CHAPTER 49 / 55 · Paid
VASP classes M, O, R, I, S and ITO issuers.
Follow each VASP class as its own shop. FS-1.14 is not Class R.
Approx. 22 min with exercisesLaw cut-off: 20 September 2026Our approach
By the end of this chapter
- Describe the shop in one paragraph from the first file on the desk.
- Decide the promoter’s next asks: which stay on this letter, which need another paper.
- Keep neighbouring permissions off this desk.
- Cite the enabling section and treat the licence letter as the book.
How this family is grouped
Follow each VASP class as its own shop. FS-1.14 is not Class R. Each code below is its own shop: a first file, a week, the asks that need a different paper, then the letter. A quieter label is not a thinner file.
VA-1.1 Virtual Asset Broker - Dealer (Class M)
FSC · VA-1.1 · Licence
1. TokenDesk Ltd’s shop
TokenDesk Ltd is the desk this chapter is for. Carry on VASP business as Class M (broker-dealer) under section 7.
The first file on the desk is this. TokenDesk Ltd will buy and sell virtual assets as agent/principal for clients, without operating the marketplace or holding itself out as a custodian. VA-1.1 Class M.
Three facts have to stay true of that book. First, the letter is the activity specified. This is a licence under Virtual Asset and Initial Token Offering Services Act 2021, Section 7. A company name is not a permission.
Second, neighbouring papers stay off this desk. Not a securities investment dealer, not Class R custody, not Class S marketplace, and not FS-1.14.
Third, the assumptions stay in the file. Fictional VASP. Cut-off 20 September 2026.
Virtual Asset and Initial Token Offering Services Act 2021, Section 7. See the register note · Open the published text ↗.
2. A week with A token broker-dealer
Monday. The promoter walks in with “A token broker-dealer.” Write the facts before anyone names a code: TokenDesk Ltd will buy and sell virtual assets as agent/principal for clients, without operating the marketplace or holding itself out as a custodian.
Tuesday. The team writes the activity in the words of the licence letter, not the brass plate. Carry on VASP business as Class M (broker-dealer) under section 7.
Wednesday. They record what this permission is used for. VA-1.1 Class M.
Thursday. They write what the letter does not cover. Not SEC-2.1B. Not Class R. Not FS-1.14.
Friday. They lock the assumptions. Fictional VASP. Cut-off 20 September 2026. The file is ready for the application, not for a slogan on a slide.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what VA-1.1 is used for. The Act matters when TokenDesk Ltd applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
This licence
A token broker-dealer
TokenDesk Ltd will buy and sell virtual assets as agent/principal for clients, without operating the marketplace or holding itself out as a custodian.
Why it fits. VA-1.1 Class M.
Different paper
The same promoter asks for securities investment dealer
The slide says the VA-1.1 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not SEC-2.1B. Not Class R. Not FS-1.14.
Different paper
The same promoter asks for Class R custody
The slide says the VA-1.1 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not SEC-2.1B. Not Class R. Not FS-1.14.
| The promoter asks TokenDesk Ltd to… | This licence? | Why |
|---|---|---|
| A token broker-dealer | Yes | VA-1.1 Class M. |
| The same promoter asks for securities investment dealer | No | Keep the neighbouring paper off this desk. Not SEC-2.1B. Not Class R. Not FS-1.14. |
| The same promoter asks for Class R custody | No | Keep the neighbouring paper off this desk. Not SEC-2.1B. Not Class R. Not FS-1.14. |
4. Papers that sit beside this one
Not a securities investment dealer, not Class R custody, not Class S marketplace, and not FS-1.14. Name the other desk when the work changes: a securities investment dealer; Class R custody; Class S marketplace; FS-1.14.
- a securities investment dealer
- Class R custody
- Class S marketplace
- FS-1.14
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
A company carrying on VASP activities in or from Mauritius, as VAITOS applies. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. Fees as at 1 July 2026: Processing fee USD 1,000 (MUR 45,000). Status at cut-off: Published VASP class as at 1 July 2026.
Who may hold it. A company carrying on VASP activities in or from Mauritius, as VAITOS applies.
Published criteria. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. They neither derogate from nor restrict the Commission’s statutory powers, and they must be read with the relevant Act, rules, codes and circulars. Class-specific criteria PDF on the directory.
Rules, codes and circulars. FSC VAITOS guide distinguishes VASP licences from ITO registration. CL20260107 for FSC fees generally.
6. How to cite VA-1.1
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | VA-1.1 Virtual Asset Broker - Dealer (Class M) |
| Legal nature | Licence |
| Enabling law | Virtual Asset and Initial Token Offering Services Act 2021 · Section 7 |
| Fees as at 1 July 2026 | Processing fee USD 1,000 (MUR 45,000). Fixed annual fee USD 2,000 (MUR 90,000). Unless the directory states a different conversion rule, USD figures apply only to an applicant for a Global Business Licence or a corporation holding a Global Business Licence. FSC Circular Letter CL20260107 (1 July 2026) records that the replacement fee schedule operates from 1 July 2026 and that annual fees are due by 30 September 2026. A circular does not rewrite the activity this code authorises. |
| Status at cut-off | Published VASP class as at 1 July 2026. |
The structured library card keeps the same coordinates for search. Open VA-1.1 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC guide on the VAITOS Act ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register note
VA-1.2 Virtual Asset Wallet Services (Class O)
FSC · VA-1.2 · Licence
1. WalletIsle Ltd’s shop
WalletIsle Ltd is the desk this chapter is for. Class O wallet services.
The first file on the desk is this. WalletIsle Ltd will provide hosted wallets so clients can store and transfer virtual assets. VA-1.2 Class O.
Three facts have to stay true of that book. First, the letter is the activity specified. This is a licence under Virtual Asset and Initial Token Offering Services Act 2021, Section 7. A company name is not a permission.
Second, neighbouring papers stay off this desk. Not Class R custodian, not Class M broker-dealer, and not a BoM payment wallet by slogan.
Third, the assumptions stay in the file. Fictional VASP. Cut-off 20 September 2026.
Virtual Asset and Initial Token Offering Services Act 2021, Section 7. See the register note · Open the published text ↗.
2. A week with A hosted wallet app
Monday. The promoter walks in with “A hosted wallet app.” Write the facts before anyone names a code: WalletIsle Ltd will provide hosted wallets so clients can store and transfer virtual assets.
Tuesday. The team writes the activity in the words of the licence letter, not the brass plate. Class O wallet services.
Wednesday. They record what this permission is used for. VA-1.2 Class O.
Thursday. They write what the letter does not cover. Not Class R safekeeping as a substitute, and not a BoM PSP by calling it a wallet.
Friday. They lock the assumptions. Fictional VASP. Cut-off 20 September 2026. The file is ready for the application, not for a slogan on a slide.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what VA-1.2 is used for. The Act matters when WalletIsle Ltd applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
This licence
A hosted wallet app
WalletIsle Ltd will provide hosted wallets so clients can store and transfer virtual assets.
Why it fits. VA-1.2 Class O.
Different paper
The same promoter asks for Class R custodian
The slide says the VA-1.2 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not Class R safekeeping as a substitute, and not a BoM PSP by calling it a wallet.
Different paper
The same promoter asks for Class M broker-dealer
The slide says the VA-1.2 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not Class R safekeeping as a substitute, and not a BoM PSP by calling it a wallet.
| The promoter asks WalletIsle Ltd to… | This licence? | Why |
|---|---|---|
| A hosted wallet app | Yes | VA-1.2 Class O. |
| The same promoter asks for Class R custodian | No | Keep the neighbouring paper off this desk. Not Class R safekeeping as a substitute, and not a BoM PSP by calling it a wallet. |
| The same promoter asks for Class M broker-dealer | No | Keep the neighbouring paper off this desk. Not Class R safekeeping as a substitute, and not a BoM PSP by calling it a wallet. |
4. Papers that sit beside this one
Not Class R custodian, not Class M broker-dealer, and not a BoM payment wallet by slogan. Name the other desk when the work changes: Class R custodian; Class M broker-dealer; a BoM payment wallet by slogan.
- Class R custodian
- Class M broker-dealer
- a BoM payment wallet by slogan
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
A VASP licensed for wallet services. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. Fees as at 1 July 2026: Processing fee USD 1,000 (MUR 45,000). Status at cut-off: Published VASP class as at 1 July 2026.
Who may hold it. A VASP licensed for wallet services.
Published criteria. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. They neither derogate from nor restrict the Commission’s statutory powers, and they must be read with the relevant Act, rules, codes and circulars. Class O criteria PDF.
Rules, codes and circulars. VAITOS guide. NPS Act PSP is a different regulator if payment services are in issue.
6. How to cite VA-1.2
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | VA-1.2 Virtual Asset Wallet Services (Class O) |
| Legal nature | Licence |
| Enabling law | Virtual Asset and Initial Token Offering Services Act 2021 · Section 7 |
| Fees as at 1 July 2026 | Processing fee USD 1,000 (MUR 45,000). Fixed annual fee USD 1,900 (MUR 85,000). Unless the directory states a different conversion rule, USD figures apply only to an applicant for a Global Business Licence or a corporation holding a Global Business Licence. FSC Circular Letter CL20260107 (1 July 2026) records that the replacement fee schedule operates from 1 July 2026 and that annual fees are due by 30 September 2026. A circular does not rewrite the activity this code authorises. |
| Status at cut-off | Published VASP class as at 1 July 2026. |
The structured library card keeps the same coordinates for search. Open VA-1.2 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC guide on the VAITOS Act ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register noteNational Payment Systems Act 2018 ↗Register note
VA-1.3 Virtual Asset Custodian (Class R)
FSC · VA-1.3 · Licence
1. VaultChain Ltd’s shop
VaultChain Ltd is the desk this chapter is for. Class R virtual-asset custody.
The first file on the desk is this. VaultChain Ltd will safekeep virtual assets for professional clients with segregated wallets. VA-1.3 Class R.
Three facts have to stay true of that book. First, the letter is the activity specified. This is a licence under Virtual Asset and Initial Token Offering Services Act 2021, Section 7. A company name is not a permission.
Second, neighbouring papers stay off this desk. Not FS-1.7, not SEC-4.1, and not the unresolved FS-1.14 directory row.
Third, the assumptions stay in the file. Fictional VASP. Cut-off 20 September 2026.
Virtual Asset and Initial Token Offering Services Act 2021, Section 7. See the register note · Open the published text ↗.
2. A week with Institutional token custody
Monday. The promoter walks in with “Institutional token custody.” Write the facts before anyone names a code: VaultChain Ltd will safekeep virtual assets for professional clients with segregated wallets.
Tuesday. The team writes the activity in the words of the licence letter, not the brass plate. Class R virtual-asset custody.
Wednesday. They record what this permission is used for. VA-1.3 Class R.
Thursday. They write what the letter does not cover. Not FS-1.14. Not SEC-4.1 CIS custody.
Friday. They lock the assumptions. Fictional VASP. Cut-off 20 September 2026. The file is ready for the application, not for a slogan on a slide.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what VA-1.3 is used for. The Act matters when VaultChain Ltd applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
This licence
Institutional token custody
VaultChain Ltd will safekeep virtual assets for professional clients with segregated wallets.
Why it fits. VA-1.3 Class R.
Different paper
The same promoter asks for FS-1.7
The slide says the VA-1.3 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not FS-1.14. Not SEC-4.1 CIS custody.
Different paper
The same promoter asks for SEC-4.1
The slide says the VA-1.3 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not FS-1.14. Not SEC-4.1 CIS custody.
| The promoter asks VaultChain Ltd to… | This licence? | Why |
|---|---|---|
| Institutional token custody | Yes | VA-1.3 Class R. |
| The same promoter asks for FS-1.7 | No | Keep the neighbouring paper off this desk. Not FS-1.14. Not SEC-4.1 CIS custody. |
| The same promoter asks for SEC-4.1 | No | Keep the neighbouring paper off this desk. Not FS-1.14. Not SEC-4.1 CIS custody. |
4. Papers that sit beside this one
Not FS-1.7, not SEC-4.1, and not the unresolved FS-1.14 directory row. Name the other desk when the work changes: FS-1.7; SEC-4.1; the unresolved FS-1.14 directory row.
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
A VASP licensed as custodian of virtual assets. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. Fees as at 1 July 2026: Processing fee USD 1,500 (MUR 70,000). Status at cut-off: Published VASP class as at 1 July 2026.
Who may hold it. A VASP licensed as custodian of virtual assets.
Published criteria. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. They neither derogate from nor restrict the Commission’s statutory powers, and they must be read with the relevant Act, rules, codes and circulars. Class R criteria PDF.
Rules, codes and circulars. VAITOS guide. FS-1.14 is not treated as current Class R.
6. How to cite VA-1.3
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | VA-1.3 Virtual Asset Custodian (Class R) |
| Legal nature | Licence |
| Enabling law | Virtual Asset and Initial Token Offering Services Act 2021 · Section 7 |
| Fees as at 1 July 2026 | Processing fee USD 1,500 (MUR 70,000). Fixed annual fee USD 2,500 (MUR 110,000). Unless the directory states a different conversion rule, USD figures apply only to an applicant for a Global Business Licence or a corporation holding a Global Business Licence. FSC Circular Letter CL20260107 (1 July 2026) records that the replacement fee schedule operates from 1 July 2026 and that annual fees are due by 30 September 2026. A circular does not rewrite the activity this code authorises. |
| Status at cut-off | Published VASP class as at 1 July 2026. |
The structured library card keeps the same coordinates for search. Open VA-1.3 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC guide on the VAITOS Act ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register note
VA-1.4 Virtual Asset Advisory Services (Class I)
FSC · VA-1.4 · Licence
1. ChainAdvice Ltd’s shop
ChainAdvice Ltd is the desk this chapter is for. Class I virtual-asset advisory.
The first file on the desk is this. ChainAdvice Ltd will advise professional clients on virtual-asset portfolios without executing or holding. VA-1.4 Class I.
Three facts have to stay true of that book. First, the letter is the activity specified. This is a licence under Virtual Asset and Initial Token Offering Services Act 2021, Section 7. A company name is not a permission.
Second, neighbouring papers stay off this desk. Not SEC-2.4, not FS-1.18, and not Class M dealing.
Third, the assumptions stay in the file. Fictional VASP. Assets are virtual assets, not listed shares. Cut-off 20 September 2026.
Virtual Asset and Initial Token Offering Services Act 2021, Section 7. See the register note · Open the published text ↗.
2. A week with A token-allocation advisory boutique
Monday. The promoter walks in with “A token-allocation advisory boutique.” Write the facts before anyone names a code: ChainAdvice Ltd will advise professional clients on virtual-asset portfolios without executing or holding.
Tuesday. The team writes the activity in the words of the licence letter, not the brass plate. Class I virtual-asset advisory.
Wednesday. They record what this permission is used for. VA-1.4 Class I.
Thursday. They write what the letter does not cover. Not SEC-2.4 and not FS-1.18.
Friday. They lock the assumptions. Fictional VASP. Assets are virtual assets, not listed shares. Cut-off 20 September 2026. The file is ready for the application, not for a slogan on a slide.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what VA-1.4 is used for. The Act matters when ChainAdvice Ltd applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
This licence
A token-allocation advisory boutique
ChainAdvice Ltd will advise professional clients on virtual-asset portfolios without executing or holding.
Why it fits. VA-1.4 Class I.
Different paper
The same promoter asks for SEC-2.4
The slide says the VA-1.4 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not SEC-2.4 and not FS-1.18.
Different paper
The same promoter asks for FS-1.18
The slide says the VA-1.4 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not SEC-2.4 and not FS-1.18.
| The promoter asks ChainAdvice Ltd to… | This licence? | Why |
|---|---|---|
| A token-allocation advisory boutique | Yes | VA-1.4 Class I. |
| The same promoter asks for SEC-2.4 | No | Keep the neighbouring paper off this desk. Not SEC-2.4 and not FS-1.18. |
| The same promoter asks for FS-1.18 | No | Keep the neighbouring paper off this desk. Not SEC-2.4 and not FS-1.18. |
4. Papers that sit beside this one
Not SEC-2.4, not FS-1.18, and not Class M dealing. Name the other desk when the work changes: SEC-2.4; FS-1.18; Class M dealing.
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
A VASP licensed to advise on virtual assets. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. Fees as at 1 July 2026: Processing fee USD 3,000 (MUR 135,000). Status at cut-off: Published VASP class as at 1 July 2026.
Who may hold it. A VASP licensed to advise on virtual assets.
Published criteria. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. They neither derogate from nor restrict the Commission’s statutory powers, and they must be read with the relevant Act, rules, codes and circulars. Class I criteria PDF.
Rules, codes and circulars. VAITOS guide. Securities advice remains the Securities Act if the product is a security.
6. How to cite VA-1.4
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | VA-1.4 Virtual Asset Advisory Services (Class I) |
| Legal nature | Licence |
| Enabling law | Virtual Asset and Initial Token Offering Services Act 2021 · Section 7 |
| Fees as at 1 July 2026 | Processing fee USD 3,000 (MUR 135,000). Fixed annual fee USD 5,000 (MUR 220,000). Unless the directory states a different conversion rule, USD figures apply only to an applicant for a Global Business Licence or a corporation holding a Global Business Licence. FSC Circular Letter CL20260107 (1 July 2026) records that the replacement fee schedule operates from 1 July 2026 and that annual fees are due by 30 September 2026. A circular does not rewrite the activity this code authorises. |
| Status at cut-off | Published VASP class as at 1 July 2026. |
The structured library card keeps the same coordinates for search. Open VA-1.4 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC guide on the VAITOS Act ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register note
VA-1.5 Virtual Asset Market Place (Class S)
FSC · VA-1.5 · Licence
1. IsleDEX Ltd’s shop
IsleDEX Ltd is the desk this chapter is for. Class S virtual-asset marketplace.
The first file on the desk is this. IsleDEX Ltd will operate an order book in virtual assets. VA-1.5 Class S.
Three facts have to stay true of that book. First, the letter is the activity specified. This is a licence under Virtual Asset and Initial Token Offering Services Act 2021, Section 7. A company name is not a permission.
Second, neighbouring papers stay off this desk. Not a securities exchange (SEC-1.1), not a spot commodity market, and not Class M (a participant is not the market).
Third, the assumptions stay in the file. Fictional marketplace. Cut-off 20 September 2026.
Virtual Asset and Initial Token Offering Services Act 2021, Section 7. See the register note · Open the published text ↗.
2. A week with A Mauritius token exchange
Monday. The promoter walks in with “A Mauritius token exchange.” Write the facts before anyone names a code: IsleDEX Ltd will operate an order book in virtual assets.
Tuesday. The team writes the activity in the words of the licence letter, not the brass plate. Class S virtual-asset marketplace.
Wednesday. They record what this permission is used for. VA-1.5 Class S.
Thursday. They write what the letter does not cover. Not SEC-1.1. Participants are not licensed by the marketplace licence alone.
Friday. They lock the assumptions. Fictional marketplace. Cut-off 20 September 2026. The file is ready for the application, not for a slogan on a slide.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what VA-1.5 is used for. The Act matters when IsleDEX Ltd applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
This licence
A Mauritius token exchange
IsleDEX Ltd will operate an order book in virtual assets.
Why it fits. VA-1.5 Class S.
Different paper
The same promoter asks for securities exchange (SEC-1.1)
The slide says the VA-1.5 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not SEC-1.1. Participants are not licensed by the marketplace licence alone.
Different paper
The same promoter asks for spot commodity market
The slide says the VA-1.5 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not SEC-1.1. Participants are not licensed by the marketplace licence alone.
| The promoter asks IsleDEX Ltd to… | This licence? | Why |
|---|---|---|
| A Mauritius token exchange | Yes | VA-1.5 Class S. |
| The same promoter asks for securities exchange (SEC-1.1) | No | Keep the neighbouring paper off this desk. Not SEC-1.1. Participants are not licensed by the marketplace licence alone. |
| The same promoter asks for spot commodity market | No | Keep the neighbouring paper off this desk. Not SEC-1.1. Participants are not licensed by the marketplace licence alone. |
4. Papers that sit beside this one
Not a securities exchange (SEC-1.1), not a spot commodity market, and not Class M (a participant is not the market). Name the other desk when the work changes: a securities exchange (SEC-1.1); a spot commodity market; Class M (a participant is not the market).
- a securities exchange (SEC-1.1)
- a spot commodity market
- Class M (a participant is not the market)
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
The marketplace operator. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. Fees as at 1 July 2026: Processing fee USD 3,000 (MUR 135,000). Status at cut-off: Published VASP class as at 1 July 2026.
Who may hold it. The marketplace operator. Broker-dealers on the market still need Class M if they carry on that business.
Published criteria. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. They neither derogate from nor restrict the Commission’s statutory powers, and they must be read with the relevant Act, rules, codes and circulars. Class S criteria PDF.
Rules, codes and circulars. VAITOS guide.
6. How to cite VA-1.5
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | VA-1.5 Virtual Asset Market Place (Class S) |
| Legal nature | Licence |
| Enabling law | Virtual Asset and Initial Token Offering Services Act 2021 · Section 7 |
| Fees as at 1 July 2026 | Processing fee USD 3,000 (MUR 135,000). Fixed annual fee USD 5,000 (MUR 220,000). Unless the directory states a different conversion rule, USD figures apply only to an applicant for a Global Business Licence or a corporation holding a Global Business Licence. FSC Circular Letter CL20260107 (1 July 2026) records that the replacement fee schedule operates from 1 July 2026 and that annual fees are due by 30 September 2026. A circular does not rewrite the activity this code authorises. |
| Status at cut-off | Published VASP class as at 1 July 2026. |
The structured library card keeps the same coordinates for search. Open VA-1.5 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC guide on the VAITOS Act ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register note
VT-1.1 Issuers of Initial Token Offerings
FSC · VT-1.1 · Registration
1. BuildToken Ltd’s shop
BuildToken Ltd is the desk this chapter is for. Registration to carry on the business of initial token offerings.
The first file on the desk is this. BuildToken Ltd will offer a utility token to the public against USDC to fund a software project. VT-1.1 / VAITOS section 23.
Three facts have to stay true of that book. First, the letter is the activity specified. This is a registration under Virtual Asset and Initial Token Offering Services Act 2021, Section 23 (directory prints 23). A company name is not a permission.
Second, neighbouring papers stay off this desk. Not Class M–S, not crowdfunding (FS-1.19), and not a CIS.
Third, the assumptions stay in the file. Fictional issuer. Token classification still a facts question. Cut-off 20 September 2026.
Virtual Asset and Initial Token Offering Services Act 2021, Section 23 (directory prints 23). See the register note · Open the published text ↗.
2. A week with A project selling utility tokens
Monday. The promoter walks in with “A project selling utility tokens.” Write the facts before anyone names a code: BuildToken Ltd will offer a utility token to the public against USDC to fund a software project.
Tuesday. The team writes the activity in the words of the licence letter, not the brass plate. Registration to carry on the business of initial token offerings.
Wednesday. They record what this permission is used for. VT-1.1 / VAITOS section 23.
Thursday. They write what the letter does not cover. Not VA-1.1 and not FS-1.19.
Friday. They lock the assumptions. Fictional issuer. Token classification still a facts question. Cut-off 20 September 2026. The file is ready for the application, not for a slogan on a slide.
The other files on this desk should look like that first one: a named person, a specified activity, and a letter that matches the work. That is what VT-1.1 is used for. The Act matters when BuildToken Ltd applies, when the Commission writes conditions onto the letter, and when the same promoter telephones with a different idea.
3. What the same promoter asks next
The facts are fictional. The method is the course: keep the shop you have just watched, and ask which desk is now doing the work.
This licence
A project selling utility tokens
BuildToken Ltd will offer a utility token to the public against USDC to fund a software project.
Why it fits. VT-1.1 / VAITOS section 23.
Different paper
The same promoter asks for Class M–S
The slide says the VT-1.1 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not VA-1.1 and not FS-1.19.
Different paper
The same promoter asks for crowdfunding (FS-1.19)
The slide says the VT-1.1 letter already covers it because the same company, the same officers or the same client are on the file.
Why it does not. Keep the neighbouring paper off this desk. Not VA-1.1 and not FS-1.19.
| The promoter asks BuildToken Ltd to… | This licence? | Why |
|---|---|---|
| A project selling utility tokens | Yes | VT-1.1 / VAITOS section 23. |
| The same promoter asks for Class M–S | No | Keep the neighbouring paper off this desk. Not VA-1.1 and not FS-1.19. |
| The same promoter asks for crowdfunding (FS-1.19) | No | Keep the neighbouring paper off this desk. Not VA-1.1 and not FS-1.19. |
4. Papers that sit beside this one
Not Class M–S, not crowdfunding (FS-1.19), and not a CIS. Name the other desk when the work changes: Class M–S; crowdfunding (FS-1.19); a CIS.
- Class M–S
- crowdfunding (FS-1.19)
- a CIS
Neighbouring codes have their own chapters. Do not import their books into this letter.
5. The letter and the file
A company registered as an issuer of initial token offerings. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. Fees as at 1 July 2026: Processing USD 2,000 (MUR 90,000). Status at cut-off: Published ITO registration as at 1 July 2026.
Who may hold it. A company registered as an issuer of initial token offerings. VAITOS defines ITO as an offer of a virtual token to the public for fiat or another virtual asset.
Published criteria. Published licensing criteria on the FSC codified list (consolidation as at 1 July 2026) are guidance. They neither derogate from nor restrict the Commission’s statutory powers, and they must be read with the relevant Act, rules, codes and circulars. ITO criteria PDF. The guide is not a class of licence.
Rules, codes and circulars. VAITOS guide: ITO is fundraising through tokens; VASP is a service for another person.
6. How to cite VT-1.1
| Coordinate | As at 20 September 2026 |
|---|---|
| Directory code | VT-1.1 Issuers of Initial Token Offerings |
| Legal nature | Registration |
| Enabling law | Virtual Asset and Initial Token Offering Services Act 2021 · Section 23 (directory prints 23) |
| Fees as at 1 July 2026 | Processing USD 2,000 (MUR 90,000). No fixed annual fee is printed on the 1 July 2026 ITO row. |
| Status at cut-off | Published ITO registration as at 1 July 2026. Section 23, not section 7. |
The structured library card keeps the same coordinates for search. Open VT-1.1 in the reference library.
FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗Register noteVirtual Asset and Initial Token Offering Services Act 2021 ↗Register noteFSC guide on the VAITOS Act ↗Register noteFSC licensing and fees amendment rules 2026 ↗Register noteFSC Circular Letter CL20260107 — review of fees and renewal of licences ↗Register noteFSC rules and regulations directory ↗Register note
PAUSE & REFLECT
Check your understanding.
Three questions to make the ideas stick. Your score is saved on this browser; this is a learning exercise, not a qualification.
Follow the sources.
Each title opens the published text. The register note records the edition used for this course.
- FSC codified list of licences, authorisations, approvals, recognitions and registrations ↗ All published category codes, fees, forms and licensing-criteria columns; consolidation as at 1 July 2026 · Register note
- Financial Services Act 2007 ↗ Sections 2, 14, 14A, 16–18, 25, 33, 71A, 72, 77, 77A, 77B, 77C, 78, 79A; Second Schedule Parts I–III; Fifth Schedule · Register note
- FSC licensing and fees amendment rules 2026 ↗ Rule 3 and replacement First Schedule; rule 4 commencement · Register note
- FSC Circular Letter CL20260107 — review of fees and renewal of licences ↗ 1 July 2026 fee review; annual-fee due date 30 September 2026; FSCOne alternative arrangements · Register note
- FSC rules and regulations directory ↗ Consolidated licensing and fees rules; sector-specific rules including Securities (Licensing) Rules and Family Office Rules · Register note
- Virtual Asset and Initial Token Offering Services Act 2021 ↗ Section 7 (VASP licence); section 23 (ITO registration) · Register note
- FSC guide on the VAITOS Act ↗ VASP licensing versus ITO registration; AML/CFT overlay · Register note
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