Forex License: Regulated Jurisdictions Compared (2026)
A forex or CFD brokerage needs authorisation from a securities regulator in the jurisdiction it operates from, and often in the markets it serves. The jurisdictions below are the ones Zitadelle AG advises on most often. They differ in market access, regulator standing, capital, substance and banking, so the right choice depends on who your clients are and how you plan to operate.
In short
- EU and EEA clients: only a CySEC-authorised Cyprus Investment Firm on this list can passport services across the EEA under MiFID II.
- International clients outside the EEA: Mauritius, Seychelles, Labuan, Vanuatu and Panama each license broker-dealers under their own securities laws.
- Company set-ups in St Lucia or St Vincent and the Grenadines are not licences from a securities regulator.
- Capital, fees and timelines differ by licence category; each jurisdiction guide below sets them out.
Regulated forex licence jurisdictions
| Jurisdiction | Regulator | Authorisation | EEA passporting | Guide |
|---|---|---|---|---|
| Cyprus | Cyprus Securities and Exchange Commission (CySEC) | Cyprus Investment Firm (CIF) under MiFID II | Yes | Cyprus CIF guide |
| Mauritius | Financial Services Commission (FSC) | Investment Dealer (Full Service Dealer, excluding Underwriting) | No | Mauritius forex licence guide |
| Seychelles | Financial Services Authority (FSA) | Securities Dealer | No | Seychelles securities dealer guide |
| Labuan (Malaysia) | Labuan Financial Services Authority | Money Broking licence | No | Labuan money broking guide |
| Vanuatu | Vanuatu Financial Services Commission (VFSC) | Financial Dealers Licence | No | Vanuatu FDL guide |
| Panama | Superintendencia del Mercado de Valores (SMV) | Casa de Valores (broker-dealer) | No | Panama broker licence guide |
Capital, fees and timelines are set out on each jurisdiction page.
Company set-ups that are not a forex licence
Our St Lucia and St Vincent and the Grenadines pages cover company set-up routes rather than a licence from a securities regulator. They can suit some proprietary-trading and technology structures, but they do not replace a regulated broker licence where your target markets require one.
Buying an existing licensed company
Acquiring an already-licensed entity can be an alternative to a new application. The regulator still has to approve the change of control, and the entity's history needs full due diligence.
See licensed companies for saleWhat we need to recommend a route
- Where your clients are, and whether you need to serve EEA clients
- Products: FX and CFDs, crypto-asset products, other securities
- Execution model: agency (A-book), principal (B-book) or hybrid
- Whether you will hold client money
- Your budget and target launch date
- Existing group companies, licences and people you can place in the jurisdiction
How Zitadelle AG helps
We compare jurisdictions against your client base, product range and budget, then prepare the application, policies and substance plan for the regulator you choose.
Frequently Asked Questions
Of the jurisdictions on this page, only a CySEC-authorised Cyprus Investment Firm can passport its services across the EEA under MiFID II. Licences from Mauritius, Seychelles, Labuan, Vanuatu or Panama do not carry EEA passporting rights.