every licence issued under the Act that a licensed undertaking shall not hold client monies or any other client assets. There is no safeguarding regime because the holding itself is barred, and a product with stored balances needs a different jurisdiction.
How much capital is required?+
Licensing is conditioned on the minimum criteria in Schedule 1 under section 11(2). The consolidated text published on the official site truncates before that schedule, so we obtain and confirm the money service business minimum net assets for your case rather than repeat a figure from a secondary source. For digital asset business the authority publishes $10,000 for Class T and $100,000 for Class M and above.
How long does the authority take?+
The Act imposes no time limit within which the authority must decide. Its guidance notes say it would not generally expect an application to remain outstanding in excess of three months. Plan on five to eight months from first call, including preparation and question rounds.
What does the licence cost?+
An application fee of $2,840 under section 10(2)(e), a licensing fee of $6,460 under section 13(1)(a) on grant, and an annual fee of $6,460 under section 13(1)(b), payable on or before 31 March each year.
How many licensees are there?+
One money service business licensee at 31 December 2024, on the authority's own annual report. The digital asset side is larger: 36 businesses, split 18 Class F, 10 Class M and 8 Class T.
What about digital assets?+
The Digital Asset Business Act 2018 creates three classes in section 12(3) - Class F without a term limit, Class M time-limited and extendable, and Class T for a pilot or beta test. Net assets are $10,000 for Class T and $100,000 for Class M and above, with grant and annual fees from $15,000 to $450,000.
Is a Bermuda head office required?+
For digital asset business, yes: section 21(1) of the 2018 Act requires a licensed undertaking to maintain a head office in Bermuda directing the business, except for Class T. For money service business the sections we read impose no express head-office or resident-director rule, so presence is settled with the authority before filing.
How are money service businesses taxed?+
There is no personal income tax, no capital gains tax and no VAT. Employers pay payroll tax from 0.5% to 9.50% by annual payroll, 9.75% for exempt undertakings, with an employee share reaching 12.50% and a cap of $1,000,000 a person. Corporate income tax of 15% applies only to in-scope groups above EUR 750 million.
Why Bermuda rather than the Cayman Islands or the BVI?+
Bermuda has the lowest annual fee of the three at $6,460 and a supervisor that publishes its own timing expectation, and its digital asset framework is the deepest in the region. Cayman lets you hold customer money without saying how; the BVI requires a segregated customer account and permits the holding. If your model never touches client funds, Bermuda is the cleanest of the three.
Which licence?+
Money service business under the 2016 Act.
Client money?+
Not held - condition of every licence.
Capital?+
Schedule 1; confirmed for your case.
How long?+
Three months expected; 5-8 months real.
Fees?+
$2,840, $6,460, then $6,460 a year.
Licensees?+
One MSB; 36 digital asset businesses.
Digital assets?+
Classes T, M and F under the 2018 Act.
Head office?+
Required for DABA Classes M and F.
Taxes?+
Payroll tax; CIT 15% above EUR 750M.
vs Cayman / BVI?+
Cheapest annual fee; no client money.
Client notes
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Prifinance is an independent law and advisory firm. We are not a regulator and are not affiliated with, endorsed by, or acting on behalf of the Bermuda Monetary Authority or any other public authority. Authorisations are granted by, and obtained directly from, the competent authorities.